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. § 

________________________________________________§ 

FINAL JUDGMENT BY DEFAULT 

AGAINST DEFENDANTS META 1 COIN TRUST, ROBERT P. DUNLAP, individually 

and d/b/a CLEAR INTERNATIONAL TRUST, and NICOLE BOWDLER 

 Plaintiff Securities and Exchange Commission (“Plaintiff” or the “Commission”) 

filed a Complaint (“Complaint”) in this action, Defendants Meta 1 Coin Trust (“Meta1”), Robert 

P. Dunlap, individually and d/b/a Clear International Trust (“Dunlap”), and Nicole Bowdler 

(“Bowdler”) (together, “Defendants”) failed to answer or to otherwise defend this action, and the 

District Clerk entered default against Defendants. Thereafter, the Court granted the 

Commission’s Motion for Default Final Judgment and Motion for Remedies and Entry of Final 

Judgment against Defendants (“Motion”). Based on all the files, records, and proceedings 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 1 of 9
herein, the Court enters Final Judgment against Defendants as follows: 

I. 

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendants are 

permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the 

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

promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of 

interstate commerce, or of the mails, or of any facility of any national securities exchange, in 

connection with the purchase or sale of any security: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to make any untrue statement of a material fact or to omit to state a material fact 

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

 under which they were made, not misleading; or 

(c) to engage in any act, practice, or course of business which operates or would 

 operate as a fraud or deceit upon any person. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants’ 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

II. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendants are permanently restrained and enjoined from violating Section 17(a) of the 

Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 2 of 9
security by the use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to obtain money or property by means of any untrue statement of a material fact 

 or any omission of a material fact necessary in order to make the statements 

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

 or 

 (c) to engage in any transaction, practice, or course of business which operates or 

 would operate as a fraud or deceit upon the purchaser. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants’ 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

III. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendants are permanently restrained and enjoined from violating Section 5 of the Securities 

Act [15 U.S.C. § 77e] by, directly or indirectly, in the absence of any applicable exemption: 

 (a) Unless a registration statement is in effect as to a security, making use of any 

means or instruments of transportation or communication in interstate commerce 

or of the mails to sell such security through the use or medium of any prospectus 

or otherwise; 

 (b) Unless a registration statement is in effect as to a security, carrying or causing to 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 3 of 9
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; or 

 (c) Making 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 

or medium of any prospectus or otherwise any security, unless a registration 

statement has been filed with the Commission as to such security, or while the 

registration statement is the subject of a refusal order or stop order or (prior to the 

effective date of the registration statement) any public proceeding or examination 

under Section 8 of the Securities Act [15 U.S.C. § 77h]. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants’ 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

IV. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Meta1 and 

Dunlap are liable, jointly and severally, for disgorgement of $10,849,776.47, representing net 

profits gained as a result of the conduct alleged in the Complaint, together with prejudgment 

interest thereon in the amount of $939,183.45, for a total of $11,788,959.92. Further, Meta1 and 

Dunlap shall pay, on a joint and several basis, a civil penalty in the amount of $10,849,776.47

pursuant to Section 20(d) of the Securities Act and Section 21(d)(3) of the Exchange Act. 

Of the total disgorgement and prejudgment interest amount ordered above, $5,938,180.21 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 4 of 9
is owed jointly and severally with relief defendants Peter Shamoon and Pramana Capital Inc. 

(together, “the Shamoon Relief Defendants”) representing the amount of disgorgement 

previously ordered against as to the Shamoon Relief Defendants [see Doc. 113], offset by the 

amount collected pursuant to that judgment. Further, $1,540,679.48 is owed jointly and 

severally with Bowdler. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Bowdler is liable for 

disgorgement in the amount of $1,540,679.48, together with prejudgment interest thereon of 

$133,365.03 for a total of $1,674,044.51, jointly and severally with Meta1 and Dunlap. Further, 

Bowdler shall pay a civil penalty of $1,540,679.48 pursuant to Section 20(d) of the Securities 

Act and Section 21(d)(3) of the Exchange Act.

Defendants shall satisfy this obligation by paying $3,214,723.99 to the Securities and 

Exchange Commission within 30 days after entry of this Final Judgment. 

Defendants may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request. Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm. Defendants may also pay by certified check, bank 

cashier’s check, or United States postal money order payable to the Securities and Exchange 

Commission, which shall be delivered or mailed to 

Enterprise Services Center 

Accounts Receivable Branch 

6500 South MacArthur Boulevard 

Oklahoma City, OK 73169 

 and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; Defendant’s name as a defendant in this action; and specifying that payment is made 

pursuant to this Final Judgment. 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 5 of 9
Defendants shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission’s counsel in this action. By making this payment, 

Defendants relinquish all legal and equitable right, title, and interest in such funds and no part of 

the funds shall be returned to Defendants. 

The Commission may enforce the Court’s judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, 

moving for civil contempt at any time after 30 days following entry of this Final Judgment. 

The Commission may enforce the Court’s judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action. Defendants shall pay post judgment interest on any amounts due after 30 

days of the entry of this Final Judgment pursuant to 28 U.S.C. § 1961. The Commission shall 

hold the funds, together with any interest and income earned thereon (collectively, the “Fund”), 

pending further order of the Court. 

