SEC v. mUrgent Corporation; Vladimir Boris Bugarski; Vladislav Walter Bugarski; and Aleksander Negovan Bugarski, Central District of California (Apr. 21, 2011) — Complaint

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COpy
 
GREGORY C. GLYNN, Cal. 
BarNo. 039999 
Email: 
glY!lng@sec.~ov 
JASONP. LEE, Cal. BarNo. 196520 
Email: [email protected] 
Attorneys for Plaintiff
Securities and Exchange Commission
Rosalind 
R. Tyson Regional Director 
John 
M. McCoy IIi, Associate Regional Director
5670 Wilshire Boulevar'k 
11th Floor 
Los Angeles, California y0036 
Telephone: (323) 965-3998 
FacsImile: (323) 965-3908 
CJ 
n
-< 
0:­
~r"" 
z::X.l 
-4::J'1: 
~ 
\ 
,:Uc: 
""0 
c....... ,.. 
:::0
 
~~;-~") 
\ 
:.-9:2 
N 
;
 
Z~""t/")
 
~,") -~-4 
""0
:Xl
i 
'Tl
..-0-
:x
i 
m~n 
lI' ...... 
-
~n 
00 
~ 0 
N
Cc: 
\ 
-.1
7':u 
-4 
;\ 
UNITED STATES DISTRICT COURT 
~ I~I . ":t . 
CENTRAL DISTRICT OF CALIFORNIA "'i 
SECURITIES AND EXCHANGE 
COMMISSION, 
Plaintiff, 
v. 
mURGENT 
CORPORATIO~ VLADIMIR 
BORIS BUGARSKL 
VLADI~LAV 
WALTERBUGAR~KI, and 
ALEKSANDERNEGOVANBUGARSKI, 
Defendants. 
cms«<CV11-0 062. 6' DOC -' SSJ. 
COMPLAINT FOR VIOLATION" 
OF THE FEDERAL SECURITIES 
LAWS 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Plaintiff Securities and Exchange Commission ("Commission") alleges as 
follows: 
JURISDICTION AND VENUE 
1. This Court has jurisdiction over this action pursuant to Sections 20(b), 
20(d)(1), 20(e), and 22(a) 
ofthe Securities Act of 1933 ("Securities Act"), 15 
U.S.C. §§ 77t(b), 77t(d)(1), 77t(e) & 77v(a), and Sections 21(d)(I), 21(d)(2), 
21(d)(3)(A), 21(e) and 27 
ofthe Securities Exchange Act of 1934 ("Exchange 
Act"), 
15 U.S.C. §§ 78u(d)(l), 78u(d)(2), 78u(d)(3)(A), 78u(e) & 78aa. 
Defendants have, directly or indirectly, made use 
of the means or instrumentalities 
ofinterstatecommerce, ofthe mails, or ofthe facilities ofa national securities 
exchange, in connection with the transactions, acts, practices, and courses 
of 
business alleged in this Complaint. 
2. Venue is proper in this district pursuant to Section 22(a) 
of the 
Securities Act, 
15 U.S.C. § 77v(a), and Section 27 ofthe Exchange Act, 15 U.S.C. 
§ 78aa,because certain 
ofthetransactions, acts,practices, andcourses ofconduct 
constituting violations 
of the federal securities laws occurred within this district, 
and the Defendants transact or have transacted business in this district. 
SUMMARY 
3. Since at least 2008, Defendant mUrgent Corporation, a family-
controlled, private company located in Santa Ana, California, and its principals 
raised approximately $9.6 million from at least 130 investors through unregistered 
offerings by making material misrepresentations and omissions concerning the 
company's financing plans and business performance. Defendants Vladimir Boris 
Bugarski ("Boris"), ChiefExecutive Officer, Vladislav Walter Bugarski 
("Walter"), Boris' and AIeles' father and Chief Financial Officer, and AIeksander 
Negovan Bugarski ("Aleks"), Boris' twin and ChiefOperating Officer 
(collectively, "the Bugarskis"), created and utilized a "boiler-room" to sell 
mUrgent stock. Walter and Aleks supervised mUrgent employees working in this 
2
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
boiler-room -  "fronters" and "closers" -  who cold-called investors, used high 
pressure sales tactics, and made material misrepresentations concerning, among 
other things, mUrgent's purportedly imminent IPO. Walter and Aleks instructed 
these employees to make this misrepresentation, among others, and repeated them 
to investors directly. mUrgent, however, has never taken any concrete steps to 
conduct an IPO. As mUrgent's chiefexecutive officer, Boris was responsible for 
and oversaw the totality 
ofmUrgent's business, including its offering activities, 
and as such was well-aware ofthe magnitude and extensiveness ofmUrgent's 
capital raising. While Boris communicated regularly with mUrgent's shareholders, 
he delegated the logistics ofthe securities offerings to his father and brother, who 
themselves directly participated in and supervised these activities. However, 
mUrgent's stock sales were not effectuated until Boris executed the critical 
offering-related documents. Many investors wrote checks 
or wired monies to buy 
mUrgent shares solely in reliance on the false promise ofmUrgent's upcoming 
public offering or other rosy business prospects. 
4. The Defendants have violated the securities registration provisions 
of 
Sections 5(a) and 5(c) ofthe Securities Act, 15 U.S.C. §§ 77e(a) & 77e(c), the 
brokerregistrationprovisions ofSection 15(a)(I) oftheExchangeAct, 15U.S.C. 
§§ 78o(a)(I), and the antifraud provisions ofSection 17(a) ofthe Securities Act, 15 
U.S.C. § 77q(a), and Section lO(b) ofthe Exchange Act, 15 U.S.C. § 78j(b), and 
Rule 10b-5 thereunder, 17 C.F.R. § 240.IOb-5. By this action, the Commission 
seeks permanent injunctions prohibiting future such violations, disgorgement 
of 
the Defendants' ill-gotten gains, civil penalties, and, as to Defendants Boris, . 
Walter, and Aleks Bugarski, a prohibition from serving 
as officers or directors of 
any public company. 
THE DEFENDANTS 
5. mUrgent Corporation is a private, California corporation with 
headquarters in Santa Ana, California. 
3
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6. Vladimir Boris Bugarski, age 36, is mUrgent's Chief Executive 
Officer and President. 
He resides in Costa Mesa, California. He is also subject to 
a cease and desist order issued 
by the Division of Securities, Department of 
Financial Institutions, State of Wisconsin ("Wisconsin securities regulator") in July 
2000. 
7. Vladislav Walter Bugarski, age 67, is mUrgent's Chief Financial 
Officer. He resides in Corona, California, and is the father 
ofidentical twins Ale1es 
and Boris Bugarski. Walter is subject to cease and desist orders issued by the 
Securities Commissioner 
ofthe State ofKansas in July 1995, Pennsylvania 
Securities Commission in January 2001, and Wisconsin securities regulator in July 
2000. 
8. Aleksander Negovan Bugarski, age 36, is mUrgent's Chief 
Operating Officer and Executive Vice President. He resides in Corona, California. 
THE FRAUDULENT SCHEME 
A. 
The Defendants Established a "Boiler-room" to Sell mUrgent Shares 
9. mUrgent is a closely-held, family-controlled, private company located 
in Santa Ana, California, that provides Internet-related marketing services, 
including email advertising.primarily to restaurant franchises. Walter, the father 
and CFO, and Aleks and Boris, identical twin brothers and 
ChiefOperating Officer 
and CEO, respectively, are mUrgent's top management, majority shareholders, and 
board members. 
10. Beginning in 2008, mUrgent offered $10 million 
ofstock in two $5 
million offerings through cold-calls 
by more than a dozen employees. Through 
these unregistered offerings, the company has sold approximately $9.6 million 
of 
its securities, in the form ofcommon stock with detachable warrants, to over 130 
individuals throughout the country. 
The company used this capital raising activity 
to 
fund, in part, its operations. 
11. Walter and 
AIe1es set up and supervised a ''boiler-room'' dedicated to 
4
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the offer and sale ofmUrgent securities. They hired "fronters" who made over a 
thousand cold-calls a month to investors identified from lead lists purchased by 
Aleles. Most investors had never heard of mUrgent prior to being contacted. The 
fronters identified likely investors during these calls and handed them over 
to the 
"closers" to finish the sale. The closers were paid solely by commission ranging 
from 12% to 15% 
of the amount sold. 
12. In addition to these cold-calls, Walter and Aleks and the closers 
contacted pre-existing mUrgent shareholders, who had initially been cold-called by 
mUrgent and invested as a result, to offer and sell them additional mUrgent shares. 
In instances where Walter and Aleks sold shares to investors, they also received 
commissions. Walter earned at least $75,000 from commissions. Aleks also 
received additional compensation 
of approximately $107,961 outside of his salary, 
which consists at least in part 
of commissions from stock sales. 
13. As the CEO, Boris knew about the company's and his father's and 
brother's offering and sale activity and that boiler-room employees received 
commissions from their sales 
of mUrgent stock. Boris also played an integral role 
in the company's offerings. He signed all the subscription agreements and stock 
certificates and communicated with investors about the company's financial 
condition and business prospects. 
14. The closers also pressured investors to buy mUrgent shares by falsely 
telling them that share purchases by other investors were quickly depleting the 
available supply. In reality, the closers struggled to sell mUrgent shares to 
investors they cold-called and used this tactic to induce investments. In other 
instances, investors were told that 
ifthey purchased a certain number ofshares at 
the $2.50 per share offering price, they would then be immediately eligible to 
purchase a larger amount 
ofshares at a steeply discounted price ranging from $1 to 
$1.50 per share. mUrgent used the perception ofthis discount -  which was not 
reflected in and flatly contradicted by mUrgent's offering materials -
to induce 
5
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
investors to buy additional shares. 
15. Once an investor indicated an interest in investing, mUrgent used the 
inter-state mails 
to deliver a folder containing offering and promotional materials 
("Investor Packet") or requested that the investor submit the funds immediately. 
The Investor Packet contained, among other things, a "Confidential 
Memorandum," Subscription Agreement, and Investor Questionnaire. The 
Confidential Memorandum was the company's offering document and relied 
primarily on Rule 
506 of Regulation D, 17 C.F.R § 230.506, to explain why the 
offerings were unregistered. The Investor Packet did not contain even rudimentary 
financial information about mUrgent or its operating history. 
16. The closers continued to call prospective investors after delivering the 
Investor Packet, pushed them to invest, and urged them 
to write a check 
immediately. Once a prospective investor decided to invest, mUrgent arranged and 
paid for Federal Express to pick up the check and deliver it to the company. 
17. Although mUrgent purported to have policies and procedures 
governing the conduct 
oftheir fronters and closers, those policies were largely 
superficial and not enforced in practice. 
B.	 The Defendants Made Material Misrepresentations About 
mUrgent And Misappropriated Investor Money 
18. The Defendants, either directly or through the fronters and closers, 
made the following misrepresentations when soliciting investors: 
a.	 mUrgent's IPO was imminent; 
b.	 mUrgent had retained a financial consulting company 
to take 
the company public; 
c.	 mUrgent had recently signed or already had a stable ofmajor 
and well-known customers; 
d.	 mUrgent shares would surge in value following the IPO; and 
e.	 The offering proceeds would be used for company operations 
6 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
and not to pay salaries to the Bugarskis. 
mUrgent Had No Real Plans to Go Public 
19. mUrgent's primary pitch to investors focused on the company's 
purportedly imminent IPO. Closers told investors that the company had just filed 
"registration papers" and "it 
won't be long" before the IPO. In other instances, 
closers told investors that the IPO was scheduled for a date certain and even 
provided the anticipated price, which was well above the offering price. They 
added that mUrgent had retained a reputable financial consulting company that had 
brought hundreds 
ofcompanies public to facilitate mUrgent's public offering. 
Aleks also told investors 
ofthe financial consulting company's involvement with 
the company and that mUrgent was on the brink 
ofan IPO. mUrgent repeated this 
theme in offering and selling its securities to numerous investors, many 
of whom 
invested as a result. Examples 
ofthese misrepresentations, some ofwhich are 
reflected in sales scripts and similar documents, include: 
a. "We talked to [the financial consulting company president] 
again which is the gentlemen who we were talking to about taking us 
public and this company is going to be a monster. He has taken over 
200 companies public and 
he stated that we could easily raise 50 
million." 
b. "Please look at our company very seriously as this is not a start 
up project but an actual company getting ready to be publicly traded." 
c. "WE COULD BE LOOKING AT ROLLING OUT A $12.50 
IPO 
OR $9-$12 ACQUISITION OR MERGER WITHIN THE NEXT 
18-24 MONTHS, YOU SEE THE OBVIOUS POTENTIAL HERE 
(DON'T YOU?) GREAT! [capitalization in original]" 
d. "Talk about raising capital 
of50 million to go public by next 
year." 
e."...Mr. Boris Bugarski confirmed to me that the company was 
7 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
growing that there was interest from some parties to buy the company 
... It became obvious to me that [a closer], Mr. Aleks Bugarski, and 
Mr. Boris Bugarski over exaggerated when they told me that mUrgent 
was ready to go public 
... In our phone conversation [with Walter 
Bugarski], you said "We are closer than ever to going public." 
f. "We will be marching to our IPO 2
nd
/3
rd 
Quarter, and we are 
looking to close out this offering asap." 
g. 
"We are still focused on 2
nd
/3
rd 
Quarter to march to our IPO, 
and we are still thinking a $16-$19 price range per share ... This 
should 
be classified as a  'short term' investment." 
h. "We started working with a gentlemen who has taken over 200 
companies public. 
He feels we could probably go public right now 
(maybe $5-$7), but 
he wants us to continue doing what we've been 
doing and he thinks we can likely get our price up to and over double 
digits for an IPO." 
1. "We will be marching towards our IPO THIS year. Perhaps as 
earlyasAugust.. .. 
Wewanttotargeta $16-$17opening. Therefore, 
you 
may wish to consider acquiring a position that might make you 
some 'real' money." 
20. Despite these representations, mUrgent was nowhere near conducting 
an IPO. In fact, the company had not retained the financial consulting company to 
provide any services relating to 
an IPO. The financial consulting company never 
authorized mUrgent 
to represent to anyone that the firm was involved in an)' 
offering relating to mUrgent securities. 
mUrgent Misrepresented Its Business Results and Prospects 
21. When discussing mUrgent's business prospects with investors, the 
closerstoutedcompaniesthattheyclaimedweremajorcustomers 
ofmUrgent. In 
the Investor Packet, mUrgent enclosed "reference letters" from certain major, well­
8
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
known companies, among others, to suggest that there were on-going business 
relationships with those companies. These letters drove many investors to 
purchase mUrgent securities. 
22. In fact, some 
of these major, well-known companies did not have any 
business relationship with mUrgent when investors were solicited. 
23. In October 2009, Boris requested that T-Mobile write a reference 
letter to be used for mUrgent's prospective email marketing clients. T-Mobile, 
which was once a mUrgent customer, agreed. mUrgent, however, included the T­
Mobile reference letter with mUrgent's offering materials and made 
misrepresentations concerning T-Mobile's existing business relationship with 
mUrgent. When T-Mobile discovered that its letter was included in mUrgent's 
offering materials, T-Mobile requested that Boris remove it. Boris agreed but 
never removed the letter from mUrgent's offering materials, and mUrgent 
continued making misrepresentations concerning its business relationship with 
T­
Mobile. 
24. Finally, closers touted mUrgent's business prospects and emphasized 
the company's growth and success. 
The defendants, however, failed to include any 
financial information 
in the offering materials provided to investors. This 
information would have revealed the company's dismal financial condition. 
Instead, closers represented that the company's business was prospering when 
in 
reality mUrgent had never made a profit. In fact, the company's internal 
documents forecasted increasing losses, belying its representations to investors. 
The Bugarskis Misused Investor Funds 
25. The Bugarskis also misused investor funds. The Confidential 
Memoranda for the two offerings during the relevant period stated that the 
executive officers were not to receive any cash compensation. Despite this 
representation, Walter, Aleks, and Boris received cash salaries and bonuses during 
the relevant period of$398,511, $470,077, and $457,750, respectively. 
9
 

