SEC v. Alex Duain Forester

1

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
CASEY R. FRONK (Illinois State Bar No. 6296535)
PRO HAC VICE APPLICATION PENDING
[email protected]
Counsel for Plaintiff
U.S. Securities and Exchange Commission
351 South West Temple, Suite 6.100
Salt Lake City, UT 84101-1950
Tel.: (801) 524-5796
Fax: (801) 524-3558

Local Counsel:
AMY J. LONGO (Cal. Bar. No. 198304)
444 S. Flower Street, Suite 900
Los Angeles, CA 90071
[email protected]
Tel: (323) 965-3835
Fax: (213) 443-1904

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SECURITIES AND EXCHANGE
COMMISSION,
                     Plaintiff,
          vs.

ALEX DUAIN FORESTER, an
individual; MICHAEL ROBERT
HICKS, an individual; YARDEN
MOSHE MONY KRAMPF, an
individual; CHRISTOPHER
BYUNGIN LEE, an individual;
SEAN ANDREW O’NEAL, an
individual; MICHAEL ROY
RAYNOR, an individual; and, LEE
SOBEL, an individual,
                     Defendants.

Case No.:

COMPLAINT

2

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges
as follows:
JURISDICTION AND VENUE
1. The Commission brings this action pursuant to Sections 21(d) and (e)
of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d)
and (e)] to enjoin such acts, practices, and courses of business, and to obtain civil
money penalties and such other and further relief as this Court may deem just and
appropriate.
2. Defendants Alex Duain Forester, Michael Robert Hicks, Yarden
Moshe Mony Krampf, Christopher Byugin Lee, Sean Andrew O’Neal, Michael
Roy Raynor, and Lee Sobel were, collectively, involved in the offer and sale of the
common stock of numerous companies, with each such stock a “security” as that
term is defined under Section 3(a)(10) of the Exchange Act [15 U.S.C. §
78c(a)(10)].
3. Each Defendant, directly or indirectly, made use of the mails or the
means or instrumentalities of interstate commerce in connection with the conduct
alleged in this Complaint.
4. This Court has subject matter jurisdiction over this action pursuant to
Sections 21(d) and 27 of the Exchange Act [15 U.S.C. §§ 78u(d) and 78a(a)] and
28 U.S.C. § 1331.
5. Venue in this District is proper because each Defendant is found in,
inhabits, and/or transacted business in the Central District of California and
because one or more acts or transactions constituting the violations occurred in the
Central District of California.
SUMMARY OF THE ACTION
6. At various points between at least October 2015 and at least
November 2019 (the “Relevant Period”), Alex Duain Forester, Michael Robert

3

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
Hicks, Yarden Moshe Mony Krampf, Christopher Byungin Lee, Sean Andrew
O’Neal, Michael Roy Raynor, and Lee Sobel (“Defendants”) were each
individually engaged in the solicitation of numerous investors to purchase various
securities.
7. In aggregate, during the Relevant Period, Defendants earned,
collectively and in gross, over $2.8 million in illicit commissions from their
securities solicitation work.
8. While engaged in these solicitations, each Defendant was neither
registered with the Commission as a broker or dealer nor associated with a broker
or dealer registered with the Commission.
9. By engaging in this conduct, as further described herein, each
Defendant violated and, unless restrained and enjoined by this Court, may continue
to violate Section 15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)].
DEFENDANTS
10. Alex Duain Forester (f/k/a Duain Vincent Preitz), age 69, is a
resident of Simi Valley, California. Forester was the subject of a 2012 “Desist and
Refrain Order” issued by the California Business, Transportation and Housing
Agency, Department of Corporations for selling unregistered stock. Forester
solicited investors to purchase various securities and received commissions
thereby. When called to appear for investigative testimony, Forester admitted to his
solicitation conduct.
11. Michael Robert Hicks (a/k/a Mike Rosen), age 48, is a resident of
Fountain Valley, California. Hicks, who operated through 2 Tone Marketing LLC,
solicited investors to purchase various securities and received commissions
thereby. When called to appear for investigative testimony, Hicks admitted to his
solicitation conduct.

4

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
12. Yarden Moshe Mony Krampf (a/k/a Jordan Field), age 34, is a
resident of Santa Monica, California. Krampf, who operated through Advantage
Marketing Associates Inc., directly and indirectly through others solicited investors
to purchase various securities and received commissions thereby. When called to
appear for investigative testimony, Krampf invoked his Fifth Amendment privilege
against self-incrimination.
13. Christopher Byungin Lee (a/k/a Christopher Walters), age 27, is a
resident of Walnut, California. Lee, who sometimes operated through J.C. Margin,
LLC, directly and indirectly through others solicited investors to purchase various
securities and received commissions thereby. When called to appear for
investigative testimony, Lee invoked his Fifth Amendment privilege against self-
incrimination in response to most of the questions posed to him.
14. Sean Andrew O’Neal (a/k/a Sean Sipos, Andrew Sipos, Sean
Ryan), age 58, is currently incarcerated at FCI Lompoc with a scheduled release
date of July 5, 2023, arising from his prosecution and conviction for wire fraud.
O’Neal was the subject of a 2018 “Desist and Refrain Order” issued by the
California Business, Consumer Services and Housing Agency, Department of
Business Oversight for fraudulently selling unregistered securities. O’Neal, who
operated through Penny Pros, LLC and Vanguard Equities, LLC (among others),
solicited investors to purchase various securities and received commissions
thereby.
15. Michael Roy Raynor, age 58, is a resident of West Hollywood,
California. Raynor, who operated through Martel Marketing Inc., solicited
investors to purchase various securities and received commissions thereby. When
called to appear for investigative testimony, Raynor invoked his Fifth Amendment
privilege against self-incrimination in response to most of the questions posed to
him.