The Commission may propose a plan to distribute the Fund subject to the Court’s 

approval. Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund 

provisions of Section 308(a) of the Sarbanes-Oxley Act of 2002. The Court shall retain 

jurisdiction over the administration of any distribution of the Fund and the Fund may only be 

disbursed pursuant to an Order of the Court. 

Regardless of whether any such Fair Fund distribution is made, amounts ordered to be 

paid as civil penalties pursuant to this Judgment shall be treated as penalties paid to the 

government for all purposes, including all tax purposes. To preserve the deterrent effect of the 

civil penalty, Defendants shall not, after offset or reduction of any award of compensatory 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 6 of 9
damages in any Related Investor Action based on Defendants’ payment of disgorgement in this 

action, argue that Defendants are entitled to, nor shall Defendants further benefit by, offset or 

reduction of such compensatory damages award by the amount of any part of Defendants’ 

payment of a civil penalty in this action (“Penalty Offset”). If the court in any Related Investor 

Action grants such a Penalty Offset, Defendants shall, within 30 days after entry of a final order 

granting the Penalty Offset, notify the Commission’s counsel in this action and pay the amount 

of the Penalty Offset to the United States Treasury or to a Fair Fund, as the Commission directs. 

Such a payment shall not be deemed an additional civil penalty and shall not be deemed to 

change the amount of the civil penalty imposed in this Judgment. For purposes of this 

paragraph, a “Related Investor Action” means a private damages action brought against 

Defendants by or on behalf of one or more investors based on substantially the same facts as 

alleged in the Complaint in this action. 

V. 

DIRECTIVE TO FINANCIAL INSTITUTIONS 

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that within 3 days after 

being served with a copy of this Final Judgment, each bank or financial institution identified 

below (the “Banks”) shall transfer to the Commission the entire balance of the account(s) which 

were frozen pursuant to an Order of this Court, and shall close the accounts. These accounts 

include the following: 

Bank Account Name Acct. ending 

in: 

Bank of America Robert P Dunlap Jr Thomas Colt Dunlap *1284 

Bank of America Robert Dunlap Jr. *0124 

Bank of America Robert P Dunlap Jr., Robert Paul Dunlap III *8258 

Bank of America David Alan Schmidt Penelope A Genter *7418 

Bank of America The Sedona Connection LLC (David Schmidt) *9828 

Bank of America Nicole M Bowdler *1771 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 7 of 9
Bank of America Clear International Trust Robert P Dunlap Jr Trtee 

U/A 5/16/2016 

*2678 

BMO Harris Bank Meta 1 Coin Trust (Peter Shamoon) *7012 

BMO Harris Bank Meta 1 Coin Trust (Peter Shamoon) *0179 

Fidelity Brokerage Service 

(Fidelity Investment) 

FMTC Custodian of the IRA SEPP, FBO Robert Paul 

Dunlap 

*2801 

Fidelity Brokerage Service 

(Fidelity Investment) 

FMTC Custodian - SIMPLE 

Evision Systems 

FBO Robert Paul Dunlap 

*4895 

Fidelity Brokerage Service 

(Fidelity Investment) 

Robert Dunlap, N M Bowdler Trustees 

Meta 1 Coin Trust 

FBO Robert P Dunlap 

*3691 

Fifth Third Bank Pramana Capital Inc. (Peter Shamoon) *8456 

Fifth Third Bank Pramana Capital Inc. *5300 

TD Ameritrade PETER A. SHAMOUN *0129 

The Bankcorp Bank - PayPal, Inc. David Schmidt *2216 

The Bankcorp Bank - PayPal, Inc. Nicole Bowdler *5579 

Wells Fargo Bank, NA Pramana Capital LLC *0848 

Wells Fargo Bank, NA Koole Bare Investments *2570 

Wells Fargo Bank, NA Peter K Shamoon *3006 

BOKF, NA d/b/a Bank of Texas Ironheart Trust, Alfred Warner and Wanda Ironheart 

Traversie Warner 

*9431 

BOKF, NA d/b/a Bank of Texas Ironheart Trust *2598 

Navy Federal Credit Union Ironheart Trust *1212 

Navy Federal Credit Union Ironheart Trust Savings *9523 

Navy Federal Credit Union Wanda I. Traversie-Warner Checking *3752 

Navy Federal Credit Union Wanda I Traversie-Warner-Savings *8944 

Navy Federal Credit Union Alfred D. Warner *0453 

 The Banks may transmit payment electronically to the Commission, which will 

provide detailed ACH transfer/Fedwire instructions upon request. Payment may also be made 

directly from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm. BMO Harris also may transfer these funds by 

certified check, bank cashier’s check, or United States postal money order payable to the 

Securities and Exchange Commission, which shall be delivered or mailed to: 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 8 of 9
Enterprise Services Center 

Accounts Receivable Branch 

6500 South MacArthur Boulevard 

Oklahoma City, OK 73169 

and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; and specifying that payment is made pursuant to this Final Judgment.

VI. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

VII. 

There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil 

Procedure, the Clerk is ordered to enter this Final Judgment forthwith and without further notice. 

 SO ORDERED this ____ day of __________, 2022. 

 ____________________________________ 

 ROBERT PITMAN 

 UNITED STATES DISTRICT JUDGE 

Case 1:20-cv-00273-RP Document 133-3 Filed 09/22/22 Page 9 of 9