SEC v. Legendary Partners, LLC; and Scott L. Snyder, No. 8:23-cv-01282, Central District of California (July 18, 2023) — Complaint

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DEAN M. CONWAY (DC Bar 457433)
pro hac vice pending
Email:  [email protected]
CAROLYN KURR (Maryland Bar No. 9512130114)
pro hac vice pending
Email:  [email protected]

Attorneys for Plaintiff
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Telephone: (202) 551-4412
Facsimile: (202) 772-9245

LOCAL COUNSEL:
GARY Y. LEUNG (Cal. Bar No. 302928)
444 S. Flower Street, Suite 900
Securities and Exchange Commission
Los Angeles, California 90071
Email: [email protected]
Phone: (323) 965-3998
Fax: (213) 443-1904

Attorneys for Plaintiff
Securities and Exchange Commission

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
LEGENDARY PARTNERS, LLC
AND SCOTT L. SNYDER,

Defendants.

    Case    No.

COMPLAINT

DEMAND FOR JURY TRIAL

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 Plaintiff Securities and Exchange Commission (“Commission”) alleges:
JURISDICTION AND VENUE
1. The Court has jurisdiction over this action pursuant to Sections 20(b),
20(d), and 22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b),
77t(d), and 77v(a)] and Sections 21(d) and 27(a) of the Securities Exchange Act of
1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and 78aa].
2. Defendants have, directly or indirectly, made use of the means or
instrumentalities of interstate commerce and of the mails in connection with the acts,
practices, and courses of business alleged in this complaint.
3. Venue is proper in this district pursuant to Section 22(a) of the Securities
Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa]
because certain of the acts, practices, and courses of conduct constituting violations
of the federal securities laws occurred within this district. Defendant Scott L. Snyder
resides within the Central District of California, and at least one of the victims of the
fraud alleged herein resides within this district.
SUMMARY
4. From April 2018 through December 2021, Legendary Partners LLC
(“Legendary Partners”) and its founder and President, Scott L. Snyder (“Snyder”),
engaged in a nationwide offering fraud that targeted mostly elderly investors and
raised approximately $391,000.  The offering was pitched as an opportunity to invest
in a start-up company that purportedly would produce a reality-television series about
the refurbishment of damaged exotic and luxury vehicles.
5. In addition to the solicitation fraud, Snyder also intentionally
misdirected money to Legendary Partners from several other investors who intended
to invest in different and unrelated offerings.  Specifically, these investors intended to
invest their money in either a movie production company called Incorporated
Productions, or a pharmaceutical company called Biosynetics.  Instead of investing
the money as promised, Snyder instead tricked these investors into depositing their

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money into accounts controlled by Legendary Partners.  This money was then
misappropriated by Legendary Partners and Snyder.
6. Defendants’ fraud was accomplished through the use of “cold callers”—
including Snyder who nearly always concealed his true identity when interacting with
investors by using the alias “Bill Miller”—located in Orange County, California.  The
cold callers would contact the mostly elderly investors by phone and then engage in
aggressive sales tactics ladened with materially false and misleading statements.  For
example, Defendants routinely provided baseless and misleading profit projections
designed to entice investors.
7. Finally, a substantial portion of the Legendary Partners’ investor funds
was not used as promised. Specifically, Legendary Partners and Snyder withdrew
most investor funds as cash and paid salaries out of investor funds even though that
use was not disclosed to investors. Snyder also spent investor money on restaurants,
retail purchases, travel, and other items.
8. Through this conduct, Legendary Partners and Snyder violated Sections
17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Section 10(b) of the Exchange
Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
9. The SEC seeks Final Judgments: (a) permanently enjoining Defendants
from violating the federal securities laws and rules this Complaint alleges they have
violated including a conduct-based injunction enjoining Snyder from participating in
future securities offerings; (b) ordering Defendants to disgorge all ill-gotten gains
they received as a result of the violations alleged pursuant to Exchange Act Sections
21(d)(3), (d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)], and
to pay prejudgment interest thereon; (c) ordering Defendants to pay civil money
penalties pursuant to Section 21A of the Exchange Act [15 U.S.C. § 78u-1]; (d)
ordering Defendant Snyder barred from serving as an officer and director of a public
securities issuer pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)]
and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)]; and (e) ordering

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any other and further relief the Court may deem just and proper.
DEFENDANTS
10. Legendary Partners is a Wyoming limited liability company organized
on November 30, 2017.  According to the Wyoming Secretary of State’s website,
Legendary Partners is inactive and administratively dissolved, delinquent in payment
of its taxes, and its registered agent has resigned.  Legendary Partners controlled two
bank accounts that received investor funds solicited by Snyder and others.  Snyder
was a signatory on both accounts.
11. Snyder, age 65, resides in Mission Viejo, California.  Snyder was the
founder and president of Legendary Partners. He testified that he used the alias “Bill
Miller” in his communications with investors during the entire period of the
Legendary Partners offering. Snyder asserted his Fifth Amendment privilege in
response to certain questions in his SEC testimony, including questions related to his
solicitation of Legendary Partners investors.
12. Snyder was also a director of a Nevada-based corporation named
Incorporated Productions, which was subject to a Desist and Refrain Order issued on
June 11, 2019 by the State of California Business, Consumer Services and Housing
Agency, Department of Business Oversight (“Desist and Refrain Order”).  The Desist
ad Refrain Order found that  “[b]ased on the foregoing findings, the Commissioner is
of the opinion that the securities offered by . . . Incorporated Productions . . . were
offered in this state by means of written or oral communications that included untrue
statements of material fact or omitted to state material facts necessary in order to
make the statements made, in the light of the circumstances under which they were
made, not misleading, in violation of section 25401 of the Corporate Securities Law
of 1968.”  The Desist and Refrain Order became final on February 27, 2020.
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FACTS
A. The Legendary Partners Deceptive Investment Scheme Primarily
Targeted Elderly Investors and was Facilitated by Snyder’s
Use of an Alias.
13. On December 30, 2017, Legendary Partners was incorporated as an LLC
in Wyoming.  Snyder started the company, and Snyder came up with its concept.
14. Snyder used Legendary Partners in connection with the production and
sale of a television show about the repair and sale of wrecked exotic vehicles.
Defendants operated out of a call center located in Orange County, California (“call
center”).  At first, Snyder held a one third equity interest in Legendary Partners along
with two other partners (pursuant undocumented agreements) from the Orange
County call center until one of the partners departed.  After that departure, Snyder
and the remaining partner shared 50% interests in Legendary Partners
(undocumented).  The remaining partner assisted Snyder in soliciting investors on
behalf of Legendary Partners.
15. From April 2018 until at least December 2021, Snyder (and one of his
partners from the call center) deceptively concealed their real identities from
investors with aliases.  At nearly all times, Snyder used the alias “Bill Miller” when
communicating with Legendary Partners investors, and investors did not know his
real name.  Snyder used this alias to conceal his association with his remaining call
center partner, who was a securities law recidivist, as well as to conceal his role as a
director at Incorporated Productions, which in June 2019 became the subject of the
Desist and Cease Order.
16. Snyder and others solicited investments in Legendary Partners from 21
mainly elderly investors.  Of these 21 investors, over 75% were in their seventies or
older, many in their 80s and 90s, and only five investors were in their 60s or younger.
Similarly, of the five investors who invested in other offerings (but whose
investments were wrongly deposited into bank accounts controlled by Legendary

