SEC v. HISTORIC ASSET PLACEMENT SERVICES GLOBAL, LLC; CHRISTOPHER W. ABSHIER; BILLY W. ABSHIER; FREDERIC A. GLADLE; RONALD JOSH PENDLEY; KEVIN E. SCANNELL, et al., No. 2:24-CV-10745, District of Columbia (Dec. 17, 2024) — Complaint

COMPLAINT
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OREN GLEICH (NY Bar No. 4460135) pro hac vice pending
Email: [email protected]
DOUGLAS M. MILLER (Cal. Bar. No. 240398) (Local Counsel)
Email: [email protected]
Attorneys for Plaintiff
Securities and Exchange Commission
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Email: [email protected]
Telephone: (212) 336-0190 / Fax: (212) 336-1319
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
vs.
HISTORIC ASSET PLACEMENT SERVICES
GLOBAL, LLC, CHRISTOPHER W.
ABSHIER, BILLY W. ABSHIER, FREDERIC
A. GLADLE, RONALD JOSH PENDLEY,
KEVIN E. SCANNELL, SOVEREIGN DEBT
SOLUTIONS, LP, AND OCEAN PARK
PARTNERS,
Defendants, and
BARBARA GLADLE,
 Relief Defendant.
Case No. 2:24-cv-10745
COMPLAINT
DEMAND FOR JURY TRIAL

COMPLAINT
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Plaintiff, the Securities and Exchange Commission (“SEC”), alleges as
follows:
JURISDICTION AND VENUE
1. The Court has jurisdiction over this action pursuant to Sections 20(b),
20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C.
§§ 77t(b), 77t(d)(1) & 77v(a)] and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of
the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d)(1),
78u(d)(3)(A), 78u(e) & 78aa(a)].
2. Defendants have, directly or indirectly, made use of the means or
instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange in connection with the transactions, acts, practices and courses of
business alleged in this complaint.
3. Venue is proper in this Court pursuant to Securities Act Section 22(a)
[15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa] because acts,
practices and courses of business constituting violations alleged herein have occurred
within the jurisdiction of the United States District Court for the Central District of
California, including the solicitation of investors, many of whom reside in
this District.
4. In addition, venue is proper in this district because Defendants Ronald
Josh Pendley (“Pendley”) and Kevin E. Scannell (“Scannell”) reside in this district
and Defendants Sovereign Debt Solutions, LP (“Sovereign Debt Solutions” or
“SDS”) and Ocean Park Partners (“OPP”) have their principal places of business in
this District.
SUMMARY
5. This civil enforcement action concerns the fraudulent offer and sale of
defaulted and unredeemed bonds issued by the German Weimar Republic and certain
German utilities and by the governments of pre-revolutionary Russia and China (the
“Historical Bonds”).  This action also involves the fraudulent and unregistered offer

COMPLAINT
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and sale of promissory notes and limited partnership interests, the value of which was
tied to such Historical Bonds.  As part of the fraudulent scheme, the Defendants
promoted a fictitious redemption process for Historical Bonds which falsely claimed
that investors would receive proceeds of up to $15 million for their bonds with an
advance payment of $250,000.  In reality, this purported redemption process was a
sham, no advance payment of $250,000 was ever made, and no Historical Bonds
were ever redeemed.  In all, the fraud raised at least $3.85 million from at least 85
investors between January 2017 and August 2023 (the “Relevant Period”).  The
fraudulent scheme worked in three parts.
6. First, the Defendants Historical Asset Placement Services Global, LLC
(“HAPS”), its managing member Christopher W. Abshier (“C.W. Abshier”), and
C.W. Abshier’s father and the day-to-day operations manager of HAPS, Billy W.
Abshier (“Billy Abshier” or, together with C.W. Abshier, the “Abshiers”)
(collectively the “HAPS Defendants”) offered custodial services in which HAPS
would hold and safeguard its customers’ Historical Bonds.  They also offered
purported redemption services through which HAPS would monetize the
Historical Bonds.
7. In connection with these services, the HAPS Defendants offered
commissions to affiliates to solicit customers to use HAPS’ services.  The HAPS
Defendants claimed that these commissions would be paid from the proceeds of the
Historical Bonds once they were monetized.
8. The HAPS Defendants told their affiliates and clients materially false
information about their fictitious redemption process.  These materially false
statements included that the redemption process involved the participation of the U.S.
and foreign governments, and well-known financial institutions and accounting firms.
The HAPS Defendants claimed further that the redemption process would result in a
“global currency reset” that various national governments were negotiating which
would result in most, if not all, countries using currencies backed by assets such as

COMPLAINT
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Historical Bonds.  The HAPS Defendants also promised investors a $250,000
advance on the redemption value of each investor’s Historical Bonds.  These
representations were completely false, and no such redemption process existed.
Investors never received any advances on the supposed redemption value of their
Historical Bonds, and none were ever redeemed.
9. The HAPS Defendants knew, or were reckless in not knowing, that those
soliciting HAPS clients repeated the HAPS Defendants’ false representations
regarding the purported redemption process for the Historical Bonds in their custody.
10. Second, Defendants Frederic A. Gladle (“Fred Gladle”) and Relief
Defendant Barbara Gladle (collectively, the “Gladles”), and Defendants Pendley and
Scannell each acquired Historical Bonds, which they placed in the custody of HAPS
prior to resale to third parties.  During the Relevant Period, the Gladles purchased and
sold Historical Bonds to Pendley and at least one retail customer; Pendley resold the
bonds he purchased from the Gladles and others to retail customers.  Fred Gladle
aided and abetted some of these sales.  Scannell likewise sold Historical Bonds to
retail customers.
11. In effecting or, in the case of Fred Gladle, aiding and abetting the resales
of Historical Bonds, Fred Gladle, Pendley, and Scannell referenced HAPS’
custodianship of the bonds and repeated the HAPS Defendants’ false claims about the
redemption process to investors.  In some cases, they embellished the HAPS
Defendants’ falsehoods with their own falsehoods.
12. Fred Gladle, Pendley, and Scannell knew of the existing governments’
longstanding refusal to payout on the bonds and the adverse decisions in court actions
to recover on the bonds.
13. Fred Gladle, Pendley, and Scannell each knew, or was reckless or
negligent in not knowing, that their statements to investors were materially false or
omitted material information which made the statements materially misleading.
14. Third, Pendley and Scannell, through Sovereign Debt Solutions, and its

COMPLAINT
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general partner, Ocean Park Partners, of which Pendley and Scannell were officers,
perpetrated a related scheme involving the unregistered and fraudulent offer and sale
of promissory notes and limited partnership interests issued thereunder, the value of
which was tied to certain Historical Bonds.  Through OPP, they directed SDS to
solicit existing SDS limited partners to enter into the promissory notes with SDS.
15. These notes purported to provide investors with 10% interest on the
principal as well as limited partnership interests in Sovereign Debt Solutions.
Payment on these notes and the value of the limited partnership interests depended
entirely on the redemption of Historical Bonds owned by SDS, and for which HAPS
provided custodial and purported redemption services.
16. Prior to their soliciting Sovereign Debt Solutions’ limited partners to
purchase the promissory notes, Pendley and Scannell had plied the limited partners
for years with the same HAPS Defendants’ lies about the HAPS redemption process,
which Pendley and Scannell further embellished with their own falsehoods.
17. The promissory notes and Sovereign Debt Solutions’ limited partnership
interests were securities.  No registration statement was filed with the Commission
with respect to their offer and/or sale and no exemption from registration applies.
18. Pendley and Scannell each knew, or was reckless or negligent in not
knowing, that the statements regarding the HAPS redemption process that they made
to the Sovereign Debt Solutions limited partners to induce them to purchase the
promissory notes were materially false or omitted material information which made
the statements materially misleading.
19. Together, the Defendants’ schemes raised at least $3.85 million from at
least 85 investors located in several states, including California, Florida, Michigan,
Texas, and Virginia, all of whom lost the entirety of their investments.  Of those
proceeds raised, at least $1.74 million were routed to the bank account of Relief
Defendant Barbara Gladle, who had no legitimate claim and gave no consideration in
exchange for these proceeds.

COMPLAINT
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20. By engaging in the conduct alleged in this Complaint:
a. Defendants violated and, unless restrained and enjoined, will violate
again, Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule
10b-5 thereunder [17 C.F.R. § 240.10b-5];
b. Fred Gladle, Pendley, Scannell, Sovereign Debt Solutions, and Ocean
Park Partners violated Securities Act Section 17(a) [15 U.S.C.
§ 77q(a)];
c. Pendley, Scannell, Sovereign Debt Solutions, and Ocean Park
Partners violated Securities Act Sections 5(a) and (c) [15 U.S.C.
§§77e(a) and (c)];
d. Fred Gladle aided and abetted Pendley’s violations of Securities Act
Section 17(a);
e. Fred Gladle and Pendley violated Exchange Act Section 15(a)(1) [15
U.S.C. § 78o(a)(1)] by acting as unregistered dealers; and
f. C.W. Abshier and HAPS violated Rule 21F-17(a) under the
Exchange Act [17 C.F.R. § 240.21F-17(a)].
21. The Commission seeks entry of a final judgment:
a. imposing permanent injunctions against each of the Defendants for
their respective violations of the federal securities laws;
b. ordering Fred Gladle, Pendley, Scannell, C.W. Abshier, and Billy
Abshier to each pay civil monetary penalties;
c. permanently enjoining Fred Gladle, Pendley, Scannell, C.W. Abshier,
and Billy Abshier from directly or indirectly, including, but not
limited to, through any entity owned or controlled by each,
participating in the issuance, purchase, offer, or sale of any security;
provided, however, that such injunction shall not prevent each from
purchasing or selling securities listed on a national securities
exchange for their own personal account;

COMPLAINT
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d. ordering Fred Gladle and Barbara Gladle, on a joint and several basis,
Pendley, and Scannell to pay disgorgement and prejudgment interest;
and
e. prohibiting Pendley, Scannell, Fred Gladle, and C.W. Abshier from
serving as an officer or director of a public company.
TOLLING AGREEMENTS
22. HAPS and the SEC entered into tolling agreements suspending the
running of any applicable statute of limitations from March 28, 2024 through
September 28, 2024, and from September 29, 2024 through November 29, 2024.
23. C.W. Abshier and the SEC entered into tolling agreements suspending
the running of any applicable statute of limitations from March 28, 2024 through
September 28, 2024, and from September 29, 2024 through November 29, 2024.
24. Billy Abshier and the SEC entered into a tolling agreement suspending
the running of any applicable statute of limitations from September 30, 2024 through
November 29, 2024.
25. Fred Gladle and the SEC entered into a tolling agreement and two tolling
agreement extensions suspending the running of any applicable statute of limitations
from February 6, 2024 through November 29, 2024.
26. Pendley and the SEC entered into tolling agreements suspending the
running of any applicable statutes of limitations from January 31, 2024 through July
31, 2024, and from August 1, 2024 through October 7, 2024.
27. Scannell and the SEC entered into tolling agreements suspending the
running of any applicable statute of limitations from January 31, 2024 through July
31, 2024, and from August 1, 2024 through October 7, 2024.
28. Barbara Gladle and the SEC entered into a tolling agreement and two
tolling agreement extensions suspending the running of any applicable statute of
limitations from February 6, 2024 through November 29, 2024.

