MEMORANDUM OPINION AND ORDER
HOLWELL, District Judge.
The Securities and Exchange Commission ("SEC" or `Commission") brought this action charging Opulentica, LLC ("Opulentica"), Zarrar Sheikh, and Nasser A. Dawoud (collectively, "defendants") with engaging in a fraudulent scheme to offer unregistered securities, to divert the proceeds of the offering to the personal use of the defendants, and to make material false representations in the course of...
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