UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SECURITIES AND EXCHANGE COMMISSION,
:
Plaintiff, : CIVIL ACTION NO.
:
v. : COMPLAINT FOR
: INJUNCTIVE AND
JEFFREY R. SENGER, BRAD M. NIRENBERG and : OTHER RELIEF
NORMAN F. PIATTI, :
Defendants.
Plaintiff Securities and Exchange Commission ("SEC" or "Commission") alleges as
follows:
INTRODUCTION
1. The Commission brings this action to restrain and enjoin Jeffrey R. Senger ("Senger"),
Brad M. Nirenberg ("Nirenberg") and Norman F. Piatti ("Piatti") (collectively
"Defendants") from violating the antifraud provisions of the federal securities laws. From
approximately November 1999 through February 2000, Defendants participated in a
classic pump-and-dump scheme in the securities of Lifekeepers International, Inc.
("Lifekeepers" or "the Company"), a developmental stage, medical diagnostic company
headquartered in West Palm Beach, Florida. Defendants disseminated false and
misleading information to the investing public about Lifekeepers' assets, projected
revenues, profits, and anticipated stock price through Lifekeepers' press releases, website,
and in a massive, fraudulent e-mail campaign. When the price of Lifekeepers' stock was
artificially inflated as a result of Defendants' touting campaign, Defendants Senger and
Nirenberg sold approximately 150,000 shares of their Lifekeepers stock and reaped
approximately $260,000 in illegal profits. In addition to a permanent injunction against
Defendants the Commission seeks the imposition of civil money penalties against
Defendants, and an order requiring Defendants Senger and Nirenberg to disgorge their
ill-gotten gains, plus prejudgment interest thereon.
DEFENDANTS
2. Defendant Senger, age 36, resides in West Palm Beach, Florida. At various times
between April 1989 and March 1999, Senger was employed as a registered representative
associated with various broker-dealers.
SNIPPETS:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JEFFREY R. SENGER, BRAD M. NIRENBERG and:
Plaintiff Securities and Exchange Commission alleges as follows:
The Commission brings this action to restrain and enjoin Jeffrey R. Senger, Brad M. Nirenberg
From approximately November 1999 through February 2000, Defendants participated in a classic
When the price of Lifekeepers' stock was artificially inflated as a result of Defendants'
Defendant Nirenberg, age 38, resides in Coral Springs, Florida.
Defendant Piatti, age 48, resides in West Palm Beach, Florida.
This Court has jurisdiction over this action pursuant to Sections 20, 20and 22of the
Defendants, directly and indirectly, have made use of the means and instrumentalities of
False and Misleading Press Releases
The press releases falsely represented that Lifekeepers' stake in MyMedic was worth between
These press releases, referenced in paragraph 14 above, were false and misleading because,
Misrepresentations on Lifekeepers' Website
During January and February 2000, Defendant Niernberg arranged for Lifekeepers and its stock
The Commission repeats and realleges paragraphs 1 through 22 of the Complaint.
By reason of the foregoing, Defendants Senger, Nirenberg and Piatti, directly and indirectly,
and/or engaged in transactions, practices and courses of business which operated as a fraud
Issue Permanent Injunctions, restraining and enjoining Defendants Senger, Nirenberg and
Issue an Order directing Senger, Nirenberg and Piatti to pay civil money penalties pursuant
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