SEC v. MARIA DULCE PINO DICKERSON; CREATIVE LEGAL FUNDINGS IN CA; and THE UBIQUITY GROUP LLC, Eastern District of California (Jan. 1, 2024) — Complaint

COMPLAINT
SEC
 v. DICKERSON ET AL.

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MONIQUE C. WINKLER (Cal. Bar No. 213031)
JASON H. LEE (Cal. Bar No. 253140)
DAVID ZHOU (NY Bar No. 4926523)
ROBIN ANDREWS (Illinois Bar No. 6285644)
  [email protected]
DUNCAN C. SIMPSON LAGOY (Cal. Bar No. 298776)
  [email protected]

Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
44 Montgomery Street, Suite 700
San Francisco, CA 94104
(415) 705-2500 (Telephone)
(415) 705-2501 (Facsimile)
SECURITIES AND EXCHANGE COMMISSION,

                        Plaintiff,

            vs.

MARIA DULCE PINO DICKERSON,
CREATIVE LEGAL FUNDINGS IN CA, and
THE UBIQUITY GROUP LLC,

  Defendants.

Case No.

COMPLAINT

JURY DEMAND

Plaintiff Securities and Exchange Commission (the “Commission”) alleges:
SUMMARY OF THE ACTION
1. From approximately March 2021 through May 2023, Defendant Maria Dulce Pino
Dickerson (“Dickerson”) orchestrated a Ponzi-like scheme targeting Filipino Americans that used
sham companies to defraud investors out of approximately $7 million.  Dickerson conducted
fraudulent securities offerings and sold unregistered securities to more than 130 investors who, at
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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her request, paid her to acquire interests of her company, Creative Legal Fundings in CA
(“Creative Legal Fundings”).
2. During in-person meetings, telephone calls, and online videoconferences,
Dickerson made numerous material misrepresentations and omissions about Creative Legal
Fundings, including that Creative Legal Fundings was in the business of lending money to
personal injury lawyers to fund litigation in exchange for a share of any eventual awards or
recoveries, and that Creative Legal Fundings would pay a guaranteed return on investment of 10
percent to 17.5 percent per month.
3. In reality, Creative Legal Fundings did not lend funds to personal injury lawyers or
make any other investments, and it did not generate any revenues.  Instead, Dickerson used new
investments to make Ponzi-like payments of the promised returns to prior investors.  In addition,
unbeknownst to investors, Dickerson misappropriated more than $2.5 million of investor funds for
her own personal benefit to pay for, among other things, a $1 million house, gambling, travel, and
shopping.  Eventually, in December 2022, Dickerson was unable to raise new investor funds
quickly enough and stopped paying the guaranteed returns to prior investors.
4. In an effort to continue fraudulently raising funds, Dickerson shut down Creative
Legal Fundings in May 2023 and opened a new company called The Ubiquity Group LLC
(“Ubiquity,” and, collectively with Dickerson and Creative Legal Fundings, “Defendants”).  Her
scheme, however, remained the same.  Dickerson told prospective investors that Ubiquity also
loaned money for personal injury litigation.  At least one investor rolled his prior investment in
Creative Legal Fundings, along with the purported earnings that he had accrued from Creative
Legal Fundings’ guaranteed monthly returns, into Ubiquity.
5. As a result of the conduct alleged in this Complaint, Defendants violated the
antifraud provisions of the Securities Act of 1933 (“Securities Act”) and the Securities Exchange
Act of 1934 (“Exchange Act”) and the securities registration provisions of the Securities Act.
6. In this action, the Commission seeks permanent injunctions, disgorgement of ill-
gotten gains with prejudgment interest, and civil monetary penalties.  The Commission also seeks

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an order prohibiting Defendants from participating in the issuance, purchase, offer, or sale of any
securities and prohibiting Dickerson from acting as an officer or director of any public company.
JURISDICTION AND VENUE
7. The Commission brings this action pursuant to Sections 20(b), 20(d), 20(e), and
22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), 77t(e), and 77v(a)] and Sections 21(d),
21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa].
8. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), 20(e),
and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), 77t(e), and 77v(a)], as well as Sections
20(a), 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78t(a), 78u(d), 78u(e), and 78aa].
9. Defendants, directly or indirectly, made use of the means and instrumentalities of
interstate commerce or of the mails in connection with the acts, transactions, practices, and courses
of business alleged in this Complaint.
10. 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(a)], because acts,
transactions, practices, and courses of business that form the basis for the violations alleged in this
Complaint occurred in this District.  For example, Dickerson established the headquarters of both
Creative Legal Fundings and Ubiquity in Sacramento, California, and offered and sold interests in
Creative Legal Fundings and Ubiquity from Sacramento, California.
11. Intradistrict assignment to the Sacramento Division is proper pursuant to Rule
120(d) of the Court’s Local Rules because a substantial part of the events and omissions which
give rise to these claims occurred in Sacramento County.
DEFENDANTS
12. Maria Dulce Pino Dickerson, age 47, is a resident of Sacramento, California.  She
is the founder, sole owner, and CEO of Creative Legal Fundings and sole manager of Ubiquity.
She exercised control and decision-making authority over all aspects of the operations of Creative
Legal Fundings and Ubiquity during the entire period covered by this Complaint.
13. Creative Legal Fundings in CA is a California corporation with its principal place
of business in Sacramento, California.  It is not registered with the Commission in any capacity.  In

