[PROPOSED] ORDER OF PRELIMINARY INJUNCTION CASE NO. 3:17-CV-00223

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JINA L. CHOI (N.Y. Bar No. 2699718)

ERIN E. SCHNEIDER (Cal. Bar No. 216114)

schneidere@sec.gov

STEVEN D. BUCHHOLZ (Cal. Bar No. 202638)

buchholzs@sec.gov

ANDREW J. HEFTY (Cal. Bar No. 220450)

heftya@sec.gov

SUSAN F. LaMARCA (Cal. Bar No. 215231)

lamarcas@sec.gov

THOMAS J. EME (Ill. Bar No. 6224870)

emet@sec.gov

Attorneys for Plaintiff

SECURITIES AND EXCHANGE COMMISSION

44 Montgomery Street, Suite 2800

San Francisco, CA 94104

Telephone: (415) 705-2500

Facsimile: (415) 705-2501

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

v.

SAN FRANCISCO REGIONAL CENTER, LLC; 

THOMAS M. HENDERSON; CALIFORNIA 

GOLD MEDAL, L.P.; CALLSOCKET, L.P.;

CALLSOCKET II, L.P.; CALLSOCKET III, L.P.;

COMPREHENSIVE CARE OF OAKLAND, L.P.;

NA3PL, L.P.; WEST OAKLAND PLAZA, L.P.;

CALLSOCKET, LLC; CALLSOCKET II, LLC; 

CALLSOCKET III, LLC; COMPREHENSIVE 

CARE OF CALIFORNIA, LLC; IMMEDIA, LLC; 

and NORTH AMERICA 3PL, LLC,

Defendants, and

CALLSOCKET HOLDING COMPANY, 

LLC; CALLSOCKET III HOLDING 

COMPANY, LLC; BERKELEY 

HEALTHCARE DYNAMICS, LLC;

CENTRAL CALIFORNIA FARMS, LLC;

and JL GATEWAY, LLC,

Relief Defendants.

Case No. 3:17-cv-00223-RS

[PROPOSED] ORDER GRANTING 

MOTION FOR PRELIMINARY 

INJUNCTION 

Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 1 of 6
[PROPOSED] ORDER OF PRELIMINARY

INJUNCTION

1 CASE NO. 3:17-CV-00223

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This matter came before the Court on the motion of the Securities and Exchange Commission 

(the “SEC” or “Commission”) for an order of preliminary injunction and ancillary relief to restrain 

and enjoin Defendants Thomas M. Henderson; San Francisco Regional Center, LLC; California Gold 

Medal, L.P.; CallSocket, L.P.; CallSocket II, L.P.; CallSocket III, L.P.; Comprehensive Care of 

Oakland, L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; CallSocket, LLC; CallSocket II, LLC; 

CallSocket III, LLC; Comprehensive Care of California, LLC; Immedia, LLC; and North America 

3PL, LLC (collectively “Defendants”), during the pendency of this case. The Commission’s motion 

seeks orders: (1) Preliminarily enjoining each of the Defendants from engaging in specified conduct;

(2) Prohibiting the destruction of documents by any of the Defendants or by Relief Defendants

CallSocket Holding Company, LLC; CallSocket III Holding Company, LLC; Central California 

Farms, LLC; Berkeley Healthcare Dynamics, LLC; and JL Gateway, LLC (collectively “Relief 

Defendants”). 

The Court, having considered: (1) the complaint filed by the Commission in this case; (2) the 

Commission’s Motion for Preliminary Injunction and for Appointment of a Receiver and 

Memorandum in support thereof; (3) the Declarations of Thomas J. Eme and Ellen Chen and the

exhibits thereto; and any responses thereto and all proceedings before the Court, finds that:

1. This Court has jurisdiction over the subject matter of this action, and as to all parties, 

Defendants and Relief Defendants, and venue properly lies in this District.

2. The Commission has made a sufficient and proper showing in support of the relief 

granted herein, as required by Section 20(b) of the Securities Act of 1933 (“Securities Act”), 15 

U.S.C. § 77t(b), and Section 21(d) of the Securities Exchange Act of 1934 (“Exchange Act”), 15 

U.S.C. § 78u(b), by evidence establishing a prima facie case and a reasonable likelihood that 

Defendants have engaged in, are engaging in, are about to engage in, and will continue to engage in, 

unless enjoined by order of this Court, transactions, acts, practices, and courses of business that 

constitute violations of 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, 17 C.F.R. § 240.10b-5; and that 

Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 2 of 6
[PROPOSED] ORDER OF PRELIMINARY

INJUNCTION

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Relief Defendants are or have been in possession of the proceeds of those violations and have been 

unjustly enriched.

3. The Commission has demonstrated a likelihood of success on the merits of its action 

and that the balance of hardships weighs in its favor. With respect to the balance of hardships, the 

public interest weighs strongly in favor of issuance of injunctive relief.