5
10
15
20
25
I 26. Walter also established a slush fund for the benefit of himself and his 
2 sons. In July 2008, Walter withdrew $530,000 from mUrgent's bank account and 
3 deposited those funds into a newly opened account at another financial institution. 
4 He then wrote checks to himself, Aleks, and Boris for $55,000, $50,000, and 
$50,000, respectively. 
6 27. The Bugarskis also used mUrgent as their personal piggybank and
 
7 funded their lifestyle by charging the company for numerous personal expenses,
 
8 such as luxury cars for Walter and his wife. Walter also used company funds to
 
9 finance, in part, the purchase 
ofhis second home.
 
FIRST CLAIM FOR RELIEF 
11 UNREGISTERED OFFER AND SALE OF SECURITIES 
12 Violations of Sections 5(a) and 5(c) of the Securities Act 
13 (Against AU Defendants) 
14 28. The Commission realleges and incorporates 
by reference paragraphs 1 
through 27 above. 
16 29. The Defendants, and each ofthem, by engaging in the conduct 
17 described above, directly or indirectly, made use ofmeans or instruments of 
18 transportationorcommunicationininterstatecommerce orofthemails,toofferto 
19 sell or to sell securities, or to carry or cause such securities to be carried through 
the mails or in interstate 
commerce for the purpose ofsale or for delivery after 
21 sale. 
22 
30. No registration statement has been filed with the Commission 
or has 
23 
been in effect with respect to the offering alleged herein. 
24 
31. 
By engaging in the conduct described above, the Defendants have 
violated, and unless restrained and enjoined will continue to violate, Sections 5(a) 
26 
and 5(c) 
ofthe Securities Act, 15 U.S.C. §§ 77e(a) and 77e(c). 
27 
SECOND CLAIM FOR RELIEF 
28 
FRAUD 
IN THE OFFER OR SALE OF SECURITIES 
10
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Violations of Section 17(a) of the Securities Act 
(Against All Defendants) 
32. The Commission realleges and incorporates by reference paragraphs 1 
through 27 above. 
33. The Defendants, and each 
ofthem, by engaging in the conduct 
described above, directly or indirectly, in the offer or sale ofsecurities by the use 
ofmeans or instruments oftransportation or communication in interstate 
commerce 
orbyuseofthe mails: 
a.	 with scienter, employed devices, schemes, 
or artifices to 
defraud; 
b.	 obtainedmoney 
orpropertybymeansofuntruestatements ofa 
material fact or by omitting to state a material fact necessary in 
order to make the statements made, in light ofthe 
circumstances under which they were.made, not misleading; 
or 
c.	 engaged in transactions, practices, or courses ofbusiness which 
operated 
or would operate as a fraud or deceit upon the 
purchaser. 
34. By engaging in the conduct described above, Defendants violated, and 
unless restrained and enjoined will continue to violate, Section 17(a) 
ofthe 
Securities Act, 15 U.S.C. 
§ 77q(a). 
THIRD CLAIM FOR RELIEF
 