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Partners), all but one was in their 70s or 80s.
17. From April 2018 through December 2021, Snyder and other individuals
in the Orange County call center solicited investors on behalf of Legendary Partners
and raised approximately $391,000 from approximately 21 investors. Snyder was
responsible for raising approximately $246,000 of the $391,000 received from at least
eleven Legendary Partners investors.
18. From February 2018 through July 2019, Legendary Partners and Snyder
solicited an additional $35,700 from five investors for investments in two other
offerings that were unrelated to Legendary Partners.  Snyder was personally
responsible for raising $20,700 from at least 3 of the 5. Rather than deposit those
investor funds into bank accounts associated with those offerings, he instead
misappropriated the investments by directing investors to send their funds directly to
a Legendary Partners bank account or caused the funds to be deposited into one of the
accounts controlled by Legendary Partners.
1. Defendants Used Deceptive Sales Tactics That Included
Offering Quick and Improbable Returns.
19. From February 1, 2018 until December 13, 2021, Snyder and others used
deceptive sales tactics to pressure investors to invest in Legendary Partners.  For
example, a form letter that Legendary Partners and Snyder sent to investors stated that:
[W]e will begin to submit the show to the Networks and
Production Companies to sell in the next 60-90 days on a 1-3
season deal for a quick turn-around with an upfront payback
to our Equity Partners.  (emphasis original)
20. During the period from February 2018 through December 2021, Snyder
sent a version of the form letter referenced immediately above to potential investors
before their investments.  Snyder signed the letter as “Bill Miller, Legendary
Partners, LLC, Executive Producer – Salvage Wars TV Car Show.”
21. During the period of June 2018 through January 2021, Snyder similarly

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told at least six Legendary Partners investors that it would take only “a few months”
or “three to six months” for them to start earning a return on their investment.  This
quick time frame for making a return on the investment was especially important to
elderly investors—as one 90-year old investor explained, he “doesn’t want to wait
around forever due to his advanced age.”
22. Snyder and Legendary Partners also promised baseless and inflated
returns for a concept television simply because:
Netflix and all the other streaming services were spending
billions of dollars to buy anything and everything just to fill in
air time in competition for subscribers.  They didn’t care if it
was good or bad or the premise of the show.... So why
wouldn’t I believe that my show that was far [more] interesting
would be bought just as much as a show about popping pimples
[an apparent reference to the Netflix show Dr. Pimple Popper]?
23. Defendants knew, or were reckless in not knowing, that there was no
legitimate factual basis for the profit projections that they used to entice investors.
Indeed, Defendants knew that their profit projections were materially misleading.
24. Snyder and Legendary Partners included similar exaggerated and
unsupported profit projections in Legendary Partners Offering Memoranda (“OM”).
Defendants had multiple versions of the OM that were similar but not identical.  One of
the OM that was provided to investors contained the following baseless projections:
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25. On November 12, 2019, Snyder emailed two investors an iteration of the
OM that concluded by stating “With only 5 Seasons, we expect to generate in excess
of $18,000,000!” (emphasis original).  In addition, the version of the OM that these two
investors received did not contain the statement (supra at ¶ 24, line 14) that “These are
estimates only. No guarantee or results are implied.”
26. In November and December 2019, Snyder told another Legendary Partners
investor that although he could guarantee anything and that there was risk involved, the
prospective investor would make a 50% profit in 3-6 months.
27. On March 13, 2020, Snyder told yet another investor that if HBO or
YouTube picked up the show, it would generate $1 million in profits to be split between
the partners.
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28. Snyder told another Legendary Partners investor “to expect 10-15% return
on an ongoing basis, in addition to a dividend (which was not known), as long as they
produced the movie with my money.”
29. On January 28, 2020, Snyder also sent the same investor an undated email
that contained exaggerated profit projections, explained that the investor was being
offered a highly reduced price for his investment, and indicated that these sales were a
limited time offer.  Snyder wrote that another individual at the call center had
“overstepped his authority today when he offered you a 25k position for 12,500, but of
course, we will honor his offer to you.”  Snyder then tried to induce the prospective
investor to invest even more than the $12,500 he originally contemplated:
I originally told [the other individual at the call center] that you
are a good, long time client and have been waiting a long time
for Inc[orporated] Prod[uctions] to come to fruition and that he
should give you a 50k position for 40k, which made more sense
for us... and would be way better for you.  When we sell the
show by the end of March, we expect to get 2X to 3X return.
With those numbers, your 40k would get you back 100k to
150k – while your 12,500 will get you back 50k to 75k – not
bad, but certainly a BIG DIFFERENCE!  If you want to put in
40k, I will honor the agreement to give you a 50k position.  Or
you can stay with the 12,500, that is entirely up to you.  Just
know that as of January 24th, there will be no more room for
any additional funds for the show. ]
Despite Snyder’s aggressive efforts to induce this individual to invest more, he only
invested $12,500.
30. As founder and President of Legendary Partners, Snyder knew, or was
reckless in not knowing, that the above-described profit projections had no reasonable
factual basis and were materially false and misleading.  Defendants’ profit projections

