UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: _______________ 

SECURITIES AND EXCHANGE COMMISSION, 

 Plaintiff,

 v. 

JUDITH PARIS-PINDER, 

 

 Defendant.

__________________________________________________/ 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

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

I. INTRODUCTION

1. The Commission brings this action as a result of an offering fraud conducted by 

Judith Paris-Pinder (“Defendant”). From at least November 2019 through October 2021, 

Defendant fraudulently raised at least $2,300,000 from over 280 investors, mostly Haitians and 

Haitian-Americans living in South Florida and elsewhere, through an unregistered offering of loan 

agreements issued by Defendant falsely promising returns of up to 50%. Defendant falsely told 

investors that she would make interest generating advance loans to personal injury clients of a 

prominent Miami-based attorney and that investors would be repaid, with interest, within 30 to 90 

days. 

2. In order to carry out the scheme, Defendant made material misrepresentations to 

investors, claiming, among other things, that the investment was safe and investor funds would 

only be used to make advance loans to personal injury client borrowers. However, Defendant 

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grossly misrepresented to investors where their funds would be maintained and how their funds 

would be used. 

3. Instead of making advance loans designed to generate the promised returns, 

Defendant misappropriated at least $483,000 of investor funds and used other investor funds to 

make Ponzi-like distributions. 

4. As a result of the conduct alleged in this Complaint, Defendant violated Sections 

5(a) and (c) of the Securities Act of 1933 (the “Securities Act”), [15 U.S.C. §§ 77e(a) and (c)], 

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

Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 

C.F.R. §§ 240.10b-5]. 

5. Unless enjoined, Defendant is reasonably likely to continue to violate the federal 

securities laws.

II. DEFENDANT AND RELATED ENTITIES

A. Defendant

6. Pinder, age 48, resides in Biscayne Park, Florida. At all relevant times, Pinder has 

been the president of Pinder Associates, Inc. (“Pinder Associates”) and Pinder’s Multi-Services

and Marketing Group, LLC (“Pinder’s Multi-Services”). 

B. Related Entities

7. Pinder Associates is a Florida-registered corporation formed by Pinder in March

2020 with its principal place of business in North Miami, Florida. 

8. Pinder’s Multi-Services is a Florida limited liability company formed by Pinder in 

February 2021 with its principal place of business in North Miami, Florida. 

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9. Pinder owned and controlled both Pinder Associates and Pinder’s Multi-Services. 

III. JURISDICTION AND VENUE

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

and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)] and Sections 21(d) and 

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

11. This Court has personal jurisdiction over Defendant, and venue is proper in this

District because many of the acts and transactions constituting violations of the Securities Act and

Exchange Act occurred in this District. 

12. In connection with the conduct alleged in this Complaint, Defendant, directly and 

indirectly, made use of the means or instrumentalities of interstate commerce, the means or 

instruments of transportation or communication in interstate commerce, or the mails. 

IV. DEFENDANT’S ACTS IN VIOLATION OF THE SECURITIES LAWS

A. Defendant’s Unregistered Investments

13. From at least November 2019, Defendant offered unregistered investments to U.S.-

based investors. These offerings targeted, in particular, investors of Haitian and Haitian-American 

backgrounds. 

14. No registration statement was filed or in effect with the Commission pursuant to 

the Securities Act with respect to the securities Defendant offered and sold, and no exemption from 

registration existed with respect to these securities.

15. Defendant offered investors loan agreements that ranged from 30 days to 90 days 

and offered 50% interest per term. Defendant told investors that she had a relationship with a 

prominent Miami, Florida-based attorney whose personal injury clients needed advance loans in 

anticipation of settlements. Defendant told investors that she used investor funds to make loans to 

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the personal injury clients, and generated the investment returns from the interest paid by the 

personal injury client borrowers. 

16. Defendant assured investors that their investments were safe and that the attorney 

with whom she was working always paid out the loan proceeds from the settlements to Defendant 

who, in turn, would use those funds to repay investors pursuant to the loan agreements. 

17. Defendant promoted this investment opportunity largely through word-of-mouth 

referrals from other prior investors as well as relationships with members of the local South Florida 

Haitian and Haitian-American community. Many of these investors did not have any pre-existing 

relationship with Pinder, and Pinder did not attempt to determine their level of sophistication or 

whether the investor was accredited.

18. If a prospective investor was interested after an initial conversation with Defendant,

Defendant prepared a “loan agreement” –between Pinder and the investor – which outlined the 

investment amount, rate of return (50%), return amount, and the term of the investment (30, 60 or 

90 days). Defendant then typically emailed the loan agreement to the prospective investor for his 

or her signature. Defendant also executed the loan agreement.

19. Upon receiving an executed loan agreement, Defendant provided investors with 

instructions for sending their investment funds to Defendant in cash, via Zelle, CashApp, wire 

transfer, or through in-person bank teller deposits. Investor funds were deposited by Defendant 

into her personal bank accounts, as well as bank accounts in the names of Pinder Associates and 

Pinder’s Multi-Services, entities and accounts wholly controlled by Defendant. 

