Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 15-80446-CIV-COHN/SELTZER SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. ECAREER HOLDINGS, INC.; ECAREER, INC.; JOSEPH J. AZZATA; DEAN A. ESPOSITO; JOSEPH DEVITO, and FREDERICK J. BIRKS, Defendants, VIPER ASSET MANAGEMENT, LLC; ESPO CONSULTING, LLC; DJC CONSULTING, LLC; J & D MARKETING, LLC; GRYPHON ASSET MANAGEMENT, LLC, and CARLA AZZATA, Relief Defendants. _______________________________________________/ RECEIVER’S UNOPPOSED MOTION FOR SALE OF CERTAIN PERSONAL PROPERTY AND TO EMPLOY SALES BROKER Receiver David M. Levine, not individually, but solely in his capacity as the courtappointed receiver for Corporate Defendants eCareer Holdings, Inc. (“eCareer Holdings”) and eCareer, Inc. (“eCareer, Inc.”) (collectively, the “Corporate Defendants”), files this Motion for Sale of Certain Personal Property and to Employ Sales Broker pursuant to the Court’s May 22, 2015 Order Granting Plaintiff’s Motion for Appointment of Receiver (the “Receivership Order”) [ECF No. 72] and 28 U.S.C. §§ 2001 & 2004. Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 2 of 7 I. INTRODUCTION The Receiver seeks Court authorization to sell at public auction 65 domain names that are owned by the Corporate Defendants, but that do not contain the name of or make reference to the “eCareer” name or the Corporate Defendants’ website, OpenReq.com. The Receivership Estate does not have any use for the domain names, and the Receiver believes that many of them have substantial value. The Receiver recommends approval of the sale as in the best interest of the Receivership Estate, because the Receiver will be able to use the proceeds from the sales to fulfill his duties under the Receivership Order, and to preserve assets of the Receivership Estate for the benefit of investors and creditors. Additionally, to assist in the marketing and sale of the domain names, the Receiver seeks Court authorization to employ Trustee Services, Inc. as a sales broker. II. BACKGROUND On April 7, 2015, the Securities and Exchange Commission (the “Commission”) commenced the above-styled action against the Corporate Defendants, their principal, Defendant Joseph J. Azzata (“Azzata”), and Defendants Dean A. Esposito, Joseph Devito, and Frederick J. Birks (the “Finders”), individuals who solicited investors on behalf of the Corporate Defendants, for making material misrepresentations to investors in violation of various provisions of the Securities Act of 1933 and the Securities Exchange Act of 1934. See Compl., ECF No. 1. More specifically, the Commission alleges that the investors were told that their funds would be used as working capital to expand the Corporate Defendants’ business, but, in reality, the vast majority of funds raised from the Corporate Defendants’ investors were funneled to or for the benefit of Azzata and the Finders. See, e.g., id. ¶¶ 3, 4 &7. The Corporate Defendants’ business purportedly was to operate an online staffing company through which the Corporate Defendants 2 Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 3 of 7 supposedly sold job advertisements to companies to be posted on the Corporate Defendants’ website: openreq.com. See, e.g., id. ¶ 43. On May 22, 2015, the Court appointed the Receiver as receiver for the Corporate Defendants. See Receivership Order. Pursuant to the Receivership Order, the Receiver is authorized to “[t]ake immediate possession of all property, assets and estates of every kind of the Corporate Defendants, whatsoever and wheresoever located belonging to or in the possession of the Corporate Defendants, . . . and to administer such assets as is required to comply with the directions contained in this Order, and to hold all other assets pending further order of this Court.” See id., at 2 ¶ 1. On June 18, 2015, the Court entered a permanent injunction against the Corporate Defendants. See ECF No. 89. After his appointment, and