United States Securities and Exchange Commission v. Mediatrix Capital Inc. et al

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Judge Raymond P. Moore
Civil Action No. 1:19-cv-02594-RM
UNITED STATES SECURITIES
AND EXCHANGE COMMISSION,
Plaintiff,
v.
MEDIATRIX CAPITAL INC., BLUE ISLE MARKETS INC. (St. Vincent & the Grenadines),
BLUE ISLE MARKETS LTD., MICHAEL S. YOUNG,
MICHAEL S. STEWART, and BRYANT E. SEWALL,
Defendants,
and
MEDIATRIX CAPITAL FUND LTD., ISLAND TECHNOLOGIES LLC, VICTORIA M.
STEWART, MARIA C. YOUNG, HANNA OHONKOVA SEWALL, MICHAEL C. BAKER,
WALTER C. YOUNG III, ARUAL LP, WEST BEACH LLC, SALVE REGINA TRUST, TF
ALLIANCE, LLC, CASA CONEJO LLC, HASE HAUS, LLC, DCC ISLANDS
FOUNDATION, KEYSTONE BUSINESS TRUST, WEINZEL, LLC, THE 1989
FOUNDATION, MEDIATRIX CAPITAL PR LLC, MEDIATRIX CAPITAL, LLC, and BLUE
ISLE MARKETS INC. (Cayman Islands),
Relief Defendants.
FILED UNDER SEAL
ORDER GRANTING PLAINTIFF’S EMERGENCY MOTION
FOR AN EX PARTE ASSET FREEZE, TEMPORARY RESTRAINING ORDER,
ORDER TO SHOW CAUSE, AND OTHER EMERGENCY RELIEF
On September 12, 2019, Plaintiff United States Securities and Exchange Commission
(the “SEC” or “Commission”) filed an emergency motion for an ex parte order: (1) freezing
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funds and other assets of Defendants Mediatrix Capital Inc. (“Mediatrix Capital”), Blue Isle
Markets Inc. (“Blue Isle 1”), Blue Isle Markets Ltd. (“Blue Isle 2”), Michael S. Young
(“Young”), Michael S. Stewart (“Stewart”), and Bryant E. Sewall (“Sewall”) (collectively, the
“Defendants”) and Relief Defendants Mediatrix Capital Fund Ltd., Island Technologies LLC,
Victoria M. Stewart, Maria C. Young, Hanna Ohonkova Sewall, West Beach LLC, Salve Regina
Trust, TF Alliance, LLC, Casa Conejo LLC, Hase Haus, LLC, DCC Islands Foundation,
Keystone Business Trust, Weinzel, LLC, The 1989 Foundation, Mediatrix Capital PR, LLC,
Mediatrix Capital, LLC, and Blue Isle Markets Inc. (Cayman Islands) (collectively, with
Michael C. Baker, Walter C. Young III and Arual LP, the “Relief Defendants”);[1]
(2) prohibiting Defendants and Relief Defendants from the acceptance, deposit, or disbursement
of additional investor funds; (3) prohibiting Defendants from future violations of Sections 5(a),
5(c), and 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a), e(c), and
q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C.
§ 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder, and prohibiting Mediatrix Capital,
Young, Stewart, and Sewall from future violations of Sections 206(1), 206(2), and 206(4) of the
Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§ 80b-6(1), b-6(2) and b-6(4)]
and Rule 206(4)-8 [17 C.F.R. § 275.206(4)-8] thereunder; (4) requiring Defendants and Relief
Defendants to provide an accounting; (5) directing Defendants and Relief Defendants to
repatriate assets held abroad; (6) prohibiting Defendants and Relief Defendants from the
destruction or alteration of documents; (7) providing for expedited discovery; (8) providing for
[1] The Commission does not request that the asset freeze apply to Relief Defendants Michael C.
Baker, Walter C. Young III and Arual LP.
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alternative means of service by the SEC; and (9) setting this matter for a preliminary injunction
hearing. The Court will treat this motion as a request for a preliminary injunction as well.