FRAUD IN CONNECTION WITH THE
 
PURCHASE OR SALE OF SECURITIES
 
ViolationsofSection 1O(b)ofthe ExchangeActandRule 10b-5 Thereunder
 
(Against All Defendants)
 
35. The Commission realleges and incorporates by reference paragraphs I 
through 27 above. 
36.	 The Defendants, 
and each ofthem, by engaging in the conduct 
11 

5
10
15
20
25
I 
2 
3 
4 
6 
7 
8 
9 
11 
12 
13 
14 
16 
17 
18 
19 
21 
22 
23 
24 
26 
27 
28 
described above, directly 
or indirectly, in connection with the purchase or sale of a 
security, by the use 
of means or instrumentalities of interstate commerce, of the 
mails, or 
of the facilities ofa national securities exchange, with scienter: 
a. employed devices, schemes, or artifices to defraud; 
b. made untrue statements 
ofa material fact or omitted to state a 
material fact necessary in order to make the statements made, in the 
light 
ofthe circumstances under which they were made, not 
misleading; 
or 
c. engaged in acts, practices, or courses of business which 
operated 
or would operate as a fraud or deceit upon other persons. 
37. By engaging in the conduct described above, the Defendants violated, 
and unless restrained and enjoined will continue to violate, Section 10(b) 
of the 
Exchange Act, 
15 U.S.C. § 78j(b), and Rule 10b-5 thereunder, 17 C.F.R. § 
240.IOb-5. 
FOURTH CLAIM FOR RELIEF
 
FAILURE TO REGISTER AS A BROKER OR DEALER
 
Violations of Section 15(a)(1) of the Exchange Act
 
(Against All Defendants) 
38. The Commission realleges and incorporates 
by reference paragraphs 1 
through 27 above. 
39. The Defendants, while acting as brokers 
or dealers, effectuated
 
transactions in, or induced 
or attempted to induce the purchase or sale of,
 
securities while they were not registered with the Commission as a broker or
 
dealer or when they were not associated with an entity registered with the
 
Commission 
as a broker or dealer.
 
40. 
By engaging in the conduct described above, the Defendants have
 
violated, and unless restrained and enjoined will continue to violate, Section
 
15(a)(1) 
ofthe Exchange Act, 15 U.S.C. § 78o(a)(l).
 
12
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FIFTH CLAIM FOR RELIEF
 
CONTROL PERSON LIABILITY
 
(Pled in the Alternative Against Defendants
 
Boris, 
Walter, and Aleks Bugarski)
 
41. The Commission realleges and incorporates by reference paragraphs 1 
through 27 above. 
42. At all relevant times, Defendants Boris, Walter, and 
Aleles Bugarski 
possessed the power to direct and control mUrgent's management, policies, and 
operations and were control persons ofmUrgent pursuant to Section 20(a) 
ofthe 
Exchange Act, 
15 UoS.C. § 78t(a). 
43. Defendants Boris, Walter, and Aleks Bugarski were culpable 
participants 
in mUrgent's violations ofthe Exchange Act as described above. 
44. By reason 
ofthe foregoing, Defendants Boris, Walter, and Aleks 
Bugarski are jointly and severally liable 
as control persons with, and to the same 
extent as, mUrgent for mUrgent's violations 
of Section 10(b) of the Exchange Act, 
15 U.S.C. §§ 78j(b) and Rule IOb-5 thereunder, 17 C.F.R. 240.l0b-5, and unless 
enjoined and restrained, Defendants Boris, Walter, and Aleks Bugarski will 
continue to cause, or to fail to prevent, mUrgent's violations 
ofthese provisions. 
PRAYER FOR RELIEF 
WHEREFORE, the Commission respectfully requests that the Court: 
I. 
Issue findings of fact and conclusions oflaw that the Defendants committed 
the alleged violations. 
ll. 
Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), peIDlanently 
enjoining the Defendants and their officers, agents, servants, employees, and 
attorneys, and those persons in active concert 
or participation with any of them, 
who receiveactual notice 
ofthe order bypersonal service orotherwise, andeach of 
13
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
them, from violating Sections 5(a) and 5(c) of the Securities Act, 15 U.S.C. §§ 
77e(a) & 77e(c), Section 17(a) ofthe Securities Act, 15 U.S.C. § 77q(a), and 
Section 
lOeb) of the Exchange Act, 15 U.S.C. § 78j(b) and Rule 10b-5 thereunder, 
17 C.F.R. § 240.10b-5, and Section 15(a)(l) of the Exchange Act, 15 U.S.C. 
78o(a)(I). 
III. 
Order the Defendants to disgorge all ill-gotten gains from their illegal 
conduct, together with prejudgment interest thereon. 
IV. 
Order the Defendants to pay civil penalties under Section 20(d) ofthe 
Securities Act, 
15 U.S.C. § 77t(d), and Section 21(d)(3) of the Exchange Act, 15 
U.S.C. § 78u(d)(3). 
V. 
Order, pursuant to Section 20(e) ofthe Securities Act, 15 U.S.C. § 77t(e), 
andSection 
21(d)(2)oftheExchangeAct, 15U.S.C.§ 78u(d)(2),theprohibition of 
Defendants Boris, Walter, and Aleks Bugarski from acting as officers or directors 
ofany issuer that has a class ofsecurities registered with the Commission pursuant 
to Section 
12 of the Exchange Act, 15 U.S.C. § 78/, or that is required to file 
reports with the Commission pursuant to Section 15(d) 
ofthe Exchange Act, 15 
U.S.C.§ 78o(d). 
VI. 
Retainjurisdiction ofthis actioninaccordancewiththeprinciples ofequity 
and the Federal Rules 
ofCivil Procedure in order to implement and carry out the 
II 
II 
II 
II 
II 
14
 

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
terms ofall orders and decrees that may be entered, or to entertain any suitable 
application or motion for additional relief within the jurisdiction 
ofthis Court. 
"II. 
Grant such other and further reliefas this Court may determine to be just and 
necessary. 
DATED: April2J,2011 
Securities and Exchange Commission 
egory C. Glynn 
asonP. Lee 
Attorneys for Plaintiff 
15
 

UNITED STATES DISTRICT COURT
 
CENTRAL DISTRICT 
OF CALIFORNIA
 
NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY 
This case has been assigned to District Judge David O. Carter and the assigned 
discovery Magistrate Judge is Suzanne H. Segal. 
The case number on all documents filed with the Court should read as follows: 
SACVll-626 DOC (SSx) 
Pursuant to General Order 05-07 ofthe United States District Court for the Central 
District 
ofCalifornia, the Magistrate Judge has been designated to hear discovery related 
motions. 
All discovery related motions should 
be noticed on the calendar ofthe Magistrate Judge 
NOTICE TO COUNSEL 
A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is 
filed, 
a copy of this notice must be served on all plaintiffs). 
Subsequent documents must be filed at the following location: 
U	 Western Division 
[Xl Southern Division U Eastern Division 
312 
N. Spring St., Rm. G-a 
411 West Fourth St., Rm. 1-053 3470 Twelfth St., Rm. 134 
Los Angeles, CA 90012 
Santa Ana, CA 92701-4516 Riverside, CA 92501 
Failure to file at the proper location will result in  your documents being returned to you. 
CV-18 
(03/06) 
NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY 

Gregory Glynn, Cal. Bar No. 039999 
Email: [email protected] 
Jason 
P. Lee, Cal. Bar No. 196520 
Email: [email protected] 
Securities and Exchange Commission 
5670 Wilshire Boulevard, II th Floor, Los Angeles, California 90036 
Telephone: (323) 965-3998/ Facsimile: (323) 965-3908 
UNITED STATES DISTRICT COURT
 
CENTRAL DISTRICT OF CALIFORNIA
 
TO: DEFENDANT(S): _
 
A lawsuit has been filed against you. 
Within 
21 days after service ofthis summons on you (not counting the day you received it), you 
must serve on the plaintiff an answer to the attached 
l!l'complaint D amended complaint 
D counterclaim D cross-claim or a motion under Rule 12 ofthe Federal Rules ofCivil Procedure. The answer 
or motion must be served on the plaintiffs attorney, Gregory Glynn / Jason P. Lee , whose address is 
SEC, 5670 Wilshire Boulevard, 
11th Floor, Los Angeles, CA 90036 . Ifyou fail to do so, 
judgment 
by default will be entered against you for the relief demanded in the complaint. You also must file 
your answer or motion with the court. 
Clerk, U.S. District Court 
CHRISTOPH 
Dated: 
A_PR_2_1_2_01_1__ 
By: ----------'tt::---"'l;;~~__:#_:<.~ 
Deputy Clerk 
(Seal ofthe Court) 
[Use 60 days 
ifthe defendant is the United States or a  United States agency, or is an officer or employee ofthe United States. Allowed 
60 days by Rule 12(a)(3)). 
SECURITIES AND EXCHANGE COMMISSION 
PLAINTIFF(S) 
V. 
mURGENT CORPORATION, VLADIMIR BORIS 
BUGARSKI, VLADISLAV WALTER BUGARSKI, 
and ALEKSANDER NEGOV
AN BUGARSKI 
DEFENDANT(S). 
CASE NUMBER 
SAC V11 -0 0626' DOC SSx
 