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its February 14, 2023, Statement of Information filed with the California Secretary of State, its type
of business is described as “Legal Funds.”  Dickerson is the CEO and chair of the board of
directors of Creative Legal Fundings, and was the only signatory on Creative Legal Fundings’
bank accounts.
14. The Ubiquity Group LLC is a California limited liability company with its
principal place of business in Sacramento, California.  It is not registered with the Commission in
any capacity.  Dickerson is the sole manager of Ubiquity and was the only signatory on Ubiquity’s
bank account.
FACTUAL ALLEGATIONS
A. Dickerson’s Scheme to Defraud Investors
15. Beginning in or about March 2021, Dickerson raised funds from investors by
selling interests in her company, Creative Legal Fundings, which she claimed would provide
investors with guaranteed high monthly returns ranging from 10 percent to 17.5 percent.  She
started her scheme by soliciting relatively small investments from friends, who recommended the
Creative Legal Fundings investment to other potential investors.  Dickerson then broadened her
efforts to reach new investors by organizing in-person meetings, telephone calls, and online
videoconferences during which she discussed the purported merits of investing in Creative Legal
Fundings with potential investors.  In particular, Dickerson, who is Filipino American, targeted
other Filipino Americans with her investment pitch.
16. During those meetings and calls, Dickerson lied to prospective investors about how
Creative Legal Fundings would generate the money necessary to pay the promised high returns.
She falsely told investors that Creative Legal Fundings’ business involved extending loans to
personal injury lawyers to fund their lawsuits in exchange for a portion of any eventual settlements
or recoveries.  She also claimed that she used her own expertise to pick which attorneys would
receive loans from the company.  Moreover, she falsely told investors that two high-profile
individuals – the CEO of a well-known global hospitality and entertainment company and a former
biotechnology executive – had helped co-found Creative Legal Fundings with her and had already
invested $3.52 million.  To further the false illusion that Creative Legal Fundings was a real

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business, Dickerson misleadingly directed some investors to the website of a legitimate California-
based company with a similar name that does in fact provide loans to personal injury attorneys.
And to suggest that Creative Legal Fundings was a successful, lucrative business, Dickerson also
highlighted her own lavish lifestyle in social media posts.
17. None of these representations were true.  Creative Legal Fundings did not provide
any loans to personal injury lawyers or invest in any other kind of income-generating security,
asset, instrument, or business activities.  Instead, bank records show that investor funds were used
to make Ponzi-like payments to prior investors and pay for Dickerson’s personal expenses.
Moreover, the two high-profile individuals cited by Dickerson were not involved in Creative Legal
Fundings and did not invest any money in the company, much less the millions claimed by
Dickerson.
18. These facts, however, did not stop Dickerson from making false representations to
investors about the returns they would receive if they invested in Creative Legal Fundings.  In both
verbal statements and written investment contracts (the “Investment Contracts”), Dickerson falsely
claimed that Creative Legal Fundings would provide investors with guaranteed returns every
month ranging from 10 percent to 17.5 percent, depending on the size of the initial investments.
She also falsely and misleadingly reassured investors that they could withdraw their entire
investments, including their monthly earnings, if they provided 30 days’ written notice.  Investors
signed Investment Contracts that spelled out these terms, and Dickerson countersigned some of
them in her own name, and some in the name of Creative Legal Fundings.
19. Some of the Investment Contracts were titled “General Investors Agreement” or
“Investors Agreement.”  Certain other Investment Contracts, which included all the same
substantive terms, were styled as either a “General Partnership/Investors Agreement” or “General
Partnership Agreement.”  Although the Investment Contracts contained boilerplate language about
partners sharing in the entity’s profits and losses and deciding business affairs by a majority vote,
none of them were true partnership agreements because Creative Legal Fundings was a
corporation, not a general partnership.  As a result, the Investment Contracts did not provide any
details about what business matters would require a vote, or when or how such a vote would take