4. Good cause exists to believe that, unless enjoined by order of this Court, documents 

relevant to this action may be altered, destroyed, or become unavailable for discovery.

I.

THEREFORE IT IS HEREBY ORDERED that the SEC’s Motion for Preliminary Injunction

is GRANTED.

II.

IT IS FURTHER ORDERED that Defendants San Francisco Regional Center, LLC; Thomas 

M. Henderson; California Gold Medal, L.P.; CallSocket, L.P.; CallSocket II, L.P.; CallSocket III, 

L.P.; Comprehensive Care of Oakland, L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; CallSocket, 

LLC; CallSocket II, LLC; CallSocket III, LLC; Comprehensive Care of California, LLC; Immedia, 

LLC; and North America 3PL, LLC are preliminarily restrained and enjoined from, directly or 

indirectly, in connection with the purchase or sale of any security, by the use of any means or 

instrumentality of interstate commerce, or of the mails, or of any facility of any national securities 

exchange:

A. Employing any device, scheme or artifice to defraud;

B. Making any untrue statement of a material fact or omitting to state 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. Engaging in any act, practice, or course of business which operates or would 

operate as a fraud or deceit upon any person;

in violation of 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.

Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 3 of 6
[PROPOSED] ORDER OF PRELIMINARY

INJUNCTION

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IT IS FURTHER ORDERED 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 order 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 FURTHER ORDERED that Defendants San Francisco Regional Center, LLC; Thomas 

M. Henderson; California Gold Medal, L.P.; CallSocket, L.P.; CallSocket II, L.P.; CallSocket III, 

L.P.; Comprehensive Care of Oakland, L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; CallSocket, 

LLC; CallSocket II, LLC; CallSocket III, LLC; Comprehensive Care of California, LLC; Immedia, 

LLC; and North America 3PL, LLC are preliminarily restrained and enjoined from, directly or 

indirectly, in the offer or sale of any securities, by the use of any means or instruments of 

transportation or communication in interstate commerce or by the use of the mails:

A. Employing any device, scheme or artifice to defraud;

B. Obtaining money or property by means of any untrue statement of a material fact 

or any omission to state 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. Engaging in any transaction, practice, or course of business which operates or 

would operate as a fraud or deceit upon the purchaser;

in violation of Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a).

IT IS FURTHER ORDERED 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 order 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).

Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 4 of 6
[PROPOSED] ORDER OF PRELIMINARY

INJUNCTION

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IV.

IT IS FURTHER ORDERED that Defendants San Francisco Regional Center, LLC; Thomas 

M. Henderson; California Gold Medal, L.P.; CallSocket, L.P.; CallSocket II, L.P.; CallSocket III, 

L.P.; Comprehensive Care of Oakland, L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; CallSocket, 

LLC; CallSocket II, LLC; CallSocket III, LLC; Comprehensive Care of California, LLC; Immedia, 

LLC; and North America 3PL, LLC are preliminarily restrained and enjoined from directly or 

indirectly participating in the issuance, offer, or sale of any security of any entity controlled by, or 

under joint control with, any of them.

IT IS FURTHER ORDERED 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 order 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).

V.

IT IS FURTHER ORDERED that, except as otherwise ordered by this Court, each of the 

Defendants and Relief Defendants are preliminarily restrained and enjoined from, directly or 

indirectly: destroying, mutilating, concealing, transferring, altering, or otherwise disposing of, in any 

manner, any documents, which includes all books, records, computer programs, computer files, 

computer printouts, contracts, emails, correspondence, memoranda, brochures, or any other 

documents of any kind in their possession, custody, or control, however created, produced, or stored 

(manually, mechanically, electronically, or otherwise), pertaining in any manner to Defendants San 

Francisco Regional Center, LLC; California Gold Medal, L.P.; CallSocket, L.P.; CallSocket II, L.P.; 

CallSocket III, L.P.; Comprehensive Care of Oakland, L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; 

CallSocket, LLC; CallSocket II, LLC; CallSocket III, LLC; Comprehensive Care of California, LLC; 

Immedia, LLC; or North America 3PL, LLC; or to Relief Defendants CallSocket Holding Company, 

LLC; CallSocket III Holding Company, LLC; Central California Farms, LLC; Berkeley Healthcare 

Dynamics, LLC; or JL Gateway, LLC.

Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 5 of 6
[PROPOSED] ORDER OF PRELIMINARY

INJUNCTION

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IT IS FURTHER ORDERED 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 order by personal 

service or otherwise: (a) Defendants’ and Relief Defendants’ officers, agents, servants, employees, 

and attorneys; and (b) other persons in active concert or participation with Defendants or Relief 

Defendants or with anyone described in (a).

IT IS SO ORDERED. 

DATED , 2017 ____________________________

Richard Seeborg 

UNITED STATES DISTRICT JUDGE

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Case 3:17-cv-00223-RS Document 110 Filed 04/07/17 Page 6 of 6