ZeekReceiver Going After Paul Burks
by Ted Nuyten on September 6, 2012
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION
SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. Civil Action No. 3:12 cv 519
REX VENTURES GROUP, LLC d/b/a ZEEKREWARDS.COM, and PAUL BURKS, Defendants.
DEFENDANT PAUL BURKS’ RESPONSE TO RECEIVER’S MOTION SEEKING AMENDMENT OF AGREED ORDER APPOINTING TEMPORARY RECEIVER AND FREEZING ASSETS OF DEFENDANT NOW COMES
defendant Paul Burks, and responds in opposition to the motion filed by Kenneth D. Bell (“Receiver”) seeking amendment of the Agreed Order Appointing Temporary Receiver and Freezing Assets of Defendant Rex Ventures Group, LLC (Doc. No. 4) (“Agreed Order”). Mr. Burks opposes the Receiver’s request to expand the definition of “Recoverable Assets,” as it specifically pertains to Paul Burks, beyond the scope of the consent order entered by this Court on August 17, 2012.
In support of this motion, the defendant shows the following:
1. The instant action stems from an investigation by the Securities & Exchange Commission (“SEC”) into Rex Ventures Group, LLC and its sole shareholder Paul Burks. Prior to entering into a consent agreement with the SEC, Rex Ventures Group, LLC operated.
Because it clearly fits within the text and spirit of the Agreed Order, Mr. Burks does not oppose modifying the Agreed Order to enable the Receiver to more clearly define—and better receive—funds identified as “cashier’s checks, certified checks, money orders, and other forms of payment that are being held by the Receivership Defendant that have not been deposited with a bank.” (Doc. 14 ¶ 6) Case 3:12-cv-00519-GCM Document 20 Filed 08/29/12
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