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| | Complaint: Enrico Cortesano, Defendant |
 | | Personal jurisdiction over the Defendant and venue are proper in the Southern District of Florida, as almost all of the actions and transactions alleged and stated herein constituting violations of the Securities Act have occurred within the Southern District of Florida. |
 | | Defendant, directly and indirectly, has made use of the means and instrumentalities of interstate commerce, the means and instruments of transportation and communication in interstate commerce, and the mails, in connection with the acts, practices, and courses of business complained of herein. |
 | | Fraudulent schemes that purport to offer investments in fictitious securities and financial instruments, sometimes referred to as "prime bank instruments," that are allegedly sold by the world's leading banks or "prime banks" have proliferated during the past decade. |
| www.sec.gov /litigation/complaints/comp18458.htm (1315 words) |
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