COMPLAINT
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DEFENDANTS
29. HAPS is a Nevada LLC initially formed in September 2010 and
reformed in Wyoming in December 2021.  During the Relevant Period up to the
present, its principal place of business has been Temple, Texas.
30. C.W. Abshier, age 45, resides in Troy, Texas.  He served as the
managing member of HAPS during the Relevant Period up to at least early 2024.
31. Billy Abshier, age 68, resides in Temple, Texas and is C.W Abshier’s
father.  He served as HAPS’ day-to-day operations manager during the
Relevant Period.
32. Fred Gladle, age 65, resides in Lakeway, Texas.  During the Relevant
Period through the present, he has been married to Barbara Gladle.  During the
Relevant Period, he was not registered with the Commission in any capacity.  He
previously held Series 7, 22, 24, and 63 licenses and was associated with a series of
registered broker-dealers from November 1985 through 1997.
33. In 2004, a federal district court entered a consent judgment against Fred
Gladle permanently enjoining him from violating the antifraud, unregistered
securities offering and broker-dealer registration provisions of the federal securities
laws and ordering him to pay $100,000 in disgorgement and prejudgment interest and
civil penalties of $57,000, stemming from his allegedly having engaged in fraudulent
and unregistered sales of securities while acting as an unregistered broker-dealer.  See
SEC v. Internet Telecommunications Albany System SMR, et al., 1:99-cv-539 (CKK)
(D.D.C. March 2, 1999).  Fred Gladle has not paid the monetary relief to date.
34. Based on this permanent injunction, the Commission instituted a settled
administrative proceeding barring Fred Gladle from associating with a broker or
dealer with a right to reapply for association after five years.  See In the Matter of
Frederic A. Gladle, Admin Proc. File No. 3-11546 (July 14, 2004).
35. Pendley, age 59, resides in Burbank, California.  He co-founded
Sovereign Debt Solutions and Ocean Park Partners and has served as OPP’s secretary

COMPLAINT
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during the Relevant Period up to the present.  During the Relevant Period, he was not
registered with the Commission in any capacity.  He previously held Series 7 and 63
licenses and was associated with a series of registered broker-dealers from October
1989 through December 1998.
36. Scannell, age 59, resides in Santa Monica, California.  He co-founded
Sovereign Debt Solutions and Ocean Park Partners and has served as OPP’s president
during the Relevant Period up to the present.  During the Relevant Period, he was not
registered with the Commission in any capacity.  He previously held Series 7, 24, 63,
and 65 licenses and was associated with a series of registered broker-dealers from
July 1987 through December 2000.
37. Sovereign Debt Solutions is a Nevada limited partnership organized by
Pendley and Scannell in Nevada in April 2008.  During the Relevant Period up to the
present, it has maintained its principal place of business in Los Angeles, California.
38. Ocean Park Partners is a private company incorporated by Pendley
and Scannell in Nevada in September 2007.  It is the general partner of SDS.  During
the Relevant Period up to the present, it has maintained its principal place of business
in Los Angeles, California.
RELIEF DEFENDANT
39. Barbara Gladle, age 64, resides in Lakeway, Texas.  During the
Relevant Period through the present, she was married to Fred Gladle.  During the
Relevant Period, she was not registered with the Commission in any capacity.
FACTS
I. The Historical Bond Scheme
A. The Historical Bonds
40. The Historical Bonds at issue are predominantly dollar-denominated
bearer bonds issued in the 1920s by the German Weimar Republic and certain
German utilities.  Since the 1950s, the German government has generally disavowed
responsibility for these bonds.

COMPLAINT
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41. The Historical Bonds sold to investors also include “Super Petchili”
bonds, which the Chinese government issued in the 1910s, and various railroad bonds
the Russian government issued at the end of the 19th century and in the first years of
the 20th century.  After the 1949 Communist takeover in China and the 1917 Russian
Revolution, the governments of those countries consistently refused to recognize
the debt.
42. The Historical Bonds in this matter were offered and sold as securities.
B. HAPS’ Structure and Efforts to Find Clients
43. HAPS was formed in 2010.
44. During the Relevant Period, C.W. Abshier served as HAPS’ sole
managing member and Billy Abshier—C.W. Abshier’s father—managed HAPS’
daily operations.
45. HAPS offered its customers a custodial service in which it would hold
and safeguard its customers’ Historical Bonds.
46. HAPS also promoted a purported redemption service in which it would
monetize the Historical Bonds.
47. To entice clients to use their services, the HAPS Defendants made
materially false representations that HAPS’ clients would receive a $250,000 cash
advance before the purported full value of the Historical Bonds was monetized.
48. HAPS created a name for this purported advance payment, describing it
as “Healing Funds.”
49. To get more customers, HAPS represented that it would pay
commissions to individuals responsible for recruiting clients.
50. HAPS represented that it would fund these commissions by retaining 5%
of the redemption proceeds of the Historical Bonds.
51. HAPS and the Abshiers knew, or were reckless in not knowing, that
those individuals who solicited customers for HAPS (“HAPS affiliates”), including
Fred Gladle, Pendley, and Scannell, also sold Historical Bonds.

COMPLAINT
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52. HAPS and the Abshiers knew, or were reckless in not knowing, that the
HAPS affiliates induced prospective customers to buy Historical Bonds and to apply
to become HAPS members by promoting the HAPS redemption services, including
the $250,000 in “Healing Funds.”
53. During the Relevant Period, HAPS generally required each prospective
client to complete a “New Member Application,” provide supporting paperwork, and
enter into a “Non-Circumvention and Non-Disclosure Agreement” (“NCNDA”).
54. The New Member Application and NCNDA expressly referenced the
purported redemption process.
55. The NCNDA required the prospective client to agree not to
communicate anything about the redemption process to third parties.
56. These forms were available for HAPS Affiliates to distribute to
prospective HAPS customers.
57. For example, when Pendley sold Historical Bonds and recruited investor
customers for HAPS, he provided these customers with the New Member Application
and NCNDA.  These investors then submitted the forms to HAPS, with many noting
in the New Member Application that Pendley had referred them to HAPS.
58. HAPS maintained an internal database for tracking changes in ownership
of bonds in its custody.
59. The HAPS Defendants were put on notice of changes in ownership of
Historical Bonds that were held in their custody through the receipt of New Member
Applications and related paperwork.
60. Through New Member Applications and related paperwork, the HAPS
Defendants knew, or were reckless in not knowing, that Fred Gladle, Pendley, and
Scannell sold Historical Bonds while also recruiting HAPS clients.
61. In addition to the New Member Applications and associated
communications, Fred Gladle corresponded with the HAPS Defendants in October
2022 about Pendley and his interest in selling a sizeable block of Historical Bonds in

COMPLAINT
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HAPS’ custody to a third party and inquired if HAPS was willing to take on the buyer
as a new client.
62. Accordingly, through the New Member Application forms and the
associated communications, as well as the correspondence with Fred Gladle, the
HAPS Defendants knew, or were reckless in not knowing, that when Fred Gladle,
Pendley, and Scannell sold Historical Bonds to new investors, they conveyed the
HAPS Defendants’ material misrepresentations regarding the purported
redemption process.
C. The HAPS Defendants’ Misrepresentations to Investors
63. The Abshiers communicated with HAPS affiliates about the redemption
process in a number of ways.
64. Throughout the Relevant Period, C.W. Abshier communicated with
HAPS affiliates and certain HAPS clients via a HAPS-maintained electronic portal
(the “Portal”) to which HAPS granted access selectively.
65. C.W. Abshier would either draft and post himself, or direct Billy
Abshier to draft and post based on notes C.W. Abshier provided to him.
66. C.W. Abshier controlled the substance of all communications posted to
the Portal.
67. During the Relevant Period, Billy Abshier also communicated with
investors about the redemption process during in-person meetings and via telephone.
68. In July 2017, C.W. Abshier posted communications to the Portal that
broadly outlined the entire purported HAPS redemption process.  In these
communications, C.W. Abshier disseminated, among other things, the following false
statements to investors concerning the Historical Bonds:
a. once HAPS takes custody of a client’s bonds, it transports them by a
United States government diplomatic jet to a bank in Hong Kong;
b. the bonds are reviewed and authenticated in Hong Kong;
c. once the bonds are authenticated, a “Redemption Platform” housed

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within a second Hong Kong bank would route funds into a
“paymaster account” for the benefit of HAPS’ clients;
d. HAPS’ redemption efforts would culminate in a “global currency
reset” that various national governments were purportedly
negotiating; and
e. this reset would move most, if not all, countries from using fiat-based
currencies to currencies backed by assets such as gold and Historical
Bonds.
69. Throughout the Relevant Period, with slight variations, the Abshiers
disseminated to their affiliates and clients the same false information about the
purported redemption process as was in the July 2017 postings to the Portal.
70. For example, on or about March 3, 2022, during an in-person meeting in
Temple, Texas, Billy Abshier told Pendley, among other things, the following false
information: (a) that the U.S. military transports bonds from HAPS to Hong Kong;
and (b) the Redemption Platform had generated enough funds to pay off “the debt of
the world.”
71. During the Relevant Period, Billy Abshier also told Pendley that the U.S.
Department of the Treasury was involved in the redemption process, but that Billy
Abshier could not elaborate further as HAPS was subject to a non-disclosure
agreement with the Treasury Department.
72. As described more fully below, Pendley, who was formerly a licensed
and trained securities professional, used the HAPS misstatements to sell Historical
Bonds to unsuspecting investors.  Pendley knew, or was reckless or negligent in not
knowing, that these HAPS misstatements were materially false.
73. As noted, the Abshiers also falsely claimed throughout the Relevant
Period that each HAPS client would receive an advance on the ultimate final
redemption value of their bonds in the amount of $250,000, which they termed
Healing Funds.

COMPLAINT
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74. Both immediately prior to and throughout the Relevant Period, C.W.
Abshier gave repeated false assurances to HAPS affiliates and clients that the
disbursal of these “Healing Funds” to HAPS clients was imminent, examples of
which include the following:
a. On November 4, 2016, C.W. Abshier posted this message on the
Portal: “We were advised that we can expect to see the release and
authorization to disburse [Healing Funds] not long after the [2016
U.S. presidential] election takes place.”
b. On January 6, 2017, C.W. Abshier posted this message on the Portal:
“Some of the disinformation currently being propagated is that this
[redemption of Historical Bonds] could be pushed off to this summer,
and even a couple of people have been told that we won’t see
anything before 2018 at the earliest.  THAT, folks, is NOT what we
are being told! ... [T]he process has moved way too far forward to be
halted now.  We have passed the point-of-no-return in this process.”
c. On October 23, 2020, C.W. Abshier posted this message on the
Portal: “Our representative is currently in HK [Hong Kong], he was
told to travel in order to receive the funds, and we are told he will
come back with the Healing Funds in the paymaster account in the
next few days.”
d. On December 30, 2022, C.W. Abshier posted this message on the
Portal: “We continue to receive good news and can share that great
progress was made throughout the holidays toward approval for
release of Healing Funds.”
75. During an in-person meeting at HAPS’ office in Temple, Texas on or
around March 3, 2022, Billy Abshier falsely represented to Pendley that the Healing
Funds had actually arrived.  Billy Abshier declined to show Pendley any
documentation or account statements to verify that statement.

COMPLAINT
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76. In a December 2021 email to Scannell, C.W. or Billy Abshier falsely
stated that the Healing Funds “are here and are mine” but could not yet be disbursed.
This was false.
77. Like Pendley, Scannell was also a formerly licensed and trained
securities professional who used the HAPS misstatements to sell Historical Bonds to
unsuspecting investors.  Scannell knew, or was reckless or negligent in not knowing,
that these HAPS misstatements were materially false.
78. By early 2023, C.W. Abshier generally stopped promising the imminent
arrival of the Healing Funds via the Portal, asking HAPS clients to join him in
trusting “God’s timing and delivery” and stating that he cannot give any further
updates on the bonds because he is under a “gag order” of an unspecified source.
79. Contrary to the HAPS Defendants’ representations, the above-described
HAPS redemption process did not exist, and the so-called “Healing Funds” were
never distributed.
80. Beyond requiring throughout the Relevant Period that a prospective
client enter into an NCNDA stating that the client will not share information about
HAPS, C.W. Abshier and HAPS sought to curtail and control clients’ access to and
sharing of information in other ways.
81. For example, throughout the Relevant Period, HAPS periodically
warned its clients that their accounts would be suspended if they attempted to copy
the updates posted to the Portal.
82. Further, periodic updates that C.W. Abshier posted or had posted to the
Portal were initially archived on the Portal and accessible to those to whom HAPS
granted Portal access.  In or around 2020, however, C.W. Abshier directed the
removal of the archived updates and that each new update be deleted and made
inaccessible to a client after he or she reviewed it.
83. Beginning in March 2023, C.W. Abshier directed HAPS to take the
added step of demanding that certain existing and new clients, who wanted access to

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the Portal, sign an affidavit affirming that they had “not lodged any complaints nor
grievances with the SEC, FBI, or any other regulatory and/or law enforcement
agency” and promising to “not file, nor participate in any legal action against HAPS
Global... and its affiliates, members, managers, officers, directors, employees,
agents, attorneys, staff, volunteers, representatives, predecessors and successors.”
84. At least 22 investors, of which 18 had purchased Historical Bonds from
Pendley, executed the affidavit and submitted them to HAPS.
85. By demanding that clients sign this affidavit, C.W. Abshier and HAPS,
took action to impede the HAPS’ clients from communicating directly with the SEC
about possible federal securities law violations.
86. The HAPS Defendants continued to periodically post materially false
and misleading updates to the Portal throughout the Relevant Period in an effort to
lull investors.
87. The HAPS Defendants knew, or were reckless in not knowing, that each
employed a device, scheme, or artifice to defraud; made untrue statements of a
material fact or omitted to state material facts necessary to make those statements that
were made not misleading; and engaged in acts, practices, or courses of business
which operated or would operate as a fraud or deceit on investors in connection with
the sale of a security.
88. C.W. Abshier’s scienter is imputed to HAPS as its managing member.
D. Fred Gladle Sold Historical Bonds In Furtherance of the Scheme
89. The Gladles’ principal business activity and primary source of income
during the Relevant Period came from buying and selling Historical Bonds.
90. Fred Gladle and Barbara Gladle each listed his or her occupation as
“Historic Document Reseller” in their joint federal tax returns for calendar years 2020
and 2021.
91. Fred Gladle has been buying and selling Historical Bonds for at least 20
years despite knowing of the existing governments’ longstanding refusal to payout on