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place, and they did not provide investors with rights and powers that are commonplace in true
general partnerships, such as the ability to initiate a ballot, the power to remove the manager of the
partnership, or the right to access the entity’s books and records.  Creative Legal Fundings also did
not operate as a general partnership.  Investors who signed the Investment Contracts understood
that they were passive investors and had no role in running Creative Legal Fundings, and they
were not asked to vote on any business matters and did not receive any share of the company’s net
profits or losses.
20. Investors in Creative Legal Fundings expected to make a profit based on the false
and misleading statements that Dickerson made to them and believed that they could rely on
Dickerson’s efforts and skill, including in selecting personal injury litigation to invest in, to obtain
those profits.
21. From March 2021 through May 2023, Dickerson raised approximately $7 million
from more than 130 investors by her offer and sale of interests in Creative Legal Fundings, which
were unregistered securities.  Dickerson pooled investor funds and led investors to believe that
they would receive guaranteed monthly returns based on her expertise in making loans to personal
injury lawyers.  No registration statement has ever been filed or in effect with respect to these
securities, and no exceptions to registration applied.  Dickerson and Creative Legal Fundings did
not take steps to determine the accredited status of Creative Legal Fundings investors, and
investors were not asked for, nor did they provide, any records verifying their net worth or income.
Based on their net worth and lack of professional financial qualifications, most investors were not
accredited at the time of their investments; the securities laws thus prohibited Dickerson and
Creative Legal Fundings from marketing a private offering to those investors.
22. Dickerson knew or was reckless in not knowing that Creative Legal Fundings did
not make loans to any personal injury attorneys, and was not entitled to receive portions of any
settlements or recoveries.  She had sole control of the bank accounts that contained investor funds.
Moreover, she was the CEO, chair of the board, and only decision-maker at Creative Legal
Fundings.  Consequently, she knew or was reckless in not knowing that Creative Legal Fundings
did not use investors’ funds to invest in any type of income-generating security, asset, instrument,

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or business activities.  Rather, she knew or was reckless in not knowing that she engaged in a
Ponzi-like scheme where she pooled new investor funds in order to pay prior investors their
promised returns, while also misappropriating funds for her own personal use.
23. Dickerson’s misrepresentations and omissions, including her misrepresentations
and omissions concerning how she would use investors’ money, were critically important to
investors in deciding to purchase the interests in Creative Legal Fundings.  Investors were denied
the opportunity to make a fully informed investment decision.
B. Dickerson Tries to Keep Her Scheme Afloat After Creative Legal Fundings
Collapses
24. By approximately December 2022, Dickerson was having difficulty making the
promised monthly return payments to investors.  To explain the lack of payments, Dickerson
falsely told certain investors that Creative Legal Fundings’ bank account had been temporarily
frozen because of a money laundering investigation.  Later, she falsely told those investors that the
Federal Bureau of Investigation had cleared her of any wrongdoing.
25. In May 2023, Dickerson told investors that she was closing down Creative Legal
Fundings.  Over the next few months, she emptied the bank accounts that held investor money,
including by sending some money to existing investors, transferring money to her personal bank
accounts, and withdrawing cash.
26. After closing Creative Legal Fundings, Dickerson formed a new company, The
Ubiquity Group LLC, and invited certain investors to roll over their initial investments, as well as
their purported returns, into interests in Ubiquity.  Dickerson also solicited new potential investors
in both California and Arizona to invest in Ubiquity.  No registration statement has ever been filed
or in effect with respect to Ubiquity’s securities, and no exceptions to the registration requirements
under the securities laws applied.
27. Dickerson recycled many of the false and misleading statements that she had used
to promote Creative Legal Fundings.  For example, she falsely told prospective investors that
Ubiquity would pool together investor funds to provide loans to personal injury attorneys as well
as certain small businesses, and Dickerson led investors to believe that they would receive

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guaranteed monthly returns based on her expertise in making loans to personal injury lawyers and
small businesses.  The same misrepresentations about Ubiquity’s supposed business appeared on
the company’s website and in its investment contract.  In addition, the Ubiquity investment
contract promised a 17.5 percent monthly dividend and stated that investors could withdraw their
investments with 30 days’ notice.
28. One investor, who had originally invested approximately $250,000 in Creative
Legal Fundings, signed an investment contract in August 2023 that converted his interests in
Creative Legal Fundings to interests in Ubiquity.  According to the contract, the value of that
investor’s investment had supposedly ballooned to $2.5 million due to the fake monthly returns
from Creative Legal Fundings.
29. Contrary to Dickerson’s misrepresentations to investors, Ubiquity was another
sham company.  Like Creative Legal Fundings, Ubiquity did not make any loans or conduct any
other business to earn revenue.  Dickerson knew or was reckless in not knowing these facts.
Indeed, she had exclusive control of Ubiquity’s bank account and was the sole manager of the
company.
30. Dickerson’s misrepresentations and omissions related to Ubiquity deprived
investors of important information relevant to their decision about whether to invest in Ubiquity.
C. Misappropriation of Investor Funds
31. Dickerson did not disclose to investors that she would use investor funds for her
own expenses and entertainment.  For the time period from March 2021 through May 2023, she
misappropriated at least $2.5 million in investor funds.  She transferred more than $1 million from
the bank accounts containing funds from Creative Legal Fundings investors to her own personal
bank accounts, she used $1 million of investor funds to buy a personal residence, and she spent
hundreds of thousands of dollars of investor funds on gambling, luxury goods, travel, and other
personal expenses.  Notably, Dickerson spent more than $280,000 at casinos in Las Vegas and
California, almost $23,000 on designer goods, and more than $75,000 on flights and hotels.
Finally, Dickerson misappropriated an additional approximately $1 million of investor funds
through withdrawals of cash and cashier’s checks.

