1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

________________________________________________

SECURITIES AND EXCHANGE COMMISSION, §

§

Plaintiff, §

§

v. §

§

META 1 COIN TRUST, §

ROBERT P. DUNLAP, individually and d/b/a § Civil Action No.: 1:20-cv-273-RP

CLEAR INTERNATIONAL TRUST, §

NICOLE BOWDLER, and DAVID A. SCHMIDT, §

§

Defendants, § 

§

and §

§

PRAMANA CAPITAL, INC., §

PETER K. SHAMOUN a/k/a PETER K. SHAMOON, §

WANDA IRONHEART TRAVERSIE-WARNER, §

ALFRED DEWITT WARNER JR. §

AND IRONHEART TRUST, §

§

Relief Defendants. §

________________________________________________§

PLAINTIFF’S STATUS REPORT 

Pursuant to the Court’s Order dated 4/06/2021 [Doc. 121], Plaintiff Securities and 

Exchange Commission (“SEC”) files this Status Report and respectfully shows the following:

1. On February 8, 2021, the Court entered an Order of default, against: (1) Meta 1 

Coin Trust (“Meta1”), Robert P. Dunlap, individually and d/b/a Clear International Trust

(“Dunlap”) and Nicole Bowdler (“Bowdler”) (together, “Defendants”); and (2) Relief 

Defendants Wanda Ironheart Traversie-Warner (“Traversie”), Alfred Dewitt Warner Jr. 

(“Warner”), and Ironheart Trust (“Ironheart”) (together, “Relief Defendants”) (the “Default 

Order”) [Doc. 114]. The Default Order imposed injunctive relief against Defendants, and 

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reserved the determination of the amount of monetary remedies to be imposed against 

Defendants and Relief Defendants for a later date, as the SEC explained that it was aware of ongoing activity that needed to be included in the motion for remedies.

2. Since the SEC’s last status report, the SEC has issued multiple subpoenas to 

obtain records from individuals, banks and financial institutions and has received and scheduled 

the records that have been received to trace the flow of investor funds. The SEC’s efforts to 

trace investor funds and receive and review financial records is ongoing. The SEC also 

continues to coordinate with criminal authorities about this case.

3. By way of update to the Court, Dunlap and Meta1 continue to operate and market 

the investment scheme through various means, including its website (https://meta1.io), on an 

internet radio show (https://www.thejimpriceshow.com), and on social media such as Twitter 

(@META1Coin). Meta1 has also begun a new “ambassador program,” whereby current 

investors receive “referral bonuses” equal to 5% of amounts deposited from referrals. Recent 

review of records shows that Richard Grassie continues to receive and disseminate hundreds of 

thousands of dollars in investor funds for improper purposes.

4. Relief Defendant Peter Shamoon still has not made a single payment pursuant to 

his obligations, and his attorneys of record no longer represent him in this action. 

5. A number of subpoenas are outstanding, and new documents have been recently 

received. The SEC requests additional time to review and schedule the records, and will file its 

motion for monetary remedies and related evidence after its review. Additionally, SEC staff 

must receive Commission approval to seek specific disgorgement and penalty amounts, and that 

process may take approximately 60 days.

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6. The SEC will update the Court on the status, and/or will file its motion for 

monetary remedies, within 90 days (June 21, 2022), or at such time that the Court orders.

Dated: March 21, 2022 Respectfully submitted, 

/s/ Jennifer D. Reece 

Jennifer D. Reece

Texas Bar No. 00796242

James E. Etri

Texas Bar No. 24002061

United States Securities and Exchange Commission 

Burnett Plaza, Suite 1900 

801 Cherry Street, Unit 18 

Fort Worth, Texas 76102 

Direct phone: (817) 978-6442 (JDR)

Fax: (817) 978-4927 

reecej@sec.gov

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

I certify that on March 21, 2022, I electronically submitted the foregoing document with 

the clerk of court for the U.S. District Court, Western District of Texas, using the electronic case 

filing system of the court. I hereby certify that I have served all parties according to FED. R. CIV. 

P. 5(b)(2).

/s/ Jennifer D. Reece 

Jennifer D. Reece

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