5

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
16. Lee Sobel (a/k/a Lee Reynolds), age 56, is a resident of Gardena
California.  Sobel solicited investors to purchase various securities and received
commissions thereby. When called to appear for investigative testimony, Sobel
invoked his Fifth Amendment privilege against self-incrimination in response to
most of the questions posed to him.
FACTS
 Defendants’ Matched-Trading Scheme
17. At points during the Relevant Period, each Defendant, among other
activities, engaged in soliciting investors to purchase securities in connection with
a scheme referred to herein as a “matched-trading” scheme. The matched-trading
scheme is understood to have operated in the following manner:
a. Certain individuals, referred to hereinafter as “selling
shareholders,” through various means obtained large blocks of at
least nominally unrestricted shares of small capitalization
securities (“microcap”) issuers and sought to profit quickly from
them by selling the shares into the market. However, likely
because they understood that selling large amounts of thinly traded
microcap securities through standard brokerage sell orders likely
would take a long while and/or cause a collapse in the prices of the
shares they sought to sell, the selling shareholders sought out and
entered into arrangements with individuals who operated boiler
room enterprises employing telephone “solicitors” such as the
Defendants. Pursuant to these arrangements, the boiler room
operators, through the solicitors they hired, such as the Defendants,
undertook to cold call and solicit investors to purchase the selling
shareholders’ shares at prices set by the selling shareholders or
their agents.

6

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
b. The solicitors cold called prospective investors and inquired if the
prospective investor had an active brokerage account with online
order-entry functionality and, if so, advised the prospective
investor about the attractiveness of the security.
c. If the prospective investor was swayed and decided to purchase the
promoted shares, the solicitor inquired of the prospective investor
how much money he or she would like to invest.
d. The solicitor then alerted the boiler room operator as to the
prospective investor’s interest, and the boiler room operator then
contacted the selling shareholder or his or her agent and
communicated the total dollar amount that the investor wanted to
invest. The selling shareholder or his or her agent then checked the
then current level II quotation for the subject security and provided
the boiler room operator with a limit order price at or below the
then current share price, which was then communicated, through
the solicitor, to the prospective investor.
e. The prospective investor then entered a purchase limit order online
in his or her brokerage account at the price provided by the
solicitor. Nearly simultaneously, the selling shareholder or his or
her agent entered a sale limit order for the same amount of shares
at the same price. Via these means, the investor’s order and the
selling shareholder’s order were likely, at least in part, to match
with the effect that the selling shareholder was able to liquidate his
or her position in the subject security, piecemeal, into a market
with ready purchasers while concomitantly increasing the trading
volume in the security, which may attract other purchasers.

7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
f. The selling shareholder and the boiler room operator then
communicated about how many shares were matched between the
investor and the selling shareholder, and the selling shareholder
then paid the boiler room operator a commission payment that was
generally between 25% and 50% of the invested funds. The boiler
room operator then paid a portion of these commissions to the
solicitor responsible for producing the transaction, such as the
Defendants.
18. During the time that Defendants were involved as solicitors in the
above-discussed scheme, none was registered with the Commission as a broker,
nor were the Defendants associated with any registered broker-dealers.
 Defendants’ Participation In The Matched-Trading Scheme
 Alex Duain Forester
19. Defendant Alex Duain Forester first became involved in matched-
trading securities solicitation work, as described above, in or around July 2015
when he accepted employment as a solicitor for a boiler room business operated by
David Alan Wolfson with offices located in the Los Angeles area.
20. Forester received commission payments from Wolfson through at
least November 2017 for soliciting investors to purchase securities through
matched trades.
21. In addition to working in Wolfson’s boiler room operation, Forester
engaged in securities solicitation work for various other boiler room operators.
22. Most notably, between June 2018 and March 2019, Forester worked
as a solicitor for a securities solicitation business operated by Defendant Yarden
Moshe Mony Krampf and earned commissions totaling at least $139,719 thereby.
23. While working as a solicitor for the Wolfson operation, the Krampf
operation, and other boiler rooms, Forester cold called prospective investors, used