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32. Investors in Dickerson’s scheme did not know that their money was being
misappropriated by Dickerson for her own use.  The investors were entitled to know this
information and would have wanted to know this information prior to making their investments.
Without this information, investors were denied the opportunity to make a fully informed
investment decision.
FIRST CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act and Rule 10b-5
33. The Commission re-alleges and incorporates by reference Paragraph Nos. 1
through 32.
34. Defendants, by engaging in the conduct described above, directly or indirectly, in
connection with the purchase or sale of securities, by use of the means or instruments of
transportation or communication in interstate commerce or by use of the mails, or of the facilities
of a national securities exchange, with scienter:
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 the light of the
circumstances under which they were made, not misleading; and
c. Engaged in acts, practices, or courses of business which operated or would
operate as a fraud or deceit upon other persons, including purchasers of
securities.
35. By reason of the foregoing, 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. § 240.10b-5].

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SECOND CLAIM FOR RELIEF
Violations of Section 17(a) of the Securities Act
36. The Commission re-alleges and incorporates by reference Paragraph Nos. 1
through 32.
37. Defendants, by engaging in the conduct described above, directly or indirectly, in
the offer or sale of securities, by use of the 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 of untrue statements of material fact
or by omitting to state a material fact necessary in order to make the
statements made, in light of the circumstances under which they were
made, not misleading; and
c. engaged in transactions, practices, or courses of business which operated or
would operate as a fraud or deceit upon purchasers.
38. By reason of the foregoing, 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
Violations of Sections 5(a) and 5(c) of the Securities Act
39. The Commission re-alleges and incorporates by reference Paragraph Nos. 1
through 32.
40. Creative Legal Fundings and Ubiquity interests offered and sold by Defendants are
securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(10)
of the Exchange Act [15 U.S.C. § 77c(a)(10)].
41. By engaging in the conduct described above, Defendants, directly or indirectly,
made use of the means or instruments of transportation or communication in interstate commerce,
or of the mails, to offer to sell or to sell securities through the use or medium of any prospectus or
otherwise, or carried or caused to be carried through the mails or in interstate commerce, by means
or instruments of transportation, securities for the purpose of sale or for delivery after sale, when

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no registration statement had been filed or was in effect as to such securities, and when no
exemption from registration was applicable.
42. By reason of the foregoing, Defendants violated, and unless restrained and enjoined
will continue to violate, Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and
77e(c)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court:
I.
Enter an order permanently enjoining Defendants from directly or indirectly violating
Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5]
thereunder, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and Sections 5(a) and 5(c) of
the Securities Act [15 U.S.C. §§ 77e(a) and 77e(c)].
II.
Enter an order permanently enjoining Defendants from directly or indirectly, including, but
not limited to, through any entity owned or controlled by them, participating in the issuance,
purchase, offer, or sale of any security, provided, however, that such injunction shall not prevent
Defendant Dickerson from purchasing or selling securities for her own personal accounts, pursuant
to Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Sections 21(d)(1) and 21(d)(5) of
the Exchange Act [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)].
III.
Enter an order barring Defendant Dickerson from serving as an officer or director of any
issuer having a class of securities registered with the Commission pursuant to Section 12 of the
Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the
Exchange Act [15 U.S.C. § 78o(d)], 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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IV.
Enter an order requiring Defendants to disgorge all ill-gotten gains received as a result of
their unlawful conduct plus prejudgment interest thereon pursuant to Sections 21(d)(3), 21(d)(5),
and 21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)].
V.
Enter an order requiring Defendants to pay civil monetary penalties pursuant to Section
20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C.
§ 78u(d)].
VI.
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.
VII.
Grant such other and further relief as this Court may determine to be just and necessary.

Dated:  September 3, 2024             Respectfully            submitted,

   /s/  Duncan Simpson LaGoy
Duncan C. Simpson LaGoy
Attorney for Plaintiff
SECURITIES AND EXCHANGE COMMISSION

COMPLAINT  
SEC v. DICKERSON ET AL. 
 