20. Beyond signing the loan agreement and sending cash to fund their investments, 

investors did not have any input or otherwise participate in Defendant’s advance loan business. 

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Investors’ returns were to be generated solely from the business activities of Defendant and the 

attorney with whom she purportedly worked. 

21. Defendant engaged in general solicitation activities in offering and selling loan 

agreements. Defendant had no pre-existing relationship with most of the investors, many of whom 

were referred via word-of-mouth. Defendant had no personal knowledge of these investors’ 

financial circumstances, never inquired as to whether they were accredited, and did not take any 

steps to determine or verify their financial condition. At least ten of the investors who invested 

with Defendant were unaccredited.

22. Investors furnished capital contributions to Defendant through Defendant’s loan 

agreements. Purported profits from investments were derived “solely from the efforts” of 

Defendant and the attorney with whom she claimed to work because, as Defendant represented, 

Defendant and the attorney exercised exclusive control over the selection of personal injury client 

borrowers purportedly generating investor returns. Defendant’s investors relied on Defendant to 

invest their funds with no expectation that the investors themselves would be required to 

participate in efforts to generate returns.

23. By October 2021, Defendant had raised at least $2,300,000 from over 280 investors

through her advance loan agreement scheme. 

B. Defendant Materially Misrepresented Her Experience,

the Safety of the Investment, and Use of Investor Funds

24. Defendant made numerous material misrepresentations to investors and prospective 

investors about, among other things, her experience with the loan agreements, the existence of an 

underlying advance loan operation funding personal injury clients awaiting settlements, the 

purported 50% “returns” on investments and the safety of loan agreements.

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25. For example, Defendant told investors and prospective investors that she had been 

in the business of making advance loans to personal injury clients for over five years, boasting 

about her personal relationship with a prominent Miami, Florida attorney. In truth, Defendant had 

not been making advance loans to personal injury clients for over five years, and had no 

relationship with the Miami attorney – or any other attorney providing a base of personal injury 

clients awaiting settlement. 

26. Additionally, Defendant falsely promised investors that their funds were safe, that 

the funds would be placed in an attorney’s escrow account, and that their investment proceeds 

would be paid by the attorney upon each client’s settlement. Defendant did not actually deposit 

investor funds in an attorney’s escrow account and there here is no evidence that Defendant 

actually made any underlying advance loans to personal injury clients or anyone else. 

27. Instead, Defendant used the investor funds she raised through the offer and sale of 

loan agreements to enrich herself and make “interest” payments to investors in a Ponzi-like 

fashion. 

28. Because Defendant controlled the accounts into which investor funds were 

deposited, she knew that investor funds were not being used to make advance loans to personal 

injury clients, and therefore she was lying to investors about her use of funds. 

29. Had investors known the truth about Defendant’s misrepresentations, they would 

not have invested.

C. Defendant Misappropriated Investor Funds

30. Of the approximately $2,300,000 raised, Defendant misappropriated at least 

$483,000 for her personal expenses. She diverted funds to pay for purchases or expenses wholly 

unrelated to the advance loan investment operation: 

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D. Defendant’s Investment Scheme Unravels

31. Between August and October 2021, Defendant’s scheme began to unravel. In 

August 2021, Defendant failed to make principal and interest payments to investors. To quell 

investor concerns, Defendant falsely told investors their payments were delayed due to issues with 

her bank. In fact, numerous transactions cleared Defendant’s accounts during the time period in 

which she claimed payments were delayed because of her bank, including payments to other 

investors. 

Approximate 

Amount 

Misappropriated 

Date Purpose

$89,000 November 2019 – January 2022 Living Expenses

$72,000 November 2019 – November 2021 Retail & Apparel

$60,000 November 2019 – November 2021 Travel & Entertainment

$53,000 November 2019 – November 2021 Credit Cards, Debt Recovery, & 

Credit Monitoring

$46,000 November 2019 – August 2021 Gifts to Family & Friends

$38,000 November 2019 – March 2022 Insurance Payments

$37,000 November 2019 – September 2021 Automobile Expenses

$35,000 March 2020 – August 2021 Defendant’s Wedding

$17,000 November 2019 – September 2021 Beauty, Personal Care, & 

Cosmetic Surgery

$12,000 January 2020 – October 2021 Transfers to Defendant’s Other 

Accounts

$24,000 November 2019 – November 2021 Other Unrelated Spending

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32. Despite Defendant’s default, Defendant continued to solicit funds from investors 

raising approximately $327,000 from new loan agreements issued between August 1, 2021 and 

October 31, 2021. 

33. While some investors initially received the promised “returns” from their 

investments, including two who invested with Defendant in late 2020, others did not because 

Defendant had convinced them to reinvest returns into new loan agreements. In or around 

November 2021, Defendant stopped paying returns at all. Most investors have failed to recover 

either investment principal or any promised returns. 

34. Despite assurances from Defendant to several investors that they would be paid, 

many investors have not recovered their investments and have been unable to contact Defendant

since October 2021. 