pursuant to the responsibilities with which he is charged, the Receiver identified and took control of certain personal property of the Corporate Defendants, including 65 domain names that do not contain the name of or make reference to the “eCareer” name or the Corporate Defendants’ website, OpenReq (the “Domain Names”). Most of the domain names contain medical references, such as “cardiologists.com” and “pharmaciststoday.com.” An inventory of the Domain Names is attached as Exhibit A. With this Motion, the Receiver seeks Court authorization to sell the 65 Domain Names. Additionally, the Receiver seeks Court authorization to employ Trustee Services, Inc. as a sales broker to assist in the marketing and sale of the domain names. III. ARGUMENT Pursuant to 28 U.S.C. §§ 2001 & 2004, a receiver may sell personal property of a receivership estate at public auction in the district in which the receiver was first appointed. 3 Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 4 of 7 Additionally, pursuant to 28 U.S.C. § 2004, the Court may waive or modify the provisions of 28 U.S.C. § 2001 for the sale of personal property. The Receiver desires to sell the Domain Names. The Receivership Estate has no use for the Domain Names, and the Receiver, in his business judgment, believes that many of the Domain Names have substantial value. The Receiver recommends approval of the sale as in the best interest of the Receivership Estate, because the Receiver will be able to use the proceeds from the sales to fulfill his duties under the Receivership Order, and to preserve assets of the Receivership Estate for the benefit of investors and creditors. A. Sale Procedure The Receiver, in his business judgment, recommends that the Domain Names be sold by public auction. For those Domain Names with identifiable target buyer groups, the Receiver recommends that those Domain Names first be marketed to the target buyer groups (e.g., cardiologists.com would be marketed to the members of the American College of Cardiology), and then be sold through a public auction hosted by Trustee Services, Inc. For those domain names that lack an identifiable target buyer group, the Receiver recommends that those Domain Names be marketed and sold through an online auction website, such as GoDaddy.com. For the latter group of Domain Names, the Receiver recommends the use of an online auction to maximize the pool of potential purchasers. The Receiver, in his business judgment, believes that these procedures are the most expedient and beneficial means of selling the Domain Names, and preserving assets for the benefit of investors and creditors. Accordingly, the Receiver, pursuant to 28 U.S.C. § 2004 and 28 U.S.C. § 2001, requests that the Court authorize the Receive to sell the Domain Names by public auction. 4 Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 5 of 7 B. Employment of Trustee Services, Inc. To assist in the marketing and logistics of the sale of the Domain Names, the Receiver requests approval to employ Trustee Services, Inc. Pursuant to the Receivership Order, the Receiver is authorized to “employ . . . consultants and assistants as the Receiver deems necessary, and to fix and pay their reasonable compensation.” See Receivership Order, at 3, ¶ 4. The Receiver believes it is necessary and in the best interest of the Receivership Estate to employ Trustee Services, Inc. to assist in the marketing and logistics of the sale of the Domain Names. Trustee Services, Inc. and its President, Kenneth A. Welt, have extensive experience in asset liquidation, including the sale of domain names by public auction. A copy of Trustee Services, Inc.’s brochure and the resume of Kenneth A. Welt are attached hereto as Exhibit B. If approved by the Court, the Receiver and Trustee Services, Inc. have agreed to the following commissionbased compensation structure for Trustee Services, Inc.’s services, which the Receiver, in his business