 
 

 

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MONIQUE C. WINKLER (Cal. Bar No. 213031)   
JASON H. LEE (Cal. Bar No. 253140)   
DAVID ZHOU (NY Bar No. 4926523)    
ROBIN ANDREWS (Illinois Bar No. 6285644)   
  [email protected]        
DUNCAN C. SIMPSON LAGOY (Cal. Bar No. 298776) 
  [email protected] 
 
 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
44 Montgomery Street, Suite 700 
San Francisco, CA 94104  
(415) 705-2500 (Telephone) 
(415) 705-2501 (Facsimile) 

SECURITIES AND EXCHANGE COMMISSION, 
 
  Plaintiff, 
 
 vs. 
 
MARIA DULCE PINO DICKERSON, 
CREATIVE LEGAL FUNDINGS IN CA, and 
THE UBIQUITY GROUP LLC, 
 

  Defendants. 
 

Case No.  
 
 
COMPLAINT 
 
JURY DEMAND 
 

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

SUMMARY OF THE ACTION 

1. From approximately March 2021 through May 2023, Defendant Maria Dulce Pino 

Dickerson (“Dickerson”) orchestrated a Ponzi-like scheme targeting Filipino Americans that used 

sham companies to defraud investors out of approximately $7 million.  Dickerson conducted 

fraudulent securities offerings and sold unregistered securities to more than 130 investors who, at 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

SACRAMENTO DIVISION 

 

Case 2:24-at-01121   Document 1   Filed 09/03/24   Page 1 of 12



  

COMPLAINT 
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her request, paid her to acquire interests of her company, Creative Legal Fundings in CA 

(“Creative Legal Fundings”).   

2. During in-person meetings, telephone calls, and online videoconferences, 

Dickerson made numerous material misrepresentations and omissions about Creative Legal 

Fundings, including that Creative Legal Fundings was in the business of lending money to 

personal injury lawyers to fund litigation in exchange for a share of any eventual awards or 

recoveries, and that Creative Legal Fundings would pay a guaranteed return on investment of 10 

percent to 17.5 percent per month.   

3. In reality, Creative Legal Fundings did not lend funds to personal injury lawyers or 

make any other investments, and it did not generate any revenues.  Instead, Dickerson used new 

investments to make Ponzi-like payments of the promised returns to prior investors.  In addition, 

unbeknownst to investors, Dickerson misappropriated more than $2.5 million of investor funds for 

her own personal benefit to pay for, among other things, a $1 million house, gambling, travel, and 

shopping.  Eventually, in December 2022, Dickerson was unable to raise new investor funds 

quickly enough and stopped paying the guaranteed returns to prior investors.   

4. In an effort to continue fraudulently raising funds, Dickerson shut down Creative 

Legal Fundings in May 2023 and opened a new company called The Ubiquity Group LLC 

(“Ubiquity,” and, collectively with Dickerson and Creative Legal Fundings, “Defendants”).  Her 

scheme, however, remained the same.  Dickerson told prospective investors that Ubiquity also 

loaned money for personal injury litigation.  At least one investor rolled his prior investment in 

Creative Legal Fundings, along with the purported earnings that he had accrued from Creative 

Legal Fundings’ guaranteed monthly returns, into Ubiquity.   

5. As a result of the conduct alleged in this Complaint, Defendants violated the 

antifraud provisions of the Securities Act of 1933 (“Securities Act”) and the Securities Exchange 

Act of 1934 (“Exchange Act”) and the securities registration provisions of the Securities Act. 

6. In this action, the Commission seeks permanent injunctions, disgorgement of ill-

gotten gains with prejudgment interest, and civil monetary penalties.  The Commission also seeks 

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COMPLAINT 
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an order prohibiting Defendants from participating in the issuance, purchase, offer, or sale of any 

securities and prohibiting Dickerson from acting as an officer or director of any public company.   

JURISDICTION AND VENUE 

7. The Commission brings this action pursuant to Sections 20(b), 20(d), 20(e), and 

22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), 77t(e), and 77v(a)] and Sections 21(d), 

21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. 

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

and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), 77t(e), and 77v(a)], as well as Sections 

20(a), 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78t(a), 78u(d), 78u(e), and 78aa].  

9. Defendants, directly or indirectly, made use of the means and instrumentalities of 

interstate commerce or of the mails in connection with the acts, transactions, practices, and courses 

of business alleged in this Complaint. 

10. 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(a)], because acts, 

transactions, practices, and courses of business that form the basis for the violations alleged in this 

Complaint occurred in this District.  For example, Dickerson established the headquarters of both 

Creative Legal Fundings and Ubiquity in Sacramento, California, and offered and sold interests in 

Creative Legal Fundings and Ubiquity from Sacramento, California. 

11. Intradistrict assignment to the Sacramento Division is proper pursuant to Rule 

120(d) of the Court’s Local Rules because a substantial part of the events and omissions which 

give rise to these claims occurred in Sacramento County. 