8

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
scripts to pitch them on one or more investment opportunities, and, under the
direction of the boiler room operator, instructed investors to place purchase limit
orders at designated prices and volumes.
24. Forester received commissions on the securities purchases he was
responsible for obtaining.
25. Forester also received occasional commission payments on the
securities purchases others were responsible for obtaining (known as a commission
“override”).
26. Between October 9, 2015, and July 19, 2019, Forester received at
least $349,875 in commission payments arising from his securities solicitation
activities, matched trading and otherwise.
Michael Robert Hicks
27. Beginning as early as 2011 and ending in or around November 2019,
Defendant Michael Robert Hicks worked as a solicitor for various boiler room
operations engaged in the matched-trading scheme described above.
28. While working as a solicitor, Hicks sometimes operated under the
pseudonym “Mike Rosen.”
29. Among the boiler room operations Hicks worked for was the David
Wolfson operation, in which Hicks periodically worked as a solicitor from at least
October 2015 through at least February 2018.
30. While working as a solicitor for the Wolfson operation and other
boiler rooms, Hicks cold called prospective investors, used scripts to pitch them on
one or more investment opportunities, and, under the direction of the boiler room
operator, instructed investors to place purchase limit orders at designated prices
and volumes.
31. Hicks received commissions on the securities purchases he was
responsible for obtaining.

9

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
32. Hicks also acted as an intermediary by passing commissions on to
another solicitor who worked under him.
33. Between October 16, 2015, and December 20, 2019, Hicks and his
business received $180,570 in commission payments arising from his securities
solicitation activities, matched trading and otherwise.
Yarden Moshe Mony Krampf
34. Sometime towards the end of 2017, Defendant Yarden Moshe Mony
Krampf was introduced to the securities solicitation business and set up his own
boiler room operation that was engaged in securities solicitation activities, and
specifically in the matched-trading scheme described above in paragraph 17.
35. Krampf recruited solicitors to work in his operation by posting
recruiting advertisements on Craigslist. Krampf provided his solicitors with lead
lists that he had purchased, and he and his solicitors used those lists to cold call
prospective investors.
36. During the time that he ran his securities solicitation operation,
Krampf promoted multiple securities, including, principally, a deal promoting the
sale of SanSal Wellness Holdings, Inc., which later changed its name to Veritas
Farms, Inc.
37. Between December 2, 2017, and October 31, 2019, Krampf and his
operation received $345,739 in commission payments. Krampf retained a portion
of these commissions and used the remainder to pay the solicitors working for him.
Christopher Byugin Lee
38. Defendant Christopher Byugin Lee operated as a securities solicitor
from at least February 2016 through at least May 2019.
39. Among the boiler room operations Lee worked for was the David
Wolfson operation, where he worked as an investor solicitor from at least June
2016 through at least February 2018.

10

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
40. While working as a solicitor in the Wolfson operation and other boiler
rooms, Lee cold called prospective investors, used scripts to pitch them on an
investment opportunity, and, under the direction of the boiler room operator,
instructed investors to place purchase limit orders at designated prices and
volumes.
41. Although Lee never operated his own physical boiler room, he
recruited others to work remotely for him as securities solicitors.
42. To recruit these solicitors, Lee posted Craigslist advertisements which
stated, for example, “We are an investor relations firm seeking experienced closers
and I.S.O.’s
1
 to help raise money for publicly traded companies. You must have
market knowledge and sales experience, you will be talking to savvy investors and
asking for big money.”
43. Another Craigslist advertisement posted by Lee stated, “I am looking
for remote investment sales pros that have experience in selling stocks, private
placements, real estate, REITs, gold/silver, oil/gas, movie deals, or any other
investments. You must be comfortable speaking to and negotiating with high net
worth individuals. I will provide leads, ...”
44. Between February 22, 2016, and May 25, 2019, Lee received
$1,160,817 in commission payments arising from his securities solicitation
activities, matched trading and otherwise, a portion of which he used to pay the
solicitors working under him.
Andrew O’Neal
45. Defendant Andrew O’Neal worked as a securities solicitor for at least
two boiler room operations between March 2016 and June 2017.

1
  I.S.O., in this context, is believed to mean independent sales organization or
independent sales office.

11

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
46. Specifically, during this period, O’Neal received commission
payments from Conrad Cane, who ran a boiler room operation in the Los Angeles
area, and Scott Messier and Jay Scoratow, who jointly ran a boiler room operation
from the San Diego area.
47. Both the Cane and Messier/Scoratow operations engaged in the
matched-trading scheme described above in paragraph 17.
48. While working as a solicitor in the Cane and Messier/Scoratow
operations, O’Neal cold called prospective investors, used scripts to pitch them on
an investment opportunity, and, under the direction of the boiler room operators,
instructed investors to place purchase limit orders at designated prices and
volumes.
49. O’Neal received commissions on the securities purchases he was
responsible for obtaining.
50. Between March 4, 2016, and June 22, 2017, O’Neal received $99,276
in commission payments arising from his securities solicitation activities, matched
trading and otherwise.
Michael Roy Raynor
51. Defendant Michael Roy Raynor worked as a solicitor for various
boiler room operations between at least October 2015 and November 2019.
52. Among the boiler room operations Raynor worked for are the
Wolfson operation and the Cane operation.
53. While working as a securities solicitor, Raynor cold called prospective
investors, used scripts to pitch them on an investment opportunity, and, under the
direction of the boiler room operators, instructed investors to place purchase limit
orders at designated prices and volumes.