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and investment returns, moreover, were material to reasonable investors.
31. As President and control person of Legendary Partners, Snyder’s scienter,
conduct, and statements are imputed to Legendary Partners.
B. Investor Funds Were Misappropriated by Defendants through Activities
that Were Outside of the Designated Use of Proceeds.
32. Legendary Partners and Snyder misappropriated investor funds in two
ways.  First, Defendants took funds that investors wished to invest in other offerings
and deposited that money into Legendary Partner’s bank accounts—an outright
misappropriation.  Second, Defendants misappropriated a significant portion of investor
funds intended for Legendary Partners by using that money in a manner that was not
disclosed to investors.
1. Misappropriation of Funds Meant for Other Offerings.
33. From February 2018 through July 2019, Legendary Partners and Snyder
misappropriated investments totaling $35,700 from five investors.  Even though these
investors had each invested in an entirely different offering than Legendary Partners,
their funds were deposited into one of Legendary Partners’ accounts.  Snyder was
responsible for soliciting and misappropriating investments totaling $20,700 from three
of those investors.
34. Specifically, Snyder solicited a $7,500 investment from one investor for
shares in an unrelated offering called Biosynetics.  In a January 3, 2019 email from
Snyder (posing as “Bill Miller, V.P. Client Relations, Biosynetics”) with the subject
line “Information on our Pharmaceutical company and Instructions,” Snyder provided
the prospective investor with a business plan and other company material and provided
news regarding “our product SOMNUS VI” (which was Biosynetics’ purported sleep
agent product).  Finally, he falsely claimed that Legendary Partners was Biosynetics’
“transfer agent” and then directed the investor to wire $7,500 to one of Legendary
Partners’ bank accounts.
35. On January 4, 2019, following Snyder’s instructions, the Biosynetics

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investor wired funds to Legendary Partners and received a share certificate for 7,500
shares of Biosynetics.  Snyder did not, however, transfer this money to Biosynetics’
account but rather misappropriated it.  When the person at the call center responsible for
spearheading the Biosynetics offering learned of Snyder’s misappropriation, he and
Snyder had a “falling out from the stealing [of the Biosynetics investment funds].”
36. When Snyder was asked questions about Biosynetics under oath during
SEC testimony, he asserted his Fifth Amendment rights against self-incrimination.
37. Snyder misappropriated another investor’s $10,000 investment in another
unrelated offering by Incorporated Productions by directing the investor to make his
checks out to Legendary Partners, LLC.
38. Snyder told the Incorporated Productions investor to make out two checks
to “Legendary Partners, LLC” for $5,000 each.  On January 23, 2019, the investor
wrote a check with a “For” line that stated “Stock – Incorporated Productions.”  On July
25, 2019, the investor wrote a second check with a “For” line that stated “Incorporated
Productions stock.”  Although the investor intended that these funds be used for the
purchase of stock in Incorporated Productions, Snyder misappropriated the $10,000 by
depositing the checks into Legendary Partners’ bank account.
39. Snyder similarly misappropriated $3,200 from a third investor who also
intended to invest money in Incorporated Productions.  This investor believed that
Incorporated Productions was a movie production company then working on a movie
about NASCAR racer Bobby Allison and another film, “Sons of the Cross,” in which
the company purportedly was seeking to hire either Jeremy Renner or Matt
McConaughey as the lead actor.
40. Snyder accomplished this theft by sending an e-mail to the investor that
directed the investor to wire funds to a Legendary Partners bank account.  Snyder
repeated the same lie to this investor (that he also had told to the Biosynetics investor)
about Legendary Partners purportedly being a “stock transfer agent.”
41. On February 19, 2019, following Snyder’s directions, the investor wired

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$3,200 to Legendary Partners (on behalf of his wife).  His wife, on or about February
15, 2019, then separately wired another $6,800 from her 401(k) account to Incorporated
Productions, for a purported $10,000 combined investment in Incorporated Productions.
Although all of the offering documents received by the investor were for Incorporated
Productions, Snyder did not invest any of the $3,200 in that company as the investor
intended but instead misappropriated it.
42. When Snyder was asked questions about Incorporated Productions under
oath during SEC testimony, he asserted his Fifth Amendment rights against self-
incrimination.
2. Misuse of Proceeds.
43. From April 2018 until at least December 2021, a substantial portion of
investor funds, however, were not used as promised and therefore were
misappropriated.
44. Legendary Partners’ form letter, a version of which Snyder sent to
prospective investors during the offering period from April 2018 through December
2021, included as an attachment an Offering Memorandum (“OM”) stating:

45. Snyder sent another investor an OM similarly stating,
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46. These promises led investors to expect that their investments would be
used primarily for video and film production costs.  Bank records reflect, however, that
most investor funds were withdrawn as cash for uses that were largely undocumented,
including that Snyder was using investor money for his own use.
47. Of the amounts that were not withdrawn as cash, a significant portion
was used for retail, restaurant, travel, and gas expenses (approximately $10,000);
payments to an energy company unrelated to Legendary Partners (approximately
$6,700); and miscellaneous or unknown expenses (approximately $7,700).
48. There was no disclosure in the OM provided to investors that their
investment funds would be taken out as cash or used for salaries.
THE STATUTORY PERIOD HAS BEEN TOLLED
49. On February 1, 2023, Snyder executed a “Tolling Agreement” on behalf
of himself and on behalf of Legendary Partners, LLC (as its President) tolling and
suspending the period beginning on February 1, 2023 through April 1, 2023.
50. On March 30, 2023, Snyder executed an additional “Tolling Agreement”
on behalf of himself and on behalf of Legendary Partners, LLC (as its President) tolling
and suspending the period beginning on February 1, 2023 through May 15, 2023.
51. On April 17, 2023, Snyder executed an additional “Tolling Agreement”
on behalf of himself and on behalf of Legendary Partners, LLC (as its President)
tolling and suspending the period beginning on February 1, 2023 through July 31,
2023.

