Securities and Exchange Commission

Litigation Release No. 17532 / May 23, 2002

Court Freezes $2 Million Yacht Purchased by Defendant Carol C. Martino with
Proceeds of Her Alleged Illegal Brokerage Activities

Securities and Exchange Commission v. Carol C. Martino, et al., 98 Civ. 3446
(S.D.N.Y.)

   On May 21, 2002, U.S. District Judge Milton Pollack issued an order
   against defendant Carol C. Martino and her husband, relief defendant
   Gerard Haryman, freezing Martino's $2 million yacht, pending the
   outcome of the Commission's civil enforcement action against Martino.
   The Court entered the order following a hearing on the matter held
   earlier that day.

   The Commission sued Martino and her stock brokerage firm in May 1998
   for repeated violations of a 1992 Commission order that barred Martino
   from acting as a stock broker. The Commission alleges that, from 1992
   through 1995, Martino brokered millions of dollars in sales of stock
   by U.S. companies to foreign purchasers and, thus, accumulated
   millions of dollars in illegal brokerage commissions and fees. The
   Commission seeks disgorgement of Martino's ill-gotten gains, as well
   as monetary penalties and other relief.

   The Commission recently learned that Martino used some of her illegal
   brokerage revenues to purchase a $2 million yacht, and that she and
   her husband have been attempting to sell the yacht to pay personal
   expenses (including a mortgage on their Palm Beach, Florida home).
   Consequently, the Commission requested an emergency freeze from the
   Court.

   In the freeze order, Judge Pollack determined that (1) the Commission
   presented sufficient evidence for the Court to infer for present
   purposes that Martino and her brokerage company "illegally brokered
   millions of dollars of stock sales," and that "Martino thus
   accumulated millions of dollars in illegal brokerage fees and
   commissions"; (2) in November 1997, Martino used at least $1.28
   million of her illegal brokerage revenues to purchase a $2 million
   seventy-five foot motor yacht called "Je T'aime"; (3) in December
   1997, Martino and Haryman registered the yacht in the British Virgin
   Islands in the name of "JTM Limited" -- an offshore corporation wholly
   owned and controlled by Haryman -- "to hide Martino's assets from her
   creditors and potential creditors, including the Commission"; and (4)
   the Commission made an adequate showing that "Martino owns the Yacht,
   seeks to maintain it beyond the court's jurisdiction, and seeks to
   sell the Yacht and dissipate the sale proceeds for her and Haryman's