12

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
54. As evinced by a document produced by an issuer of a private real
estate investment, which listed Raynor as one of its solicitors, Raynor also solicited
investments in at least one private securities placement.
55. Raynor received commissions on the securities purchases he was
responsible for obtaining.
56. Between October 16, 2015, and November 12, 2019, Raynor received
$660,898.76 in commission payments arising from his securities solicitation
activities, matched trading and otherwise.
Lee Sobel
57. Defendant Lee Sobel worked as a securities solicitor in at least three
boiler room operations between February 2016 and October 2017.
58. Specifically, Sobel worked as a solicitor in the boiler room operations
of Wolfson and Cane as well as another operation based in the Los Angeles area
and managed by Gregory Drake, which also engaged in the matched-trading
scheme described above in paragraph 17.
59. While working as a securities solicitor in each of these operations,
Sobel, at minimum, cold called prospective investors, pitched them on one or more
investment opportunities, and received commissions on the securities purchases his
cold calls resulted in.
60. Between February 8, 2016, and October 26, 2017, Sobel received
$103,252 in commission payments arising from his securities solicitation activities,
matched trading and otherwise.

13

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
CLAIM FOR RELIEF
Violations of Section 15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)]
(Against each Defendant)
61. The Commission re-alleges and incorporates by reference each and
every allegation in paragraphs 10–60, inclusive, as if they were fully set forth
herein.
62. By engaging in the conduct described above, each Defendant:
a. engaged in the business of effecting transactions in securities for
the account of others; and
b. directly or indirectly, made use of the mails or the means or
instrumentalities of interstate commerce to effect transactions in,
or to induce or attempt to induce the purchase or sale of, securities
without being registered as a broker or dealer with the Commission
or associated with a broker or dealer registered with the
Commission.
63. By reason of the foregoing, each Defendant violated and, unless enjoined,
will continue to violate Sections 15(a)(1) of the Exchange Act [15 U.S.C.
§ 78o(a)(1)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court enter a
final judgment:
I.
Permanently restraining and enjoining each Defendant from, directly or
indirectly, engaging in conduct in violation of Section 15(a)(1) of the Exchange
Act [15 U.S.C. § 78o(a)(1)];

14

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
II.
Permanently restraining and enjoining each Defendant from, directly or
indirectly, including, but not limited to, through any entity owned or controlled by
each Defendant, soliciting any person or entity to purchase or sell any security;
III.
Ordering each Defendant to pay civil monetary penalties pursuant to Section
21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)];
IV.
Retaining 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,
V.
Granting such other and further relief as this Court may deem just, equitable,
or necessary in connection with the enforcement of the federal securities laws and
for the protection of investors.

Dated:  October 26, 2020

     /s/ Amy J. Longo
     Amy J. Longo
                                                  Attorney          for          Plaintiff
                                                  Securities          and          Exchange          Commission

Complaints and Other Initiating Documents
2:20-cv-09813 Securities and Exchange Commission v. Forester et al
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing
The following transaction was entered by Longo, Amy on 10/26/2020 at 3:19 PM PDT and filed on
10/26/2020
Case Name:Securities and Exchange Commission v. Forester et al
Case Number:2:20-cv-09813
Filer:Securities and Exchange Commission
Document Number:
1
Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and
Exchange Commission. (Attorney Amy J Longo added to party Securities and Exchange
Commission(pty:pla))(Longo, Amy)
2:20-cv-09813 Notice has been electronically mailed to:
Amy J Longo     [email protected], [email protected], [email protected], [email protected]
2:20-cv-09813 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:F:\marcelom\Forester\Complaint (for filing).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=10/26/2020] [FileNumber=30788234-
0] [2fd66e8369d8572c36ecb5bd0ce0f4484583651b47d4f20f0c18f2f6edc9752f8f
73e90b66f67e45077b1074129cb801728e92799e2ff0f4102fcf2821c889fd]]

1 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

CASEY R. FRONK (Illinois State Bar No. 6296535) 
PRO HAC VICE APPLICATION PENDING 
[email protected] 
Counsel for Plaintiff 
U.S. Securities and Exchange Commission 
351 South West Temple, Suite 6.100 
Salt Lake City, UT 84101-1950 
Tel.: (801) 524-5796 
Fax: (801) 524-3558 
 
Local Counsel: 
AMY J. LONGO (Cal. Bar. No. 198304) 
444 S. Flower Street, Suite 900 
Los Angeles, CA 90071 
[email protected] 
Tel: (323) 965-3835 
Fax: (213) 443-1904 
 

UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 

 
 

 
SECURITIES AND EXCHANGE 
COMMISSION, 

 Plaintiff, 
 vs. 
 