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FIRST CLAIM FOR RELIEF
Fraud in Violation of Section 10(b) and Rule 10b-5 Thereunder
(Against Both Defendants)
52. The Commission realleges and reincorporates paragraphs 1 through 51
as if fully set forth herein.
53. As set forth above, Defendants Legendary Partners and Snyder   knew,
or were reckless in not knowing that, they made materially untrue and misleading
misstatements and omissions to investors in the offer and sale of securities and
misappropriated investor funds. By engaging in the conduct described above,
Defendants Legendary Partners and Snyder directly or indirectly, in connection with
the purchase or sale of securities, by use of the means or instrumentalities of
interstate commerce, or the mails, or the facilities of a national securities exchange:
(a) employed devices, schemes or artifices to defraud; (b) made untrue statements of
material facts or omitted to state material facts necessary in order to make the
statements made, in light of the circumstances under which they were made, not
misleading; and/or (c) engaged in acts, practices, or courses of business which
operated or would operate as a fraud or deceit upon any person in connection with the
purchase or sale of any security.
54. By engaging in the conduct described above, Defendants Legendary
Partners and Snyder 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 thereunder
[17 C.F.R. § 240.10b-5].
SECOND CLAIM FOR RELIEF
Fraud in Violation of Section 17(a)of the Securities Act
(Against Both Defendants)
55. The Commission realleges and reincorporates paragraphs 1 through 51
as if fully set forth herein.
56. By engaging in the conduct described above, Defendants Legendary

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Partners and Snyder, singly or in concert with others, in connection with the offer or
sale of securities, by use of the means or instrumentalities of interstate commerce, or
of the mails, or a facility of a national securities exchange, directly or indirectly: (a)
employed devices, schemes, or artifices to defraud; (b) made untrue statements of
material fact or omitted to state material facts necessary in order to make the
statements made, in 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 have operated as a fraud or deceit upon persons.
57. By engaging in the conduct described above, Defendants Legendary
Partners and Snyder, violated, and unless restrained and enjoined will continue to
violate, Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a).
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter
Final Judgments:
(a) Permanently enjoining Defendants Legendary Partners and Snyder, and
those persons in active concert or participation with any of them, who receive actual
notice of the judgment by personal service or otherwise, and each of them, from
violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of
the Exchange Act [15 U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. §
240.10b-5];
(b) Permanently enjoining Snyder from directly or indirectly, including, but
not limited to, through any entity owned or controlled by him, participating in the
issuance, purchase, offer, or sale of any security, provided, however, that such
injunction shall not prevent him from purchasing or selling securities for his own
personal account;
(c)  Ordering that Defendant Snyder be barred from serving as an officer
and director of a public issuer pursuant to Section 20(e) of the Securities Act [15
U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)].;

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(d) Ordering Defendants to disgorge all ill-gotten gains obtained within the
statute of limitations, together with prejudgment interest thereon, pursuant to Section
21(d)(3), (d)(5) and 21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5)
and 78u(d)(7)].
(e) Ordering Defendants Legendary Partners and Snyder to pay civil
penalties pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)] and Exchange
Act Section 21(d) [15 U.S.C. § 78u(d)];
(f) Retain jurisdiction of this action in accordance with the principles of
equity and the Federal Rules of Civil Procedure in order to implement and carry out
the 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; and
(g) Grant such other relief to the Commission as the Court may deem just
and proper.
DEMAND FOR JURY TRIAL
Pursuant to Federal Rule of Civil Procedure 38, the Commission demands trial
by jury.

Dated:  July 18, 2023
 /s/ Gary Y. Leung
Gary Y.Leung
Dean M. Conway
Carolyn Kurr
Attorneys for Plaintiff
Securities and Exchange Commission

7/18/23, 7:58 AMCM/ECF - California Central District
https://ecf.cacd.uscourts.gov/cgi-bin/Dispatch.pl?1126618674635391/1
Complaints and Other Initiating Documents
8:23-cv-01282 Securities and Exchange Commission v. Legendary Partners, LLC et al
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing
The following transaction was entered by Leung, Gary on 7/18/2023 at 7:58 AM PDT and filed on 7/18/2023
Case Name:Securities and Exchange Commission v. Legendary Partners, LLC et al
Case Number:8:23-cv-01282
Filer:Securities and Exchange Commission
Document Number:1
Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange
Commission. (Attorney Gary Y. Leung added to party Securities and Exchange
Commission(pty:pla))(Leung, Gary)
8:23-cv-01282 Notice has been electronically mailed to:
Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]
8:23-cv-01282 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:C:\fakepath\Legendary Partners Complaint.pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=7/18/2023] [FileNumber=36201241-0
] [5f093ab6eac4ab48cdf00aefe608966529913b33b6cd29b83f1247ccbadec59d421
9f326342afbb566f2b1883c640fe04a6459a4e34e9b475d206efcf0731d37]]

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DEAN M. CONWAY (DC Bar 457433) 
pro hac vice pending 
Email:  [email protected] 
CAROLYN KURR (Maryland Bar No. 9512130114) 
pro hac vice pending 
Email:  [email protected] 
 
Attorneys for Plaintiff 
Securities and Exchange Commission 
100 F Street, NE 
Washington, DC 20549 
Telephone: (202) 551-4412 
Facsimile: (202) 772-9245 
 
LOCAL COUNSEL: 
GARY Y. LEUNG (Cal. Bar No. 302928)  
444 S. Flower Street, Suite 900  
Securities and Exchange Commission 
Los Angeles, California 90071  
Email: [email protected]  
Phone: (323) 965-3998 
Fax: (213) 443-1904 
 
Attorneys for Plaintiff 
Securities and Exchange Commission 
 
 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

LEGENDARY PARTNERS, LLC 
AND SCOTT L. SNYDER, 
 

Defendants. 
 