DEFENDANTS 

12. Maria Dulce Pino Dickerson, age 47, is a resident of Sacramento, California.  She 

is the founder, sole owner, and CEO of Creative Legal Fundings and sole manager of Ubiquity.  

She exercised control and decision-making authority over all aspects of the operations of Creative 

Legal Fundings and Ubiquity during the entire period covered by this Complaint.  

13. Creative Legal Fundings in CA is a California corporation with its principal place 

of business in Sacramento, California.  It is not registered with the Commission in any capacity.  In 

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its February 14, 2023, Statement of Information filed with the California Secretary of State, its type 

of business is described as “Legal Funds.”  Dickerson is the CEO and chair of the board of 

directors of Creative Legal Fundings, and was the only signatory on Creative Legal Fundings’ 

bank accounts.  

14. The Ubiquity Group LLC is a California limited liability company with its 

principal place of business in Sacramento, California.  It is not registered with the Commission in 

any capacity.  Dickerson is the sole manager of Ubiquity and was the only signatory on Ubiquity’s 

bank account. 

FACTUAL ALLEGATIONS 

A. Dickerson’s Scheme to Defraud Investors 

15. Beginning in or about March 2021, Dickerson raised funds from investors by 

selling interests in her company, Creative Legal Fundings, which she claimed would provide 

investors with guaranteed high monthly returns ranging from 10 percent to 17.5 percent.  She 

started her scheme by soliciting relatively small investments from friends, who recommended the 

Creative Legal Fundings investment to other potential investors.  Dickerson then broadened her 

efforts to reach new investors by organizing in-person meetings, telephone calls, and online 

videoconferences during which she discussed the purported merits of investing in Creative Legal 

Fundings with potential investors.  In particular, Dickerson, who is Filipino American, targeted 

other Filipino Americans with her investment pitch.  

16. During those meetings and calls, Dickerson lied to prospective investors about how 

Creative Legal Fundings would generate the money necessary to pay the promised high returns.  

She falsely told investors that Creative Legal Fundings’ business involved extending loans to 

personal injury lawyers to fund their lawsuits in exchange for a portion of any eventual settlements 

or recoveries.  She also claimed that she used her own expertise to pick which attorneys would 

receive loans from the company.  Moreover, she falsely told investors that two high-profile 

individuals – the CEO of a well-known global hospitality and entertainment company and a former 

biotechnology executive – had helped co-found Creative Legal Fundings with her and had already 

invested $3.52 million.  To further the false illusion that Creative Legal Fundings was a real 

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business, Dickerson misleadingly directed some investors to the website of a legitimate California-

based company with a similar name that does in fact provide loans to personal injury attorneys.  

And to suggest that Creative Legal Fundings was a successful, lucrative business, Dickerson also 

highlighted her own lavish lifestyle in social media posts.  

17. None of these representations were true.  Creative Legal Fundings did not provide 

any loans to personal injury lawyers or invest in any other kind of income-generating security, 

asset, instrument, or business activities.  Instead, bank records show that investor funds were used 

to make Ponzi-like payments to prior investors and pay for Dickerson’s personal expenses.  

Moreover, the two high-profile individuals cited by Dickerson were not involved in Creative Legal 

Fundings and did not invest any money in the company, much less the millions claimed by 

Dickerson. 

18. These facts, however, did not stop Dickerson from making false representations to 

investors about the returns they would receive if they invested in Creative Legal Fundings.  In both 

verbal statements and written investment contracts (the “Investment Contracts”), Dickerson falsely 

claimed that Creative Legal Fundings would provide investors with guaranteed returns every 

month ranging from 10 percent to 17.5 percent, depending on the size of the initial investments.  

She also falsely and misleadingly reassured investors that they could withdraw their entire 

investments, including their monthly earnings, if they provided 30 days’ written notice.  Investors 

signed Investment Contracts that spelled out these terms, and Dickerson countersigned some of 

them in her own name, and some in the name of Creative Legal Fundings.   

19. Some of the Investment Contracts were titled “General Investors Agreement” or 

“Investors Agreement.”  Certain other Investment Contracts, which included all the same 

substantive terms, were styled as either a “General Partnership/Investors Agreement” or “General 

Partnership Agreement.”  Although the Investment Contracts contained boilerplate language about 

partners sharing in the entity’s profits and losses and deciding business affairs by a majority vote, 

none of them were true partnership agreements because Creative Legal Fundings was a 

corporation, not a general partnership.  As a result, the Investment Contracts did not provide any 

details about what business matters would require a vote, or when or how such a vote would take 

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place, and they did not provide investors with rights and powers that are commonplace in true 

general partnerships, such as the ability to initiate a ballot, the power to remove the manager of the 

partnership, or the right to access the entity’s books and records.  Creative Legal Fundings also did 

not operate as a general partnership.  Investors who signed the Investment Contracts understood 

that they were passive investors and had no role in running Creative Legal Fundings, and they 

were not asked to vote on any business matters and did not receive any share of the company’s net 

profits or losses.   