SUMMONS
 
CV-OIA (12/07) SUMMONS 

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA 
CIVIL COVER SHEET 
I (a) PLAINTIFFS (Check box ifyou are representing yOUISelfO) DEFENDANTS
 
SECURITIES AND EXCHANGE COMMISSION
 
mURGENT CORPORATION. VLADIMIR BORIS BUGARSKI. 
VLADISLAV WALTER BUGARSKI AND ALEKSANDER NEGOVAN 
BUGARSKI 
Orange County 
Attorneys 
(If Known) 
yOUISelf, provide same.) 
(b) Attorneys (Firm Name, Address and Telepbone Nwnber. 
If you are representing 
Darryl C. Sheetz, Esq. (949)553-0300 
Gregory Glynn 
1Jason P. Lee (323) 965-3998 
Law Offices 
of Darryl C. Sheetz 
Securities and Exchange Commission 
335 Centennial Way, Suite 100 Tustin, 
CA 92780 
5670 Wilshire Boulevard, 11th Floor, Los Angeles, CA 90036 
II. BASIS 
OF JURISDICTION (Place an X in one box only.) 111.	 CITIZENSHIP OF PRINCIPAL PARTIES -  For Diversity Cases Only 
(Place an X in one box for plaintiffand one for defendant.) 
ri1 U.S. Government Plaintiff 
o 3 Fedeml Question (U.S. 
PTF DEF 
PTF 
DEF 
Government Not a Party) Citizen 
ofThis State 
01 
01 
InCOlpOrated or Principal Place 04 04 
of Business in this State 
02 U.S. Government Defendant 04 Diversity (Indicate Citizenship Citizen ofAnother State 02 
02 
IncolpOrated and Principal Place 
05 05 
of Parties in Item III) 
ofBusiness in Another State 
Citizen 
or Subject ofa Foreign Country 0 3 0  3 Foreign Nation 
06 06 
IV. ORIGIN (Place an X in one box only.) 
Iffl Original 0  2 Removed from 0  3 Remanded from 
Proceeding State Court Appellate Court 
V. 
REQUESTED IN COMPLAINT: JURy DEMAND: 0 
04 Reinstated or 
Reopened 
Yes 
iiNo (Check 
0  5 Transferred from another district (specify): 
'Yes' only ifdemanded in complaint.) 
0  6 Multi-
District 
Litigation 
o 7 Appeal to District 
Judge from 
Magistrate Judge 
CLASS 
ACTION underF.R.C.P. 23: 0 Yes rYNo 0 MONEY DEMANDED IN COMPLAINT: S 
VI. 
CAUSEOFACTION(CitetheU.S.CivilStatuteunderwhichyouarefiling andwritea briefstatementofcause. Donotcitejurisdictionalstatutesunlessdiversity.) 
The Complaint alleges violations 
ofthe federal securities laws. 15 U.S.c. §§ 77t(b), 77t(d)(I), 77t(e) & 77v(a); 15 U.S.c. §§ 78u(d)(IX2), 78u(d)(3)(A), 78u(e) & 78aa. 
VII. 
NATURE OF SUIT (Place an X in one box only.) 
0400 
State Reapportionment 0110 
Insurance 
0410 Antitrust 0120 Marine 
Airplane 
0430 Banks and Banking 0130 Miller Act 
Airplane Product 
Liability 
Rates/etc. 
0150 Recovery of 
0450	 CommercelICC 
0140 Negotiable Instrument 
0320	 Assault, Libel & 
Slander
0460	 
Deportation Overpayment & 
0330	 Fed. Employers' 
0470	 Racketeer Influenced 
Enforcement 
of 
Liability
and Corrupt Judgment 
0340	 Marine
Organizations 
0151 Medicare Act	 
1_.11••11.2110550 CivilRights
0345	 Marine Product 
0480 
Consumer Credit 0152 Recovery of Defaulted 
0422 
Appeal 28 USC 0555 Prison Condition 
Liability
o490 Cable/Sat TV 
Student Loan (ExcL 
158
0350 Motor Vehicle 
0423	 
Withdrawal 28 
~10 Selective Service 
Veterans) 
0355 Motor Vehicle 
850 Securities/Commodities! 0153 Recovery of 
Product Liability 
1,,~.UiSC.1157•••10 610 Agriculture
Exchange 
Overpayment 
of 
0360 Other Personal 
I!	 0 620 Other Food & 
o 510 Motions to 
0370 
Other Fraud Vacate Sentence 
0371 
Truth 
in Lending Habeas Corpus 
0380 
Other Personal 0 
530 General 
Property Damage 0 535 
Death Penalty 
0385 
Property Damage 0 540 Mandamus! 
Product 
Liabili~ Other 
0875	 
Customer Challenge 12 
Veteran's Benefits 
Injury 
USC 3410 
0160 Stockholders' Suits 
0362 Personal Injury­
0890 
Other Statutory Actions 0190 Other Contract 
Med Malpractice 
0891 
Agricu1turaI Act 0195 Contract Product 
0365 Personal Injury­
0892 
Economic Stabilization Liability 
Product Liability 
Act 
0196 Franchise 
0368 Asbestos Personal 
0893 
Environmental Matters 
Injury Product 
0894 
Energy Allocation Act 0210 Land Condemnation 
Liabili 
0895 
Freedom ofInfo. Act 0220 Foreclosure 
0900 
Appeal ofFee Determi-0230 
Rent Lease & Ejectment 
0462 Naturalization 
nation Under 
EquaI 0240 Torts to Land 
Application 
Access 
to Justice 0245 Tort Product Liability 
0463	 Habeas Corpus-
Alien Detainee 
0950 
Constitutionality of o 290 All Other Real Property 
0465 
Other Immigration 
State Statutes 
Actions 
0441 
Voting Drug 
Employment
0442 
0 625 Drug Related 
Housing!Acco­
0443 
Seizure 
of 
mmodations Property 21 USC 
Welfare
0444 
881 
0445 
American with 0 630 Liquor Laws 
Disabilities -0 640 R.R. 
& Truck 
Employment 0 650 Airline Regs 
==e:~th
0446 
0 660 ~~~:~ 
Other 0 690 Other 
Other Civil 
0440 
Rights 
0710	 Fair Labor Standards 
Act 
o 720 LaborlMgmt. 
Relations 
o 730 LaborlMgmt 
Reporting 
& 
Disclosure Act 
o 740	 Railway Labor Act 
o 790 Other Labor 
Litigation 
o 791 Empl. Ret Inc. 
o 820 
Securi%Act
• 
Copyrights 
i i 
0830 Patent 
o 840 Trademarlc 
0861 RIA (1395ft) 
0862 Black Lung (923) 
0 863 
DIWClDrww 
(405(g» 
0 864 
ssm Title XVI 
0865	 RSI (405(IU 
0 870 Taxes (U.S. Plaintiff 
or Defendant) 
0 
871 IRS-Third Party 26 
USC 7609 
FOR OFFICE USE ONLY: Case Number: -----------v-fll~'J-.........a.......I.---\oJ"""""'J-J'J-"""....­
AFTER COMPLETING THE FRONT SIDE OF FORMCV-71, COMPLETE THE INFORMATION REQUESTED BELOW.
 
CV-71 (05/08) CIVIL COVER SHEET	 Page I of2 

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
 
CIVIL COVER SHEET
 
VIII(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? ri'No 0 Yes
 
Ifyes, list case nwnber(s): _
 
VIII(b). RELATED CASES: Have any cases been previously filed in this court that are related to the present case? riNo 0 Yes
 
If yes, list case number(s): _
 
Civil cases 
are deemed related if a previonsly filed case and the present case:
 
(Check all boxes that apply)	 
0 A. Arise from the same or closely related transactions, happenings, or events; o~ 
DB. Call for detem:Lination ofthe same or substantially related or similar questions of law and fact; or 
o C. For other reasons would entail substantial duplication of labor ifheard by differentjudges; or 
o D. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present. 
IX. 
VENUE: (When completing the following information, use an additional sheet ifnecessary.) 
(al List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named plaintiff resides. 
~ Checkhereifthegovernment,itslll!encies oremoloveesis a namedplaintiff. Ifthisboxis checked, gOtoitem(bl. 
CaliforniaCounty outside 
ofthis District; State, ifother than California; or Foreign Country 
County in this District:· 
(b) 
List the County in this District; California County outside ofthis District; State ifother than California; or Foreign Country, in which EACH named defendant resides. 
0 
Checkhereifthegovernment,itslll!encies oremoloveesis a nameddefendant. Ifthisboxis checked, gotoitem(c). 
CaliforniaCountyoutside 
ofthis District; State,ifother than California; or ForeignCountry 
County 
in this District:· 
Orange County 
(c) List the County in this District; California County outside ofthis District; State ifother than California; or Foreign Country, in which EACH claim arose. 
Note' In land condemnation cases, use the location of the tract ofland involved 
County in this District:· 
California County outside 
ofthis District; State, ifother than California; or Foreign Country 
Orange County 
* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties 
Note: In land condemnation cases use the location ofthe tract 0 . 
X. SIGNATURE OF ATTORNEY (OR PRO PER ." :"-~:"""".L---:::"","",::::""'.L-~";::'~ __".. 
Notice to CounsellParties: The CV-7 (1S-44) Civil ver Sheet and the information contained herein nei er replace nor s plement e filing and service ofpleadings 
orother papers as required by law. fonn, a Cd bytheJudicialConference oftheUnitedStates inSeptember1974,is requiredpursuanttoLocalRule3-1 is notfiled 
but is used by the Clerk ofthe Court r. urpose ofstatistics, venue and initiating the civil docket sheet (For more detailed instructions, see separate instructions sheet) 
Key to Statistical codes relating to Social Security Cases: 
Nature ofSuit Code Abbreviation 
861 HIA 
862 BL 
863 D1WC 
863 D1WW 
864 
ssm 
865 RSI 
Substantive Statement of Cause ofAction 
All claims for health insurance benefits (Medicare) under Title 18, Part A, ofthe Social Security Act, as amended. 
Also, include claims 
by hospitals, skilled nursing facilities, etc., for certification as providers ofservices under the 
program. (42 U.S.C. 1935FF(b» 
All claims for 
"Black Lung" benefits under Title 4, Part B, ofthe Federal Coal Mine Health and Safety Act of 1969. 
(30 U.S.C. 
923) 
All claims filed by insured workers for disability insurance benefits under Title 2 ofthe Social Security Act, as 
amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g» 
All claims filed for widows or widowers insurance benefits based on disability under Title 2 ofthe Social Security 
Act, 
as amended. (42 U.S.C. 405(g» 
All claims 
for supplemental security income payments based upon disability filed under Title 16 ofthe Social Security 
Act, 
as amended 
All claims for retirement (old age) and survivolS benefits under Title 2 ofthe Social Security Act, as amended. (42 
U.S.C. 
(g» 
CV-71 (05/08) 
CIVIL COVER SHEET	 Page 2 of2 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