 Case No.  
 
COMPLAINT 
 
DEMAND FOR JURY TRIAL 
 

 
 

Case 8:23-cv-01282   Document 1   Filed 07/18/23   Page 1 of 16   Page ID #:1



 

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 Plaintiff Securities and Exchange Commission (“Commission”) alleges: 

JURISDICTION AND VENUE 

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

20(d), and 22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b), 

77t(d), and 77v(a)] and Sections 21(d) and 27(a) of the Securities Exchange Act of 

1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and 78aa].  

2. Defendants have, directly or indirectly, made use of the means or 

instrumentalities of interstate commerce and of the mails in connection with the acts, 

practices, and courses of business alleged in this complaint.  

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

Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa] 

because certain of the acts, practices, and courses of conduct constituting violations 

of the federal securities laws occurred within this district. Defendant Scott L. Snyder 

resides within the Central District of California, and at least one of the victims of the 

fraud alleged herein resides within this district. 

SUMMARY 

4. From April 2018 through December 2021, Legendary Partners LLC 

(“Legendary Partners”) and its founder and President, Scott L. Snyder (“Snyder”), 

engaged in a nationwide offering fraud that targeted mostly elderly investors and 

raised approximately $391,000.  The offering was pitched as an opportunity to invest 

in a start-up company that purportedly would produce a reality-television series about 

the refurbishment of damaged exotic and luxury vehicles. 

5. In addition to the solicitation fraud, Snyder also intentionally 

misdirected money to Legendary Partners from several other investors who intended 

to invest in different and unrelated offerings.  Specifically, these investors intended to 

invest their money in either a movie production company called Incorporated 

Productions, or a pharmaceutical company called Biosynetics.  Instead of investing 

the money as promised, Snyder instead tricked these investors into depositing their 

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money into accounts controlled by Legendary Partners.  This money was then 

misappropriated by Legendary Partners and Snyder. 

6. Defendants’ fraud was accomplished through the use of “cold callers”—

including Snyder who nearly always concealed his true identity when interacting with 

investors by using the alias “Bill Miller”—located in Orange County, California.  The 

cold callers would contact the mostly elderly investors by phone and then engage in 

aggressive sales tactics ladened with materially false and misleading statements.  For 

example, Defendants routinely provided baseless and misleading profit projections 

designed to entice investors.   

7. Finally, a substantial portion of the Legendary Partners’ investor funds 

was not used as promised. Specifically, Legendary Partners and Snyder withdrew 

most investor funds as cash and paid salaries out of investor funds even though that 

use was not disclosed to investors. Snyder also spent investor money on restaurants, 

retail purchases, travel, and other items. 

8. Through this conduct, Legendary Partners and Snyder violated Sections 

17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Section 10(b) of the Exchange 

Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].   

9. The SEC seeks Final Judgments: (a) permanently enjoining Defendants 

from violating the federal securities laws and rules this Complaint alleges they have 

violated including a conduct-based injunction enjoining Snyder from participating in 

future securities offerings; (b) ordering Defendants to disgorge all ill-gotten gains 

they received as a result of the violations alleged pursuant to Exchange Act Sections 

21(d)(3), (d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)], and 

to pay prejudgment interest thereon; (c) ordering Defendants to pay civil money 

penalties pursuant to Section 21A of the Exchange Act [15 U.S.C. § 78u-1]; (d) 

ordering Defendant Snyder barred from serving as an officer and director of a public 

securities issuer pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 

and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)]; and (e) ordering 

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any other and further relief the Court may deem just and proper. 

DEFENDANTS 

10. Legendary Partners is a Wyoming limited liability company organized 

on November 30, 2017.  According to the Wyoming Secretary of State’s website, 

Legendary Partners is inactive and administratively dissolved, delinquent in payment 

of its taxes, and its registered agent has resigned.  Legendary Partners controlled two 

bank accounts that received investor funds solicited by Snyder and others.  Snyder 

was a signatory on both accounts.  

11. Snyder, age 65, resides in Mission Viejo, California.  Snyder was the 

founder and president of Legendary Partners. He testified that he used the alias “Bill 

Miller” in his communications with investors during the entire period of the 

Legendary Partners offering. Snyder asserted his Fifth Amendment privilege in 

response to certain questions in his SEC testimony, including questions related to his 

solicitation of Legendary Partners investors. 

12. Snyder was also a director of a Nevada-based corporation named 

Incorporated Productions, which was subject to a Desist and Refrain Order issued on 

June 11, 2019 by the State of California Business, Consumer Services and Housing 

Agency, Department of Business Oversight (“Desist and Refrain Order”).  The Desist 

ad Refrain Order found that  “[b]ased on the foregoing findings, the Commissioner is 

of the opinion that the securities offered by . . . Incorporated Productions . . . were 

offered in this state by means of written or oral communications that included untrue 

statements of material fact or omitted to state material facts necessary in order to 

make the statements made, in the light of the circumstances under which they were 

made, not misleading, in violation of section 25401 of the Corporate Securities Law 

of 1968.”  The Desist and Refrain Order became final on February 27, 2020. 

/// 

/// 

/// 

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FACTS 

A. The Legendary Partners Deceptive Investment Scheme Primarily 

Targeted Elderly Investors and was Facilitated by Snyder’s 

Use of an Alias. 

13. On December 30, 2017, Legendary Partners was incorporated as an LLC 

in Wyoming.  Snyder started the company, and Snyder came up with its concept.   

14. Snyder used Legendary Partners in connection with the production and 

sale of a television show about the repair and sale of wrecked exotic vehicles.  

