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U.S. Securities and Exchange Commission

Supplementary Material for LR-16026
Questionnaire of Investors’ Experience

For SEC v. Alan Benlolo, et al.,
U. S. District Court for the Southern District of New York,
Civil Action Number 99-Civ-0341 (LS) (S.D.N.Y.)

The Securities and Exchange Commission has filed a Complaint in the United States District Court for the Southern District of New York alleging that four Canadian nationals – Alan Benlolo ("Benlolo"), Lenny Nacher ("Nacher"), and Stephen Dale ("Dale") working in concert, and Michael Risman ("Risman") working independently – operated a variety of "recovery room" frauds. The defendants are alleged to have targeted individuals worldwide who had previously been sold one or more U.S. microcap securities in offshore cold-calling telemarketing schemes. The Complaint alleges that the defendants carried out elaborate frauds to create the false appearance that they were established United States stock brokers, offered to repurchase those microcap securities at a substantial premium, successfully induced at least 55 individuals to post cash deposits of at least $1,536,514 to insure the proposed transaction, and absconded with those funds.

Please draft a brief narrative describing your encounter with this fraudulent scheme, including the following information:

  • Describe your initial purchase of the stocks. Where and when was the initial purchase made?
  • List the stocks that the person contacting you was interested in buying.
  • Describe the pitch made by the person calling you, including the representations made by such person, the price offered, the name of the alleged purchaser, the amount you were to receive after the transaction closed, and the means by which you were to make your payment.
  • The SEC may not ask you to make a tape of any conversations you have with the individuals calling you regarding the stock transactions. However, if you have made any tapes of the individuals calling you, then we would like a copy.
  • Identify any phone numbers, fax numbers, addresses, references, bank accounts, and mail drops used by the persons calling you.
  • Identify the same information for any other similar and more recent pitches offered to you since you were first contacted.
  • Identify your own telephone and fax numbers, and e-mail and home addresses at which we can contact you.
  • Send copies (you should keep the originals) of the narrative, as well as any documents involving the transaction, including contracts, faxes, letters, the front and back of any checks, and wire transfers to the following address:
Bernard A. McDonough, Esq.
Securities and Exchange Commission
Fifth Street, N.W.
Mail-Stop 7-6
Washington, D.C. 20549

View Litigation Release LR-16026


Modified: 01/22/1999