The Court has considered the entire record of this case, including: (1) the Complaint;
(2) Plaintiff’s Emergency Motion for an Ex Parte Asset Freeze, Temporary Restraining Order,
Order to Show Cause, and Other Emergency Relief; (3) and the Declaration of Jeffrey D.
Felder, with attached exhibits.
Based on this record, the Court finds:
1. 	The Court has jurisdiction over the subject matter of this action and over
Defendants and Relief Defendants.
2. 	The SEC has made a sufficient and proper showing in support of the relief
granted herein, as required by Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)], Section
21(d) of the Exchange Act [15 U.S.C. § 78u(d)], and Section 209(d) of the Advisers Act
[15 U.S.C. § 80b-9(d)] by establishing:
a. 	For purposes of freezing assets, a likelihood of success on the merits, or
that an inference can be drawn that the party has violated the federal securities laws; and
b. 	For purposes of a temporary restraining order, a prima facie case for each
of the violations in the Complaint and a likelihood that the SEC will prevail at trial on the
merits and that the Defendants, and each of them, directly or indirectly, have engaged in
and, unless restrained and enjoined by order of this Court, will continue to engage in acts,
practices, and courses of business constituting violations of Sections 5(a), 5(c), and 17(a)
of the Securities Act; and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder
[17 C.F.R. § 240.10b-5]; and Mediatrix Capital, Young, Stewart, and Sewall, and each of
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them, directly or indirectly, have engaged in and, unless restrained and enjoined by order
of this Court, will continue to engage in acts, practices, and courses of business
constituting violations of Sections 206(1), 206(2), and 206(4) of the Advisers Act and
Rule 206(4)-8 thereunder.
There is good cause to believe that, unless restrained and enjoined by order of this Court,
the Defendants and Relief Defendants will dissipate, conceal, or transfer from the jurisdiction of
this Court assets that could be subject to an order directing disgorgement or the payment of civil
money penalties in this action, and that unless restrained Defendants may solicit additional funds
from investors. Accordingly, an order freezing the Defendants’ and Relief Defendants’ assets, as
specified herein, is necessary to preserve the status quo and to protect this Court’s ability to
award equitable relief in the form of disgorgement of illegal profits from fraud, unregistered
securities offerings, and Advisers Act violations, as well as civil penalties.
3. 	There is good cause to believe that an immediate accounting is necessary to
identify the location of additional assets subject to an asset freeze.
4. 	There is good cause to believe that, unless restrained and enjoined by order of
this Court, Defendants and Relief Defendants may alter or destroy documents relevant to this
action.
5. 	There is good cause to believe that expedited discovery and alternative means
of service are warranted.
6. 	There is good cause to believe that an order directing Defendants and Relief
Defendants to repatriate assets to the United States is warranted.
7. 	Pursuant to Fed. R. Civ. P. 65(b), this Court specifically finds that there is a
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likelihood of irreparable injury to investors unless this order is issued ex parte. This Court
finds that the SEC has made a prima facie showing that Defendants have engaged in deceptive
conduct in order to defraud investors, made false and misleading statements to investors and
omitted material facts in connection with the purchase or sale or the offer or sale of securities.
8. 	Based on these and other facts alleged by the SEC, there is good cause to
believe that Defendants and Relief Defendants will dispose of, dissipate, or remove investor
funds and assets from the jurisdiction of the Court. Such dissipation of investor funds and
assets would constitute irreparable harm to investors. To avoid this irreparable harm, it is
appropriate for the Court to issue this Order ex parte so that prompt service on appropriate
financial institutions and persons acting in concert with or directing the activities of Defendants
and Relief Defendants can be made, thus preventing the dissipation of investor funds.
Now, therefore,
I.
IT IS HEREBY ORDERED that, pending the determination of the SEC’s request for
a preliminary injunction and the implementation of the asset freeze requested therein:
A. 	The assets, funds, or other property held by or under the direct or indirect
control of Defendants or Relief Defendants, whether held in any of their names or for their
direct or indirect beneficial interests, wherever located, up to the amount of $251,074,084 are
frozen, including but not limited to the accounts listed below in Schedule A to this Order and
the assets listed in Schedule B to this order.