Defendants operated out of a call center located in Orange County, California (“call 

center”).  At first, Snyder held a one third equity interest in Legendary Partners along 

with two other partners (pursuant undocumented agreements) from the Orange 

County call center until one of the partners departed.  After that departure, Snyder 

and the remaining partner shared 50% interests in Legendary Partners 

(undocumented).  The remaining partner assisted Snyder in soliciting investors on 

behalf of Legendary Partners. 

15. From April 2018 until at least December 2021, Snyder (and one of his 

partners from the call center) deceptively concealed their real identities from 

investors with aliases.  At nearly all times, Snyder used the alias “Bill Miller” when 

communicating with Legendary Partners investors, and investors did not know his 

real name.  Snyder used this alias to conceal his association with his remaining call 

center partner, who was a securities law recidivist, as well as to conceal his role as a 

director at Incorporated Productions, which in June 2019 became the subject of the 

Desist and Cease Order.   

16. Snyder and others solicited investments in Legendary Partners from 21 

mainly elderly investors.  Of these 21 investors, over 75% were in their seventies or 

older, many in their 80s and 90s, and only five investors were in their 60s or younger.  

Similarly, of the five investors who invested in other offerings (but whose 

investments were wrongly deposited into bank accounts controlled by Legendary 

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Partners), all but one was in their 70s or 80s.  

17. From April 2018 through December 2021, Snyder and other individuals 

in the Orange County call center solicited investors on behalf of Legendary Partners 

and raised approximately $391,000 from approximately 21 investors. Snyder was 

responsible for raising approximately $246,000 of the $391,000 received from at least 

eleven Legendary Partners investors. 

18. From February 2018 through July 2019, Legendary Partners and Snyder 

solicited an additional $35,700 from five investors for investments in two other 

offerings that were unrelated to Legendary Partners.  Snyder was personally 

responsible for raising $20,700 from at least 3 of the 5. Rather than deposit those 

investor funds into bank accounts associated with those offerings, he instead 

misappropriated the investments by directing investors to send their funds directly to 

a Legendary Partners bank account or caused the funds to be deposited into one of the 

accounts controlled by Legendary Partners.   

1. Defendants Used Deceptive Sales Tactics That Included 

Offering Quick and Improbable Returns. 

19. From February 1, 2018 until December 13, 2021, Snyder and others used 

deceptive sales tactics to pressure investors to invest in Legendary Partners.  For 

example, a form letter that Legendary Partners and Snyder sent to investors stated that: 

[W]e will begin to submit the show to the Networks and 

Production Companies to sell in the next 60-90 days on a 1-3 

season deal for a quick turn-around with an upfront payback 

to our Equity Partners.  (emphasis original)   

20. During the period from February 2018 through December 2021, Snyder 

sent a version of the form letter referenced immediately above to potential investors 

before their investments.  Snyder signed the letter as “Bill Miller, Legendary 

Partners, LLC, Executive Producer – Salvage Wars TV Car Show.”  

21. During the period of June 2018 through January 2021, Snyder similarly 

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told at least six Legendary Partners investors that it would take only “a few months” 

or “three to six months” for them to start earning a return on their investment.  This 

quick time frame for making a return on the investment was especially important to 

elderly investors—as one 90-year old investor explained, he “doesn’t want to wait 

around forever due to his advanced age.”  

22. Snyder and Legendary Partners also promised baseless and inflated 

returns for a concept television simply because: 

Netflix and all the other streaming services were spending 

billions of dollars to buy anything and everything just to fill in 

air time in competition for subscribers.  They didn’t care if it 

was good or bad or the premise of the show.… So why 

wouldn’t I believe that my show that was far [more] interesting 

would be bought just as much as a show about popping pimples 

[an apparent reference to the Netflix show Dr. Pimple Popper]?   

23. Defendants knew, or were reckless in not knowing, that there was no 

legitimate factual basis for the profit projections that they used to entice investors.  

Indeed, Defendants knew that their profit projections were materially misleading.   

24. Snyder and Legendary Partners included similar exaggerated and 

unsupported profit projections in Legendary Partners Offering Memoranda (“OM”).  

Defendants had multiple versions of the OM that were similar but not identical.  One of 

the OM that was provided to investors contained the following baseless projections: 

/// 

/// 

/// 

/// 

/// 

/// 

/// 

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25. On November 12, 2019, Snyder emailed two investors an iteration of the 

OM that concluded by stating “With only 5 Seasons, we expect to generate in excess 

of $18,000,000!” (emphasis original).  In addition, the version of the OM that these two 

investors received did not contain the statement (supra at ¶ 24, line 14) that “These are 

estimates only. No guarantee or results are implied.”   

26. In November and December 2019, Snyder told another Legendary Partners 

investor that although he could guarantee anything and that there was risk involved, the 

prospective investor would make a 50% profit in 3-6 months.   

27. On March 13, 2020, Snyder told yet another investor that if HBO or 

YouTube picked up the show, it would generate $1 million in profits to be split between 

the partners.   

/// 

/// 

/// 

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28. Snyder told another Legendary Partners investor “to expect 10-15% return 

on an ongoing basis, in addition to a dividend (which was not known), as long as they 

produced the movie with my money.”  

29. On January 28, 2020, Snyder also sent the same investor an undated email 

that contained exaggerated profit projections, explained that the investor was being 

offered a highly reduced price for his investment, and indicated that these sales were a 

limited time offer.  Snyder wrote that another individual at the call center had 

“overstepped his authority today when he offered you a 25k position for 12,500, but of 

course, we will honor his offer to you.”  Snyder then tried to induce the prospective 

investor to invest even more than the $12,500 he originally contemplated:  

I originally told [the other individual at the call center] that you 

are a good, long time client and have been waiting a long time 

for Inc[orporated] Prod[uctions] to come to fruition and that he 

should give you a 50k position for 40k, which made more sense 

for us… and would be way better for you.  When we sell the 

show by the end of March, we expect to get 2X to 3X return.  