judgment, believes to be reasonable and appropriate. Trustee Services, Inc. will be solely responsible for the all expenses associated with the marketing, auction, and sale of the Domain Names. Public Auction Hosted by Trustee Services, Inc. DOMAIN SALE PRICE $0 - $5,000 $5,001 - $25,000 $25,000 + COMMISSION 20% 15% 10% Online Auction Hosted by GoDaddy.com (or similar auction site) DOMAIN SALE PRICE $0 - $5,000 $5,001 - $25,000 $25,000 + COMMISSION 35% $1,000 + 30% $4,000 + 25% 5 Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 6 of 7 For these reasons, the Receiver seeks to employ Trustee Services, Inc. to assist in the marketing and logistics of the sale of the Domain Names. In accordance with the Receivership Order, the Receiver will seek the Court’s approval and provide an accounting prior compensating Trustee Services, Inc. WHEREFORE, for the foregoing reasons, the Receiver requests that the Court approve the Receiver’s request to sell the 65 Domain Names by public auction and to employ Trustee Services, Inc. as a sales broker. The Receiver has conferred with Christopher Martin, counsel for the Commission, and he has advised that the Commission has no objection to the relief requested herein. A proposed order is submitted herewith as Exhibit C. Respectfully submitted, LEVINE KELLOGG LEHMAN SCHNEIDER + GROSSMAN LLP Counsel for the Receiver Miami Center, 22nd Floor 201 South Biscayne Blvd. Miami, Florida 33131 Phone: (305) 403-8788 Fax: (305) 403-8789 By: _/s/Stephanie Hauser________ Stephanie Hauser, Esq. Fla. Bar No. 92765 Email: slh@lklsg.com CERTIFICATE OF SERVICE I hereby certify that, on July 2, 2015, a true and correct copy of the foregoing has been served upon all counsel of record via transmission of Notices of Electronic Filing generated by CM/ECF and to all pro se parties identified on the attached Service List via U.S. mail. _/s/Stephanie Hauser________ Stephanie Hauser, Esq. 6 Case 9:15-cv-80446-JIC Document 93 Entered on FLSD Docket 07/02/2015 Page 7 of 7 SERVICE LIST Arthur C. Koski Arthur C Koski P.A. Counsel for DJC Consulting, LLC, Espo Consulting, LLC, J & D Marketing, LLC, Viper Asset Management, LLC, Dean A. Esposito, and Joseph Devito 101 N Federal Highway Suite 602 Boca Raton, FL 33432 561-362-9800 362-9870 (fax) Christopher E. Martin Securities & Exchange Commission 801 Brickell Avenue Suite 1800 Miami, FL 33131 305-982-6386 536-4154 (fax) martinc@sec.gov akoski@koskilaw.com Mark C. Perry Counsel for Joseph J. Azzata 2400 East Commercial Blvd Suite 201 Fort Lauderdale, FL 33308 954-351-2601 954-351-2605 (fax) James D. Sallah Sallah Astarita & Cox, LLC Counsel for Carla Azzata One Boca Place 2255 Glades Road Suite 300E Boca Raton, FL 33431 561 989-9080 561-989-9020 (fax) jds@sallahlaw.com Gryphon Asset Management, LLC Defendant Attention: Frederick J. Birks 3685 Cassia Drive Orlando, FL 32828 markperryesq@yahoo.com Frederick J. Birks Defendant 3685 Cassia Drive Orlando, FL 32828 7 Case 9:15-cv-80446-JIC Document 93-1 Entered on FLSD Docket 07/02/2015 Page 1 of 2 Domain Names 13weektraveler.com anesthesiologist.com biofuelzone.com cablenewsjobs.com cardiologists.com cardiologiststoday.com cardiologisttoday.com certifiedtraveler.com clinicalcoderstoday.com cliniciancoders.com dermatologisttoday.com doctorsrule.com endodontiststoday.com gqnurse.com hctraveler.com healthcarecoders.com healthcaretravelerjobs.com hematologisttoday.com hospitalisttoday.com hottechtalent.com hydropowerzone.com icd10careers.com icunursetoday.com jobsrule.com labclinicians.com locumstoday.com malenursetoday.com massivemedical.com medicaljobsrus.com medicaltourismcareers.com medicaltourismjobs.com medicalwebster.com medwebster.com micujobs.com micutoday.com monstermedical.com omegacapitalsolutions.biz omegacapitalsolutions.com omegacapitalsolutions.info omegacapitalsolutions.net omegacapitalsolutions.us oncologiststoday.com ophthalmologisttoday.com orthodontiststoday.com