COpy
 
GREGORY C. GLYNN, Cal. BarNo. 039999 
Email: glY!lng@sec.~ov 
JASONP. LEE, Cal. BarNo. 196520 
Email: [email protected] 

Attorneys for Plaintiff
Securities and Exchange Commission
Rosalind R. Tyson Regional Director 
John M. McCoy IIi, Associate Regional Director
5670 Wilshire Boulevar'k 11th Floor 
Los Angeles, California y0036 
Telephone: (323) 965-3998 
FacsImile: (323) 965-3908 

CJ n-< 0:­
~r"" 
z::X.l 
-4::J'1: ~ 

\ ,:Uc: ""0 
c....... ,.. :::0
 
~~;- ~") 

\ :.-9:2 
N 

;
 Z~""t/")
 

~,") -~-4 ""0:Xli 'Tl
..-0- :x

i m~n 
lI' ...... -~n 00 

~ 0 NCc: 

\ 
-.17':u 

-4 

;\ 

UNITED STATES DISTRICT COURT 
~ I~I . ":t . 

CENTRAL DISTRICT OF CALIFORNIA "'i 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

v. 

mURGENT CORPORATIO~ VLADIMIR 
BORIS BUGARSKL VLADI~LAV 
WALTERBUGAR~KI, and 
ALEKSANDERNEGOVANBUGARSKI, 

Defendants. 

cms«<CV11- 0062. 6' DOC -' SSJ. 
COMPLAINT FOR VIOLATION" 
OF THE FEDERAL SECURITIES 
LAWS 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Plaintiff Securities and Exchange Commission ("Commission") alleges as 

follows: 

JURISDICTION AND VENUE 

1. This Court has jurisdiction over this action pursuant to Sections 20(b), 

20(d)(1), 20(e), and 22(a) of the Securities Act of 1933 ("Securities Act"), 15 

U.S.C. §§ 77t(b), 77t(d)(1), 77t(e) & 77v(a), and Sections 21(d)(I), 21(d)(2), 

21(d)(3)(A), 21(e) and 27 of the Securities Exchange Act of 1934 ("Exchange 

Act"), 15 U.S.C. §§ 78u(d)(l), 78u(d)(2), 78u(d)(3)(A), 78u(e) & 78aa. 

Defendants have, directly or indirectly, made use of the means or instrumentalities 

of interstate commerce, of the mails, or of the facilities of a national securities 

exchange, in connection with the transactions, acts, practices, and courses of 

business alleged in this Complaint. 

2. Venue is proper in this district pursuant to Section 22(a) of the 

Securities Act, 15 U.S.C. § 77v(a), and Section 27 of the Exchange Act, 15 U.S.C. 

§ 78aa, because certain ofthe transactions, acts, practices, and courses ofconduct 

constituting violations of the federal securities laws occurred within this district, 

and the Defendants transact or have transacted business in this district. 

SUMMARY 

3. Since at least 2008, Defendant mUrgent Corporation, a family-

controlled, private company located in Santa Ana, California, and its principals 

raised approximately $9.6 million from at least 130 investors through unregistered 

offerings by making material misrepresentations and omissions concerning the 

company's financing plans and business performance. Defendants Vladimir Boris 

Bugarski ("Boris"), ChiefExecutive Officer, Vladislav Walter Bugarski 

("Walter"), Boris' and AIeles' father and Chief Financial Officer, and AIeksander 

Negovan Bugarski ("Aleks"), Boris' twin and ChiefOperating Officer 

(collectively, "the Bugarskis"), created and utilized a "boiler-room" to sell 

mUrgent stock. Walter and Aleks supervised mUrgent employees working in this 

2
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

boiler-room - "fronters" and "closers" - who cold-called investors, used high 

pressure sales tactics, and made material misrepresentations concerning, among 

other things, mUrgent's purportedly imminent IPO. Walter and Aleks instructed 

these employees to make this misrepresentation, among others, and repeated them 

to investors directly. mUrgent, however, has never taken any concrete steps to 

conduct an IPO. As mUrgent's chief executive officer, Boris was responsible for 

and oversaw the totality ofmUrgent's business, including its offering activities, 

and as such was well-aware ofthe magnitude and extensiveness ofmUrgent's 

capital raising. While Boris communicated regularly with mUrgent's shareholders, 

he delegated the logistics of the securities offerings to his father and brother, who 

themselves directly participated in and supervised these activities. However, 

mUrgent's stock sales were not effectuated until Boris executed the critical 

offering-related documents. Many investors wrote checks or wired monies to buy 

mUrgent shares solely in reliance on the false promise ofmUrgent's upcoming 

public offering or other rosy business prospects. 

4. The Defendants have violated the securities registration provisions of 

Sections 5(a) and 5(c) of the Securities Act, 15 U.S.C. §§ 77e(a) & 77e(c), the 

broker registration provisions of Section 15(a)(I) of the Exchange Act, 15 U.S.C. 

§§ 78o(a)(I), and the antifraud provisions of Section 17(a) of the Securities Act, 15 

U.S.C. § 77q(a), and Section lO(b) of the Exchange Act, 15 U.S.C. § 78j(b), and 

Rule 10b-5 thereunder, 17 C.F.R. § 240.IOb-5. By this action, the Commission 

seeks permanent injunctions prohibiting future such violations, disgorgement of 

the Defendants' ill-gotten gains, civil penalties, and, as to Defendants Boris, . 

Walter, and Aleks Bugarski, a prohibition from serving as officers or directors of 

any public company. 

THE DEFENDANTS 

5. mUrgent Corporation is a private, California corporation with 

headquarters in Santa Ana, California. 

3
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

6. Vladimir Boris Bugarski, age 36, is mUrgent's Chief Executive 

Officer and President. He resides in Costa Mesa, California. He is also subject to 

a cease and desist order issued by the Division of Securities, Department of 

Financial Institutions, State of Wisconsin ("Wisconsin securities regulator") in July 

2000. 

7. Vladislav Walter Bugarski, age 67, is mUrgent's Chief Financial 

Officer. He resides in Corona, California, and is the father of identical twins Ale1es 

and Boris Bugarski. Walter is subject to cease and desist orders issued by the 

Securities Commissioner of the State ofKansas in July 1995, Pennsylvania 

Securities Commission in January 2001, and Wisconsin securities regulator in July 

2000. 

8. Aleksander Negovan Bugarski, age 36, is mUrgent's Chief 

Operating Officer and Executive Vice President. He resides in Corona, California. 

THE FRAUDULENT SCHEME 

A. The Defendants Established a "Boiler-room" to Sell mUrgent Shares 

9. mUrgent is a closely-held, family-controlled, private company located 

in Santa Ana, California, that provides Internet-related marketing services, 

including email advertising.primarily to restaurant franchises. Walter, the father 

and CFO, and Aleks and Boris, identical twin brothers and Chief Operating Officer 

and CEO, respectively, are mUrgent's top management, majority shareholders, and 

board members. 

10. Beginning in 2008, mUrgent offered $10 million of stock in two $5 

million offerings through cold-calls by more than a dozen employees. Through 

these unregistered offerings, the company has sold approximately $9.6 million of 

its securities, in the form ofcommon stock with detachable warrants, to over 130 

individuals throughout the country. The company used this capital raising activity 

to fund, in part, its operations. 

11. Walter and AIe1es set up and supervised a ''boiler-room'' dedicated to 

4
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the offer and sale ofmUrgent securities. They hired "fronters" who made over a 

thousand cold-calls a month to investors identified from lead lists purchased by 

Aleles. Most investors had never heard of mUrgent prior to being contacted. The 

fronters identified likely investors during these calls and handed them over to the 

"closers" to finish the sale. The closers were paid solely by commission ranging 

from 12% to 15% of the amount sold. 

12. In addition to these cold-calls, Walter and Aleks and the closers 

contacted pre-existing mUrgent shareholders, who had initially been cold-called by 

mUrgent and invested as a result, to offer and sell them additional mUrgent shares. 