With those numbers, your 40k would get you back 100k to 

150k – while your 12,500 will get you back 50k to 75k – not 

bad, but certainly a BIG DIFFERENCE!  If you want to put in 

40k, I will honor the agreement to give you a 50k position.  Or 

you can stay with the 12,500, that is entirely up to you.  Just 

know that as of January 24th, there will be no more room for 

any additional funds for the show. ] 

Despite Snyder’s aggressive efforts to induce this individual to invest more, he only 

invested $12,500. 

30. As founder and President of Legendary Partners, Snyder knew, or was 

reckless in not knowing, that the above-described profit projections had no reasonable 

factual basis and were materially false and misleading.  Defendants’ profit projections 

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and investment returns, moreover, were material to reasonable investors. 

31. As President and control person of Legendary Partners, Snyder’s scienter, 

conduct, and statements are imputed to Legendary Partners. 

B. Investor Funds Were Misappropriated by Defendants through Activities 

that Were Outside of the Designated Use of Proceeds. 

32. Legendary Partners and Snyder misappropriated investor funds in two 

ways.  First, Defendants took funds that investors wished to invest in other offerings 

and deposited that money into Legendary Partner’s bank accounts—an outright 

misappropriation.  Second, Defendants misappropriated a significant portion of investor 

funds intended for Legendary Partners by using that money in a manner that was not 

disclosed to investors.   

1. Misappropriation of Funds Meant for Other Offerings. 

33. From February 2018 through July 2019, Legendary Partners and Snyder 

misappropriated investments totaling $35,700 from five investors.  Even though these 

investors had each invested in an entirely different offering than Legendary Partners, 

their funds were deposited into one of Legendary Partners’ accounts.  Snyder was 

responsible for soliciting and misappropriating investments totaling $20,700 from three 

of those investors.   

34. Specifically, Snyder solicited a $7,500 investment from one investor for 

shares in an unrelated offering called Biosynetics.  In a January 3, 2019 email from 

Snyder (posing as “Bill Miller, V.P. Client Relations, Biosynetics”) with the subject 

line “Information on our Pharmaceutical company and Instructions,” Snyder provided 

the prospective investor with a business plan and other company material and provided 

news regarding “our product SOMNUS VI” (which was Biosynetics’ purported sleep 

agent product).  Finally, he falsely claimed that Legendary Partners was Biosynetics’ 

“transfer agent” and then directed the investor to wire $7,500 to one of Legendary 

Partners’ bank accounts.   

35. On January 4, 2019, following Snyder’s instructions, the Biosynetics 

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investor wired funds to Legendary Partners and received a share certificate for 7,500 

shares of Biosynetics.  Snyder did not, however, transfer this money to Biosynetics’ 

account but rather misappropriated it.  When the person at the call center responsible for 

spearheading the Biosynetics offering learned of Snyder’s misappropriation, he and 

Snyder had a “falling out from the stealing [of the Biosynetics investment funds].”   

36. When Snyder was asked questions about Biosynetics under oath during 

SEC testimony, he asserted his Fifth Amendment rights against self-incrimination. 

37. Snyder misappropriated another investor’s $10,000 investment in another 

unrelated offering by Incorporated Productions by directing the investor to make his 

checks out to Legendary Partners, LLC.   

38. Snyder told the Incorporated Productions investor to make out two checks 

to “Legendary Partners, LLC” for $5,000 each.  On January 23, 2019, the investor 

wrote a check with a “For” line that stated “Stock – Incorporated Productions.”  On July 

25, 2019, the investor wrote a second check with a “For” line that stated “Incorporated 

Productions stock.”  Although the investor intended that these funds be used for the 

purchase of stock in Incorporated Productions, Snyder misappropriated the $10,000 by 

depositing the checks into Legendary Partners’ bank account.  

39. Snyder similarly misappropriated $3,200 from a third investor who also 

intended to invest money in Incorporated Productions.  This investor believed that 

Incorporated Productions was a movie production company then working on a movie 

about NASCAR racer Bobby Allison and another film, “Sons of the Cross,” in which 

the company purportedly was seeking to hire either Jeremy Renner or Matt 

McConaughey as the lead actor.   

40. Snyder accomplished this theft by sending an e-mail to the investor that 

directed the investor to wire funds to a Legendary Partners bank account.  Snyder 

repeated the same lie to this investor (that he also had told to the Biosynetics investor) 

about Legendary Partners purportedly being a “stock transfer agent.”  

41. On February 19, 2019, following Snyder’s directions, the investor wired 

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$3,200 to Legendary Partners (on behalf of his wife).  His wife, on or about February 

15, 2019, then separately wired another $6,800 from her 401(k) account to Incorporated 

Productions, for a purported $10,000 combined investment in Incorporated Productions.  

Although all of the offering documents received by the investor were for Incorporated 

Productions, Snyder did not invest any of the $3,200 in that company as the investor 

intended but instead misappropriated it. 

42. When Snyder was asked questions about Incorporated Productions under 

oath during SEC testimony, he asserted his Fifth Amendment rights against self-

incrimination. 

2. Misuse of Proceeds. 

43. From April 2018 until at least December 2021, a substantial portion of 

investor funds, however, were not used as promised and therefore were 

misappropriated.   

44. Legendary Partners’ form letter, a version of which Snyder sent to 

prospective investors during the offering period from April 2018 through December 

2021, included as an attachment an Offering Memorandum (“OM”) stating: 

 

45. Snyder sent another investor an OM similarly stating, 

/// 

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46. These promises led investors to expect that their investments would be 

used primarily for video and film production costs.  Bank records reflect, however, that 

most investor funds were withdrawn as cash for uses that were largely undocumented, 

including that Snyder was using investor money for his own use.   

47. Of the amounts that were not withdrawn as cash, a significant portion 

was used for retail, restaurant, travel, and gas expenses (approximately $10,000); 

payments to an energy company unrelated to Legendary Partners (approximately 

$6,700); and miscellaneous or unknown expenses (approximately $7,700).    

48. There was no disclosure in the OM provided to investors that their 

investment funds would be taken out as cash or used for salaries. 