20. Investors in Creative Legal Fundings expected to make a profit based on the false 

and misleading statements that Dickerson made to them and believed that they could rely on 

Dickerson’s efforts and skill, including in selecting personal injury litigation to invest in, to obtain 

those profits.   

21. From March 2021 through May 2023, Dickerson raised approximately $7 million 

from more than 130 investors by her offer and sale of interests in Creative Legal Fundings, which 

were unregistered securities.  Dickerson pooled investor funds and led investors to believe that 

they would receive guaranteed monthly returns based on her expertise in making loans to personal 

injury lawyers.  No registration statement has ever been filed or in effect with respect to these 

securities, and no exceptions to registration applied.  Dickerson and Creative Legal Fundings did 

not take steps to determine the accredited status of Creative Legal Fundings investors, and 

investors were not asked for, nor did they provide, any records verifying their net worth or income.  

Based on their net worth and lack of professional financial qualifications, most investors were not 

accredited at the time of their investments; the securities laws thus prohibited Dickerson and 

Creative Legal Fundings from marketing a private offering to those investors. 

22. Dickerson knew or was reckless in not knowing that Creative Legal Fundings did 

not make loans to any personal injury attorneys, and was not entitled to receive portions of any 

settlements or recoveries.  She had sole control of the bank accounts that contained investor funds.  

Moreover, she was the CEO, chair of the board, and only decision-maker at Creative Legal 

Fundings.  Consequently, she knew or was reckless in not knowing that Creative Legal Fundings 

did not use investors’ funds to invest in any type of income-generating security, asset, instrument, 

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or business activities.  Rather, she knew or was reckless in not knowing that she engaged in a 

Ponzi-like scheme where she pooled new investor funds in order to pay prior investors their 

promised returns, while also misappropriating funds for her own personal use.  

23. Dickerson’s misrepresentations and omissions, including her misrepresentations 

and omissions concerning how she would use investors’ money, were critically important to 

investors in deciding to purchase the interests in Creative Legal Fundings.  Investors were denied 

the opportunity to make a fully informed investment decision.    

B. Dickerson Tries to Keep Her Scheme Afloat After Creative Legal Fundings 
Collapses 

24. By approximately December 2022, Dickerson was having difficulty making the 

promised monthly return payments to investors.  To explain the lack of payments, Dickerson 

falsely told certain investors that Creative Legal Fundings’ bank account had been temporarily 

frozen because of a money laundering investigation.  Later, she falsely told those investors that the 

Federal Bureau of Investigation had cleared her of any wrongdoing.  

25. In May 2023, Dickerson told investors that she was closing down Creative Legal 

Fundings.  Over the next few months, she emptied the bank accounts that held investor money, 

including by sending some money to existing investors, transferring money to her personal bank 

accounts, and withdrawing cash.   

26. After closing Creative Legal Fundings, Dickerson formed a new company, The 

Ubiquity Group LLC, and invited certain investors to roll over their initial investments, as well as 

their purported returns, into interests in Ubiquity.  Dickerson also solicited new potential investors 

in both California and Arizona to invest in Ubiquity.  No registration statement has ever been filed 

or in effect with respect to Ubiquity’s securities, and no exceptions to the registration requirements 

under the securities laws applied.    

27. Dickerson recycled many of the false and misleading statements that she had used 

to promote Creative Legal Fundings.  For example, she falsely told prospective investors that 

Ubiquity would pool together investor funds to provide loans to personal injury attorneys as well 

as certain small businesses, and Dickerson led investors to believe that they would receive 

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guaranteed monthly returns based on her expertise in making loans to personal injury lawyers and 

small businesses.  The same misrepresentations about Ubiquity’s supposed business appeared on 

the company’s website and in its investment contract.  In addition, the Ubiquity investment 

contract promised a 17.5 percent monthly dividend and stated that investors could withdraw their 

investments with 30 days’ notice. 

28. One investor, who had originally invested approximately $250,000 in Creative 

Legal Fundings, signed an investment contract in August 2023 that converted his interests in 

Creative Legal Fundings to interests in Ubiquity.  According to the contract, the value of that 

investor’s investment had supposedly ballooned to $2.5 million due to the fake monthly returns 

from Creative Legal Fundings. 

29. Contrary to Dickerson’s misrepresentations to investors, Ubiquity was another 

sham company.  Like Creative Legal Fundings, Ubiquity did not make any loans or conduct any 

other business to earn revenue.  Dickerson knew or was reckless in not knowing these facts.  

Indeed, she had exclusive control of Ubiquity’s bank account and was the sole manager of the 

company. 