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the Historical Bonds and adverse decisions in court actions to recover on the
Historical Bonds.
92. During the Relevant Period, the Gladles sold Historical Bonds from their
inventory, which they maintained with HAPS, to among others, Pendley.
93. During the Relevant Period, Pendley paid at least $837,000 to a bank
account in Barbara Gladle’s name.
94. Fred Gladle knew throughout the Relevant Period that Pendley
purchased Historical Bonds from the Gladles for purposes of resale to retail investors.
95. At Pendley’s request, Fred Gladle prepared purchase agreements for
Pendley’s use in selling Historical Bonds to investors, using a template purportedly
obtained from Pendley.
96. For example, Fred Gladle prepared purchase agreements that Pendley
used to sell at least 30 Historical Bonds to at least two investors for at least $190,000
in 2019 and 2020.
97. The purchase agreements prepared by Fred Gladle to sell 30 Historical
Bonds falsely stated that the bonds had been “authenticated” and had “legal claim
values that are hundreds of times more than the purchase price being paid.”  These
false claims were made without disclosing the existing governments’ longstanding
refusal to payout on the bonds and the adverse decisions in court actions to recover
on the bonds.
98. During the Relevant Period, Fred Gladle also emailed HAPS on behalf
of at least three of Pendley’s clients to ask HAPS to grant them access to the Portal,
facilitating the clients’ direct access to HAPS’ lulling statements.
99. From March 2019 through May 2019, the Gladles also effected a series
of bond sales totaling $910,000 to an investor (“Investor A”) from their inventory
using similarly-worded purchase agreements.
100. Initially structured as a direct sale from the Gladles to Investor A, in
relation to which Fred Gladle prepared a purchase agreement signed by Barbara

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Gladle but never fully executed, the transaction was ultimately restructured to have
the Gladles engage in a series of sales to a middleman, who was Pendley’s associate,
(“Associate A”), who then sold the bonds to Investor A.
101. Fred Gladle prepared at least one agreement for Barbara Gladle’s
signature memorializing the sale of bonds from the Gladles’ inventory to Associate
A, which Barbara signed and emailed to Pendley and Associate A for the
latter’s execution.
102. Fred Gladle also prepared at least two agreements relating to Associate
A’s resale of the bonds to Investor A, with Barbara Gladle and Fred Gladle each
emailing one of the two agreements to Pendley and/or Associate A.
103. All of these agreements Fred Gladle prepared falsely represented that the
bonds, for which HAPS served as custodian, had “legal claim values that are
hundreds of times more than the purchase price being paid,” without disclosing the
existing governments’ longstanding refusal to payout on the bonds and the adverse
decisions in court actions to recover on the bonds.
104. Associate A wired the $910,000 total purchase price that he received
from Investor A to a bank account in Barbara Gladle’s name, from which the Gladles
paid “commissions” to Pendley and Associate A in the amounts of $315,135 and
$268,369, respectively, retaining $326,496.
105. At the time of the foregoing sales, the Gladles resided in Texas and
Pendley, the Associate A, and Investor A resided in California.
106. The Gladles never sought to verify the HAPS redemption process or
whether any bond had a legal claim value hundreds of times more than the purchase
price paid.
107. As a formerly licensed and trained securities professional, Fred Gladle
knew, or was reckless or negligent in not knowing, that the HAPS redemption
process was fraudulent.
108. Fred Gladle knew, or was reckless or negligent in not knowing, that, in

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the sale or offer of a security or in connection with the sale of a security, he employed
a device, scheme, or artifice to defraud; made untrue statements of a material fact or
omitted to state material facts necessary to make those statements that were made not
misleading, and thereby obtained money or property; and engaged in acts, practices,
or courses of business which operated or would operate as a fraud or deceit on
investors in connection with the sale of a security.
109. By knowingly or recklessly providing substantial assistance to Pendley
by preparing for Pendley’s use in selling Historical Bonds, purchase agreements that
contained false information, or omitted material information that made those
statements that were made materially misleading, Fred Gladle aided and abetted
Pendley’s violations of Section 17(a) of the Securities Act.
110. Barbara Gladle received ill-gotten gains into a bank account held in her
name, as stated above, to which she does not have a legitimate claim, and which was
subject to use by both Fred Gladle and Barbara Gladle.
E. Pendley’s Fraudulent Sales of Historical Bonds
111. During the Relevant Period, Pendley raised at least $2.46 million from at
least 55 investors in multiple U.S. states through fraudulent offerings and sales of
Historical Bonds from his own inventory for which HAPS served as custodian.
112. Pendley’s principal business activity and sole source of income during
the Relevant Period were from his purchase and sale of Historical Bonds.
113. To sell the Historical Bonds, Pendley cultivated a clientele among his
friends and associates.  These included members of a golf club located in Burbank,
California to which he belonged during the Relevant Period.
114. Pendley induced investors to purchase the Historical Bonds, which he
typically sold for $5,000 each, by making material misstatements or omitting material
information which made those statements which were made materially misleading,
some of which originated with HAPS and the Abshiers and others of which
Pendley devised.

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115. Among the material misrepresentations Pendley made during the
Relevant Period to multiple investors were the following:
a. HAPS had a redemption process in place for the Historical Bonds;
b. The return per bond would be in the range of $5 million to
$15 million;
c. Internationally known accounting firms specifically named by
Pendley were involved in facilitating investor payouts;
d. Each bondholder would receive $250,000 in Healing Funds within
months of the bond purchase; and
e. The SEC, FBI, and Department of Homeland Security were all aware
of the redemption process and would be monitoring clients’ accounts.
116. In addition to the foregoing material misrepresentations communicated
to multiple investors, Pendley also made the following material misrepresentations to
individual investors:
a. On June 30, 2019, Pendley told an investor that Pendley had
“personally verified bank statements in HAPS’ name”;
b. On July 3, 2019, Pendley told an investor that “HAPS has sufficient
funds to cover [$250,000 in Healing Funds] for over 30,000 client
accounts”; and
c. On September 20, 2021, Pendley told an investor that, “[t]he State
Department has completed its database findings of the 50K HAPS
clients and have [sic] cleared the path for deposit distributions.”
117. Pendley also presented at least 41 investors with a bond purchase
agreement which falsely represented that “the bond [or bonds] being transferred has
legal claim values that are hundreds of times more than the purchase price being
paid,” without disclosing the existing governments’ longstanding refusal to payout on
the bonds and adverse decisions in court actions to recover on the bonds.
118. Of the 41 investors, at least 16 were repeat customers of Pendley’s.

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119. As a formerly licensed and trained securities professional, Pendley
knew, or was reckless or negligent in not knowing, that the statements he repeated
regarding the HAPS redemption process were materially misleading.
120. Pendley further falsely represented to several investors that he did not
retain any proceeds from bond sales and that he transferred all proceeds he received
to HAPS.
121. Other than paying those from whom he purchased Historical Bonds,
including the Gladles, Pendley retained the remaining funds and used them on
personal expenses such as his golf club membership and his children’s
college tuition.
122. Contemporaneous with each bond sale, Pendley typically provided to
each investor a HAPS New Member Application and NCNDA and directed the
investor to complete both and send them directly to HAPS.  Once approved, this
would result in HAPS changing the name of the bondholder on its records from
Pendley to the investor and granting the investor access to the Portal.
123. Pendley knew, or was reckless or negligent in not knowing, that, in the
sale or offer of a security or in connection with the sale of a security, he employed a
device, scheme, or artifice to defraud; made untrue statements of a material fact or
omitted to state material facts necessary to make those statements that were made not
misleading, and thereby obtained money or property; and engaged in acts, practices,
or courses of business which operated or would operate as a fraud or deceit on
investors in connection with the sale of a security.
F. Scannell’s Fraudulent Sales of Historical Bonds
124. Scannell primarily sold Historical Bonds to preexisting investors in
Sovereign Debt Solutions, which he had formed with Pendley in 2008 as a vehicle for
pooling Historical Bonds for liquidation.
125. Beginning in 2008, Pendley and Scannell, via Sovereign Debt Solutions’
general partner Ocean Park Partners, directed SDS’ sale of limited partnership

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interests in SDS in exchange for Historical Bonds, claiming that they planned to
pursue litigation against the successors of German utility companies which issued the
bearer bonds and, alternatively, pursue “direct negotiations” with the
German government.
126. By 2013, they had ceased all litigation efforts due to other bondholders’
unsuccessful lawsuits.
127. At that time, Pendley and Scannell touted the HAPS redemption process
to the Sovereign Debt Solution’s limited partners, and with their knowledge, placed
all of SDS’ Historical Bonds with HAPS.
128. Pendley and Scannell thereafter regularly provided summaries of HAPS’
misleading Portal updates to the Sovereign Debt Solutions’ limited partners.
129. Additionally, between April 2017 and June 2022, Scannell sold
Historical Bonds from his own inventory to at least 29 of the Sovereign Debt
Solutions limited partners located in different states, raising at least $374,000.
130. Scannell made these sales after having plied the Sovereign Debt
Solutions’ nearly 100 limited partners for years with false information about the
HAPS redemption process.
131. Scannell’s principal business activity and primary source of income from
April 2017 through June 2022 were his sales of Historical Bonds.
132. The purchase agreements that Scannell used in his bond sales falsely
stated that the bonds “have legal claim values that are hundreds of times more than
the purchase price being paid,” without disclosing certain red flags that revealed that
the HAPS redemption process was fraudulent, including but not limiting to, existing
impediments to recovery and continued adverse court decisions.
133. As a licensed and trained securities professional, Scannell knew, or was
reckless or negligent in not knowing, that the HAPS redemption process
was fraudulent.
134. Scannell claimed that he sold Historical Bonds to Sovereign Debt

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Solutions’ clients so that they could become HAPS clients in their own right and gain
direct access to the Portal, rather than rely on his and Pendley’s summaries of the
updates.  Scannell thereby facilitated their direct access to HAPS’ lulling statements.
135. Scannell knew, or was reckless or negligent in not knowing, that, in the
sale or offer of a security or in connection with the sale of a security, he employed a
device, scheme, or artifice to defraud; made untrue statements of a material fact or
omitted to state material facts necessary to make those statements that were made not
misleading, and thereby obtained money or property; and engaged in acts, practices,
or courses of business which operated or would operate as a fraud or deceit on
investors in connection with the sale of a security.
II. Pendley’s, Scannell’s, Sovereign Debt Solutions’, and Ocean Park
Partners’ Fraudulent and Unregistered Offer and Sale of Promissory
Notes and SDS Limited Partnership Interests
136. Beginning in at least April 2017 and continuing to at least May 2022,
Pendley and Scannell, in their roles as officers of Sovereign Debt Solutions’ general
partner, Ocean Park Partners, solicited existing SDS investors to loan SDS monies in
exchange for a promissory note and additional limited partnership interests in SDS.
137. The promissory notes provided for repayment of principal with 10%
annual interest within six months, subject to indefinite extension at Sovereign Debt
Solutions’ discretion, or at the latest on the occurrence of a “Liquidity Event.”
138. This “Liquidity Event” was variously defined in the promissory notes as
the sale of securitization of Sovereign Debt Solutions’ Historical Bonds or the
obtaining of a settlement or judgment in any litigation against the bonds’ issuers.
139. The promissory notes were to be subordinated to a purported $1 million
outstanding loan from Ocean Park Partners to Sovereign Debt Solutions.
140. As described above, Pendley and Scannell ceased pursuing litigation as a
means to redeeming the Historical Bonds in or about 2013, and the HAPS redemption
process did not exist.