B. 	Defendants and Relief Defendants, and their officers, directors, successor
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corporations, subsidiaries, affiliates, agents, servants, employees, attorneys-in-fact, and those
persons in active concert or participation with them who receive actual notice of this order by
personal service or otherwise, and each of them, shall hold and retain within their control, and
otherwise prevent any disposition, transfer, pledge, encumbrance, assignment, dissipation,
concealment, or other disposal whatsoever of any of their funds or other assets or things of
value presently held by them, under their control or over which they exercise actual or apparent
investment or other authority, in whatever form such assets may presently exist and wherever
located, including but not limited to the accounts and assets listed in Schedules A and B, as
defined above, up to the amounts identified in paragraph I.A.
C. 	Any bank, financial or brokerage institution, storage facility, or other person or
entity holding any funds, securities or other assets of Defendants or Relief Defendants, up to the
amounts identified in paragraph I.A, held in the name of, for the benefit of, or under the control
of Defendants or Relief Defendants; or their officers, directors, successor corporations,
subsidiaries, affiliates, agents, servants, employees, attorneys-in-fact, and those persons in
active concert or participation with them, and each of them, shall hold and retain within their
control and prohibit the withdrawal, removal, transfer or other disposal of any such funds or
other assets, including but not limited to assets held listed in Schedules A and B, as defined
above.
D. 	No person or entity, including Defendants or Relief Defendants, or any creditor
or claimant against the Defendants or Relief Defendants, or any person acting on behalf of such
creditor or claimant, shall take any action to interfere with the asset freeze, including, but not
limited to, the filing of any lawsuits, liens, or encumbrances, or bankruptcy cases to impact the
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property and assets subject to this order; provided, however, that any party or non-party may
seek leave from this order upon a proper showing.
E. 	The SEC may file Notices of Lis Pendens, or any similar document that has the
effect of clouding title, on all pieces of real property in which Defendants or Relief Defendants
have an interest. Should the Defendant or Relief Defendants wish to sell any piece of real
property in which they have an interest, they shall give counsel for the SEC notice of the
proposed sale and seek and obtain an order of the Court permitting the sale prior to the sale.
Defendants and Relief Defendants shall fully account for any proceeds received from the sale of
such property to the Court and counsel for the SEC, and the proceeds of such sales shall be
frozen pursuant to the provisions of this Order; and Defendants and Relief Defendants are
hereby prohibited from further encumbering their interests in any real or personal property by
means of pledging it for collateral for any purpose or by allowing it to secure any obligation.
This order applies, but is not limited, to the following properties:
• 	5406 South Cottonwood Court, Greenwood Village, Colorado 80121;
• 	8082 East Arroyo Hondo Road, Scottsdale, Arizona 85266;
• 	1201 Lloyds Road, Little Elm, Texas 75068;
• 	330 Dorado Beach East, Dorado, Puerto Rico 00646;
• 	319 Dorado Beach East, Dorado, Puerto Rico 00646;
• 	Mira Mar Villas, #15 Garden Drive, Paradise Island, Bahamas; and
• 	Unit Number 704, Ocean Place Condominiums, Paradise Island, Bahamas.
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II.
IT IS FURTHER ORDERED that, pending the determination of the SEC’s request for a
preliminary injunction and the implementation of the asset freeze requested therein:
Defendants and Relief Defendants are prohibited, directly or indirectly, from accepting
funds from investors for investment in any investment program. Defendants and Relief
Defendants and their officers, directors, successor corporations, subsidiaries and affiliates,
agents, servants, employees, attorneys-in-fact, and those persons in active concert or
participation with them who receive actual notice of this order by personal service or otherwise,
and each of them, shall refrain from accepting, taking control of, or depositing in any financial
institution, funds from investors.
III.
