==========================================START OF PAGE 1====== U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 14815 / February 12, 1996 SECURITIES AND EXCHANGE COMMISSION v. CITI FINANCIAL SERVICES, CITI CORP REALTY PARTNERS IV, HAROLD GOLDSTEIN, RICHARD THOMAS MANDELL, a.k.a. MARK MORGENLENDER, ROBERT SINGLETON, MARK BARQUERA, a.k.a. MARK CABRERRO and ROBERTA CRAMPTON, Civil Action No. 96-0349 WJR (BQRx) (C.D. Cal.) The Securities and Exchange Commission ("Commission") announced that on February 9, 1996, it obtained a preliminary injunction against the defendants in the above matter. The Commission had previously obtained a temporary restraining order against the defendants on January 18, 1996. In that proceeding, the Court stopped the defendants' sale of fictitious certificates of deposit which they falsely claimed were issued by Citibank in New York and insured by the federal government. The preliminary injunction continues to bar the defendants from committing the fraudulent sales. In its lawsuit, which was filed in the United States District Court for the Central District of California, the Commission obtained an order preliminarily enjoining the following entities and individuals from future violations of the antifraud provisions of the federal securities laws: Citi Financial Services ("Citi Financial"); Citi Corp Realty Partners IV ("CCRP"); Harold Goldstein ("Goldstein"), an inmate at the federal correctional facility in Lompoc, California; Richard Thomas Mandell ("Mandell"), of Los Angeles, who is currently on federal parole; Robert Singleton ("Singleton"), of Salt Lake City, Utah, who is also currently on federal parole; Mark Barquera of Los Angeles, a convicted felon; and Roberta Crampton of Duluth, Georgia. The order also continues an asset freeze against defendants Citi Financial, CCRP, Goldstein, Mandell and Singleton. The Commission's Complaint alleged that the scheme was directed by Goldstein, an inmate from federal prison, and executed by several paroled felons living in Los Angeles and Salt Lake City. In selling the fictitious instruments, the defendants conducted a nationwide newspaper and direct marketing campaign aimed at luring elderly investors into purchasing the bogus securities. Since the scheme began in October 1995, the defendants have defrauded individual investors out of approximately $320,000. In addition, the Commission has learned that in response to the defendants' marketing efforts, hundreds of potential victims have expressed an interest in purchasing the fictitious securities. The Complaint also alleges that inmate Goldstein directed parolee Mandell to create two entities, Citi Financial Services and Citi Corp Realty Partners IV. The names of these entities were purposely designed to mislead investors into believing that ==========================================START OF PAGE 2====== the entities were affiliated with Citibank, and its parent holding company, Citicorp. Goldstein further instructed Mandell - 2 - to assume the identity of "Mark Morgenlender," an actual executive employed by Citicorp, and to create investor letters and other solicitation materials on letterhead looking like Citicorp's. Goldstein also caused the printing of various forms of false identification for Mandell to allow him to pose as Morgenlender. The Complaint further alleges that beginning in October 1995, Mandell and Singleton ran advertisements in major newspapers soliciting investors to call a "CD Hot Line." Interested investors who called the "CD Hot Line" were provided with solicitation materials describing the investment as federally insured brokered certificates of deposit offered through the "top 150 financial institutions." The solicitation materials also falsely represented that Citi Financial and CCRP were licensed broker-dealers and members of the New York Stock Exchange, the National Association of Securities Dealers (NASD) and the Securities Investor Protection Corporation (SIPC). The Commission further alleges in its Complaint that the defendants are not in any way affiliated with Citicorp. Moreover, the defendants did not purchase federally insured certificates of deposit or any other securities on behalf of the victims, but instead misappropriated investor monies for their own personal gain. The Complaint seeks permanent injunctions, and other relief, including disgorgement and civil penalties, against the defendants. The Commission acknowledges the cooperation and assistance provided in this matter by the Federal Bureau of Investigation.