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141. Therefore, Pendley and Scannell knew, or were reckless or negligent in
not knowing, that there was no realistic expectation of any investor being repaid or
receiving interest, given the improbability of a Liquidation Event ever occurring or
the resulting proceeds being enough to cover the purported loan from OPP.
142. At least eight existing Sovereign Debt Solutions’ investors in different
states entered into 28 promissory notes pursuant to which they paid a cumulative total
of $103,500 to SDS and received at least 41 limited partnership interests.
143. Scannell signed the notes on behalf of Sovereign Debt Solutions in his
role as president of Ocean Park Partners, SDS’ general partner.
144. The $103,500 was deposited into a bank account in the name of
Sovereign Debt Solutions, from which Pendley and/or Scannell, as officers of Ocean
Park Partners, directed the transfer of at least $50,500 to a bank account in OPP’s
name to pay business expenses.
145. No registration statement was filed with the Commission as to the offer
or sale of the promissory notes or the limited partnership interests, and neither
Pendley nor Scannell made any effort to determine whether any investor was an
accredited investor as defined by Rule 501 of Regulation D [17 C.F.R §230.501].
146. The promissory notes and the limited partnership interests are securities.
147. No exemption to the registration requirements applies to the issuance of
the promissory notes or the limited partnership interests.
148. Sovereign Debt Solutions has not repaid the principal nor any interest on
the promissory notes.
149. Pendley and Scannell each knew, or was reckless or negligent in not
knowing, that, in the sale or offer of a security or in connection with the sale of a
security, he employed a device, scheme, or artifice to defraud; made untrue
statements of a material fact or omitted to state material facts necessary to make those
statements that were made not misleading, and thereby obtained money or property;
and engaged in acts, practices, or courses of business which operated or would

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operate as a fraud or deceit on investors in connection with the sale of a security.
150. Pendley’s and Scannell’s scienter is imputable to Ocean Park Partners,
whose scienter is imputable to Sovereign Debt Solutions.
III. Fred Gladle and Pendley Acted as Unregistered Dealers
151. Fred Gladle and Pendley each engaged in the regular business of buying
and selling securities for his own account.
152. On his current LinkedIn page, Fred Gladle identifies himself as having
spent approximately twenty years working with buyers and sellers of
Historical Bonds
153. Tax return records further show that his principal source of income was
from the profits he made from the purchase and sale of Historical Bonds.
154. In or around late 2016, Fred Gladle placed his inventory of Historical
Bonds in the custody of HAPS.
155. As detailed above, during the Relevant Period, Fred Gladle sold
Historical Bonds to Pendley, whom Gladle knew was going to resell the Historical
Bonds to retail customers, and to a retail customer introduced to him by Pendley.
156. Like Fred Gladle, Pendley also developed a business of buying and
selling Historical Bonds.
157. In November 2023, Pendley gave sworn testimony that proceeds from
the purchase and sale of Historical Bonds had been his sole source of income the
prior five years.
158. Pendley purchased Historical Bonds from Fred Gladle and third parties,
using HAPS’ custodial services.
159. As detailed above, during the Relevant Period, Pendley sold Historical
Bonds to at least 55 investors.
160. Post-sale, both Pendley and Fred Gladle fielded investor inquiries.  For
example, Pendley fielded inquiries as to when investors could expect to receive
“Healing Funds” and redemption proceeds.  Fred Gladle assisted clients with gaining

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access to the HAPS portal.
161. During the Relevant Period, neither Fred Gladle nor Pendley was
registered with the Commission as a dealer, nor associated with any registered
broker-dealer.  Neither was eligible for an exemption from registration.
162. Therefore, Fred Gladle and Pendley acted as unregistered dealers.
FIRST CLAIM FOR RELIEF
Violations of Section 17(a) of the Securities Act
(Against Defendants Fred Gladle, Pendley, Scannell,
Sovereign Debt Solutions, and Ocean Park Partners)
163. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 150.
164. By engaging in the conduct described above, Defendants Fred Gladle,
Pendley, Scannell, Sovereign Debt Solutions, and Ocean Park Partners, directly or
indirectly, singly or in concert, in the offer or sale of securities, and by the use of
means or instruments of transportation or communication in interstate commerce or
by use of the mails: (a) knowingly or recklessly have employed one or more devices,
schemes, or artifices to defraud; (b) knowingly, recklessly, or negligently have
obtained money or property by means of one or more untrue statements of material
fact, or omissions of a material fact necessary in order to make the statements made,
in the light of the circumstances under which they were made, not misleading; and/or
(c) knowingly, recklessly, or negligently have engaged in one or more transactions,
practices, and courses of business which operated or would operate as a fraud or
deceit upon the purchaser.
165. By reason of the foregoing, Defendants Fred Gladle, Pendley, Scannell,
Sovereign Debt Solutions, and Ocean Park Partners, violated, and unless enjoined
will continue to violate, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].

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SECOND CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange and Rule 10b-5
(Against All Defendants)
166. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 150.
167. By engaging in the conduct described above, the Defendants, directly or
indirectly, singly or in concert, in connection with the purchase or sale of securities,
and by the use of means or instrumentalities of interstate commerce, or the mails, or
the facilities of a national securities exchange, knowingly or recklessly have: (a)
employed one or more devices, schemes, or artifices to defraud; (b) made one or
more untrue statements of material fact, or omitted to state one or more material facts
necessary to make the statements made, in the light of the circumstances under which
they were made, not misleading; and/or (c) engaged in one or more acts, practices, or
courses of business that operated or would operate as a fraud and deceit upon
other persons.
168. By reason of the foregoing, the Defendants violated, and unless
restrained and enjoined will continue to violate, Section 10(b) of the Exchange Act
[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Violations of Sections 5(a) and (c) of the Securities Act
(Against Defendants Pendley, Scannell,
Sovereign Debt Solutions, and Ocean Park Partners)
169. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 42, 45 through 48, and 124 through 150.
170. By engaging in the conduct described above, Defendants Pendley,
Scannell, Sovereign Debt Solutions, and Ocean Park Partners, without a registration
statement in effect as to the offer and sale of the promissory notes and limited
partnership interests referenced in paragraphs 136 through 150 above: (a) made use of

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the means and instruments of transportation or communications in interstate
commerce or of the mails to sell securities through the use of medium of any
prospectus or otherwise; (b) carried or caused to be carried through the mails or in
interstate commerce, by any means or instruments of transportation, any such security
for the purpose of sale or for delivery after sale; and (c) made use of the means and
instruments of transportation or communication in interstate commerce or of the
mails to offer to sell through the use or medium of a prospectus or otherwise,
securities as to which no registration statement was filed.
171. By reason of the foregoing, Pendley, Scannell, Sovereign Debt
Solutions, and Ocean Park Partners violated Sections 5(a) and 5(c) of the Securities
Act [15 U.S.C. §§ 77e(a) & 77e(c)].
FOURTH CLAIM FOR RELIEF
Aiding and Abetting Violations of Securities Act Section 17(a)
(Against Defendant Fred Gladle)
172. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 109.
173. Defendant Pendley, in the offer or sale of securities, and by the use of
means or instruments of transportation or communication in interstate commerce or
by use of the mails, directly or indirectly: (a) knowingly or recklessly had employed
one or more devices, schemes, or artifices to defraud; (b) knowingly, recklessly, or
negligently had obtained money or property by means of one or more untrue
statements of material fact, or omissions of a material fact necessary in order to make
the statements made, in the light of the circumstances under which they were made,
not misleading; and/or (c) knowingly, recklessly, or negligently had engaged in one
or more transactions, practices, and courses of business which operated or would
operate as a fraud or deceit upon the purchaser.
174. Defendant Gladle knowingly or recklessly provided substantial
assistance to Defendant Pendley with respect to his violations of Section 17(a) of the

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Securities Act by, among other things, knowingly or recklessly preparing purchase
agreements with false information that Pendley used to sell Historical Bonds.
175. By engaging in the conduct described above, Defendant Gladle aided
and abetted Pendley’s violations of Section 17(a) of the Exchange Act [15 U.S.C.
§ 78q(a)].
FIFTH CLAIM FOR RELIEF
Violations of Section 15(a)(1) of the Exchange Act
(Against Defendants Fred Gladle and Pendley)
176. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 42, 45 through 48, 59, 61, 89 through 106, 111 through 114,
117, 118, 121, 122, and 151 through 162.
177. By engaging in the conduct described above, Defendants Fred Gladle
and Pendley, directly or indirectly, by the use of the mails or any means or
instrumentality of interstate commerce effected transactions in, or induced or
attempted to induce the purchase or sale of securities, while they were not registered
with the Commission as a broker or dealer or when they were not associated with an
entity registered with the Commission as a broker-dealer.
178. By engaging in the conduct described above, Fred Gladle and Pendley
violated and, unless enjoined, will continue to violate Section 15(a)(1) of the
Exchange Act [15 U.S.C. § 78o(a)(1)].
SIXTH CLAIM FOR RELIEF
Violations of Rule 21F-17(a) of the Exchange Act
(Against Defendants C.W. Abshier and HAPS)
179. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 88.
180. By engaging in the conduct described above, Defendants C.W. Abshier
and HAPS, directly or indirectly, by the use of the mails or any means or
instrumentality of interstate commerce, took action to impede an individual from

COMPLAINT
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communicating directly with the Commission staff about a possible federal securities
law violation, or threatening to enforce a confidentiality agreement with respect to
such communications.
181. By engaging in the conduct described above, C.W. Abshier and HAPS
violated and, unless enjoined, will continue to violate Rule 21F-17(a) under the
Exchange [17 C.F.R. § 240.21F-17(a)].
SEVENTH CLAIM FOR RELIEF
Unjust Enrichment
(Against Relief Defendant Barbara Gladle)
182. The SEC re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 110.
183. Exchange  Act  Section 21(d)(5) [15 U.S.C. § 78u(d)(5)] states: “In any
action  or proceeding  brought  or  instituted  by  the  SEC  under  any  provision  of  the
securities laws,  the  SEC  may  seek,  and  any  Federal  court  may  grant,  any  equitable
relief that may be appropriate or necessary for the benefit of investors.”
184. As alleged in paragraphs 19, 93, 104, and 110, Relief Defendant Barbara
Gladle received the proceeds of unlawful activity to which she has no legitimate claim
and gave no consideration for exchange of those funds.
RELIEF REQUESTED
WHEREFORE, the Commission respectfully requests that this Court:
I.
 Issue findings of fact and conclusions of law that Defendants committed the
alleged violations.
II.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently enjoin Defendants Fred Gladle, Pendley, Scannell,
Sovereign Debt Solutions, and Ocean Park Partners from directly or indirectly
violating Securities Act Section 17(a) [15 U.S.C. § 77q(a) and all Defendants from

COMPLAINT
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directly or indirectly violating Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and
Exchange Act Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
III.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restrain and enjoin Defendants Pendley, Scannell,
Sovereign Debt Solutions, and Ocean Park Partners from directly or indirectly
violating Securities Act Sections 5(a) and (c) [15 U.S.C. §§ 77e(a) and 77e(c)].
IV.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restrain and enjoin Defendants Fred Gladle and
Pendley from directly or indirectly violating Exchange Act Section 15(a)(1) [15
U.S.C. § 78o(a)(1)].
V.
Issue Judgements, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restrain and enjoin Defendants C.W. Abshier and
HAPS from directly or indirectly violating Exchange Act Rule 21F-17(a) [17 C.F.R.
§ 240.21F-17(a)].
VI.
Permanently restrain and enjoin Defendants Fred Gladle, Pendley, Scannell,
C.W. Abshier, and Billy Abshier from directly or indirectly, including, but not
limited to, through any entity owned or controlled by each, participating in the
issuance, purchase, offer, or sale of any security; provided, however, that such
injunction shall not prevent each from purchasing or selling securities listed on a
national securities exchange for his own personal account.
VII.
Order Defendant Fred Gladle and Relief Defendant Barbara Gladle, on a joint
and several basis, and Defendants Pendley and Scannell to disgorge the ill-gotten
gains received because of the violations alleged in this Complaint, including

COMPLAINT
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prejudgment interest, 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)].
VIII.
Order Defendants Fred Gladle, Pendley, and Scannell to pay civil penalties
pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)] and Exchange Act
Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and order C.W. Abshier and Billy Abshier
to pay civil penalties pursuant to Exchange Act Section 21(d)(3).
                                                         IX.
Order that Defendants Fred Gladle, C.W. Abshier, Pendley, and Scannell be
permanently prohibited from serving as an officer or director of any company that has
a class of securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or
that is required to file reports under Exchange Act Section 15(d) [15 U.S.C. §
78o(d)], pursuant to Securities Act Section 20(e) [15 U.S.C. § 77t(e)] and Exchange
Act Section 21(d)(2) [15 U.S.C. § 78u(d)(2)].
X.
Granting such other and further relief as the Court determines to be necessary and
appropriate.
Dated:  December 13, 2024
 /s/ Douglas M. Miller
Douglas M. Miller
Oren Gleich (pro hac vice pending)
Attorneys for Plaintiff
Securities and Exchange Commission

COMPLAINT

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OREN GLEICH (NY Bar No. 4460135) pro hac vice pending 

Email: [email protected] 

DOUGLAS M. MILLER (Cal. Bar. No. 240398) (Local Counsel) 

Email: [email protected] 

Attorneys for Plaintiff 

Securities and Exchange Commission 

100 Pearl Street, Suite 20-100 

New York, NY 10004-2616 

Email: [email protected] 

Telephone: (212) 336-0190 / Fax: (212) 336-1319 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

vs. 

HISTORIC ASSET PLACEMENT SERVICES 

GLOBAL, LLC, CHRISTOPHER W. 

ABSHIER, BILLY W. ABSHIER, FREDERIC 

A. GLADLE, RONALD JOSH PENDLEY,

KEVIN E. SCANNELL, SOVEREIGN DEBT

SOLUTIONS, LP, AND OCEAN PARK

PARTNERS,

Defendants, and 

BARBARA GLADLE, 

 Relief Defendant. 