IT IS FURTHER ORDERED that, pending the determination of the SEC’s request
for a preliminary injunction and the implementation of the asset freeze requested therein:
A. 	Defendants and their officers, directors, subsidiaries, affiliates, agents, servants,
employees, attorneys-in-fact, and those persons in active concert or participation with them who
receive actual notice of this order by personal service or otherwise, and each of them, are
enjoined and restrained from, directly or indirectly, in violation of Section 17(a) of the Securities
Act of 1933 [15 U.S.C. § 77q(a)], in the offer or sale of any security by the use of any means or
instruments of transportation, or communication in interstate commerce or by the use of the
mails:
(1) employing any device, scheme, or artifice to defraud; or
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(2) obtaining money or property by means of any untrue statement of a material
fact or any omission to state a material fact necessary in order to make the
statements made, in the light of the circumstances under which they were made,
not misleading; or
(3) engaging in any transaction, practice, or course of business that operates or
would operate as a fraud or deceit upon the purchaser.
B. 	Defendants and their officers, directors, subsidiaries, affiliates, agents, servants,
employees, attorneys-in-fact, and those persons in active concert or participation with them who
receive actual notice of this order by personal service or otherwise, and each of them, are
enjoined and restrained from, directly or indirectly, in violation of Section 10(b) of the Exchange
Act of 1934 [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-
5], in connection with the purchase or sale of any security by the use of any means or
instruments of transportation, or communication in interstate commerce or by the use of the
mails:
(1) employing any device, scheme, or artifice to defraud; or
(2) making any untrue statement of a material fact or to omit to state a material
fact necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; or
(3) engaging in any act, practice, or course of business which operates or would
operate as a fraud or deceit upon any person.
C. 	Mediatrix Capital, Young, Stewart, and Sewall, and their officers, directors,
subsidiaries, affiliates, agents, servants, employees, attorneys-in-fact, and those persons in active
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concert or participation with them who receive actual notice of this order by personal service or
otherwise, and each of them, are enjoined and restrained from, directly or indirectly, in violation
of Sections 206(1) and 206(2) of the Advisers Act of 1940 [15 U.S.C. §§ 80b-6(1) and 80b-6(2)],
by the use of the mails or by any means or instrumentality of interstate commerce:
(1) employing any device, scheme, or artifice to defraud any client or prospective
client; or
(2) engaging in any transaction, practice, or course of business which operates as
fraud or deceit upon any client or prospective client.
D. 	Mediatrix Capital, Young, Stewart, and Sewall, and their officers, directors,
subsidiaries, affiliates, agents, servants, employees, attorneys-in-fact, and those persons in active
concert or participation with them who receive actual notice of this order by personal service or
otherwise, and each of them, are enjoined and restrained from, directly or indirectly, in violation
of Section 206(4) of the Advisers Act of 1940 [15 U.S.C. § 80b-6(4)] and Rule 206(4)-8
thereunder [17 C.F.R. § 275.206(4)-8)], by the use of the mails or by any means or
instrumentality of interstate commerce:
(1) making any untrue statement of a material fact or omitting to state a material
fact necessary to make statements made, in the light of the circumstances under
which they were made, not misleading, to any investor or prospective investor in
a pooled investment vehicle; or
(2) otherwise engaging in any act, practice, or course of business that is
fraudulent, deceptive, or manipulative with respect to any investor or prospective
investor in a pooled investment vehicle.
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E. 	Defendants and their officers, directors, subsidiaries, affiliates, agents, servants,
employees, attorneys-in-fact, and those persons in active concert or participation with them who
receive actual notice of this order by personal service or otherwise, and each of them, are
enjoined and restrained from, directly or indirectly, in violation of Sections 5(a) and (c) of the
Securities Act [15 U.S.C. § 77e], in the absence of any applicable exemption:
(1) unless a registration statement is in effect as to a security, making use of any
means or instruments of transportation or communication in interstate commerce
or of the mails to sell such security through the use or medium of any prospectus
or otherwise; or
(2) unless a registration statement is in effect as to a security, carrying or causing
to be carried through the mails or in interstate commerce, by any means or
instruments of transportation, any such security for the purpose of sale or for
delivery after sale; or
(3) making use of any means or instruments of transportation or communication
in interstate commerce or of the mails to offer to sell or offer to buy through the
use or medium of any prospectus or otherwise any security, unless a registration
statement has been filed with the Commission as to such security, or while the
registration statement is the subject of a refusal order or stop order or (prior to the
effective date of the registration statement) any public proceeding or examination
under Section 8 of the Securities Act [15 U.S.C. § 77h].
