Here we go. ECMH
SECURITIES AND EXCHANGE COMMISSION,
11 Civ. _____ Plaintiff, COMPLAINT -against-ECF Case THE NIR GROUP, LLC; COREY RIBOTSKY; and DARYL DWORKIN, Jury Trial Demand Defendants.
1. Furthermore, in November and December 2008, Ribotsky purported to sell $43.2 million ofthe AJW Funds' assets to a third-party (the "Purchaser") in an apparent effort to show investors that NIR was continuing to generate cash (or realized gains) in the fourth quarter of 2008. The Purchaser, however, did not pay cash for the AJW Funds' assets; rather, he signed "promissory notes" agreeing to pay the full $43.2 million purchase price in cash within 3-6 months. The Purchaser defaulted on the promissory notes and never paid for the assets, yet he continues to own and control the assets and has not returned them to the AJW Funds.