pathologists.com pathologiststoday.com EXHIBIT A Case 9:15-cv-80446-JIC Document 93-1 Entered on FLSD Docket 07/02/2015 Page 2 of 2 pharmaciststoday.com pharmacisttoday.com physicianjobstoday.com physiciansrule.com proctologist.com radiologists.com radiologiststoday.com radiologisttoday.com railstalent.com realityshowcareers.com realityshowjobs.com rubyonrailstalent.com rubytalent.com solarsystemjobs.com thehottesttechtalent.com therapistschat.com traveler13.com travelergossip.com travelscrubs.com Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 1 of 10 business management • turnaround specialist bankruptcy trustee • receiver business support services Business People Finding Business Solutions to Business Problems EXHIBIT B Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 2 of 10 Business People Finding Business Solutions to Business Problems SERVICES Short Term Interim Business Management We are assigned to evaluate potential “problem credits” for major banks throughout the United States. For example, a lender may be asked to extend terms on a loan via a forbearance agreement. After a review of certain background information including financial statements and other pertinent data, we will be asked to travel to a facility, interview staff and equity owners, suppliers, etc. and then report as to our findings in regard to a “going forward” basis. We are not attorneys or accountants but give realistic opinions based on actual business models. We do this quickly and economically for the benefit of all parties. Asset Liquidation Selling assets regardless of type, size or location is the forte of bankruptcy trustees. Our group has numerous contacts throughout the world that facilitate the turning of “hard assets” into cash economically and within short time constraints. Furthermore, through effective promotional efforts, we stimulate the market and bring forth legitimate interested buyers, thus maximizing the potential realization. No matter what assets you have or where they may be located, we are capable of handling the liquidation. Commercial Accounts Receivable Collection The conversion of non performing accounts is one of the major duties of a bankruptcy trustee in any given case. Our 22 years of experience has allowed our team Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 3 of 10 Business People Finding Business Solutions to Business Problems to efficiently and professionally turn these past due accounts into cash for our clients. Utilizing the most efficient tracking and reporting software, our state licensed and bonded professionals specialize in collecting receivables in the United States, South America and the Caribbean. Document Management Using the latest technology, we are able to transform voluminous amounts of paper documents into digital form which is stored securely on our servers. Documents are then accessible using a web-based interface which provides an intuitive and organized manner for searching and retrieving required information. Our system provides optimal efficiency for our clients such as bank officers, attorneys and accountants who have various data sharing and storage requirements. Each client can customize the manner in which information is stored and provide different levels of access to various users in any location. Case Management and Administration Handling the vast amounts of information and dealing with the administrative complexities of bankruptcy cases, Assignment for Benefit of Creditors and other legal engagements can be a daunting task. In order to help you effectively and efficiently manage your cases, we’ve collected our expertise to implement and offer various services and cost effective solutions. We currently act as Claims and Noticing Agents in several large Chapter 11 cases and also offer additional services covering the entire spectrum of various engagements including plan distribution, balloting, solicitation, tabulation, disbursements