Case No. 2:24-cv-10745 

COMPLAINT 

DEMAND FOR JURY TRIAL 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 1 of 32   Page ID #:1



 

COMPLAINT 2  

 

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

follows: 

JURISDICTION AND VENUE 

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

20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. 

§§ 77t(b), 77t(d)(1) & 77v(a)] and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of 

the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d)(1), 

78u(d)(3)(A), 78u(e) & 78aa(a)]. 

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

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

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

business alleged in this complaint.  

3. Venue is proper in this Court pursuant to Securities Act Section 22(a) 

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

practices and courses of business constituting violations alleged herein have occurred 

within the jurisdiction of the United States District Court for the Central District of 

California, including the solicitation of investors, many of whom reside in 

this District.  

4. In addition, venue is proper in this district because Defendants Ronald 

Josh Pendley (“Pendley”) and Kevin E. Scannell (“Scannell”) reside in this district 

and Defendants Sovereign Debt Solutions, LP (“Sovereign Debt Solutions” or 

“SDS”) and Ocean Park Partners (“OPP”) have their principal places of business in 

this District. 

SUMMARY 

5. This civil enforcement action concerns the fraudulent offer and sale of 

defaulted and unredeemed bonds issued by the German Weimar Republic and certain 

German utilities and by the governments of pre-revolutionary Russia and China (the 

“Historical Bonds”).  This action also involves the fraudulent and unregistered offer 

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and sale of promissory notes and limited partnership interests, the value of which was 

tied to such Historical Bonds.  As part of the fraudulent scheme, the Defendants 

promoted a fictitious redemption process for Historical Bonds which falsely claimed 

that investors would receive proceeds of up to $15 million for their bonds with an 

advance payment of $250,000.  In reality, this purported redemption process was a 

sham, no advance payment of $250,000 was ever made, and no Historical Bonds 

were ever redeemed.  In all, the fraud raised at least $3.85 million from at least 85 

investors between January 2017 and August 2023 (the “Relevant Period”).  The 

fraudulent scheme worked in three parts. 

6. First, the Defendants Historical Asset Placement Services Global, LLC 

(“HAPS”), its managing member Christopher W. Abshier (“C.W. Abshier”), and 

C.W. Abshier’s father and the day-to-day operations manager of HAPS, Billy W. 

Abshier (“Billy Abshier” or, together with C.W. Abshier, the “Abshiers”) 

(collectively the “HAPS Defendants”) offered custodial services in which HAPS 

would hold and safeguard its customers’ Historical Bonds.  They also offered 

purported redemption services through which HAPS would monetize the 

Historical Bonds.  

7. In connection with these services, the HAPS Defendants offered 

commissions to affiliates to solicit customers to use HAPS’ services.  The HAPS 

Defendants claimed that these commissions would be paid from the proceeds of the 

Historical Bonds once they were monetized.  

8. The HAPS Defendants told their affiliates and clients materially false 

information about their fictitious redemption process.  These materially false 

statements included that the redemption process involved the participation of the U.S. 

and foreign governments, and well-known financial institutions and accounting firms.  

The HAPS Defendants claimed further that the redemption process would result in a 

“global currency reset” that various national governments were negotiating which 

would result in most, if not all, countries using currencies backed by assets such as 

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Historical Bonds.  The HAPS Defendants also promised investors a $250,000 

advance on the redemption value of each investor’s Historical Bonds.  These 

representations were completely false, and no such redemption process existed.  

Investors never received any advances on the supposed redemption value of their 

Historical Bonds, and none were ever redeemed.   

9. The HAPS Defendants knew, or were reckless in not knowing, that those 

soliciting HAPS clients repeated the HAPS Defendants’ false representations 

regarding the purported redemption process for the Historical Bonds in their custody. 

10. Second, Defendants Frederic A. Gladle (“Fred Gladle”) and Relief 

Defendant Barbara Gladle (collectively, the “Gladles”), and Defendants Pendley and 

Scannell each acquired Historical Bonds, which they placed in the custody of HAPS 

prior to resale to third parties.  During the Relevant Period, the Gladles purchased and 

sold Historical Bonds to Pendley and at least one retail customer; Pendley resold the 

bonds he purchased from the Gladles and others to retail customers.  Fred Gladle 

aided and abetted some of these sales.  Scannell likewise sold Historical Bonds to 

retail customers.    

11. In effecting or, in the case of Fred Gladle, aiding and abetting the resales 

of Historical Bonds, Fred Gladle, Pendley, and Scannell referenced HAPS’ 

custodianship of the bonds and repeated the HAPS Defendants’ false claims about the 

redemption process to investors.  In some cases, they embellished the HAPS 

Defendants’ falsehoods with their own falsehoods.   

12. Fred Gladle, Pendley, and Scannell knew of the existing governments’ 

longstanding refusal to payout on the bonds and the adverse decisions in court actions 

to recover on the bonds.  

13. Fred Gladle, Pendley, and Scannell each knew, or was reckless or 

negligent in not knowing, that their statements to investors were materially false or 

omitted material information which made the statements materially misleading.   

14. Third, Pendley and Scannell, through Sovereign Debt Solutions, and its 

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general partner, Ocean Park Partners, of which Pendley and Scannell were officers, 

perpetrated a related scheme involving the unregistered and fraudulent offer and sale 

of promissory notes and limited partnership interests issued thereunder, the value of 

which was tied to certain Historical Bonds.  Through OPP, they directed SDS to 

solicit existing SDS limited partners to enter into the promissory notes with SDS.  

15. These notes purported to provide investors with 10% interest on the 

principal as well as limited partnership interests in Sovereign Debt Solutions.  

Payment on these notes and the value of the limited partnership interests depended 

entirely on the redemption of Historical Bonds owned by SDS, and for which HAPS 

provided custodial and purported redemption services.   

16. Prior to their soliciting Sovereign Debt Solutions’ limited partners to 

purchase the promissory notes, Pendley and Scannell had plied the limited partners 

for years with the same HAPS Defendants’ lies about the HAPS redemption process, 

which Pendley and Scannell further embellished with their own falsehoods.  

17. The promissory notes and Sovereign Debt Solutions’ limited partnership 

interests were securities.  No registration statement was filed with the Commission 

with respect to their offer and/or sale and no exemption from registration applies.  

18. Pendley and Scannell each knew, or was reckless or negligent in not 

knowing, that the statements regarding the HAPS redemption process that they made 

to the Sovereign Debt Solutions limited partners to induce them to purchase the 

promissory notes were materially false or omitted material information which made 

the statements materially misleading. 

19. Together, the Defendants’ schemes raised at least $3.85 million from at 

least 85 investors located in several states, including California, Florida, Michigan, 

Texas, and Virginia, all of whom lost the entirety of their investments.  Of those 

proceeds raised, at least $1.74 million were routed to the bank account of Relief 

Defendant Barbara Gladle, who had no legitimate claim and gave no consideration in 

exchange for these proceeds.  

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COMPLAINT 6  

 

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20. By engaging in the conduct alleged in this Complaint:   

a. Defendants violated and, unless restrained and enjoined, will violate  

again, Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 

10b-5 thereunder [17 C.F.R. § 240.10b-5];  

b. Fred Gladle, Pendley, Scannell, Sovereign Debt Solutions, and Ocean 

Park Partners violated Securities Act Section 17(a) [15 U.S.C. 

§ 77q(a)]; 

c. Pendley, Scannell, Sovereign Debt Solutions, and Ocean Park 

Partners violated Securities Act Sections 5(a) and (c) [15 U.S.C. 

§§77e(a) and (c)]; 

d. Fred Gladle aided and abetted Pendley’s violations of Securities Act 

Section 17(a); 

e. Fred Gladle and Pendley violated Exchange Act Section 15(a)(1) [15 

U.S.C. § 78o(a)(1)] by acting as unregistered dealers; and 

f. C.W. Abshier and HAPS violated Rule 21F-17(a) under the 

Exchange Act [17 C.F.R. § 240.21F-17(a)]. 

21. The Commission seeks entry of a final judgment:  

a. imposing permanent injunctions against each of the Defendants for 

their respective violations of the federal securities laws;  

b. ordering Fred Gladle, Pendley, Scannell, C.W. Abshier, and Billy 

Abshier to each pay civil monetary penalties; 

c. permanently enjoining Fred Gladle, Pendley, Scannell, C.W. Abshier, 

and Billy Abshier from directly or indirectly, including, but not 

limited to, through any entity owned or controlled by each, 

participating in the issuance, purchase, offer, or sale of any security; 

provided, however, that such injunction shall not prevent each from 

purchasing or selling securities listed on a national securities 

exchange for their own personal account; 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 6 of 32   Page ID #:6



 

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d. ordering Fred Gladle and Barbara Gladle, on a joint and several basis, 

Pendley, and Scannell to pay disgorgement and prejudgment interest; 

and 

e. prohibiting Pendley, Scannell, Fred Gladle, and C.W. Abshier from 

serving as an officer or director of a public company.  

TOLLING AGREEMENTS 

22. HAPS and the SEC entered into tolling agreements suspending the 

running of any applicable statute of limitations from March 28, 2024 through 

September 28, 2024, and from September 29, 2024 through November 29, 2024. 

23. C.W. Abshier and the SEC entered into tolling agreements suspending 

the running of any applicable statute of limitations from March 28, 2024 through 

September 28, 2024, and from September 29, 2024 through November 29, 2024. 

24. Billy Abshier and the SEC entered into a tolling agreement suspending 

the running of any applicable statute of limitations from September 30, 2024 through 

November 29, 2024. 

25. Fred Gladle and the SEC entered into a tolling agreement and two tolling 

agreement extensions suspending the running of any applicable statute of limitations 

from February 6, 2024 through November 29, 2024. 

26. Pendley and the SEC entered into tolling agreements suspending the 

running of any applicable statutes of limitations from January 31, 2024 through July 

31, 2024, and from August 1, 2024 through October 7, 2024. 

27. Scannell and the SEC entered into tolling agreements suspending the 

running of any applicable statute of limitations from January 31, 2024 through July 

31, 2024, and from August 1, 2024 through October 7, 2024. 

28. Barbara Gladle and the SEC entered into a tolling agreement and two 

tolling agreement extensions suspending the running of any applicable statute of 

limitations from February 6, 2024 through November 29, 2024. 

 

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DEFENDANTS 

29. HAPS is a Nevada LLC initially formed in September 2010 and 

reformed in Wyoming in December 2021.  During the Relevant Period up to the 

present, its principal place of business has been Temple, Texas. 

30. C.W. Abshier, age 45, resides in Troy, Texas.  He served as the 

managing member of HAPS during the Relevant Period up to at least early 2024. 

31. Billy Abshier, age 68, resides in Temple, Texas and is C.W Abshier’s 

father.  He served as HAPS’ day-to-day operations manager during the 

Relevant Period. 

32. Fred Gladle, age 65, resides in Lakeway, Texas.  During the Relevant 

Period through the present, he has been married to Barbara Gladle.  During the 

Relevant Period, he was not registered with the Commission in any capacity.  He 

previously held Series 7, 22, 24, and 63 licenses and was associated with a series of 

registered broker-dealers from November 1985 through 1997.  

33. In 2004, a federal district court entered a consent judgment against Fred 

Gladle permanently enjoining him from violating the antifraud, unregistered 

securities offering and broker-dealer registration provisions of the federal securities 

laws and ordering him to pay $100,000 in disgorgement and prejudgment interest and 

civil penalties of $57,000, stemming from his allegedly having engaged in fraudulent 

and unregistered sales of securities while acting as an unregistered broker-dealer.  See 

SEC v. Internet Telecommunications Albany System SMR, et al., 1:99-cv-539 (CKK) 

(D.D.C. March 2, 1999).  Fred Gladle has not paid the monetary relief to date. 

34. Based on this permanent injunction, the Commission instituted a settled 

administrative proceeding barring Fred Gladle from associating with a broker or 

dealer with a right to reapply for association after five years.  See In the Matter of 

Frederic A. Gladle, Admin Proc. File No. 3-11546 (July 14, 2004).  

35. Pendley, age 59, resides in Burbank, California.  He co-founded 

Sovereign Debt Solutions and Ocean Park Partners and has served as OPP’s secretary 

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during the Relevant Period up to the present.  During the Relevant Period, he was not 

registered with the Commission in any capacity.  He previously held Series 7 and 63 

licenses and was associated with a series of registered broker-dealers from October 

1989 through December 1998. 

36. Scannell, age 59, resides in Santa Monica, California.  He co-founded 

Sovereign Debt Solutions and Ocean Park Partners and has served as OPP’s president 

during the Relevant Period up to the present.  During the Relevant Period, he was not 

registered with the Commission in any capacity.  He previously held Series 7, 24, 63, 

and 65 licenses and was associated with a series of registered broker-dealers from 

July 1987 through December 2000. 