In instances where Walter and Aleks sold shares to investors, they also received 

commissions. Walter earned at least $75,000 from commissions. Aleks also 

received additional compensation of approximately $107,961 outside of his salary, 

which consists at least in part of commissions from stock sales. 

13. As the CEO, Boris knew about the company's and his father's and 

brother's offering and sale activity and that boiler-room employees received 

commissions from their sales of mUrgent stock. Boris also played an integral role 

in the company's offerings. He signed all the subscription agreements and stock 

certificates and communicated with investors about the company's financial 

condition and business prospects. 

14. The closers also pressured investors to buy mUrgent shares by falsely 

telling them that share purchases by other investors were quickly depleting the 

available supply. In reality, the closers struggled to sell mUrgent shares to 

investors they cold-called and used this tactic to induce investments. In other 

instances, investors were told that if they purchased a certain number ofshares at 

the $2.50 per share offering price, they would then be immediately eligible to 

purchase a larger amount ofshares at a steeply discounted price ranging from $1 to 

$1.50 per share. mUrgent used the perception ofthis discount - which was not 

reflected in and flatly contradicted by mUrgent's offering materials - to induce 

5
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

investors to buy additional shares. 

15. Once an investor indicated an interest in investing, mUrgent used the 

inter-state mails to deliver a folder containing offering and promotional materials 

("Investor Packet") or requested that the investor submit the funds immediately. 

The Investor Packet contained, among other things, a "Confidential 

Memorandum," Subscription Agreement, and Investor Questionnaire. The 

Confidential Memorandum was the company's offering document and relied 

primarily on Rule 506 of Regulation D, 17 C.F.R § 230.506, to explain why the 

offerings were unregistered. The Investor Packet did not contain even rudimentary 

financial information about mUrgent or its operating history. 

16. The closers continued to call prospective investors after delivering the 

Investor Packet, pushed them to invest, and urged them to write a check 

immediately. Once a prospective investor decided to invest, mUrgent arranged and 

paid for Federal Express to pick up the check and deliver it to the company. 

17. Although mUrgent purported to have policies and procedures 

governing the conduct of their fronters and closers, those policies were largely 

superficial and not enforced in practice. 

B.	 The Defendants Made Material Misrepresentations About 

mUrgent And Misappropriated Investor Money 

18. The Defendants, either directly or through the fronters and closers, 

made the following misrepresentations when soliciting investors: 

a.	 mUrgent's IPO was imminent; 

b.	 mUrgent had retained a financial consulting company to take 

the company public; 

c.	 mUrgent had recently signed or already had a stable ofmajor 

and well-known customers; 

d.	 mUrgent shares would surge in value following the IPO; and 

e.	 The offering proceeds would be used for company operations 

6 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

and not to pay salaries to the Bugarskis. 

mUrgent Had No Real Plans to Go Public 

19. mUrgent's primary pitch to investors focused on the company's 

purportedly imminent IPO. Closers told investors that the company had just filed 

"registration papers" and "it won't be long" before the IPO. In other instances, 

closers told investors that the IPO was scheduled for a date certain and even 

provided the anticipated price, which was well above the offering price. They 

added that mUrgent had retained a reputable financial consulting company that had 

brought hundreds ofcompanies public to facilitate mUrgent's public offering. 

Aleks also told investors ofthe financial consulting company's involvement with 

the company and that mUrgent was on the brink ofan IPO. mUrgent repeated this 

theme in offering and selling its securities to numerous investors, many of whom 

invested as a result. Examples of these misrepresentations, some ofwhich are 

reflected in sales scripts and similar documents, include: 

a. "We talked to [the financial consulting company president] 

again which is the gentlemen who we were talking to about taking us 

public and this company is going to be a monster. He has taken over 

200 companies public and he stated that we could easily raise 50 

million." 

b. "Please look at our company very seriously as this is not a start 

up project but an actual company getting ready to be publicly traded." 

c. "WE COULD BE LOOKING AT ROLLING OUT A $12.50 

IPO OR $9-$12 ACQUISITION OR MERGER WITHIN THE NEXT 

18-24 MONTHS, YOU SEE THE OBVIOUS POTENTIAL HERE 

(DON'T YOU?) GREAT! [capitalization in original]" 

d. "Talk about raising capital of50 million to go public by next 

year." 

e."...Mr. Boris Bugarski confirmed to me that the company was 

7 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

growing that there was interest from some parties to buy the company 

... It became obvious to me that [a closer], Mr. Aleks Bugarski, and 

Mr. Boris Bugarski over exaggerated when they told me that mUrgent 

was ready to go public ... In our phone conversation [with Walter 

Bugarski], you said "We are closer than ever to going public." 

f. "We will be marching to our IPO 2nd/3rd Quarter, and we are 

looking to close out this offering asap." 

g. "We are still focused on 2nd/3rd Quarter to march to our IPO, 

and we are still thinking a $16-$19 price range per share ... This 

should be classified as a 'short term' investment." 

h. "We started working with a gentlemen who has taken over 200 

companies public. He feels we could probably go public right now 

(maybe $5-$7), but he wants us to continue doing what we've been 

doing and he thinks we can likely get our price up to and over double 

digits for an IPO." 

1. "We will be marching towards our IPO THIS year. Perhaps as 

early as August. . .. We want to target a $16-$17 opening. Therefore, 

you may wish to consider acquiring a position that might make you 

some 'real' money." 

20. Despite these representations, mUrgent was nowhere near conducting 

an IPO. In fact, the company had not retained the financial consulting company to 

provide any services relating to an IPO. The financial consulting company never 

authorized mUrgent to represent to anyone that the firm was involved in an)' 

offering relating to mUrgent securities. 

mUrgent Misrepresented Its Business Results and Prospects 

21. When discussing mUrgent's business prospects with investors, the 

closers touted companies that they claimed were major customers ofmUrgent. In 

the Investor Packet, mUrgent enclosed "reference letters" from certain major, well­

8
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

known companies, among others, to suggest that there were on-going business 

relationships with those companies. These letters drove many investors to 

purchase mUrgent securities. 

22. In fact, some of these major, well-known companies did not have any 

business relationship with mUrgent when investors were solicited. 

23. In October 2009, Boris requested that T-Mobile write a reference 

letter to be used for mUrgent's prospective email marketing clients. T-Mobile, 

which was once a mUrgent customer, agreed. mUrgent, however, included the T­

Mobile reference letter with mUrgent's offering materials and made 

misrepresentations concerning T-Mobile's existing business relationship with 

mUrgent. When T-Mobile discovered that its letter was included in mUrgent's 

offering materials, T-Mobile requested that Boris remove it. Boris agreed but 

never removed the letter from mUrgent's offering materials, and mUrgent 

continued making misrepresentations concerning its business relationship with T­

Mobile. 

24. Finally, closers touted mUrgent's business prospects and emphasized 

the company's growth and success. The defendants, however, failed to include any 

financial information in the offering materials provided to investors. This 

information would have revealed the company's dismal financial condition. 

Instead, closers represented that the company's business was prospering when in 

reality mUrgent had never made a profit. In fact, the company's internal 

documents forecasted increasing losses, belying its representations to investors. 

The Bugarskis Misused Investor Funds 

25. The Bugarskis also misused investor funds. The Confidential 

Memoranda for the two offerings during the relevant period stated that the 

executive officers were not to receive any cash compensation. Despite this 

representation, Walter, Aleks, and Boris received cash salaries and bonuses during 

the relevant period of$398,511, $470,077, and $457,750, respectively. 

9
 



5

10

15

20

25

I 26. Walter also established a slush fund for the benefit of himself and his 

2 sons. In July 2008, Walter withdrew $530,000 from mUrgent's bank account and 

3 deposited those funds into a newly opened account at another financial institution. 

4 He then wrote checks to himself, Aleks, and Boris for $55,000, $50,000, and 

$50,000, respectively. 

6 27. The Bugarskis also used mUrgent as their personal piggybank and
 

7 funded their lifestyle by charging the company for numerous personal expenses,
 

8 such as luxury cars for Walter and his wife. Walter also used company funds to
 

9 finance, in part, the purchase ofhis second home.
 

FIRST CLAIM FOR RELIEF 

11 UNREGISTERED OFFER AND SALE OF SECURITIES 

12 Violations of Sections 5(a) and 5(c) of the Securities Act 

13 (Against AU Defendants) 

14 28. The Commission realleges and incorporates by reference paragraphs 1 

through 27 above. 

16 29. The Defendants, and each of them, by engaging in the conduct 

17 described above, directly or indirectly, made use ofmeans or instruments of 

18 transportation or communication in interstate commerce or of the mails, to offer to 

19 sell or to sell securities, or to carry or cause such securities to be carried through 

the mails or in interstate commerce for the purpose of sale or for delivery after 

21 sale. 

22 30. No registration statement has been filed with the Commission or has 

23 been in effect with respect to the offering alleged herein. 

24 31. By engaging in the conduct described above, the Defendants have 

violated, and unless restrained and enjoined will continue to violate, Sections 5(a) 

26 and 5(c) ofthe Securities Act, 15 U.S.C. §§ 77e(a) and 77e(c). 

27 SECOND CLAIM FOR RELIEF 

28 FRAUD IN THE OFFER OR SALE OF SECURITIES 

10
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Violations of Section 17(a) of the Securities Act 

(Against All Defendants) 

32. The Commission realleges and incorporates by reference paragraphs 1 

through 27 above. 