V. CLAIMS FOR RELIEF

Count I

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

35. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

36. No registration statement was filed or in effect with the Commission pursuant to 

the Securities Act with respect to the securities and transactions issued by Defendant described in 

this Complaint and no exemption from registration existed with respect to these securities and 

transactions. 

37. From at least November 2019 through October 2021, Defendant, directly or 

indirectly: 

a. made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to sell securities, through the use or medium 

of a prospectus or otherwise; 

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b. carried or caused to be carried securities through the mails or in interstate 

commerce, by any means or instruments of transportation, for the purpose of sale 

or delivery after sale; or

c. made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to offer to sell or offer to buy through the use 

of medium of any prospectus or otherwise any security, 

without a registration statement having been filed or being in effect with the Commission as to 

such securities. 

38. By reason of the foregoing, Defendant violated, and unless enjoined, is reasonably 

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

77e(c)].

Count II

Violations of Section 17(a)(1) of the Securities Act

39. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

40. From at least November 2019 through October 2021, Defendant, in the offer or sale 

of securities by use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly, knowingly or recklessly employed devices, 

schemes, or artifices to defraud.

41. By reason of the foregoing, Defendant, directly and indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate, Section 17(a)(1) of the Securities Act [15 

U.S.C. § 77q(a)(1)].

Count III

Violations of Section 17(a)(2) of the Securities Act

42. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

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43. From at least November 2019 through October 2021, Defendant, in the offer or sale 

of securities by use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly, negligently obtained money or property by 

means of untrue statements of material facts and omissions to state material facts necessary in 

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

not misleading.

44. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)].

Count IV

Violations of Section 17(a)(3) of the Securities Act

45. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint. 

46. From at least November 2019 through October 2021, Defendant, in the offer or sale 

of securities by use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly, negligently engaged in transactions, 

practices, or courses of business which have operated, are now operating or will operate as a fraud 

or deceit upon the purchasers. 

47. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate, Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)].

Count V

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

48. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

49. From at least November 2019 through October 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

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knowingly or recklessly employed devices, schemes or artifices to defraud in connection with the 

purchase or sale of any security.

50. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange 

Act Rule 10b-5(a) [17 C.F.R. § 240.10b-5(a)].

Count VI

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

51. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

52. From at least November 2019 through October 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly made untrue statements of material facts or omitted to state material facts 

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

were made, not misleading, in connection with the purchase or sale of any security.

53. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange 

Act Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)].

Count VII

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

54. The Commission repeats and realleges paragraphs 1 through 34 of this Complaint.

55. From at least November 2019 through October 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly engaged in acts, practices, and courses of business which have operated, 

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are now operating or will operate as a fraud upon any person in connection with the purchase or 

sale of any security.

56. By reason of the foregoing, Defendant violated and, unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange 

Act Rule 10b-5(c) [17 C.F.R. § 240.10b-5(c)].

VI. RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that the Court find Defendant

committed the violations alleged in this Complaint and:

A. Permanent Injunctive Relief

Issue Permanent Injunctions, restraining and enjoining Defendant, and her agents, servants, 

employees, attorneys, and representatives, and all persons in active concert or participation with 

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

77e(a) and (c), Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a), Section 10(b) of the 

Exchange Act, 15 U.S.C. § 78j(b) and Exchange Act Rule 10b-5 thereunder, 17 C.F.R. § 240.10b5. 

B. Officer and Director Bar

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

and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], permanently barring Defendant

from acting as an officer or director of any issuer whose securities are registered with the 

Commission pursuant to Section 12 of the Exchange Act or which is required to file reports with 

the Commission pursuant to Section 15(d) of the Exchange Act. 

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C. Disgorgement and Prejudgment Interest

Issue an Order directing Defendant to disgorge all ill-gotten gains or proceeds received, 

with prejudgment interest thereon, resulting from the acts and/or courses of conduct alleged in this 

Complaint.

D. Civil Monetary Penalties

Issue an Order directing Defendant to pay civil money penalties pursuant to Section 20(d) 

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

78u(d)]. 

E. Further Relief

Grant such other and further relief as the Court may deem just and proper.

F. Retention of Jurisdiction

Further, the Commission respectfully requests that the Court retain jurisdiction over this 

action in order to implement and carry out the terms of all orders and decrees that it may enter, or 

to entertain any suitable application or motion by the Commission for additional relief within the 

jurisdiction of this Court. 

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Dated: September 26, 2022

Respectfully submitted,

By: s/ Teresa Verges

Teresa Verges, Esq. 

Regional Trial Counsel

Florida Bar No.: 997651

Telephone: (305) 982-6376

Email: vergest@sec.gov

Attorney for Plaintiff

Securities and Exchange Commission

801 Brickell Avenue, Suite 1950

Miami, Florida 33131

Telephone: (305) 982-6300

Facsimile: (305) 536-4154

Of counsel:

Najwa-Monique Sharpe, Esq.

Counsel

Securities and Exchange Commission

801 Brickell Avenue, Suite 1950

Miami, Florida 33131

Telephone: (305) 416-6260

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