THE STATUTORY PERIOD HAS BEEN TOLLED 

49. On February 1, 2023, Snyder executed a “Tolling Agreement” on behalf 

of himself and on behalf of Legendary Partners, LLC (as its President) tolling and 

suspending the period beginning on February 1, 2023 through April 1, 2023. 

50. On March 30, 2023, Snyder executed an additional “Tolling Agreement” 

on behalf of himself and on behalf of Legendary Partners, LLC (as its President) tolling 

and suspending the period beginning on February 1, 2023 through May 15, 2023. 

51. On April 17, 2023, Snyder executed an additional “Tolling Agreement” 

on behalf of himself and on behalf of Legendary Partners, LLC (as its President) 

tolling and suspending the period beginning on February 1, 2023 through July 31, 

2023. 

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FIRST CLAIM FOR RELIEF 

Fraud in Violation of Section 10(b) and Rule 10b-5 Thereunder  

(Against Both Defendants) 

52. The Commission realleges and reincorporates paragraphs 1 through 51 

as if fully set forth herein. 

53. As set forth above, Defendants Legendary Partners and Snyder   knew, 

or were reckless in not knowing that, they made materially untrue and misleading 

misstatements and omissions to investors in the offer and sale of securities and 

misappropriated investor funds. By engaging in the conduct described above, 

Defendants Legendary Partners and Snyder directly or indirectly, in connection with 

the purchase or sale of securities, by use of the means or instrumentalities of 

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

(a) employed devices, schemes or artifices to defraud; (b) made untrue statements of 

material facts or omitted to state material facts necessary in order to make the 

statements made, in light of the circumstances under which they were made, not 

misleading; and/or (c) engaged in acts, practices, or courses of business which 

operated or would operate as a fraud or deceit upon any person in connection with the 

purchase or sale of any security. 

54. By engaging in the conduct described above, Defendants Legendary 

Partners and Snyder 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 thereunder 

[17 C.F.R. § 240.10b-5]. 

SECOND CLAIM FOR RELIEF 

Fraud in Violation of Section 17(a)of the Securities Act 

(Against Both Defendants) 

55. The Commission realleges and reincorporates paragraphs 1 through 51 

as if fully set forth herein. 

56. By engaging in the conduct described above, Defendants Legendary 

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Partners and Snyder, singly or in concert with others, in connection with the offer or 

sale of securities, by use of the means or instrumentalities of interstate commerce, or 

of the mails, or a facility of a national securities exchange, directly or indirectly: (a) 

employed devices, schemes, or artifices to defraud; (b) made untrue statements of 

material fact or omitted to state material facts necessary in order to make the 

statements made, in 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 have operated as a fraud or deceit upon persons. 

57. By engaging in the conduct described above, Defendants Legendary 

Partners and Snyder, violated, and unless restrained and enjoined will continue to 

violate, Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a). 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court enter 

Final Judgments: 

(a) Permanently enjoining Defendants Legendary Partners and Snyder, and 

those persons in active concert or participation with any of them, who receive actual 

notice of the judgment by personal service or otherwise, and each of them, from 

violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of 

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

240.10b-5]; 

(b) Permanently enjoining Snyder from directly or indirectly, including, but 

not limited to, through any entity owned or controlled by him, participating in the 

issuance, purchase, offer, or sale of any security, provided, however, that such 

injunction shall not prevent him from purchasing or selling securities for his own 

personal account;   

(c)  Ordering that Defendant Snyder be barred from serving as an officer 

and director of a public issuer pursuant to Section 20(e) of the Securities Act [15 

U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)].;  

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(d) Ordering Defendants to disgorge all ill-gotten gains obtained within the 

statute of limitations, together with prejudgment interest thereon, pursuant to Section 

21(d)(3), (d)(5) and 21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5) 

and 78u(d)(7)]. 

(e) Ordering Defendants Legendary Partners and Snyder to pay civil 

penalties pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)] and Exchange 

Act Section 21(d) [15 U.S.C. § 78u(d)];  

(f) Retain jurisdiction of this action in accordance with the principles of 

equity and the Federal Rules of Civil Procedure in order to implement and carry out 

the 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; and  

(g) Grant such other relief to the Commission as the Court may deem just 

and proper.  

DEMAND FOR JURY TRIAL 

Pursuant to Federal Rule of Civil Procedure 38, the Commission demands trial 

by jury. 

 

Dated:  July 18, 2023  

 /s/ Gary Y. Leung 
Gary Y.Leung 
Dean M. Conway 
Carolyn Kurr 
Attorneys for Plaintiff 
Securities and Exchange Commission 
 

 

Case 8:23-cv-01282   Document 1   Filed 07/18/23   Page 16 of 16   Page ID #:16



7/18/23, 7:58 AM CM/ECF - California Central District

https://ecf.cacd.uscourts.gov/cgi-bin/Dispatch.pl?112661867463539 1/1

Complaints and Other Initiating Documents
8:23-cv-01282 Securities and Exchange Commission v. Legendary Partners, LLC et al

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Leung, Gary on 7/18/2023 at 7:58 AM PDT and filed on 7/18/2023
Case Name: Securities and Exchange Commission v. Legendary Partners, LLC et al
Case Number: 8:23-cv-01282
Filer: Securities and Exchange Commission
Document Number:1

Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange
Commission. (Attorney Gary Y. Leung added to party Securities and Exchange
Commission(pty:pla))(Leung, Gary)

8:23-cv-01282 Notice has been electronically mailed to:

Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]

8:23-cv-01282 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :

The following document(s) are associated with this transaction:

Document description:Main Document
Original filename:C:\fakepath\Legendary Partners Complaint.pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=7/18/2023] [FileNumber=36201241-0
] [5f093ab6eac4ab48cdf00aefe608966529913b33b6cd29b83f1247ccbadec59d421
9f326342afbb566f2b1883c640fe04a6459a4e34e9b475d206efcf0731d37]]

https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?891827
https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?891827
https://ecf.cacd.uscourts.gov/doc1/031140444589?caseid=891827&de_seq_num=4&magic_num=MAGIC