ALEX DUAIN FORESTER, an 
individual; MICHAEL ROBERT 
HICKS, an individual; YARDEN 
MOSHE MONY KRAMPF, an 
individual; CHRISTOPHER 
BYUNGIN LEE, an individual; 
SEAN ANDREW O’NEAL, an 
individual; MICHAEL ROY 
RAYNOR, an individual; and, LEE 
SOBEL, an individual,  

 Defendants. 
 

 
Case No.: 
 
 
 
 
COMPLAINT 
 
 
 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 1 of 14   Page ID #:1



 

2 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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

as follows:  

JURISDICTION AND VENUE 

1. The Commission brings this action pursuant to Sections 21(d) and (e) 

of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) 

and (e)] to enjoin such acts, practices, and courses of business, and to obtain civil 

money penalties and such other and further relief as this Court may deem just and 

appropriate. 

2. Defendants Alex Duain Forester, Michael Robert Hicks, Yarden 

Moshe Mony Krampf, Christopher Byugin Lee, Sean Andrew O’Neal, Michael 

Roy Raynor, and Lee Sobel were, collectively, involved in the offer and sale of the 

common stock of numerous companies, with each such stock a “security” as that 

term is defined under Section 3(a)(10) of the Exchange Act [15 U.S.C. § 

78c(a)(10)].  

3. Each Defendant, directly or indirectly, made use of the mails or the 

means or instrumentalities of interstate commerce in connection with the conduct 

alleged in this Complaint. 

4. This Court has subject matter jurisdiction over this action pursuant to 

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

28 U.S.C. § 1331. 

5. Venue in this District is proper because each Defendant is found in, 

inhabits, and/or transacted business in the Central District of California and 

because one or more acts or transactions constituting the violations occurred in the 

Central District of California. 

SUMMARY OF THE ACTION 

6. At various points between at least October 2015 and at least 

November 2019 (the “Relevant Period”), Alex Duain Forester, Michael Robert 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 2 of 14   Page ID #:2



 

3 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

Hicks, Yarden Moshe Mony Krampf, Christopher Byungin Lee, Sean Andrew 

O’Neal, Michael Roy Raynor, and Lee Sobel (“Defendants”) were each 

individually engaged in the solicitation of numerous investors to purchase various 

securities.  

7. In aggregate, during the Relevant Period, Defendants earned, 

collectively and in gross, over $2.8 million in illicit commissions from their 

securities solicitation work.  

8. While engaged in these solicitations, each Defendant was neither 

registered with the Commission as a broker or dealer nor associated with a broker 

or dealer registered with the Commission.  

9. By engaging in this conduct, as further described herein, each 

Defendant violated and, unless restrained and enjoined by this Court, may continue 

to violate Section 15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)]. 

DEFENDANTS 

10. Alex Duain Forester (f/k/a Duain Vincent Preitz), age 69, is a 

resident of Simi Valley, California. Forester was the subject of a 2012 “Desist and 

Refrain Order” issued by the California Business, Transportation and Housing 

Agency, Department of Corporations for selling unregistered stock. Forester 

solicited investors to purchase various securities and received commissions 

thereby. When called to appear for investigative testimony, Forester admitted to his 

solicitation conduct.  

11. Michael Robert Hicks (a/k/a Mike Rosen), age 48, is a resident of 

Fountain Valley, California. Hicks, who operated through 2 Tone Marketing LLC, 

solicited investors to purchase various securities and received commissions 

thereby. When called to appear for investigative testimony, Hicks admitted to his 

solicitation conduct.  

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 3 of 14   Page ID #:3



 

4 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

12. Yarden Moshe Mony Krampf (a/k/a Jordan Field), age 34, is a 

resident of Santa Monica, California. Krampf, who operated through Advantage 

Marketing Associates Inc., directly and indirectly through others solicited investors 

to purchase various securities and received commissions thereby. When called to 

appear for investigative testimony, Krampf invoked his Fifth Amendment privilege 

against self-incrimination.  

13. Christopher Byungin Lee (a/k/a Christopher Walters), age 27, is a 

resident of Walnut, California. Lee, who sometimes operated through J.C. Margin, 

LLC, directly and indirectly through others solicited investors to purchase various 

securities and received commissions thereby. When called to appear for 

investigative testimony, Lee invoked his Fifth Amendment privilege against self-

incrimination in response to most of the questions posed to him.  

14. Sean Andrew O’Neal (a/k/a Sean Sipos, Andrew Sipos, Sean 

Ryan), age 58, is currently incarcerated at FCI Lompoc with a scheduled release 

date of July 5, 2023, arising from his prosecution and conviction for wire fraud. 

O’Neal was the subject of a 2018 “Desist and Refrain Order” issued by the 

California Business, Consumer Services and Housing Agency, Department of 

Business Oversight for fraudulently selling unregistered securities. O’Neal, who 

operated through Penny Pros, LLC and Vanguard Equities, LLC (among others), 

solicited investors to purchase various securities and received commissions 

thereby. 