37. Sovereign Debt Solutions is a Nevada limited partnership organized by 

Pendley and Scannell in Nevada in April 2008.  During the Relevant Period up to the 

present, it has maintained its principal place of business in Los Angeles, California. 

38. Ocean Park Partners is a private company incorporated by Pendley 

and Scannell in Nevada in September 2007.  It is the general partner of SDS.  During 

the Relevant Period up to the present, it has maintained its principal place of business 

in Los Angeles, California. 

RELIEF DEFENDANT 

39. Barbara Gladle, age 64, resides in Lakeway, Texas.  During the 

Relevant Period through the present, she was married to Fred Gladle.  During the 

Relevant Period, she was not registered with the Commission in any capacity. 

FACTS 

I. The Historical Bond Scheme 

A. The Historical Bonds 

40. The Historical Bonds at issue are predominantly dollar-denominated 

bearer bonds issued in the 1920s by the German Weimar Republic and certain 

German utilities.  Since the 1950s, the German government has generally disavowed 

responsibility for these bonds.   

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41. The Historical Bonds sold to investors also include “Super Petchili” 

bonds, which the Chinese government issued in the 1910s, and various railroad bonds 

the Russian government issued at the end of the 19th century and in the first years of 

the 20th century.  After the 1949 Communist takeover in China and the 1917 Russian 

Revolution, the governments of those countries consistently refused to recognize 

the debt. 

42. The Historical Bonds in this matter were offered and sold as securities.  

B. HAPS’ Structure and Efforts to Find Clients 

43. HAPS was formed in 2010.   

44. During the Relevant Period, C.W. Abshier served as HAPS’ sole 

managing member and Billy Abshier—C.W. Abshier’s father—managed HAPS’ 

daily operations.  

45. HAPS offered its customers a custodial service in which it would hold 

and safeguard its customers’ Historical Bonds.  

46. HAPS also promoted a purported redemption service in which it would 

monetize the Historical Bonds.  

47. To entice clients to use their services, the HAPS Defendants made 

materially false representations that HAPS’ clients would receive a $250,000 cash 

advance before the purported full value of the Historical Bonds was monetized.    

48. HAPS created a name for this purported advance payment, describing it 

as “Healing Funds.”   

49. To get more customers, HAPS represented that it would pay 

commissions to individuals responsible for recruiting clients.    

50. HAPS represented that it would fund these commissions by retaining 5% 

of the redemption proceeds of the Historical Bonds.  

51. HAPS and the Abshiers knew, or were reckless in not knowing, that 

those individuals who solicited customers for HAPS (“HAPS affiliates”), including 

Fred Gladle, Pendley, and Scannell, also sold Historical Bonds. 

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52. HAPS and the Abshiers knew, or were reckless in not knowing, that the 

HAPS affiliates induced prospective customers to buy Historical Bonds and to apply 

to become HAPS members by promoting the HAPS redemption services, including 

the $250,000 in “Healing Funds.”   

53. During the Relevant Period, HAPS generally required each prospective 

client to complete a “New Member Application,” provide supporting paperwork, and 

enter into a “Non-Circumvention and Non-Disclosure Agreement” (“NCNDA”). 

54. The New Member Application and NCNDA expressly referenced the 

purported redemption process. 

55. The NCNDA required the prospective client to agree not to 

communicate anything about the redemption process to third parties.   

56. These forms were available for HAPS Affiliates to distribute to 

prospective HAPS customers. 

57. For example, when Pendley sold Historical Bonds and recruited investor 

customers for HAPS, he provided these customers with the New Member Application 

and NCNDA.  These investors then submitted the forms to HAPS, with many noting 

in the New Member Application that Pendley had referred them to HAPS.     

58. HAPS maintained an internal database for tracking changes in ownership 

of bonds in its custody.   

59. The HAPS Defendants were put on notice of changes in ownership of 

Historical Bonds that were held in their custody through the receipt of New Member 

Applications and related paperwork. 

60. Through New Member Applications and related paperwork, the HAPS 

Defendants knew, or were reckless in not knowing, that Fred Gladle, Pendley, and 

Scannell sold Historical Bonds while also recruiting HAPS clients.   

61. In addition to the New Member Applications and associated 

communications, Fred Gladle corresponded with the HAPS Defendants in October 

2022 about Pendley and his interest in selling a sizeable block of Historical Bonds in 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 11 of 32   Page ID #:11



 

COMPLAINT 12  

 

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HAPS’ custody to a third party and inquired if HAPS was willing to take on the buyer 

as a new client.   

62. Accordingly, through the New Member Application forms and the 

associated communications, as well as the correspondence with Fred Gladle, the 

HAPS Defendants knew, or were reckless in not knowing, that when Fred Gladle, 

Pendley, and Scannell sold Historical Bonds to new investors, they conveyed the 

HAPS Defendants’ material misrepresentations regarding the purported 

redemption process. 

C. The HAPS Defendants’ Misrepresentations to Investors 

63. The Abshiers communicated with HAPS affiliates about the redemption 

process in a number of ways.  

64. Throughout the Relevant Period, C.W. Abshier communicated with 

HAPS affiliates and certain HAPS clients via a HAPS-maintained electronic portal 

(the “Portal”) to which HAPS granted access selectively.   

65. C.W. Abshier would either draft and post himself, or direct Billy 

Abshier to draft and post based on notes C.W. Abshier provided to him.   

66. C.W. Abshier controlled the substance of all communications posted to 

the Portal.   

67. During the Relevant Period, Billy Abshier also communicated with 

investors about the redemption process during in-person meetings and via telephone.   

68. In July 2017, C.W. Abshier posted communications to the Portal that 

broadly outlined the entire purported HAPS redemption process.  In these 

communications, C.W. Abshier disseminated, among other things, the following false 

statements to investors concerning the Historical Bonds: 

a. once HAPS takes custody of a client’s bonds, it transports them by a 

United States government diplomatic jet to a bank in Hong Kong; 

b. the bonds are reviewed and authenticated in Hong Kong;  

c. once the bonds are authenticated, a “Redemption Platform” housed 

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COMPLAINT 13  

 

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within a second Hong Kong bank would route funds into a 

“paymaster account” for the benefit of HAPS’ clients; 

d. HAPS’ redemption efforts would culminate in a “global currency 

reset” that various national governments were purportedly 

negotiating; and  

e. this reset would move most, if not all, countries from using fiat-based 

currencies to currencies backed by assets such as gold and Historical 

Bonds. 

69. Throughout the Relevant Period, with slight variations, the Abshiers 

disseminated to their affiliates and clients the same false information about the 

purported redemption process as was in the July 2017 postings to the Portal.   

70. For example, on or about March 3, 2022, during an in-person meeting in 

Temple, Texas, Billy Abshier told Pendley, among other things, the following false 

information: (a) that the U.S. military transports bonds from HAPS to Hong Kong; 

and (b) the Redemption Platform had generated enough funds to pay off “the debt of 

the world.”   

71. During the Relevant Period, Billy Abshier also told Pendley that the U.S. 

Department of the Treasury was involved in the redemption process, but that Billy 

Abshier could not elaborate further as HAPS was subject to a non-disclosure 

agreement with the Treasury Department.   

72. As described more fully below, Pendley, who was formerly a licensed 

and trained securities professional, used the HAPS misstatements to sell Historical 

Bonds to unsuspecting investors.  Pendley knew, or was reckless or negligent in not 

knowing, that these HAPS misstatements were materially false.   

73. As noted, the Abshiers also falsely claimed throughout the Relevant 

Period that each HAPS client would receive an advance on the ultimate final 

redemption value of their bonds in the amount of $250,000, which they termed 

Healing Funds. 

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COMPLAINT 14  

 

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74. Both immediately prior to and throughout the Relevant Period, C.W. 

Abshier gave repeated false assurances to HAPS affiliates and clients that the 

disbursal of these “Healing Funds” to HAPS clients was imminent, examples of 

which include the following: 

a. On November 4, 2016, C.W. Abshier posted this message on the 

Portal: “We were advised that we can expect to see the release and 

authorization to disburse [Healing Funds] not long after the [2016 

U.S. presidential] election takes place.” 

b. On January 6, 2017, C.W. Abshier posted this message on the Portal: 

“Some of the disinformation currently being propagated is that this 

[redemption of Historical Bonds] could be pushed off to this summer, 

and even a couple of people have been told that we won’t see 

anything before 2018 at the earliest.  THAT, folks, is NOT what we 

are being told! … [T]he process has moved way too far forward to be 

halted now.  We have passed the point-of-no-return in this process.” 

c. On October 23, 2020, C.W. Abshier posted this message on the 

Portal: “Our representative is currently in HK [Hong Kong], he was 

told to travel in order to receive the funds, and we are told he will 

come back with the Healing Funds in the paymaster account in the 

next few days.” 

d. On December 30, 2022, C.W. Abshier posted this message on the 

Portal: “We continue to receive good news and can share that great 

progress was made throughout the holidays toward approval for 

release of Healing Funds.” 

75. During an in-person meeting at HAPS’ office in Temple, Texas on or 

around March 3, 2022, Billy Abshier falsely represented to Pendley that the Healing 

Funds had actually arrived.  Billy Abshier declined to show Pendley any 

documentation or account statements to verify that statement. 

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COMPLAINT 15  

 

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76. In a December 2021 email to Scannell, C.W. or Billy Abshier falsely 

stated that the Healing Funds “are here and are mine” but could not yet be disbursed.  

This was false. 

77. Like Pendley, Scannell was also a formerly licensed and trained 

securities professional who used the HAPS misstatements to sell Historical Bonds to 

unsuspecting investors.  Scannell knew, or was reckless or negligent in not knowing, 

that these HAPS misstatements were materially false. 

78. By early 2023, C.W. Abshier generally stopped promising the imminent 

arrival of the Healing Funds via the Portal, asking HAPS clients to join him in 

trusting “God’s timing and delivery” and stating that he cannot give any further 

updates on the bonds because he is under a “gag order” of an unspecified source. 

79. Contrary to the HAPS Defendants’ representations, the above-described 

HAPS redemption process did not exist, and the so-called “Healing Funds” were 

never distributed.  

80. Beyond requiring throughout the Relevant Period that a prospective 

client enter into an NCNDA stating that the client will not share information about 

HAPS, C.W. Abshier and HAPS sought to curtail and control clients’ access to and 

sharing of information in other ways.   

81. For example, throughout the Relevant Period, HAPS periodically 

warned its clients that their accounts would be suspended if they attempted to copy 

the updates posted to the Portal. 

82. Further, periodic updates that C.W. Abshier posted or had posted to the 

Portal were initially archived on the Portal and accessible to those to whom HAPS 

granted Portal access.  In or around 2020, however, C.W. Abshier directed the 

removal of the archived updates and that each new update be deleted and made 

inaccessible to a client after he or she reviewed it.   

83. Beginning in March 2023, C.W. Abshier directed HAPS to take the 

added step of demanding that certain existing and new clients, who wanted access to 

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COMPLAINT 16  

 

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the Portal, sign an affidavit affirming that they had “not lodged any complaints nor 

grievances with the SEC, FBI, or any other regulatory and/or law enforcement 

agency” and promising to “not file, nor participate in any legal action against HAPS 

Global… and its affiliates, members, managers, officers, directors, employees, 

agents, attorneys, staff, volunteers, representatives, predecessors and successors.” 

84. At least 22 investors, of which 18 had purchased Historical Bonds from 

Pendley, executed the affidavit and submitted them to HAPS. 

85. By demanding that clients sign this affidavit, C.W. Abshier and HAPS, 

took action to impede the HAPS’ clients from communicating directly with the SEC 

about possible federal securities law violations.  

86. The HAPS Defendants continued to periodically post materially false 

and misleading updates to the Portal throughout the Relevant Period in an effort to 

lull investors.     

87. The HAPS Defendants knew, or were reckless in not knowing, that each 

employed a device, scheme, or artifice to defraud; made untrue statements of a 

material fact or omitted to state material facts necessary to make those statements that 

were made not misleading; and engaged in acts, practices, or courses of business 

which operated or would operate as a fraud or deceit on investors in connection with 

the sale of a security.   

88. C.W. Abshier’s scienter is imputed to HAPS as its managing member. 

D. Fred Gladle Sold Historical Bonds In Furtherance of the Scheme 

89. The Gladles’ principal business activity and primary source of income 

during the Relevant Period came from buying and selling Historical Bonds.   

90. Fred Gladle and Barbara Gladle each listed his or her occupation as 

“Historic Document Reseller” in their joint federal tax returns for calendar years 2020 

and 2021.  

91. Fred Gladle has been buying and selling Historical Bonds for at least 20 

years despite knowing of the existing governments’ longstanding refusal to payout on 

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COMPLAINT 17  

 

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the Historical Bonds and adverse decisions in court actions to recover on the 

Historical Bonds. 