33. The Defendants, and each of them, by engaging in the conduct 

described above, directly or indirectly, in the offer or sale of securities by the use 

of means or instruments of transportation or communication in interstate 

commerce or by use of the mails: 

a.	 with scienter, employed devices, schemes, or artifices to 

defraud; 

b.	 obtained money or property by means ofuntrue statements ofa 

material fact or by omitting to state a material fact necessary in 

order to make the statements made, in light ofthe 

circumstances under which they were .made, not misleading; or 

c.	 engaged in transactions, practices, or courses ofbusiness which 

operated or would operate as a fraud or deceit upon the 

purchaser. 

34. By engaging in the conduct described above, Defendants violated, and 

unless restrained and enjoined will continue to violate, Section 17(a) of the 

Securities Act, 15 U.S.C. § 77q(a). 

THIRD CLAIM FOR RELIEF
 

FRAUD IN CONNECTION WITH THE
 

PURCHASE OR SALE OF SECURITIES
 

Violations of Section 1O(b) of the Exchange Act and Rule 10b-5 Thereunder
 

(Against All Defendants)
 

35. The Commission realleges and incorporates by reference paragraphs I 

through 27 above. 

36.	 The Defendants, and each of them, by engaging in the conduct 

11 



5

10

15

20

25

I 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

described above, directly or indirectly, in connection with the purchase or sale of a 

security, by the use of means or instrumentalities of interstate commerce, of the 

mails, or of the facilities ofa national securities exchange, with scienter: 

a. employed devices, schemes, or artifices to defraud; 

b. made untrue statements ofa material fact or omitted 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 

c. engaged in acts, practices, or courses of business which 

operated or would operate as a fraud or deceit upon other persons. 

37. By engaging in the conduct described above, the Defendants violated, 

and unless restrained and enjoined will continue to violate, Section 10(b) of the 

Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 thereunder, 17 C.F.R. § 

240.IOb-5. 

FOURTH CLAIM FOR RELIEF
 

FAILURE TO REGISTER AS A BROKER OR DEALER
 

Violations of Section 15(a)(1) of the Exchange Act
 

(Against All Defendants) 

38. The Commission realleges and incorporates by reference paragraphs 1 

through 27 above. 

39. The Defendants, while acting as brokers or dealers, effectuated
 

transactions in, or induced or attempted to induce the purchase or sale of,
 

securities while they were not registered with the Commission as a broker or
 

dealer or when they were not associated with an entity registered with the
 

Commission as a broker or dealer.
 

40. By engaging in the conduct described above, the Defendants have
 

violated, and unless restrained and enjoined will continue to violate, Section
 

15(a)(1) ofthe Exchange Act, 15 U.S.C. § 78o(a)(l).
 

12
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

FIFTH CLAIM FOR RELIEF
 

CONTROL PERSON LIABILITY
 

(Pled in the Alternative Against Defendants
 

Boris, Walter, and Aleks Bugarski)
 

41. The Commission realleges and incorporates by reference paragraphs 1 

through 27 above. 

42. At all relevant times, Defendants Boris, Walter, and Aleles Bugarski 

possessed the power to direct and control mUrgent's management, policies, and 

operations and were control persons ofmUrgent pursuant to Section 20(a) of the 

Exchange Act, 15 UoS.C. § 78t(a). 

43. Defendants Boris, Walter, and Aleks Bugarski were culpable 

participants in mUrgent's violations of the Exchange Act as described above. 

44. By reason of the foregoing, Defendants Boris, Walter, and Aleks 

Bugarski are jointly and severally liable as control persons with, and to the same 

extent as, mUrgent for mUrgent's violations of Section 10(b) of the Exchange Act, 

15 U.S.C. §§ 78j(b) and Rule IOb-5 thereunder, 17 C.F.R. 240.l0b-5, and unless 

enjoined and restrained, Defendants Boris, Walter, and Aleks Bugarski will 

continue to cause, or to fail to prevent, mUrgent's violations of these provisions. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court: 

I. 

Issue findings of fact and conclusions of law that the Defendants committed 

the alleged violations. 

ll. 

Issue orders, in a form consistent with Fed. R. Civ. P. 65(d), peIDlanently 

enjoining the Defendants and their officers, agents, servants, employees, and 

attorneys, and those persons in active concert or participation with any of them, 

who receive actual notice of the order by personal service or otherwise, and each of 

13
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

them, from violating Sections 5(a) and 5(c) of the Securities Act, 15 U.S.C. §§ 

77e(a) & 77e(c), Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a), and 

Section lOeb) of the Exchange Act, 15 U.S.C. § 78j(b) and Rule 10b-5 thereunder, 

17 C.F.R. § 240.10b-5, and Section 15(a)(l) of the Exchange Act, 15 U.S.C. 

78o(a)(I). 

III. 

Order the Defendants to disgorge all ill-gotten gains from their illegal 

conduct, together with prejudgment interest thereon. 

IV. 

Order the Defendants to pay civil penalties under Section 20(d) of the 

Securities Act, 15 U.S.C. § 77t(d), and Section 21(d)(3) of the Exchange Act, 15 

U.S.C. § 78u(d)(3). 

V. 

Order, pursuant to Section 20(e) of the Securities Act, 15 U.S.C. § 77t(e), 

and Section 21 (d)(2) ofthe Exchange Act, 15 U.S.C.§ 78u(d)(2), the prohibition of 

Defendants Boris, Walter, and Aleks Bugarski from acting as officers or directors 

ofany issuer that has a class ofsecurities registered with the Commission pursuant 

to Section 12 of the Exchange Act, 15 U.S.C. § 78/, or that is required to file 

reports with the Commission pursuant to Section 15(d) of the Exchange Act, 15 

U.S.C.§ 78o(d). 

VI. 

Retain jurisdiction of this action in accordance with the principles ofequity 

and the Federal Rules ofCivil Procedure in order to implement and carry out the 

II 

II 

II 

II 

II 

14
 



1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

terms of all orders and decrees that may be entered, or to entertain any suitable 

application or motion for additional relief within the jurisdiction of this Court. 

"II. 

Grant such other and further relief as this Court may determine to be just and 

necessary. 

DATED: April2J,2011 

Securities and Exchange Commission 

egory C. Glynn 
asonP. Lee 

Attorneys for Plaintiff 

15
 



UNITED STATES DISTRICT COURT
 
CENTRAL DISTRICT OF CALIFORNIA
 

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY 

This case has been assigned to District Judge David O. Carter and the assigned 
discovery Magistrate Judge is Suzanne H. Segal. 

The case number on all documents filed with the Court should read as follows: 

SACVll- 626 DOC (SSx) 

Pursuant to General Order 05-07 of the United States District Court for the Central 
District of California, the Magistrate Judge has been designated to hear discovery related 
motions. 

All discovery related motions should be noticed on the calendar of the Magistrate Judge 

NOTICE TO COUNSEL 

A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is 
filed, a copy of this notice must be served on all plaintiffs). 

Subsequent documents must be filed at the following location: 

U	 Western Division [Xl Southern Division U Eastern Division 
312 N. Spring St., Rm. G-a 411 West Fourth St., Rm. 1-053 3470 Twelfth St., Rm. 134 
Los Angeles, CA 90012 Santa Ana, CA 92701-4516 Riverside, CA 92501 

Failure to file at the proper location will result in your documents being returned to you. 

CV-18 (03/06) NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY 



Gregory Glynn, Cal. Bar No. 039999 
Email: [email protected] 
Jason P. Lee, Cal. Bar No. 196520 
Email: [email protected] 
Securities and Exchange Commission 
5670 Wilshire Boulevard, II th Floor, Los Angeles, California 90036 
Telephone: (323) 965-3998/ Facsimile: (323) 965-3908 

UNITED STATES DISTRICT COURT
 
CENTRAL DISTRICT OF CALIFORNIA
 

TO: DEFENDANT(S): _
 

A lawsuit has been filed against you. 

Within 21 days after service of this summons on you (not counting the day you received it), you 
must serve on the plaintiff an answer to the attached l!l'complaint D amended complaint 
D counterclaim D cross-claim or a motion under Rule 12 of the Federal Rules ofCivil Procedure. The answer 
or motion must be served on the plaintiffs attorney, Gregory Glynn / Jason P. Lee , whose address is 
SEC, 5670 Wilshire Boulevard, 11th Floor, Los Angeles, CA 90036 . If you fail to do so, 

judgment by default will be entered against you for the relief demanded in the complaint. You also must file 
your answer or motion with the court. 

Clerk, U.S. District Court 

CHRISTOPH 
Dated: A_PR_2_1_2_01_1__ By: ----------'tt::---"'l;;~~__:#_:<.~ 

Deputy Clerk 

(Seal ofthe Court) 

[Use 60 days ifthe defendant is the United States or a United States agency, or is an officer or employee ofthe United States. Allowed 
60 days by Rule 12(a)(3)). 

SECURITIES AND EXCHANGE COMMISSION 

PLAINTIFF(S) 

V. 

mURGENT CORPORATION, VLADIMIR BORIS 
BUGARSKI, VLADISLAV WALTER BUGARSKI, 
and ALEKSANDER NEGOVAN BUGARSKI 

DEFENDANT(S). 