IV.
IT IS FURTHER ORDERED that Defendants and Relief Defendants, and each of
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their successor corporations, subsidiaries, and affiliates, shall within five days of service of this
Order, each file with the Court, and serve on the SEC at the address of its counsel of record, a
sworn accounting of:
A. 	Each account, including safe deposit boxes, with any bank, financial institution
or brokerage firm, maintained in the names of Defendants or Relief Defendants, or the names
of any subsidiary, affiliate, or agent, in which they have direct or indirect control or beneficial
interest, and the current value and makeup of that account;
B. 	All investments, securities, funds, real estate, collectibles, and other assets held
in the names of Defendants or Relief Defendants, or in the names of any subsidiary, affiliate, or
agent or under their direct or indirect control, stating a description, a value, and location of
such assets; and
C. 	Every transaction in which the ownership, direction, or control of any funds or
other assets of any kind have been transferred, directly or indirectly, to or from: (i) Defendants
or their affiliates, subsidiaries, or agents since February 2016; and (ii) Relief Defendants or
their affiliates, subsidiaries, or agents since February 2016.
V.
IT IS HEREBY FURTHER ORDERED that Defendants and Relief Defendants shall,
in conjunction with the ordered asset freeze, repatriate, and take such steps as are necessary to
repatriate, to the territory of the United States of America, any and all assets and funds, held by
or in the name of Defendants or Relief Defendants, or in which any of them, directly or
indirectly, has or had any beneficial interest, or over which any of them maintained or maintains
and/or exercised or exercises control, including but not limited to any and all assets and funds:
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A. Held in foreign bank, brokerage, or other financial accounts; or
B. Transferred out of the United States from any account within the territory of the
United States at any point from February 2016 to the present.
To effectuate this repatriation, Defendants shall provide to this Court and to the SEC,
within five days of this Order, a written description of all such funds and assets required to be
repatriated, and the status and location of such funds, so that the Court may Order the unfreezing
of these assets to allow for their repatriation.
VI.
IT IS FURTHER ORDERED that, pending the determination of the SEC’s request for a
preliminary injunction and the implementation of the asset freeze requested therein:
Defendants and Relief Defendants, and any of their officers, agents, servants, employees,
attorneys, and those persons in active concert or participation with them who receive actual
notice of this Order by personal service or otherwise, and each of them, are hereby enjoined and
restrained from destroying, altering, concealing or otherwise interfering with the access of the
SEC to any and all documents, books and records, that are in the possession, custody or control
of the Defendants or Relief Defendants, and any of their officers, agents, servants, employees,
attorneys, and those persons in active concert or participation with them, that refer, reflect or
relate to the allegations in the Complaint, or that refer, reflect or relate to Defendants’ or Relief
Defendants’ assets, finances or business operations.
VII.
IT IS FURTHER ORDERED that the SEC’s application for expedited discovery is
granted and that, commencing with the time and date of this Order, in lieu of the time periods,
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notice provisions, and other requirements of Rules 26, 30, 33, 34, 36, and 45 of the Federal
Rules of Civil Procedure, discovery shall proceed as follows:
A. 	Pursuant to Rule 30(a) of the Federal Rules of Civil Procedure, the parties may
take depositions upon oral examination on three days’ notice of any such deposition.
Depositions may be taken telephonically. As to Defendants and Relief Defendants, and their
officers, directors, subsidiaries and affiliates, agents, servants, employees, owners, brokers,
associates, trustees, and underwriters, the SEC may depose such witnesses after serving a
deposition notice by facsimile, e-mail, mail, hand or overnight courier upon such Defendant or
Relief Defendants and without serving a subpoena on such witness. Depositions that have not
been signed by the witness may be used for purposes of the hearing on the SEC’s motion for a
preliminary injunction;
B. 	Pursuant to Rule 33(a) of the Federal Rules of Civil Procedure, the Parties shall
answer interrogatories within three days of service of such interrogatories. Interrogatories may
be served and answered by facsimile, e-mail, mail, hand or overnight courier upon the parties or
their counsel;
C. 	Pursuant to requests under Rule 34(b) of the Federal Rules of Civil Procedure,
the parties shall produce all documents requested within five days of service of such request.