15. Michael Roy Raynor, age 58, is a resident of West Hollywood, 

California. Raynor, who operated through Martel Marketing Inc., solicited 

investors to purchase various securities and received commissions thereby. When 

called to appear for investigative testimony, Raynor invoked his Fifth Amendment 

privilege against self-incrimination in response to most of the questions posed to 

him.  

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 4 of 14   Page ID #:4



 

5 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

16. Lee Sobel (a/k/a Lee Reynolds), age 56, is a resident of Gardena 

California.  Sobel solicited investors to purchase various securities and received 

commissions thereby. When called to appear for investigative testimony, Sobel 

invoked his Fifth Amendment privilege against self-incrimination in response to 

most of the questions posed to him. 

FACTS 

 Defendants’ Matched-Trading Scheme 

17. At points during the Relevant Period, each Defendant, among other 

activities, engaged in soliciting investors to purchase securities in connection with 

a scheme referred to herein as a “matched-trading” scheme. The matched-trading 

scheme is understood to have operated in the following manner: 

a. Certain individuals, referred to hereinafter as “selling 

shareholders,” through various means obtained large blocks of at 

least nominally unrestricted shares of small capitalization 

securities (“microcap”) issuers and sought to profit quickly from 

them by selling the shares into the market. However, likely 

because they understood that selling large amounts of thinly traded 

microcap securities through standard brokerage sell orders likely 

would take a long while and/or cause a collapse in the prices of the 

shares they sought to sell, the selling shareholders sought out and 

entered into arrangements with individuals who operated boiler 

room enterprises employing telephone “solicitors” such as the 

Defendants. Pursuant to these arrangements, the boiler room 

operators, through the solicitors they hired, such as the Defendants, 

undertook to cold call and solicit investors to purchase the selling 

shareholders’ shares at prices set by the selling shareholders or 

their agents.  

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 5 of 14   Page ID #:5



 

6 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

b. The solicitors cold called prospective investors and inquired if the 

prospective investor had an active brokerage account with online 

order-entry functionality and, if so, advised the prospective 

investor about the attractiveness of the security.  

c. If the prospective investor was swayed and decided to purchase the 

promoted shares, the solicitor inquired of the prospective investor 

how much money he or she would like to invest.  

d. The solicitor then alerted the boiler room operator as to the 

prospective investor’s interest, and the boiler room operator then 

contacted the selling shareholder or his or her agent and 

communicated the total dollar amount that the investor wanted to 

invest. The selling shareholder or his or her agent then checked the 

then current level II quotation for the subject security and provided 

the boiler room operator with a limit order price at or below the 

then current share price, which was then communicated, through 

the solicitor, to the prospective investor.  

e. The prospective investor then entered a purchase limit order online 

in his or her brokerage account at the price provided by the 

solicitor. Nearly simultaneously, the selling shareholder or his or 

her agent entered a sale limit order for the same amount of shares 

at the same price. Via these means, the investor’s order and the 

selling shareholder’s order were likely, at least in part, to match 

with the effect that the selling shareholder was able to liquidate his 

or her position in the subject security, piecemeal, into a market 

with ready purchasers while concomitantly increasing the trading 

volume in the security, which may attract other purchasers.  

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 6 of 14   Page ID #:6



 

7 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

f. The selling shareholder and the boiler room operator then 

communicated about how many shares were matched between the 

investor and the selling shareholder, and the selling shareholder 

then paid the boiler room operator a commission payment that was 

generally between 25% and 50% of the invested funds. The boiler 

room operator then paid a portion of these commissions to the 

solicitor responsible for producing the transaction, such as the 

Defendants.  

18. During the time that Defendants were involved as solicitors in the 

above-discussed scheme, none was registered with the Commission as a broker, 

nor were the Defendants associated with any registered broker-dealers.  

 Defendants’ Participation In The Matched-Trading Scheme 

 Alex Duain Forester 

19. Defendant Alex Duain Forester first became involved in matched-

trading securities solicitation work, as described above, in or around July 2015 

when he accepted employment as a solicitor for a boiler room business operated by 

David Alan Wolfson with offices located in the Los Angeles area.  

20. Forester received commission payments from Wolfson through at 

least November 2017 for soliciting investors to purchase securities through 

matched trades. 

21. In addition to working in Wolfson’s boiler room operation, Forester 

engaged in securities solicitation work for various other boiler room operators. 

22. Most notably, between June 2018 and March 2019, Forester worked 

as a solicitor for a securities solicitation business operated by Defendant Yarden 

Moshe Mony Krampf and earned commissions totaling at least $139,719 thereby. 

23. While working as a solicitor for the Wolfson operation, the Krampf 

operation, and other boiler rooms, Forester cold called prospective investors, used 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 7 of 14   Page ID #:7



 

8 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

scripts to pitch them on one or more investment opportunities, and, under the 

direction of the boiler room operator, instructed investors to place purchase limit 

orders at designated prices and volumes. 