92. During the Relevant Period, the Gladles sold Historical Bonds from their 

inventory, which they maintained with HAPS, to among others, Pendley.   

93. During the Relevant Period, Pendley paid at least $837,000 to a bank 

account in Barbara Gladle’s name.  

94. Fred Gladle knew throughout the Relevant Period that Pendley 

purchased Historical Bonds from the Gladles for purposes of resale to retail investors.   

95. At Pendley’s request, Fred Gladle prepared purchase agreements for 

Pendley’s use in selling Historical Bonds to investors, using a template purportedly 

obtained from Pendley.  

96. For example, Fred Gladle prepared purchase agreements that Pendley 

used to sell at least 30 Historical Bonds to at least two investors for at least $190,000 

in 2019 and 2020. 

97. The purchase agreements prepared by Fred Gladle to sell 30 Historical 

Bonds falsely stated that the bonds had been “authenticated” and had “legal claim 

values that are hundreds of times more than the purchase price being paid.”  These 

false claims were made without disclosing the existing governments’ longstanding 

refusal to payout on the bonds and the adverse decisions in court actions to recover 

on the bonds.  

98. During the Relevant Period, Fred Gladle also emailed HAPS on behalf 

of at least three of Pendley’s clients to ask HAPS to grant them access to the Portal, 

facilitating the clients’ direct access to HAPS’ lulling statements.   

99. From March 2019 through May 2019, the Gladles also effected a series 

of bond sales totaling $910,000 to an investor (“Investor A”) from their inventory 

using similarly-worded purchase agreements.  

100. Initially structured as a direct sale from the Gladles to Investor A, in 

relation to which Fred Gladle prepared a purchase agreement signed by Barbara 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 17 of 32   Page ID #:17



 

COMPLAINT 18  

 

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Gladle but never fully executed, the transaction was ultimately restructured to have 

the Gladles engage in a series of sales to a middleman, who was Pendley’s associate, 

(“Associate A”), who then sold the bonds to Investor A.  

101. Fred Gladle prepared at least one agreement for Barbara Gladle’s 

signature memorializing the sale of bonds from the Gladles’ inventory to Associate 

A, which Barbara signed and emailed to Pendley and Associate A for the 

latter’s execution.   

102. Fred Gladle also prepared at least two agreements relating to Associate 

A’s resale of the bonds to Investor A, with Barbara Gladle and Fred Gladle each 

emailing one of the two agreements to Pendley and/or Associate A.   

103. All of these agreements Fred Gladle prepared falsely represented that the 

bonds, for which HAPS served as custodian, had “legal claim values that are 

hundreds of times more than the purchase price being paid,” without disclosing the 

existing governments’ longstanding refusal to payout on the bonds and the adverse 

decisions in court actions to recover on the bonds.  

104. Associate A wired the $910,000 total purchase price that he received 

from Investor A to a bank account in Barbara Gladle’s name, from which the Gladles 

paid “commissions” to Pendley and Associate A in the amounts of $315,135 and 

$268,369, respectively, retaining $326,496. 

105. At the time of the foregoing sales, the Gladles resided in Texas and 

Pendley, the Associate A, and Investor A resided in California.  

106. The Gladles never sought to verify the HAPS redemption process or 

whether any bond had a legal claim value hundreds of times more than the purchase 

price paid. 

107. As a formerly licensed and trained securities professional, Fred Gladle 

knew, or was reckless or negligent in not knowing, that the HAPS redemption 

process was fraudulent.          

108. Fred Gladle knew, or was reckless or negligent in not knowing, that, in 

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COMPLAINT 19  

 

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the sale or offer of a security or in connection with the sale of a security, he employed 

a device, scheme, or artifice to defraud; made untrue statements of a material fact or 

omitted to state material facts necessary to make those statements that were made not 

misleading, and thereby obtained money or property; and engaged in acts, practices, 

or courses of business which operated or would operate as a fraud or deceit on 

investors in connection with the sale of a security. 

109. By knowingly or recklessly providing substantial assistance to Pendley 

by preparing for Pendley’s use in selling Historical Bonds, purchase agreements that 

contained false information, or omitted material information that made those 

statements that were made materially misleading, Fred Gladle aided and abetted 

Pendley’s violations of Section 17(a) of the Securities Act. 

110. Barbara Gladle received ill-gotten gains into a bank account held in her 

name, as stated above, to which she does not have a legitimate claim, and which was 

subject to use by both Fred Gladle and Barbara Gladle.  

E. Pendley’s Fraudulent Sales of Historical Bonds 

111. During the Relevant Period, Pendley raised at least $2.46 million from at 

least 55 investors in multiple U.S. states through fraudulent offerings and sales of 

Historical Bonds from his own inventory for which HAPS served as custodian.  

112. Pendley’s principal business activity and sole source of income during 

the Relevant Period were from his purchase and sale of Historical Bonds.   

113. To sell the Historical Bonds, Pendley cultivated a clientele among his 

friends and associates.  These included members of a golf club located in Burbank, 

California to which he belonged during the Relevant Period.  

114. Pendley induced investors to purchase the Historical Bonds, which he 

typically sold for $5,000 each, by making material misstatements or omitting material 

information which made those statements which were made materially misleading, 

some of which originated with HAPS and the Abshiers and others of which 

Pendley devised. 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 19 of 32   Page ID #:19



 

COMPLAINT 20  

 

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115. Among the material misrepresentations Pendley made during the 

Relevant Period to multiple investors were the following:  

a. HAPS had a redemption process in place for the Historical Bonds; 

b. The return per bond would be in the range of $5 million to 

$15 million;  

c. Internationally known accounting firms specifically named by 

Pendley were involved in facilitating investor payouts;  

d. Each bondholder would receive $250,000 in Healing Funds within 

months of the bond purchase; and  

e. The SEC, FBI, and Department of Homeland Security were all aware 

of the redemption process and would be monitoring clients’ accounts. 

116. In addition to the foregoing material misrepresentations communicated 

to multiple investors, Pendley also made the following material misrepresentations to 

individual investors:   

a. On June 30, 2019, Pendley told an investor that Pendley had 

“personally verified bank statements in HAPS’ name”; 

b. On July 3, 2019, Pendley told an investor that “HAPS has sufficient 

funds to cover [$250,000 in Healing Funds] for over 30,000 client 

accounts”; and   

c. On September 20, 2021, Pendley told an investor that, “[t]he State 

Department has completed its database findings of the 50K HAPS 

clients and have [sic] cleared the path for deposit distributions.” 

117. Pendley also presented at least 41 investors with a bond purchase 

agreement which falsely represented that “the bond [or bonds] being transferred has 

legal claim values that are hundreds of times more than the purchase price being 

paid,” without disclosing the existing governments’ longstanding refusal to payout on 

the bonds and adverse decisions in court actions to recover on the bonds.  

118. Of the 41 investors, at least 16 were repeat customers of Pendley’s.  

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 20 of 32   Page ID #:20



 

COMPLAINT 21  

 

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119. As a formerly licensed and trained securities professional, Pendley 

knew, or was reckless or negligent in not knowing, that the statements he repeated 

regarding the HAPS redemption process were materially misleading. 

120. Pendley further falsely represented to several investors that he did not 

retain any proceeds from bond sales and that he transferred all proceeds he received 

to HAPS.   

121. Other than paying those from whom he purchased Historical Bonds, 

including the Gladles, Pendley retained the remaining funds and used them on 

personal expenses such as his golf club membership and his children’s 

college tuition. 

122. Contemporaneous with each bond sale, Pendley typically provided to 

each investor a HAPS New Member Application and NCNDA and directed the 

investor to complete both and send them directly to HAPS.  Once approved, this 

would result in HAPS changing the name of the bondholder on its records from 

Pendley to the investor and granting the investor access to the Portal. 

123. Pendley knew, or was reckless or negligent in not knowing, that, in the 

sale or offer of a security or in connection with the sale of a security, he employed a 

device, scheme, or artifice to defraud; made untrue statements of a material fact or 

omitted to state material facts necessary to make those statements that were made not 

misleading, and thereby obtained money or property; and engaged in acts, practices, 

or courses of business which operated or would operate as a fraud or deceit on 

investors in connection with the sale of a security.  

F. Scannell’s Fraudulent Sales of Historical Bonds 

124. Scannell primarily sold Historical Bonds to preexisting investors in 

Sovereign Debt Solutions, which he had formed with Pendley in 2008 as a vehicle for 

pooling Historical Bonds for liquidation. 

125. Beginning in 2008, Pendley and Scannell, via Sovereign Debt Solutions’ 

general partner Ocean Park Partners, directed SDS’ sale of limited partnership 

Case 2:24-cv-10745     Document 1     Filed 12/13/24     Page 21 of 32   Page ID #:21



 

COMPLAINT 22  

 

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interests in SDS in exchange for Historical Bonds, claiming that they planned to 

pursue litigation against the successors of German utility companies which issued the 

bearer bonds and, alternatively, pursue “direct negotiations” with the 

German government. 

126. By 2013, they had ceased all litigation efforts due to other bondholders’ 

unsuccessful lawsuits.   

127. At that time, Pendley and Scannell touted the HAPS redemption process 

to the Sovereign Debt Solution’s limited partners, and with their knowledge, placed 

all of SDS’ Historical Bonds with HAPS.  

128. Pendley and Scannell thereafter regularly provided summaries of HAPS’ 

misleading Portal updates to the Sovereign Debt Solutions’ limited partners. 

129. Additionally, between April 2017 and June 2022, Scannell sold 

Historical Bonds from his own inventory to at least 29 of the Sovereign Debt 

Solutions limited partners located in different states, raising at least $374,000.   

130. Scannell made these sales after having plied the Sovereign Debt 

Solutions’ nearly 100 limited partners for years with false information about the 

HAPS redemption process.  

131. Scannell’s principal business activity and primary source of income from 

April 2017 through June 2022 were his sales of Historical Bonds. 

132. The purchase agreements that Scannell used in his bond sales falsely 

stated that the bonds “have legal claim values that are hundreds of times more than 

the purchase price being paid,” without disclosing certain red flags that revealed that 

the HAPS redemption process was fraudulent, including but not limiting to, existing 

impediments to recovery and continued adverse court decisions.       

133. As a licensed and trained securities professional, Scannell knew, or was 

reckless or negligent in not knowing, that the HAPS redemption process 

was fraudulent. 

134. Scannell claimed that he sold Historical Bonds to Sovereign Debt 

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COMPLAINT 23  

 

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Solutions’ clients so that they could become HAPS clients in their own right and gain 

direct access to the Portal, rather than rely on his and Pendley’s summaries of the 

updates.  Scannell thereby facilitated their direct access to HAPS’ lulling statements.  

135. Scannell knew, or was reckless or negligent in not knowing, that, in the 

sale or offer of a security or in connection with the sale of a security, he employed a 

device, scheme, or artifice to defraud; made untrue statements of a material fact or 

omitted to state material facts necessary to make those statements that were made not 

misleading, and thereby obtained money or property; and engaged in acts, practices, 

or courses of business which operated or would operate as a fraud or deceit on 

investors in connection with the sale of a security.   

II. Pendley’s, Scannell’s, Sovereign Debt Solutions’, and Ocean Park 

Partners’ Fraudulent and Unregistered Offer and Sale of Promissory 

Notes and SDS Limited Partnership Interests  

136. Beginning in at least April 2017 and continuing to at least May 2022, 

Pendley and Scannell, in their roles as officers of Sovereign Debt Solutions’ general 

partner, Ocean Park Partners, solicited existing SDS investors to loan SDS monies in 

exchange for a promissory note and additional limited partnership interests in SDS. 

137. The promissory notes provided for repayment of principal with 10% 

annual interest within six months, subject to indefinite extension at Sovereign Debt 

Solutions’ discretion, or at the latest on the occurrence of a “Liquidity Event.” 

138. This “Liquidity Event” was variously defined in the promissory notes as 

the sale of securitization of Sovereign Debt Solutions’ Historical Bonds or the 

obtaining of a settlement or judgment in any litigation against the bonds’ issuers. 

139. The promissory notes were to be subordinated to a purported $1 million 

outstanding loan from Ocean Park Partners to Sovereign Debt Solutions. 

140. As described above, Pendley and Scannell ceased pursuing litigation as a 

means to redeeming the Historical Bonds in or about 2013, and the HAPS redemption 

process did not exist.  

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COMPLAINT 24  

 

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141. Therefore, Pendley and Scannell knew, or were reckless or negligent in 

not knowing, that there was no realistic expectation of any investor being repaid or 

receiving interest, given the improbability of a Liquidation Event ever occurring or 

the resulting proceeds being enough to cover the purported loan from OPP. 

142. At least eight existing Sovereign Debt Solutions’ investors in different 

states entered into 28 promissory notes pursuant to which they paid a cumulative total 

of $103,500 to SDS and received at least 41 limited partnership interests. 