Documents produced to the SEC shall be delivered to Stephen C. McKenna at
McKennaS@sec.gov and Mark L. Williams at WilliamsML@sec.gov, as well as by overnight
delivery to Stephen C. McKenna at Securities and Exchange Commission, 1961 Stout St., Suite
1700, Denver, CO 80294, phone number (303) 844-1036, or such other place as counsel for the
SEC may direct in writing. Requests for production may be served by facsimile, e-mail, mail,
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hand or overnight courier upon the parties or their counsel; and
D. 	Pursuant to Rule 36(a) of the Federal Rules of Civil Procedure, the parties
shall respond to requests for admissions within three days of such requests. Requests for
admission may be served by facsimile, e-mail, mail, hand or overnight courier upon the
parties or their counsel; and
E. 	All written responses to the SEC’s requests for discovery under the Federal
Rules of Civil Procedure shall be delivered to Stephen C. McKenna at McKennaS@sec.gov
and Mark L. Williams at WilliamsML@sec.gov, as well as by overnight delivery to Stephen
C. McKenna at Securities and Exchange Commission, 1961 Stout St., Suite 1700, Denver, CO
80294, phone number (303) 844-1036, or such other place as counsel for the SEC may direct
in writing; and
F. 	In connection with any discovery from any non-party, deposition or document
discovery may be had within five days of service of a subpoena pursuant to Rule 45.
Service of a subpoena may be made by facsimile, e-mail, mail, hand or overnight courier.
VIII.
IT IS FURTHER ORDERED that service of this Order, the Summons and Complaint
may be made by facsimile, mail, e-mail, delivery by commercial courier, or personally by any
employee of the Securities and Exchange Commission who is not counsel of record in this
matter, or special process server, or any other person, or in any other manner authorized by Rule
5 of the Federal Rules of Civil Procedure and may be made on any registered agent, officer, or
director of Defendants, or Relief Defendants or by publication. As indicated, discovery requests
may be communicated by facsimile, e-mail, mail, hand, or delivery by commercial courier.
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IX.
IT IS HEREBY FURTHER ORDERED that Defendants appear before this Court in
Courtroom A601 of the United States District Court for the District of Colorado, located at
901 19th Street, Denver, Colorado, at 9 a.m. on the 27th day of September, 2019, for a hearing at
which Plaintiff will seek a preliminary injunction extending the asset freeze and other ancillary
relief entered in this Order until final adjudication of this case on the merits.
X.
IT IS FURTHER ORDERED that Defendants and Relief Defendants shall deliver any
opposing papers in response to the requested relief no later than September 24, 2019, at 12 p.m.
Service shall be made by delivering the papers, using the most expeditious means available, by
that date and time, to Stephen C. McKenna at McKennaS@sec.gov and Mark L. Williams at
WilliamsML@sec.gov, or such other place as counsel for the SEC may direct in writing. The
SEC shall have until September 25, 2019, at 5 p.m. to serve, by the most expeditious means
available, any reply papers upon the Defendants, or their counsel, if counsel shall have made an
appearance in this action.
XI.
IT IS HEREBY FURTHER ORDERED that Plaintiff’s Emergency Motion for an
Ex Parte Order to File Under Seal the Complaint and All Papers Filed Therewith Pending
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Disposition of Plaintiff’s Motion for Temporary Restraining Order and Implementation of Asset
Freeze is GRANTED.
XII.
IT IS HEREBY FURTHER ORDERED that all documents filed in this matter are
SEALED. This Order does not preclude the Commission from serving the Temporary
Restraining Order on banks or other financial institutions in order to effectuate the asset freeze.
After the asset freeze has been effectuated, the Commission shall notify the Court and the seal
will be lifted.
XIII.
IT IS FURTHER ORDERED that the Court shall retain jurisdiction of this matter for
all purposes.