24. Forester received commissions on the securities purchases he was 

responsible for obtaining. 

25. Forester also received occasional commission payments on the 

securities purchases others were responsible for obtaining (known as a commission 

“override”). 

26. Between October 9, 2015, and July 19, 2019, Forester received at 

least $349,875 in commission payments arising from his securities solicitation 

activities, matched trading and otherwise.  

Michael Robert Hicks 

27. Beginning as early as 2011 and ending in or around November 2019, 

Defendant Michael Robert Hicks worked as a solicitor for various boiler room 

operations engaged in the matched-trading scheme described above. 

28. While working as a solicitor, Hicks sometimes operated under the 

pseudonym “Mike Rosen.” 

29. Among the boiler room operations Hicks worked for was the David 

Wolfson operation, in which Hicks periodically worked as a solicitor from at least 

October 2015 through at least February 2018. 

30. While working as a solicitor for the Wolfson operation and other 

boiler rooms, Hicks cold called prospective investors, used scripts to pitch them on 

one or more investment opportunities, and, under the direction of the boiler room 

operator, instructed investors to place purchase limit orders at designated prices 

and volumes. 

31. Hicks received commissions on the securities purchases he was 

responsible for obtaining. 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 8 of 14   Page ID #:8



 

9 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

32. Hicks also acted as an intermediary by passing commissions on to 

another solicitor who worked under him.  

33. Between October 16, 2015, and December 20, 2019, Hicks and his 

business received $180,570 in commission payments arising from his securities 

solicitation activities, matched trading and otherwise.  

Yarden Moshe Mony Krampf 

34. Sometime towards the end of 2017, Defendant Yarden Moshe Mony 

Krampf was introduced to the securities solicitation business and set up his own 

boiler room operation that was engaged in securities solicitation activities, and 

specifically in the matched-trading scheme described above in paragraph 17. 

35. Krampf recruited solicitors to work in his operation by posting 

recruiting advertisements on Craigslist. Krampf provided his solicitors with lead 

lists that he had purchased, and he and his solicitors used those lists to cold call 

prospective investors. 

36. During the time that he ran his securities solicitation operation, 

Krampf promoted multiple securities, including, principally, a deal promoting the 

sale of SanSal Wellness Holdings, Inc., which later changed its name to Veritas 

Farms, Inc. 

37. Between December 2, 2017, and October 31, 2019, Krampf and his 

operation received $345,739 in commission payments. Krampf retained a portion 

of these commissions and used the remainder to pay the solicitors working for him.  

Christopher Byugin Lee 

38. Defendant Christopher Byugin Lee operated as a securities solicitor 

from at least February 2016 through at least May 2019. 

39. Among the boiler room operations Lee worked for was the David 

Wolfson operation, where he worked as an investor solicitor from at least June 

2016 through at least February 2018. 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 9 of 14   Page ID #:9



 

10 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

40. While working as a solicitor in the Wolfson operation and other boiler 

rooms, Lee cold called prospective investors, used scripts to pitch them on an 

investment opportunity, and, under the direction of the boiler room operator, 

instructed investors to place purchase limit orders at designated prices and 

volumes. 

41. Although Lee never operated his own physical boiler room, he 

recruited others to work remotely for him as securities solicitors. 

42. To recruit these solicitors, Lee posted Craigslist advertisements which 

stated, for example, “We are an investor relations firm seeking experienced closers 

and I.S.O.’s1 to help raise money for publicly traded companies. You must have 

market knowledge and sales experience, you will be talking to savvy investors and 

asking for big money.”   

43. Another Craigslist advertisement posted by Lee stated, “I am looking 

for remote investment sales pros that have experience in selling stocks, private 

placements, real estate, REITs, gold/silver, oil/gas, movie deals, or any other 

investments. You must be comfortable speaking to and negotiating with high net 

worth individuals. I will provide leads, …” 

44. Between February 22, 2016, and May 25, 2019, Lee received 

$1,160,817 in commission payments arising from his securities solicitation 

activities, matched trading and otherwise, a portion of which he used to pay the 

solicitors working under him. 

Andrew O’Neal 

45. Defendant Andrew O’Neal worked as a securities solicitor for at least 

two boiler room operations between March 2016 and June 2017. 

                            
1  I.S.O., in this context, is believed to mean independent sales organization or 
independent sales office. 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 10 of 14   Page ID #:10



 

11 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

46. Specifically, during this period, O’Neal received commission 

payments from Conrad Cane, who ran a boiler room operation in the Los Angeles 

area, and Scott Messier and Jay Scoratow, who jointly ran a boiler room operation 

from the San Diego area. 

47. Both the Cane and Messier/Scoratow operations engaged in the 

matched-trading scheme described above in paragraph 17.  

48. While working as a solicitor in the Cane and Messier/Scoratow 

operations, O’Neal cold called prospective investors, used scripts to pitch them on 

an investment opportunity, and, under the direction of the boiler room operators, 

instructed investors to place purchase limit orders at designated prices and 

volumes. 

