UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff, :
:
v. :
:
COI SOLUTIONS, INC., ROBERT :
WILDER, and MELVIN LEVINE, :
:
Defendants.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
Plaintiff Securities and Exchange Commission ("Commission") alleges:
INTRODUCTION
1. The Commission brings this action to restrain and enjoin defendants COI Solutions,
Inc. ("COI Solutions"), Robert Wilder ("Wilder") and Melvin Levine ("Levine")
(collectively, "Defendants") from making materially false and misleading statements and
failing to disclose material information in filings with the Commission in violation of the
federal securities laws. In mid-2000, Wilder and Levine agreed to participate in a
fraudulent scheme involving the issuance of 1.575 million shares of common stock of
COI Solutions to nominees through two S-8 offerings. On October 17 and November 1,
2000, COI Solutions registered the shares in two S-8 registration statements filed with the
Commission, which falsely claimed that these shares were paid to individuals for
legitimate services rendered to the company. In fact, none of these individuals rendered
any bona fide services to COI Solutions, but rather were acting as nominees for Levine
and Wilder. Wilder and Levine planned to sell these shares to a European-based
investment fund, and deposit a portion of the proceeds in their offshore accounts.
Unbeknownst to the individual defendants, the European investment fund never existed
and its "representative" was an undercover agent of the Federal Bureau of Investigation.
In addition to a permanent injunction, the Commission seeks an order imposing civil
monetary penalties against Defendants pursuant to Section 21(d) of the Securities
Exchange Act of 1934 ("Exchange Act").
DEFENDANTS
2. Defendant COI Solutions, a Nevada Corporation, is purportedly in the health insurance
SNIPPETS:
UNITED STATES DISTRICT COURT
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
Plaintiff Securities and Exchange Commission alleges:
The Commission brings this action to restrain and enjoin defendants COI Solutions, Inc.,
Wilder and Levine agreed to participate in a fraudulent scheme involving the issuance of
On October 17 and November 1, 2000, COI Solutions registered the shares in two S-8
the European investment fund never existed and its "representative" was an undercover agent
In addition to a permanent injunction, the Commission seeks an order imposing civil monetary
Defendant Levine, age 70, lives in Pompano Beach, Florida and is a stock promoter.
In 1996, the Commission entered a cease-and-desist order against Levine for, among other
Certain of the acts and transactions constituting violations of the Exchange Act have
Defendants, directly and indirectly, have made use of the means and instrumentalities of
According to the agreed-upon scheme, the so-called "consultants" would transfer their shares
The UCA and his associates told Defendants that he worked with two due diligence officers who
On November 1, 2000, COI Solutions filed another registration statement in connection with a
The Commission repeats and realleges paragraphs 1 through 16 of its Complaint.
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