United States District Court, D. Nevada
CHRISTY J. WHITE U.S. SECURITIES AND EXCHANGE COMMISSION
COUNSEL FOR PLAINTIFF
B. KAPLAN, ESQ. PRO SE
M. KAPLAN PRO SE
MATTHEW PRUITT ALVERSON, TAYLOR, MORTENSEN & SANDERS
COUNSEL FOR DEAN PROPERTIES, LLC, JAMES V. DEAN. AND MARLA D.
STIPULATION AND ORDER REGARDING 1314 CAVE ROCK DRIVE,
the United States Securities and Exchange Commission
("SEC" or "Commission"), by its
undersigned counsel, Christy J. White, defendant, David B.
Kaplan, Esq., relief defendant, Lisa M. Kaplan, and certain
injured investors, Dean Properties. LLC, and James and Maria
Dean, by their undersigned counsel, Matthew Pruitt, hereby
stipulate as follows:
on May 19, 2016, the Commission brought suit against David B.
Kaplan, Esq. ("David Kaplan"), Synchronized
Organizational Solutions, LLC, Synchronized Organizational
Solutions International, Ltd. ("SOSI"), and Manna
International Enterprises. Inc., as Defendants, and Lisa M.
Kaplan ("Lisa Kaplan"), The Water-Walking
Foundations, Inc.. and Manna Investments, LLC, as Relief
Defendants. (ECF No. 1).
on May 20, 2016. this Court entered a Temporary Restraining
Order and Asset Freeze ("2016 Asset Freeze")
against the Defendants, Relief Defendants, and their agents,
servants, employees, attorneys-in-fact, and those persons in
active concert or participation with them. (ECF No. 13). The
Asset Freeze ordered them to retain funds and other assets
held by the Defendants and Relief Defendants, directly or
indirectly, and to prevent the "withdrawal, sale,
payment..., transfer, dissipation, assignment, pledge,
alienation, encumbrance, disposal, or diminution of
value" of such assets.
on January 8, 2018. a final judgment was entered in favor of
the Commission and against the Defendants. (ECF No. 105). The
Judgment required them to pay disgorgement in the amount of
$7, 139, 884.87. together with prejudgment interest thereon
in the amount of $680, 157.61, for a total of $7, 820,
042.48. David Kaplan was also ordered to pay a civil penalty
of $300, 000.
on January 8, 2018, a final judgment was entered in favor of
the Commission and against Relief Defendant, Lisa Kaplan, for
disgorgement in the amount of $340, 764.75, together with
prejudgment interest thereon in the amount of $26, 762.65,
for a total of $367, 527.40. (ECF No. 106).
on January 14, 2016, Dean Properties, LLC, and James and
Maria Dean (collectively, "the Deans") filed a
complaint against David Kaplan and co-defendant, SOSI, in the
District Court for the Eastern District of Virginia. See
Dean Properties, LLC, et al, v. Synchronized Organizational
Solutions International, Ltd., et al., l:16-cv-00050
on June 21, 2016, David Kaplan and SOSI consented to judgment
being entered against them in the amount of $4.08 million.
on August 22, 2016, the Deans registered their judgment
against David Kaplan and SOSI as a foreign judgment in the
District Court of Clark County, Nevada.
on February 8. 2018. the Deans filed a Writ of Execution
against property owned by David Kaplan and SOSI in the Clark
County District Court. Pursuant to the Writ, the Deans sought
to execute on any and all personal and real property owned by
David Kaplan and SOSI including, but not limited to, property
located at 1314 Cave Rock Drive, Unit B, Zephyr Cove, Nevada
a Notice of Sheriffs Sale for the Subject Property was served
by the Douglas County Sheriff on David Kaplan and SOSI on
March 20. 2018. The ...