SO ORDERED this 13th day of September, 2019, at 1 p.m.
BY THE COURT:
____________________________________
RAYMOND P. MOORE
United States District Judge
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SCHEDULE A
Financial Institution 	Account Name 	Account Number(s)
Banco Popular of Puerto Rico 	Michael S. Young 	xxxxx9843
xxxxx4983
KeyBank 	Michael S. Young and Maria C.
Young
xxxxxxxx6425
KeyBank 	Michael S. Young 	xxxxxxxx7313
xxxxxxxx7226
UBS Financial Services 	Michael Young FBO J.D.Y. 	DKxxx7894
UBS Financial Services 	Michael Young FBO L.F.Y. 	DKxxx7994
UBS Financial Services 	Michael Young FBO M.S.Y. II 	DKxxx7794
UBS Financial Services 	Michael Young FBO M.J.Y. 	DKxxx8094
UBS Financial Services 	Michael Young FBO S.M.Y. 	DKxxx7694
UBS Financial Services 	Michael S. Young and Maria C.
Young
DKxxx8594
American Funds Service
Company
Michael Young FBO J.D.Y. 	xxxxxx8096
American Funds Service
Company
Michael Young FBO L.F.Y. 	xxxxxx8130
American Funds Service
Company
Michael Young FBO M.S.Y. II 	xxxxxx8124
American Funds Service
Company
Michael Young FBO M.J.Y. 	xxxxxx8135
American Funds Service
Company
Michael Young FBO S.M.Y. 	xxxxxx8138
IRA Services Trust Company 	Michael S. Young 	xxxxx6452
Wells Fargo Bank 	Michael S. Young 	xxxxxx9510
The Penn Mutual Life
Insurance Company
Michael S. Young 	xxxxx4007
xxxxx4006
xxxxx7600
Banco Popular of Puerto Rico 	Michael S. Stewart 	xxxxx1784
BBVA Compass 	Michael Stewart 	xxxxxx7078
Hughes Federal Credit Union 	Michael Shawn Stewart 	xxx503-1
xxx503-150
MidFirst Bank 	Victoria M. Stewart and/or
Michael Shawn Stewart
xxxxxx8270
xxxxxx8059
USAA Federal Savings Bank 	Michael S. Stewart and Victoria
M. Stewart
xxxxxx8132
xxxxxx8159
Wells Fargo Bank 	Michael S. Stewart 	xxxxxx8803
xxxxxx7554
xxxxxx7876
Case No. 1:19-cv-02594-PAB-STV Document 10 filed 09/13/19 USDC Colorado
pg 18 of 21

19
Financial Institution 	Account Name 	Account Number(s)
Wells Fargo Bank 	Michael S. Stewart dba
Relentless Operating
xxxxxx7884
Wells Fargo Bank 	Michael S. Stewart
Relentless Operating
xxxxxx8787
Wells Fargo Clearing Services
LLC
Michael S. Stewart 	xxxx9286
Banco Popular of Puerto Rico 	Bryant E. Sewall 	xxxxx8741
Navy Federal Credit Union 	Bryan Sewall 	xxxxxx7165
xxxxxx7026
Service Credit Union 	Bryant E. Sewall 	xxxx4106-00
xxxx4106-09
USAA Federal Savings Bank 	Bryant E. Sewall 	xxxxxx5212
xxxxxxxxxx0814
Wells Fargo Bank 	Bryant E. Sewall 	xxxxxx4386
Ansbacher (Bahamas) Limited
(The Bahamas)
Mediatrix Capital Fund Ltd. 	xxxx1901
Wells Fargo Bank 	Island Technologies, LLC 	xxxxxx0573
xxxxxx6478
xxxxxx6486
xxxxxx2424
Banco Popular of Puerto Rico 	Island Technologies, LLC 	xxxxx9027