CASE NUMBER 

SAC V11 - 00626' DOC SSx
 

SUMMONS
 

CV-OIA (12/07) SUMMONS 

cavallones
Typewritten Text
mUrgent Corporation, Vladimir Boris Bugarski, 		

cavallones
Typewritten Text
Vladislav Walter Bugarski, and Aleksander Negovan Bugarski

cavallones
Typewritten Text



UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA 
CIVIL COVER SHEET 

I (a) PLAINTIFFS (Check box if you are representing yOUISelfO) DEFENDANTS
 
SECURITIES AND EXCHANGE COMMISSION
 mURGENT CORPORATION. VLADIMIR BORIS BUGARSKI. 

VLADISLAV WALTER BUGARSKI AND ALEKSANDER NEGOVAN 
BUGARSKI 

Orange County 

Attorneys (If Known) 
yOUISelf, provide same.) 

(b) Attorneys (Firm Name, Address and Telepbone Nwnber. If you are representing 

Darryl C. Sheetz, Esq. (949)553-0300 
Gregory Glynn 1Jason P. Lee (323) 965-3998 Law Offices of Darryl C. Sheetz 
Securities and Exchange Commission 335 Centennial Way, Suite 100 Tustin, CA 92780 
5670 Wilshire Boulevard, 11th Floor, Los Angeles, CA 90036 

II. BASIS OF JURISDICTION (Place an X in one box only.) 111.	 CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only 
(Place an X in one box for plaintiff and one for defendant.) 

ri1 U.S. Government Plaintiff o 3 Fedeml Question (U.S. PTF DEF PTF DEF 
Government Not a Party) Citizen of This State 01 01 InCOlpOrated or Principal Place 04 04 

of Business in this State 

02 U.S. Government Defendant 04 Diversity (Indicate Citizenship Citizen of Another State 02 02 IncolpOrated and Principal Place 05 05 
of Parties in Item III) of Business in Another State 

Citizen or Subject of a Foreign Country 0 3 0 3 Foreign Nation 06 06 

IV. ORIGIN (Place an X in one box only.) 

Iffl Original 0 2 Removed from 0 3 Remanded from 
Proceeding State Court Appellate Court 

V. REQUESTED IN COMPLAINT: JURy DEMAND: 0 

04 Reinstated or 
Reopened 

Yes iiNo (Check 

0 5 Transferred from another district (specify): 

'Yes' only ifdemanded in complaint.) 

0 6 Multi-
District 
Litigation 

o 7 Appeal to District 
Judge from 
Magistrate Judge 

CLASS ACTION underF.R.C.P. 23: 0 Yes rYNo 0 MONEY DEMANDED IN COMPLAINT: S 

VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a briefstatement of cause. Do not cite jurisdictional statutes unless diversity.) 

The Complaint alleges violations of the federal securities laws. 15 U.S.c. §§ 77t(b), 77t(d)(I), 77t(e) & 77v(a); 15 U.S.c. §§ 78u(d)(IX2), 78u(d)(3)(A), 78u(e) & 78aa. 

VII. NATURE OF SUIT (Place an X in one box only.) 

0400 State Reapportionment 0110 Insurance 
0410 Antitrust 0120 Marine Airplane 
0430 Banks and Banking 0130 Miller Act Airplane Product 

Liability 

Rates/etc. 0150 Recovery of 
0450	 CommercelICC 0140 Negotiable Instrument 

0320	 Assault, Libel & 
Slander0460	 Deportation Overpayment & 

0330	 Fed. Employers' 0470	 Racketeer Influenced Enforcement of 
Liabilityand Corrupt Judgment 

0340	 MarineOrganizations 0151 Medicare Act	 1_.11••11.2110550 CivilRights
0345	 Marine Product 

0480 Consumer Credit 0152 Recovery of Defaulted 0422 Appeal 28 USC 0555 Prison Condition 
Liabilityo 490 Cable/Sat TV Student Loan (ExcL 1580350 Motor Vehicle 

0423	 Withdrawal 28 ~ 10 Selective Service Veterans) 0355 Motor Vehicle 
850 Securities/Commodities! 0153 Recovery of Product Liability 1,,~.UiSC.1157•••10 610 Agriculture

Exchange Overpayment of 0360 Other Personal I!	 0 620 Other Food & 

o 510 Motions to 
0370 Other Fraud Vacate Sentence 
0371 Truth in Lending Habeas Corpus 
0380 Other Personal 0 530 General 

Property Damage 0 535 Death Penalty 
0385 Property Damage 0 540 Mandamus! 

Product Liabili~ Other 

0875	 Customer Challenge 12 Veteran's Benefits Injury 
USC 3410 0160 Stockholders' Suits 0362 Personal Injury­

0890 Other Statutory Actions 0190 Other Contract Med Malpractice 
0891 Agricu1turaI Act 0195 Contract Product 0365 Personal Injury­
0892 Economic Stabilization Liability Product Liability 

Act 0196 Franchise 0368 Asbestos Personal 
0893 Environmental Matters Injury Product 
0894 Energy Allocation Act 0210 Land Condemnation Liabili 
0895 Freedom of Info. Act 0220 Foreclosure 
0900 Appeal ofFee Determi- 0230 Rent Lease & Ejectment 0462 Naturalization 

nation Under EquaI 0240 Torts to Land Application 

Access to Justice 0245 Tort Product Liability 0463	 Habeas Corpus-
Alien Detainee 0950 Constitutionality of o 290 All Other Real Property 

0465 Other Immigration State Statutes 
Actions 

0441 Voting Drug 
Employment0442 0 625 Drug Related 
Housing!Acco­0443 Seizure of 
mmodations Property 21 USC 
Welfare0444 881 

0445 American with 0 630 Liquor Laws 
Disabilities - 0 640 R.R. & Truck 
Employment 0 650 Airline Regs 

==e:~th0446 
0 660 ~~~:~ 

Other 0 690 Other 
Other Civil 0440 
Rights 

0710	 Fair Labor Standards 
Act 

o 720 LaborlMgmt. 
Relations 

o 730 LaborlMgmt 
Reporting & 
Disclosure Act 

o 740	 Railway Labor Act 
o 790 Other Labor 

Litigation 
o 791 Empl. Ret Inc. 

o 820 

Securi%Act
• 

Copyrights 
i i 

0830 Patent 
o 840 Trademarlc 

0861 RIA (1395ft) 
0862 Black Lung (923) 
0 863 DIWClDrww 

(405(g» 
0 864 ssm Title XVI 

0865	 RSI (405(IU 

0 870 Taxes (U.S. Plaintiff 
or Defendant) 

0 871 IRS-Third Party 26 
USC 7609 

FOR OFFICE USE ONLY: Case Number: -----------v-fll~'J-.........a.......I.---\oJ"""""'J-J'J-"""....­

AFTER COMPLETING THE FRONT SIDE OF FORMCV-71, COMPLETE THE INFORMATION REQUESTED BELOW.
 

CV-71 (05/08) CIVIL COVER SHEET	 Page I of2 



UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
 
CIVIL COVER SHEET
 

VIII(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? ri'No 0 Yes
 
If yes, list case nwnber(s): _
 

VIII(b). RELATED CASES: Have any cases been previously filed in this court that are related to the present case? riNo 0 Yes
 
If yes, list case number(s): _
 

Civil cases are deemed related if a previonsly filed case and the present case:
 

(Check all boxes that apply)	 0 A. Arise from the same or closely related transactions, happenings, or events; o~ 

DB. Call for detem:Lination of the same or substantially related or similar questions of law and fact; or 

o C. For other reasons would entail substantial duplication of labor if heard by different judges; or 

o D. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present. 

IX. VENUE: (When completing the following information, use an additional sheet if necessary.) 

(al List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named plaintiff resides. 
~ Check here if the government, its lll!encies or emolovees is a named plaintiff. If this box is checked, gO to item (bl. 

California County outside of this District; State, ifother than California; or Foreign Country County in this District:· 

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides. 
0 Check here if the government, its lll!encies or emolovees is a named defendant. If this box is checked, go to item (c). 

California County outside of this District; State, ifother than California; or Foreign Country County in this District:· 

Orange County 

(c) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH claim arose. 
Note' In land condemnation cases, use the location of the tract of land involved 

County in this District:· California County outside of this District; State, ifother than California; or Foreign Country 

Orange County 

* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties 
Note: In land condemnation cases use the location of the tract 0 . 

X. SIGNATURE OF ATTORNEY (OR PRO PER ." :"-~:"""".L---:::"","",::::""'.L-~";::'~ __".. 

Notice to CounsellParties: The CV-7 (1S-44) Civil ver Sheet and the information contained herein nei er replace nor s plement e filing and service ofpleadings 
or other papers as required by law. fonn, a Cd by the Judicial Conference ofthe United States in September 1974, is required pursuant to Local Rule 3-1 is not filed 
but is used by the Clerk ofthe Court r. urpose ofstatistics, venue and initiating the civil docket sheet (For more detailed instructions, see separate instructions sheet) 

Key to Statistical codes relating to Social Security Cases: 

Nature ofSuit Code Abbreviation 

861 HIA 

862 BL 

863 D1WC 

863 D1WW 

864 ssm 

865 RSI 

Substantive Statement of Cause of Action 

All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. 
Also, include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the 
program. (42 U.S.C. 1935FF(b» 

All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. 
(30 U.S.C. 923) 

All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as 
amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g» 

All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security 
Act, as amended. (42 U.S.C. 405(g» 

All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security 
Act, as amended 

All claims for retirement (old age) and survivolS benefits under Title 2 of the Social Security Act, as amended. (42 
U.S.C. (g» 

CV-71 (05/08) CIVIL COVER SHEET	 Page 2 of2