Payday advances llc. SECURITIES AND TRADE COMMISSION

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Payday advances llc. SECURITIES AND TRADE COMMISSION

ACE PAYDAY PLUS, LLC D/B/A ACE PAYDAY PLUS II, LLC; ACE PAYDAY MANAGEMENT, INC; ACE MANAGEMENT, LLC.; AND JAMES BIANCO,

WHEREFORE , Plaintiff Commission respectfully requests that this Court:

A. Grant an Order temporarily and preliminarily, and a Final Judgment completely enjoining defendants, their officers, agents, servants, workers, lawyers, and all sorts of people in active concert or involvement from future violations of Sections 5(a) and (c), 15 U.S.C. §§ 77e(a) and 77e(c), and 17(a) of the Securities Act, 15 U.S.C. § 77q(a) with them who receive actual notice of the injunction by personal service or otherwise, and each of them.

B. Grant an Order temporarily and preliminarily, and a Final Judgment forever enjoining defendants, their officers, agents, servants, workers, solicitors, and all sorts of individuals in active concert or involvement using them whom get real notice of this injunction by individual service or else, and every of these, from future violations of part 10(b) associated with Exchange Act, 15 U.S.C. В§ 78j(b), and Rule 10b-5 promulgated thereunder, 17 C.F.R. В§ 240.10b-5.

C. Grant an Order directing defendants, and every of these, to register with this specific Court and provide upon plaintiff, within three company times, or within such expansion of the time since the Commission agrees, a confirmed written accounting, finalized by them under penalty of perjury, of:

1. All assets, liabilities and home currently held straight or indirectly by or even for the advantage of defendants, and every of those, including although not restricted to bank reports, brokerage records, opportunities, company passions, loans, personal lines of credit, and genuine and property that is personal situated, explaining each asset and obligation, as well as its present location and quantity;

2. All cash, home, assets, along with payday loans in Delaware direct lenders other earnings gotten by defendants, and every of these, and for their direct or benefit that is indirect in or whenever you want to your date for the accounting, explaining the foundation, quantity, disposition and present location of each and every of this products listed;

3. The names and final understood addresses of most bailees, debtors, as well as other individuals and entities that are presently keeping the assets, funds or home of defendants, and every of those; and

4. All assets, funds, securities, genuine or individual home gotten by defendants, and every of these, or other individual managed by them, from people whom supplied cash to defendants associated with the offer, purchase or purchase of assets of any sort, as well as the disposition of these assets, funds, opportunities, and genuine or individual home.

D. Grant a Final Judgment directing defendants to disgorge their unjust enrichment through the fraudulent conduct alleged in this grievance and also to spend prejudgment interest thereon.

E. Give a Final Judgment evaluating charges against defendants pursuant to Section d that is 20( associated with Securities Act, 15 U.S.C. В§ 77t(d), and Section 21(d)(3) for the Exchange Act, 15 U.S.C. В§ 78u(d)(3), for the violations alleged herein.

F. Grant an Order directing that defendants, and their officers, agents, servants, workers, attorneys-in-fact, and all sorts of people in active concert or involvement with every of those, whom get real notice of these purchase by individual service, facsimile solution, or else, and every of those, hold and retain in their control, and otherwise prevent any withdrawal, transfer, pledge, encumbrance, project, dissipation, concealment, or any other disposal of any assets, funds, or other properties (including cash, genuine or individual home, securities, chooses for action or home of every type whatsoever) of defendants presently held by them or under their control, whether held in almost any of these names or even for some of their direct or indirect useful interest anywhere situated, and directing each one of the economic or brokerage organizations, debtors, and bailees, or every other individual or entity keeping such assets, funds, or any other properties of defendants, and every of those, to put up or retain within its control and prohibit the withdrawal, treatment, transfer, or other disposal of any such assets, funds, or other properties.

G. Grant an Order enjoining and defendants that are restraining anybody or entity acting at their way or for the kids from destroying, changing, concealing or elsewhere interfering using the access associated with plaintiff to virtually any and all sorts of papers, publications and documents that are when you look at the control, custody or control over defendants, their agents, employees, servants, accountants, monetary or brokerage organizations, and lawyers that refer, reflect or connect with the allegations regarding the grievance, including, however limited by, documents, publications and documents referring, showing or associated with Ace Payday’s company operations, and its particular offer or purchase of securities while the utilization of profits therefrom.

H. Give such other and further relief as is simply and appropriate.

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