143. Scannell signed the notes on behalf of Sovereign Debt Solutions in his 

role as president of Ocean Park Partners, SDS’ general partner. 

144. The $103,500 was deposited into a bank account in the name of 

Sovereign Debt Solutions, from which Pendley and/or Scannell, as officers of Ocean 

Park Partners, directed the transfer of at least $50,500 to a bank account in OPP’s 

name to pay business expenses. 

145. No registration statement was filed with the Commission as to the offer 

or sale of the promissory notes or the limited partnership interests, and neither 

Pendley nor Scannell made any effort to determine whether any investor was an 

accredited investor as defined by Rule 501 of Regulation D [17 C.F.R §230.501]. 

146. The promissory notes and the limited partnership interests are securities. 

147. No exemption to the registration requirements applies to the issuance of 

the promissory notes or the limited partnership interests. 

148. Sovereign Debt Solutions has not repaid the principal nor any interest on 

the promissory notes. 

149. Pendley and Scannell each knew, or was reckless or negligent in not 

knowing, that, in the sale or offer of a security or in connection with the sale of a 

security, he employed a device, scheme, or artifice to defraud; made untrue 

statements of a material fact or omitted to state material facts necessary to make those 

statements that were made not misleading, and thereby obtained money or property; 

and engaged in acts, practices, or courses of business which operated or would 

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COMPLAINT 25  

 

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operate as a fraud or deceit on investors in connection with the sale of a security.   

150. Pendley’s and Scannell’s scienter is imputable to Ocean Park Partners, 

whose scienter is imputable to Sovereign Debt Solutions. 

III. Fred Gladle and Pendley Acted as Unregistered Dealers 

151. Fred Gladle and Pendley each engaged in the regular business of buying 

and selling securities for his own account.  

152. On his current LinkedIn page, Fred Gladle identifies himself as having 

spent approximately twenty years working with buyers and sellers of 

Historical Bonds 

153. Tax return records further show that his principal source of income was 

from the profits he made from the purchase and sale of Historical Bonds.   

154. In or around late 2016, Fred Gladle placed his inventory of Historical 

Bonds in the custody of HAPS.  

155. As detailed above, during the Relevant Period, Fred Gladle sold 

Historical Bonds to Pendley, whom Gladle knew was going to resell the Historical 

Bonds to retail customers, and to a retail customer introduced to him by Pendley.   

156. Like Fred Gladle, Pendley also developed a business of buying and 

selling Historical Bonds.  

157. In November 2023, Pendley gave sworn testimony that proceeds from 

the purchase and sale of Historical Bonds had been his sole source of income the 

prior five years.  

158. Pendley purchased Historical Bonds from Fred Gladle and third parties, 

using HAPS’ custodial services. 

159. As detailed above, during the Relevant Period, Pendley sold Historical 

Bonds to at least 55 investors.   

160. Post-sale, both Pendley and Fred Gladle fielded investor inquiries.  For 

example, Pendley fielded inquiries as to when investors could expect to receive 

“Healing Funds” and redemption proceeds.  Fred Gladle assisted clients with gaining 

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COMPLAINT 26  

 

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access to the HAPS portal.  

161. During the Relevant Period, neither Fred Gladle nor Pendley was 

registered with the Commission as a dealer, nor associated with any registered 

broker-dealer.  Neither was eligible for an exemption from registration.  

162. Therefore, Fred Gladle and Pendley acted as unregistered dealers.  

FIRST CLAIM FOR RELIEF 

Violations of Section 17(a) of the Securities Act 

(Against Defendants Fred Gladle, Pendley, Scannell,  

Sovereign Debt Solutions, and Ocean Park Partners) 

163. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 150. 

164. By engaging in the conduct described above, Defendants Fred Gladle, 

Pendley, Scannell, Sovereign Debt Solutions, and Ocean Park Partners, directly or 

indirectly, singly or in concert, in the offer or sale of securities, and by the use of 

means or instruments of transportation or communication in interstate commerce or 

by use of the mails: (a) knowingly or recklessly have employed one or more devices, 

schemes, or artifices to defraud; (b) knowingly, recklessly, or negligently have 

obtained money or property by means of one or more untrue statements of material 

fact, or omissions of a material fact necessary in order to make the statements made, 

in the light of the circumstances under which they were made, not misleading; and/or 

(c) knowingly, recklessly, or negligently have engaged in one or more transactions, 

practices, and courses of business which operated or would operate as a fraud or 

deceit upon the purchaser. 

165. By reason of the foregoing, Defendants Fred Gladle, Pendley, Scannell, 

Sovereign Debt Solutions, and Ocean Park Partners, violated, and unless enjoined 

will continue to violate, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

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COMPLAINT 27  

 

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SECOND CLAIM FOR RELIEF 

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

(Against All Defendants) 

166. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 150. 

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

indirectly, singly or in concert, in connection with the purchase or sale of securities, 

and by the use of means or instrumentalities of interstate commerce, or the mails, or 

the facilities of a national securities exchange, knowingly or recklessly have: (a) 

employed one or more devices, schemes, or artifices to defraud; (b) made one or 

more untrue statements of material fact, or omitted to state one or more material facts 

necessary to make the statements made, in the light of the circumstances under which 

they were made, not misleading; and/or (c) engaged in one or more acts, practices, or 

courses of business that operated or would operate as a fraud and deceit upon 

other persons.  

168. By reason of the foregoing, the Defendants violated, and unless 

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

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

THIRD CLAIM FOR RELIEF 

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

(Against Defendants Pendley, Scannell,  

Sovereign Debt Solutions, and Ocean Park Partners) 

169. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 42, 45 through 48, and 124 through 150. 

170. By engaging in the conduct described above, Defendants Pendley, 

Scannell, Sovereign Debt Solutions, and Ocean Park Partners, without a registration 

statement in effect as to the offer and sale of the promissory notes and limited 

partnership interests referenced in paragraphs 136 through 150 above: (a) made use of 

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COMPLAINT 28  

 

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the means and instruments of transportation or communications in interstate 

commerce or of the mails to sell securities through the use of medium of any 

prospectus or otherwise; (b) carried or caused to be carried through the mails or in 

interstate commerce, by any means or instruments of transportation, any such security 

for the purpose of sale or for delivery after sale; and (c) made use of the means and 

instruments of transportation or communication in interstate commerce or of the 

mails to offer to sell through the use or medium of a prospectus or otherwise, 

securities as to which no registration statement was filed.  

171. By reason of the foregoing, Pendley, Scannell, Sovereign Debt 

Solutions, and Ocean Park Partners violated Sections 5(a) and 5(c) of the Securities 

Act [15 U.S.C. §§ 77e(a) & 77e(c)]. 

FOURTH CLAIM FOR RELIEF 

Aiding and Abetting Violations of Securities Act Section 17(a) 

(Against Defendant Fred Gladle) 

172. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 109.  

173. Defendant Pendley, in the offer or sale of securities, and by the use of 

means or instruments of transportation or communication in interstate commerce or 

by use of the mails, directly or indirectly: (a) knowingly or recklessly had employed 

one or more devices, schemes, or artifices to defraud; (b) knowingly, recklessly, or 

negligently had obtained money or property by means of one or more untrue 

statements of material fact, or omissions of a material fact necessary in order to make 

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

not misleading; and/or (c) knowingly, recklessly, or negligently had engaged in one 

or more transactions, practices, and courses of business which operated or would 

operate as a fraud or deceit upon the purchaser. 

174. Defendant Gladle knowingly or recklessly provided substantial 

assistance to Defendant Pendley with respect to his violations of Section 17(a) of the 

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COMPLAINT 29  

 

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Securities Act by, among other things, knowingly or recklessly preparing purchase 

agreements with false information that Pendley used to sell Historical Bonds. 

175. By engaging in the conduct described above, Defendant Gladle aided 

and abetted Pendley’s violations of Section 17(a) of the Exchange Act [15 U.S.C. 

§ 78q(a)]. 

FIFTH CLAIM FOR RELIEF 

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

(Against Defendants Fred Gladle and Pendley) 

176. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 42, 45 through 48, 59, 61, 89 through 106, 111 through 114, 

117, 118, 121, 122, and 151 through 162. 

177. By engaging in the conduct described above, Defendants Fred Gladle 

and Pendley, directly or indirectly, by the use of the mails or any means or 

instrumentality of interstate commerce effected transactions in, or induced or 

attempted to induce the purchase or sale of securities, while they were not registered 

with the Commission as a broker or dealer or when they were not associated with an 

entity registered with the Commission as a broker-dealer. 

178. By engaging in the conduct described above, Fred Gladle and Pendley 

violated and, unless enjoined, will continue to violate Section 15(a)(1) of the 

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

SIXTH CLAIM FOR RELIEF 

Violations of Rule 21F-17(a) of the Exchange Act 

(Against Defendants C.W. Abshier and HAPS) 

179. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 88. 

180. By engaging in the conduct described above, Defendants C.W. Abshier 

and HAPS, directly or indirectly, by the use of the mails or any means or 

instrumentality of interstate commerce, took action to impede an individual from 

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COMPLAINT 30  

 

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communicating directly with the Commission staff about a possible federal securities 

law violation, or threatening to enforce a confidentiality agreement with respect to 

such communications. 

181. By engaging in the conduct described above, C.W. Abshier and HAPS 

violated and, unless enjoined, will continue to violate Rule 21F-17(a) under the 

Exchange [17 C.F.R. § 240.21F-17(a)]. 

SEVENTH CLAIM FOR RELIEF 

Unjust Enrichment 

(Against Relief Defendant Barbara Gladle) 

182. The SEC re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 110. 

183. Exchange Act Section 21(d)(5) [15 U.S.C. § 78u(d)(5)] states: “In any 

action or proceeding brought or instituted by the SEC under any provision of the 

securities laws, the SEC may seek, and any Federal court may grant, any equitable 

relief that may be appropriate or necessary for the benefit of investors.” 

184. As alleged in paragraphs 19, 93, 104, and 110, Relief Defendant Barbara 

Gladle received the proceeds of unlawful activity to which she has no legitimate claim 

and gave no consideration for exchange of those funds.  

RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that this Court: 

I. 

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

alleged violations. 

II. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently enjoin Defendants Fred Gladle, Pendley, Scannell, 

Sovereign Debt Solutions, and Ocean Park Partners from directly or indirectly 

violating Securities Act Section 17(a) [15 U.S.C. § 77q(a) and all Defendants from 

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COMPLAINT 31  

 

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directly or indirectly violating Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and 

Exchange Act Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

III. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restrain and enjoin Defendants Pendley, Scannell, 

Sovereign Debt Solutions, and Ocean Park Partners from directly or indirectly 

violating Securities Act Sections 5(a) and (c) [15 U.S.C. §§ 77e(a) and 77e(c)]. 

IV. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restrain and enjoin Defendants Fred Gladle and 

Pendley from directly or indirectly violating Exchange Act Section 15(a)(1) [15 

U.S.C. § 78o(a)(1)]. 

V. 

Issue Judgements, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restrain and enjoin Defendants C.W. Abshier and 

HAPS from directly or indirectly violating Exchange Act Rule 21F-17(a) [17 C.F.R.  

§ 240.21F-17(a)].  

VI. 

Permanently restrain and enjoin Defendants Fred Gladle, Pendley, Scannell, 

C.W. Abshier, and Billy Abshier from directly or indirectly, including, but not 

limited to, through any entity owned or controlled by each, participating in the 

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

injunction shall not prevent each from purchasing or selling securities listed on a 

national securities exchange for his own personal account. 

VII. 

Order Defendant Fred Gladle and Relief Defendant Barbara Gladle, on a joint 

and several basis, and Defendants Pendley and Scannell to disgorge the ill-gotten 

gains received because of the violations alleged in this Complaint, including 

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COMPLAINT 32  

 

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prejudgment interest, 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)]. 

VIII. 

Order Defendants Fred Gladle, Pendley, and Scannell to pay civil penalties 

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

Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and order C.W. Abshier and Billy Abshier 

to pay civil penalties pursuant to Exchange Act Section 21(d)(3). 

                                                         IX. 

Order that Defendants Fred Gladle, C.W. Abshier, Pendley, and Scannell be 

permanently prohibited from serving as an officer or director of any company that has 

a class of securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or 

that is required to file reports under Exchange Act Section 15(d) [15 U.S.C. § 

78o(d)], pursuant to Securities Act Section 20(e) [15 U.S.C. § 77t(e)] and Exchange 

Act Section 21(d)(2) [15 U.S.C. § 78u(d)(2)]. 

X. 

Granting such other and further relief as the Court determines to be necessary and 

appropriate.   

Dated:  December 13, 2024  

 /s/ Douglas M. Miller  

Douglas M. Miller 

Oren Gleich (pro hac vice pending) 

Attorneys for Plaintiff 

Securities and Exchange Commission 

 

 

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