49. O’Neal received commissions on the securities purchases he was 

responsible for obtaining. 

50. Between March 4, 2016, and June 22, 2017, O’Neal received $99,276 

in commission payments arising from his securities solicitation activities, matched 

trading and otherwise.  

Michael Roy Raynor 

51. Defendant Michael Roy Raynor worked as a solicitor for various 

boiler room operations between at least October 2015 and November 2019. 

52. Among the boiler room operations Raynor worked for are the 

Wolfson operation and the Cane operation. 

53. While working as a securities solicitor, Raynor cold called prospective 

investors, used scripts to pitch them on an investment opportunity, and, under the 

direction of the boiler room operators, instructed investors to place purchase limit 

orders at designated prices and volumes. 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 11 of 14   Page ID #:11



 

12 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

54. As evinced by a document produced by an issuer of a private real 

estate investment, which listed Raynor as one of its solicitors, Raynor also solicited 

investments in at least one private securities placement. 

55. Raynor received commissions on the securities purchases he was 

responsible for obtaining. 

56. Between October 16, 2015, and November 12, 2019, Raynor received 

$660,898.76 in commission payments arising from his securities solicitation 

activities, matched trading and otherwise.  

Lee Sobel 

57. Defendant Lee Sobel worked as a securities solicitor in at least three 

boiler room operations between February 2016 and October 2017. 

58. Specifically, Sobel worked as a solicitor in the boiler room operations 

of Wolfson and Cane as well as another operation based in the Los Angeles area 

and managed by Gregory Drake, which also engaged in the matched-trading 

scheme described above in paragraph 17. 

59. While working as a securities solicitor in each of these operations, 

Sobel, at minimum, cold called prospective investors, pitched them on one or more 

investment opportunities, and received commissions on the securities purchases his 

cold calls resulted in. 

60. Between February 8, 2016, and October 26, 2017, Sobel received 

$103,252 in commission payments arising from his securities solicitation activities, 

matched trading and otherwise.  

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 12 of 14   Page ID #:12



 

13 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

CLAIM FOR RELIEF 

Violations of Section 15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)] 

(Against each Defendant) 

61. The Commission re-alleges and incorporates by reference each and 

every allegation in paragraphs 10–60, inclusive, as if they were fully set forth 

herein.  

62. By engaging in the conduct described above, each Defendant: 

a. engaged in the business of effecting transactions in securities for 

the account of others; and 

b. directly or indirectly, made use of the mails or the means or 

instrumentalities of interstate commerce to effect transactions in, 

or to induce or attempt to induce the purchase or sale of, securities 

without being registered as a broker or dealer with the Commission 

or associated with a broker or dealer registered with the 

Commission. 

63. By reason of the foregoing, each Defendant violated and, unless enjoined, 

will continue to violate Sections 15(a)(1) of the Exchange Act [15 U.S.C. 

§ 78o(a)(1)]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court enter a 

final judgment: 

I. 

Permanently restraining and enjoining each Defendant from, directly or 

indirectly, engaging in conduct in violation of Section 15(a)(1) of the Exchange 

Act [15 U.S.C. § 78o(a)(1)]; 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 13 of 14   Page ID #:13



 

14 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

II. 

Permanently restraining and enjoining each Defendant from, directly or 

indirectly, including, but not limited to, through any entity owned or controlled by 

each Defendant, soliciting any person or entity to purchase or sell any security; 

III. 

Ordering each Defendant to pay civil monetary penalties pursuant to Section 

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; 

IV. 

Retaining 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, 

V. 

Granting such other and further relief as this Court may deem just, equitable, 

or necessary in connection with the enforcement of the federal securities laws and 

for the protection of investors. 

 

Dated:  October 26, 2020 

 
     /s/ Amy J. Longo      
     Amy J. Longo 
     Attorney for Plaintiff 
     Securities and Exchange Commission 

Case 2:20-cv-09813   Document 1   Filed 10/26/20   Page 14 of 14   Page ID #:14



Complaints and Other Initiating Documents 
2:20-cv-09813 Securities and Exchange Commission v. Forester et al

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Longo, Amy on 10/26/2020 at 3:19 PM PDT and filed on 
10/26/2020 
Case Name: Securities and Exchange Commission v. Forester et al
Case Number: 2:20-cv-09813
Filer: Securities and Exchange Commission
Document Number:1

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

2:20-cv-09813 Notice has been electronically mailed to: 

Amy J Longo     [email protected], [email protected], [email protected], [email protected] 

2:20-cv-09813 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:F:\marcelom\Forester\Complaint (for filing).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=10/26/2020] [FileNumber=30788234-
0] [2fd66e8369d8572c36ecb5bd0ce0f4484583651b47d4f20f0c18f2f6edc9752f8f
73e90b66f67e45077b1074129cb801728e92799e2ff0f4102fcf2821c889fd]]