To: scion who wrote (111232 ) 10/7/2010 8:25:58 PM From: scion Read Replies (1) | Respond to of 122088 SECURITIES AND EXCHANGE COMMISSION Plaintiff v. JEAN R. CHARBIT and TZEMACH DAVID NETZER KOREM, Defendants COMPLAINT Plaintiff Securities and Exchange Commission alleges as follows: I. INTRODUCTION 1. From no later than December 2009 through February 2010, Defendants Jean R. Charbit and Tzemach David Netzer Korem engaged in a fraudulent kickback scheme involving ZNext Mining Corporation, Inc. common stock in violation of the federal securities laws. 2. Charbit, a stock promoter, paid an illegal kickback to a purported corrupt stock broker to induce him to purchase $300,000 worth of ZNext stock for his clients’ discretionary accounts. The kickback consisted of $3,000 in cash and $100,000 worth of ZNext restricted stock. Korem, as ZNext’s transfer agent, issued the stock certificate for the kickback. Unbeknownst to the Defendants, the corrupt broker was actually an undercover FBI agent, and the broker’s middleman was actually a witness cooperating with the FBI. 3. The Defendants created this scheme in an effort to generate the appearance of market interest in ZNext, induce public purchases of its stock, and ultimately increase the stock’s trading price. In doing so, the Defendants intended to sell their own shares of ZNext at an artificially inflated price. 4. As a result of the conduct described in this Complaint, the Defendants violated Section 17(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. § 77q(a); and Section 10(b) and Rule 10b-5 of the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78j(b) and 17 C.F.R. §240.10b-5. Unless restrained and enjoined, they are reasonably likely to continue to violate the federal securities laws. 5. The Commission respectfully requests that the Court enter: (1) a permanent injunction restraining and enjoining the Defendants from violating the federal securities laws; (2) an order directing the Defendants to pay civil money penalties; and (3) an order barring the Defendants from participating in any offering of penny stock. II. DEFENDANTS AND RELEVANT ENTITY A. Defendants 6. Charbit is a French citizen with a residence in Miami, Florida. During the relevant time period, Charbit was involved in the promotion of ZNext’s common stock. 7. Korem is believed to reside in Los Altos, California. Korem goes by many aliases, including Mark Pedley, David Korman, Mark Wellington, and Branch Vindresser. He has a criminal record, including fraud convictions, dating back to the 1980s. Korem created a fictitious country, the Dominion of Melchizedek, which claims “ecclesiastical sovereignty” on an island in the South Pacific, and has its own Website melchizedek.com . It has been the subject of criminal prosecutions in several countries, including the United Kingdom, Australia, and the Philippines, and has been used to charter fictitious companies, banks, and stock exchanges. During the relevant time period (December 2009 through February 2010), Korem drafted press releases for ZNext and served as ZNext’s transfer agent through his company, First Public Securities Transfer. SEC Complaint v. Charbit and Korem sec.gov