xxxxx9329
Banco Popular of Puerto Rico 	West Beach, LLC 	xxxxx5590
UBS Financial Services 	Salve Regina Trust 	5Vxxx0794
DKxxx2294
DKxx422
KeyBank 	TF Alliance, LLC 	xxxxxxxx3581
xxxxxxxx0586
xxxxxxxx0022
BBVA Compass 	Keystone Business Trust 	xxxxxx4795
xxxxxx3827
xxxxxx3921
Wells Fargo Bank 	Weinzel, LLC 	xxxxxx9170
xxxxxx9354
Wells Fargo Bank 	Mediatrix Capital PR LLC 	xxxxxx9959
Wells Fargo Bank 	Mediatrix Capital, LLC 	xxxxxx3292
Global Fidelity Bank, Ltd. 	Blue Isle Markets Inc. 	100-xxxx88-1
100-xxxx88-2
100-xxxx88-3
105-xxxx88-1
Wells Fargo Clearing Services 	Victoria Marie Stewart 	xxxx9200
Case No. 1:19-cv-02594-PAB-STV Document 10 filed 09/13/19 USDC Colorado
pg 19 of 21

20
Financial Institution 	Account Name 	Account Number(s)
LLC
Wells Fargo Bank 	Victoria M. Stewart 	xxxxxx2188
Wells Fargo Bank 	Maria C. Gartner 	xxxxxxxxxxxx2868
KeyBank 	Maria Young 	xxxxxxxxxxxxxx6001
PJSC CB Privatbank
(Ukraine)
Hanna Ohonkova 	xxxxxxxxxxxx1460
xxxxxxxxxxxx2500
xxxxxxxxxx8501
xxxxxxxxxx0901
xxxxxxxxxxxx1464
xxxxxxxxxxxx2507
Česká spořitelna (Czech
Republic)
Blue Isle Markets Inc. 	xxx3192
xxx3272
xxx3352
xxx9312
xxx9582
ANZ Bank New Zealand
Limited (New Zealand)
Blue Isle Markets Ltd. 	xxxxxxxxx9449
xx9344-EUR
xx9344-USD01
xx9344-USD02
Kiwibank Ltd. 	Blue Isle Markets Ltd. 	xxxxxxxxx1911
Equiti Armenia CJSC
(Armenia)
Blue Isle Markets Inc. 	xx013
xx021
xx023
xxxx029
Equiti Capital UK Limited
(United Kingdom)
Blue Isle Markets Inc. 	xx160
xx166
xx167
Advanced Markets UK Ltd.
(United Kingdom)
Blue Isle Markets Ltd. 	xxxxxxxE_WL
xxxxxxxE2_WL
Case No. 1:19-cv-02594-PAB-STV Document 10 filed 09/13/19 USDC Colorado
pg 20 of 21

21
SCHEDULE B
Asset 	Payment Amount 	Payment Date 	Other Information
Securities (private
placement)
$375,000 	4/19/2018 	Issuer: NRS Health and
Wellness
Boat 	$293,100 	1/18/2018 	2014 Sea Vee Critical Mass
39ft
Jewelry 	$225,000
(approx.)
various 	2017 to 2019
Boat Lift 	$135,073 	6/2018 to
2/2019
Purchase and installation
Vehicle 	$124,635 	1/7/2019 	Land Rover
Vehicle 	$101,000 	8/18/2018 	2018 Tahoe; 2016 Jeep
Wrangler
Vehicle 	$88,000 	2/14/2018 	2018 BMW
Vehicle 	$68,302 	12/4/2017 	1986 Land Rover Defender
Vehicle 	$65,557 	4/18/2019 	Land Rover
Marina Expenses 	$64,761 	1/28/2019
Vehicle 	$55,000 	7/3/2017 	2017 Jeep Wrangler
Golf Carts 	$46,279 	6/8/2017 &
3/15/2019
Boat 	$28,553 	3/26/2018 	Luxury Water Toys
Vehicle 	$22,000 	2/16/2018 	2nd Payment for Ford F250
Truck
Furniture 	$51,487 	Various
Art 	$17,107 	12/4/2018 &
1/11/2019
Firearms 	$7,856 	12/10/2018 	Custom Rifle
Case No. 1:19-cv-02594-PAB-STV Document 10 filed 09/13/19 USDC Colorado
pg 21 of 21