SECURITIES AND EXCHANGE COMMISSION Washington, D.C. LITIGATION RELEASE NO. 15771 / June 5, 1998 SECURITIES AND EXCHANGE COMMISSION v. DANIEL T. TODT, et. al., 98 Civ. 3980 (JGK) (SDNY) (June 5, 1998) The Commission today filed a complaint and requested emergency injunctive relief in an action involving the offer and attempt to sell forged and fictitious securities. The complaint, filed in the U.S District Court for the Southern District of New York, seeks an injunction and other relief against Daniel T. Todt ( Todt ), Rebecca L. Todt (Rebecca Todt ), Bay State Trust, Inge Marilyn Perry ( Perry ), H. Wayne Leggett ( Leggett ), Shmmuel Emmanuel Abijah Quijano (a/k/a HRH Shmmuel Abijah, a/k/a Sergio Arcineagas) ( Abijah ), Neal Harris ( Harris ), ABE Investments Group, Inc. ( ABE ) and Jorge Bryson ( Bryson ). The Commission alleged in its complaint that since at least March 1997, the defendants have been engaging in a scheme to obtain money through the offer of fraudulent securities in violation of the antifraud provisions of the federal securities laws. The Commission alleged in its complaint that the defendants have been engaged in continuing offers and attempts to sell at least one fraudulent bank certificate being represented as issued by the Bank of Tokyo- Mitsubishi, Ltd. ( Mitsubishi Certificate ). In fact, the complaint alleges that the Mitsubishi Certificate is a sham document. Defendants Todt, Rebecca Todt, Bay State Trust, Perry, Leggett, Abijah, Harris, ABE and Bryson are all alleged to be part of a fraudulent scheme to use the Mitsubishi Certificate to obtain millions of dollars in payments for themselves, while invoking both humanitarian goals and the names of official entities, ranging from the Federal Reserve Bank to the United Nations Security Council, in an effort to make their scheme appear legitimate. The purported issuing bank for the Mitsubishi Certificate, as well as the FBI and the Federal Reserve, among others, have confirmed that the certificate is a worthless, sham document. The defendants, nonetheless, are persisting in their efforts to negotiate the Mitsubishi Certificate. Further, the Commission alleged that some of the defendants possess at least one additional bogus bank certificate which they intend to sell. To prevent the defendants from continuing to offer these and other securities and potentially selling them to investors, the Commission also requested that the District Court issue a temporary restraining order against Todt, Rebecca Todt, Bay State Trust, Perry, Abijah, Harris, ABE and Bryson and an order that the defendants tender the original fraudulent securities to the Registry of the Court. In addition to the emergency relief requested today, the Commission seeks civil injunctions and monetary penalties against the defendants for violations of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of ======END OF PAGE 1====== 1934 and Rule 10b-5 thereunder. ======END OF PAGE 2======