and other types of information dissemination. Our knowledgeable and professional staff can assist you in streamlining and managing any type of case administration. Inventory Solution and Fixed Asset Valuation This service has been used by lenders in regard to asset based loans. Our group will take “on-site” inventories and investigate the market value of these assets. Reports are then generated for the review of the client. This is also a valuable service for anyone with assets to sell. Obtaining accurate information on what assets you have and what value they hold will increase the potential of obtaining maximum return from a sale. Computer Forensics Our team will travel to any location where critical electronic data is located in order to properly preserve and collect valuable information. This allows us to analyze existing data and investigate and recover missing information vital to case administration and legal proceedings. The resulting data and analysis is a key component in numerous scenarios from fraud investigation to pursuance of avoidance actions. The Director of this department holds a Doctorate in Computer Science with a specialization in data security and data analysis as well as a strong background in computer forensics protocols and evidence control. All forms of digital data from various sources can be explored including computers, file servers, e-mail systems, backup tapes, flash cards, cell phones and others. Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 4 of 10 Business People Finding Business Solutions to Business Problems TSI STAFF MEMBERS Laura Byron Senior Associate Lillian Tarafa Accountant Diana Pena Consultant Nick Adams Consultant Justin Greenbaum Case Administrator Kenneth A. Welt President & Founder Founding member who has been a United States Bankruptcy Trustee for over twenty years in the Southern District of Florida. Appointed to serve as Trustee, Receiver and Assignee in many of the complex insolvency cases throughout the United States, Ken brings a wealth of expertise to our firm. Sandirose Magder Vice President Sandi has operated and reorganized many small, medium and large sized companies in the United States and Canada. Specializing in Forensic Accounting, Sandi is an asset to any case. Sabrina Mangroo Executive Assistant Wendy Adams Executive Assistant Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 5 of 10 Business People Finding Business Solutions to Business Problems KENNETH A. WELT RESUME 6/*5&%45"5&4#"/,3615$:53645&&t3&$&*7&3t563/"306/%41&$*"-*45t#64*/&44."/"(&.&/5 Administered more the 30,000 Chapter 7 and Chapter 11 cases and Receiverships Successfully completed extensive background investigation by the Federal Bureau of Investigation, 0óDFTPGUIF645SVTUFF6OJUFE4UBUFT+VTUJDF%FQBSUNFOUBOEUIF*OUFSOBM3FWFOVF4FSWJDF Personally bonded with several accredited bonding companies, and approved by the 0óDFPGUIF645SVTUFF%FQBSUNFOUPG+VTUJDF RECEIVER t6OJUFE4UBUFT%JTUSJDU$PVSUGPS4PVUIFSO District of Florida. t$JSDVJU$PVSUPGUIF&MFWFOUI+VEJDJBM$JSDVJU Miami-Dade County, Florida. 4&$63*5*&4"/%&9$)"/(&$0..*44*0/ t"QQPJOUFE3FDFJWFSUPFWBMVBUFBOEEJTQPTFPG real and personal property in U.S. District Court. $0/4&37"503 t.JDDPTVLFF*OEJBO(BNJOH$PNNJTTJPO Appointed Conservator to operate one of the largest gaming operations in the United States. 3&"-&45"5&%&7&-01.&/54 t4VOOZ*TMF#FBDI.JBNJ#FBDI'PSU Lauderdale & Hallandale, Florida. t5IJSUZZFBSTPGFYQFSJFODFBTBSFBMFTUBUF developer and property manager. Licensed Real Estate Broker, Consultant and Licensed Real Estate Instructor in Florida. 