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 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 regarding the injunction by individual solution or perhaps, and every of these, from future violations of parts 5(a) and (c), 15 U.S.C. §§ 77e(a) and 77e(c), and 17(a) of this Securities Act, 15 U.S.C. § 77q(a).

B. 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 using them whom get real notice of this injunction by individual solution or elsewhere, and every of these, from future violations of area 10(b) associated with the 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 due to the fact 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 these, including not restricted to bank reports, brokerage records, opportunities, company passions, loans, credit lines, and genuine and property that is personal situated, explaining each asset and obligation, and its own present location and quantity;

2. All cash, home, assets, as well as other earnings gotten by defendants, and every of those, or even for their direct or benefit that is indirect in or whenever you want to your date regarding the accounting, describing the foundation, amount, disposition and present location of every for the products detailed;

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

4. All assets, funds, securities, genuine or individual home received by defendants, and every of those, or every other individual managed by them, from people whom offered cash to defendants associated with the offer, purchase or purchase of assets of any sort, and also the disposition of these assets, funds, assets, and payday loans in Kentucky genuine or property that is personal.

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

E. Give a Final Judgment evaluating charges against defendants pursuant to Section 20(d) associated with the Securities Act, 15 U.S.C. В§ 77t(d), and Section 21(d)(3) regarding the Exchange Act, 15 U.S.C. В§ 78u(d)(3), when it comes to 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 these, whom get real notice of these purchase by individual service, facsimile solution, or else, and every of those, hold and retain inside their control, and otherwise prevent any withdrawal, transfer, pledge, encumbrance, project, dissipation, concealment, or other disposal of any assets, funds, or any 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 just about any of these names or even for some of their direct or indirect useful interest anywhere situated, and directing all the monetary or brokerage organizations, debtors, and bailees, or other individual or entity keeping such assets, funds, or other properties of defendants, and every of these, to put on or retain within its control and prohibit the withdrawal, elimination, transfer, or any other disposal of any such assets, funds, or any other properties.

G. Grant an Order enjoining and defendants that are restraining anybody or entity acting at their way or with the person from destroying, changing, concealing or elsewhere interfering utilizing 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 of defendants, their agents, workers, servants, accountants, economic or brokerage organizations, and lawyers that refer, reflect or relate with the allegations regarding the grievance, including, although not limited by, papers, publications and documents referring, showing or concerning Ace Payday’s company operations, and its own offer or sale of securities therefore the utilization of profits therefrom.

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