30. Dickerson’s misrepresentations and omissions related to Ubiquity deprived 

investors of important information relevant to their decision about whether to invest in Ubiquity. 

C. Misappropriation of Investor Funds 

31. Dickerson did not disclose to investors that she would use investor funds for her 

own expenses and entertainment.  For the time period from March 2021 through May 2023, she 

misappropriated at least $2.5 million in investor funds.  She transferred more than $1 million from 

the bank accounts containing funds from Creative Legal Fundings investors to her own personal 

bank accounts, she used $1 million of investor funds to buy a personal residence, and she spent 

hundreds of thousands of dollars of investor funds on gambling, luxury goods, travel, and other 

personal expenses.  Notably, Dickerson spent more than $280,000 at casinos in Las Vegas and 

California, almost $23,000 on designer goods, and more than $75,000 on flights and hotels.  

Finally, Dickerson misappropriated an additional approximately $1 million of investor funds 

through withdrawals of cash and cashier’s checks.   

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32. Investors in Dickerson’s scheme did not know that their money was being 

misappropriated by Dickerson for her own use.  The investors were entitled to know this 

information and would have wanted to know this information prior to making their investments.  

Without this information, investors were denied the opportunity to make a fully informed 

investment decision.        

FIRST CLAIM FOR RELIEF 

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

33. The Commission re-alleges and incorporates by reference Paragraph Nos. 1 

through 32. 

34. Defendants, by engaging in the conduct described above, directly or indirectly, in 

connection with the purchase or sale of securities, by use of the means or instruments of 

transportation or communication in interstate commerce or by use of the mails, or of the facilities 

of a national securities exchange, with scienter: 

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 the light of the 

circumstances under which they were made, not misleading; and 

c. Engaged in acts, practices, or courses of business which operated or would 

operate as a fraud or deceit upon other persons, including purchasers of 

securities. 

35. By reason of the foregoing, 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. § 240.10b-5]. 

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SECOND CLAIM FOR RELIEF 

Violations of Section 17(a) of the Securities Act 

36. The Commission re-alleges and incorporates by reference Paragraph Nos. 1 

through 32. 

37. Defendants, by engaging in the conduct described above, directly or indirectly, in 

the offer or sale of securities, by use of the 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 of untrue statements of material fact 

or by omitting to state a material fact necessary in order to make the 

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

made, not misleading; and  

c. engaged in transactions, practices, or courses of business which operated or 

would operate as a fraud or deceit upon purchasers.  

38. By reason of the foregoing, 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 

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

39. The Commission re-alleges and incorporates by reference Paragraph Nos. 1 

through 32. 

40. Creative Legal Fundings and Ubiquity interests offered and sold by Defendants are 

securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(10) 

of the Exchange Act [15 U.S.C. § 77c(a)(10)]. 

41. By engaging in the conduct described above, Defendants, directly or indirectly, 

made use of the means or instruments of transportation or communication in interstate commerce, 

or of the mails, to offer to sell or to sell securities through the use or medium of any prospectus or 

otherwise, or carried or caused to be carried through the mails or in interstate commerce, by means 

or instruments of transportation, securities for the purpose of sale or for delivery after sale, when 

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no registration statement had been filed or was in effect as to such securities, and when no 

exemption from registration was applicable. 

42. By reason of the foregoing, Defendants violated, and unless restrained and enjoined 

will continue to violate, Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and 

77e(c)]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court: 

I. 

Enter an order permanently enjoining Defendants from directly or indirectly violating 

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

thereunder, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and Sections 5(a) and 5(c) of 

the Securities Act [15 U.S.C. §§ 77e(a) and 77e(c)]. 

II. 

Enter an order permanently enjoining Defendants from directly or indirectly, including, but 

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

purchase, offer, or sale of any security, provided, however, that such injunction shall not prevent 

Defendant Dickerson from purchasing or selling securities for her own personal accounts, pursuant 

to Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Sections 21(d)(1) and 21(d)(5) of 

the Exchange Act [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)]. 

III. 

Enter an order barring Defendant Dickerson from serving as an officer or director of any 

issuer having a class of securities registered with the Commission pursuant to Section 12 of the 

Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the 

Exchange Act [15 U.S.C. § 78o(d)], 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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IV. 

Enter an order requiring Defendants to disgorge all ill-gotten gains received as a result of 

their unlawful conduct plus prejudgment interest thereon pursuant to Sections 21(d)(3), 21(d)(5), 

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

V. 

Enter an order requiring Defendants to pay civil monetary penalties pursuant to Section 

20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. 

§ 78u(d)]. 

VI. 

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. 

VII. 

Grant such other and further relief as this Court may determine to be just and necessary. 
 
Dated:  September 3, 2024  Respectfully submitted, 
 

   /s/  Duncan Simpson LaGoy                          
Duncan C. Simpson LaGoy 
Attorney for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 

 

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