130'&44*0/"-"''*-*"5*0/4 t/BUJPOBM"TTPDJBUJPOPG3FBM&TUBUF"QQSBJTFST t3FBM&TUBUF&EVDBUPST"TTPDJBUJPO t'PVOEFS#BOLSVQUDZ5SVTUFF"TTPDJBUJPOPG the Southern District of Florida t'PVOEFS3FHJPO5XFOUZ0OF#BOLSVQUDZ Trustee Association t/BUJPOBM*OTUJUVUFPG3FBM&TUBUF$POTVMUBOUT t.BTUFS3FBM&TUBUF$POTVMUBOU t/BUJPOBM"TTPDJBUJPOPG#BOLSVQUDZ5SVTUFFT $0..6/*5:"''*-*"5*0/4 t$IBJSNBO;POJOH"QQFBMT#PBSE Metropolitan Miami-Dade County, Florida t$IBJSNBO.JBNJ%BEF$PVOUZ)PUFM$PVODJM Political Action Committee t'PVOEJOH.FNCFS.JBNJ%BEF$PVOUZ)PUFM Council t1SFTJEFOU4VOOZ*TMFT#FBDI$IBNCFSPG Commerce t.FNCFS$PODFSOFE$JUJ[FOT1PMJUJDBM"DUJPO Committee t&YFDVUJWF%JSFDUPS4VOOZ*TMFT#FBDI3FTPSU Association t4FDSFUBSZ4VOOZ*TMFT#FBDI5BTL'PSDF t.FNCFS$PODFSOFE$JUJ[FOTPG/PSUIFBTU Miami-Dade &%6$"5*0/ t#BDIFMPSPG4DJFODF%FHSFF#VTJOFTT-BX Real Estate, 1967 t5FNQMF6OJWFSTJUZ1IJMBEFMQIJB1" GRADUATE STUDIES t6OJWFSTJUZPG1FOOTZMWBOJB1IJMBEFMQIJB1" t/PWB6OJWFSTJUZ'U-BVEFSEBMF't6OJWFSTJUZPG$FOUSBM'MPSJEB0SMBOEP'- Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 6 of 10 Business People Finding Business Solutions to Business Problems CASE WORK "7*"5*0/ Hamlet Construction Pembroke Development Corp. Peninsula Construction PTE Strand Co. Stuckey's Land Development Symmetrical Stair Villa Sonrise Development FINANCIAL Avteam Bimini Island Air Coex Air, Inc Falcon Air Express, Inc. Florida West Airlines, Inc (FNJOJ"JS$BSHP +FU6OJWFSTJUZ Lotus Aerospace Patriot Aviation Services, Inc. TAT Airfreight United West Airlines BUILDERS All American Insurance Company E.S. Bankest First NLC Financial Services, Inc. Founding Partners Capital Management Hurst Capital +FUMFBTF'JOBODF$PSQ +-')PMEJOHT +-'1JTUPO$PNQBOZ Lauderhill Investments Maxim Financial National Independent Insurance Nica Holding, Inc Palm Beach Finance )05&-4 "NFSJDBO(FOFSBM$PSQ Bretsnyder Metals Classic Design Builders Coastal Investment Properties Designer Builders (MFOO8SJHIU%FWFMPQNFOU$POTUSVDUJPO Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 7 of 10 Business People Finding Business Solutions to Business Problems Captain's Quarters Resort Hotel Hotel Indigo Hyatt Regency Downtown Miami Palm Hotel of Key West 1FUBM)PUFM(SPVQ 3JU[$BSMUPO)PUFM$BTJOP4BO+VBO13 Sahara Beach Club Motel Condominium Shore Haven Motor Inn INDUSTRIAL Admiral Plastics Corp. "HSJDVMUVSBM(SPXFST3FTFBSDI All American Semiconductor, Inc. American Recycling of South Florida APL, Inc. Biomed Broward Millwork $POWFY(MBTT*OEVTUSJFT CPC Concrete Crafti Specialty Tools Cruise Aluminum Products Eastern Mill Work Fuller Press (VBZBNB4PEB8BUFS*OD Hill & Strom Produce Inland Supply Intercontinental Import-Export Intercontinental Tile Supply +2VJKOUBOB1SPEVDF$PSQ +VTU3JUF-VNCFS Land Resources Latin America Media Management -FWJTPO4BDLT"EWFSUJTJOH(SPVQ .("VUP1BSUT*OD Mechanical Performance, Inc Megacolor Corporation Metropolitan Oil & Chemical Phoenix, Inc. Power Engineering Marine Profiles in Concrete Quest Racing, Inc Radiant Technologies RK Industries, Inc S.O. Distributors, Inc Sani-Pak Corp. Saunders Engineering Sheffield Industries T.C. Universal Imports, Inc Technical Environmental Services Corp. Techno Export The Engine Parts Warehouse Uni-Chem, Inc VOCAnalytical lnc Woodcrafters Cabinetry World of Auto Parts MARINAS Dania Beach Boat Club Dennison Marine (MPCBM.BSJUJNF4FSWJDFT Hideaway Marina Marbella Yacht Club Marine Conversion, Inc McNew Marine Construction Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 8 of 10 Business People Finding Business Solutions to Business Problems MEDICAL Residences at The Falls Sandalwood Condominiums Solabella South Bay Condominium The Cloister on the Bay The Village at West Miami Three Oaks Office Building REAL ESTATE Cardiac Management Chiropractic Centers, Inc Medibar Medical Industries /BUJPOBM)FBMUI(VBSE*OD Vision Development 1301&35:."/"(&.&/5 Hartline Realty Lifeforce Realty Co. Ole, International Polo Estates Premier Mortgage Residential Mortgage Rexmere League of Homeowners Security & Investment Corp. d/b/a Peoples Mortgage Stonewall Estates ;FCPO1SPQFSUJFT*OD Cabo Rico Casa Bella Condominiums Coastal Investment Properties, Inc. Cosmopolitan Residences Fourth Century Properties (SJG,P"QBSUNFOUT*OD Indian Creek Holdings Intercontinental Management Majestic View Condominium Mill Dam Lake Resort 0SDIJE(SPWF RETAIL & SERVICE Adieus International Travel Agencies, Inc Annlenn Video Distributors, Inc. Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 9 of 10 Business People Finding Business Solutions to Business Problems Bayview Diner Beezil Design of Florida Best Auto Delivery Boutique Family Shops Burger King (18 Franchises) Can-Do Foliage, Inc Caribbean Antilles Distributors Carpets of Miami Comfort Mate Computer Parts Unlimited Cuchi Quality Shoes D.E. Linardy Hardwood Flooring Dial-A-Mattress %PMMBS5JNF(SPVQ EasyTowing Evans Paint Stores Florida Finest Seafood Co. Fran's Fashions (SBQIJD%ZOBNJDT (SBQIJD1SPEVDUJPOT Hairmaster Stores Hospital Staffing Services +##PVUJRVFPG$BMJGPSOJB +##PVUJRVFPG'MPSJEB +FBOT$PTNFUJDT +PMJFhT#PPLT Key West Aloe Latino Restaurant Lewis B Freeman and Partners, Inc. Maternity Fashion Shops Miami Paging &Sound Oriental Objects of D'Art, Inc. Pavlow Company Phone 1 Pinnacle Travel Pocket Pagers, Inc. Pompano Beauty Exchange Pompano Woodworking Propeller Corp Quality Furniture Rainbow Mills Riveria Kitchen Cabinets Rothstein Rosenfeldt Adler RWT Tree and Nursery Salesworld Schwag Used Cars South West Sensations Southeast Restaurants, Inc Specialized Maintenance Services Stringfellows of Miami Tennessee Cabinet Company Thermoguard, Inc Tropical Paper Box Two K's Furniture 5;0*ODECB#VSHFS,JOH Van Dee Services 7FSBDJUZ.BOBHFNFOU(SPVQ Vine &Spirits Vinnies Restaurant of Davie 4&37*$&45"5*0/4 Bayview Petroleum Super One Stop 5&-&$0..6/*$"5*0/ Intelligent Switching and Software, Inc. Case 9:15-cv-80446-JIC Document 93-2 Entered on FLSD Docket 07/02/2015 Page 10 of 10 Business People Finding Business Solutions to Business Problems Nica Holdings, Inc. Ntera Holdings, Inc. Ntera, Inc. Radiant Telecom, Inc. Terra Communications .*4$&--"/&064 10,001 Monster Video Stores American Ammunition Antol Restoration Be Satisfied Carputer Inc Carrie Hook Writ of Execution Cascade International DelAngel Music Dunhill Exploration Empresa Naviera Santa Ltd. Evans Affiliates Evans Tempcon, Inc Hagina, Inc Maxim Enterprises, Inc RDT Enterprises Residential Covadonga, Inc SunTrust Race Cars Trans Samaritan, Inc Tucker&Palmer, Inc Vertical Source Video Superstars, Inc Vinbuild, Inc $-04*/( Trustee Services, Inc. is an affordable Business Support Service Company with the ability to collect commercial accounts receivables, act as noticing and claim agent, sale of nonperforming assets and conduct the review and analysis of preference claims. We would welcome and appreciate any opportunities you or your clients can offer regardless of size or location. Please visit our web page at www.trusteeservices.biz or call Kenneth Welt at (954) 889-3403 or (407) 4097702 for our Orlando/Central Florida office. Case 9:15-cv-80446-JIC Document 93-3 Entered on FLSD Docket 07/02/2015 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 15-80446-CIV-COHN/SELTZER SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. ECAREER HOLDINGS, INC.; ECAREER, INC.; JOSEPH J. AZZATA; DEAN A. ESPOSITO; JOSEPH DEVITO, and FREDERICK J. BIRKS, Defendants, VIPER ASSET MANAGEMENT, LLC; ESPO CONSULTING, LLC; DJC CONSULTING, LLC; J & D MARKETING, LLC; GRYPHON ASSET MANAGEMENT, LLC, and CARLA AZZATA, Relief Defendants. _______________________________________________/ ORDER GRANTING RECEIVER’S MOTION FOR SALE OF CERTAIN PERSONAL PROPERTY AND TO EMPLOY SALES BROKER THIS MATTER is before the Court on the Receiver’s Motion for Sale of Certain Personal Property and to Employ Sales Broker, filed July 2, 2015. The Court, having reviewed the Motion and being fully advised in the premises, hereby ORDERS and ADJUDGES that the Receiver’s Motion for Sale of Certain Personal Property and to Employ Sales Broker is GRANTED. DONE and ORDERED in Chambers in Ft. Lauderdale, Florida, this ___ day of July, 2015. ____________________________________ JAMES I. COHN District Court Judge Southern District of Florida cc: Counsel of record & Pro Se Parties EXHIBIT C