Notice. All statements on this site are allegations, not adjudicated findings, drawn from exemplar pleadings in United States ex rel. M.P. v. Cane et al., No. 1:26-CV-21948-LFL (S.D. Fla.), and reproduced as constitutionally protected petitioning and speech. Each allegation is corroborated by multiple independent sources — sworn statements, court pleadings, SEC/EDGAR filings, and emails. ·– Read the full notice — source, protection & purpose →  ·  The About page gives a site-wide overview of the pages and underlying support material →
Notice — Source, Protection & Purpose

Source. Every factual assertion on this site is drawn from exemplar pleadings in United States ex rel. M.P. v. Cane et al., No. 1:26-CV-21948-LFL (S.D. Fla.). This site is a navigation aid — a way for investigators, judges, and counsel to work through those pleadings and their exhibits in manageable chunks — and is not itself the operative filing.

Protection. The material is reproduced here as constitutionally protected petitioning and speech: a citizen's report to the government and the public about matters of public concern, drawn from documents already filed in, or produced to, courts and agencies.

Corroboration. Every allegation is supported by multiple independent sources — sworn statements, court pleadings, SEC/EDGAR filings, recorded instruments, and emails — and each citation opens the underlying document with footnotes and online cross-references.

All statements are allegations, not adjudicated findings. Nothing here is a finding of liability or guilt by any court; where a matter has been adjudicated, the outcome is noted.

forensic analysis securities · money-laundering corpus
Follow the Stock

The Anatomy of a
Decades-Long Stock-Laundering Pipeline

How attorney Kyleen E. Cane issued private stock to herself and family, ran it through four corporate shells — Tele-Lawyer → Dynamic / LATI → MW Medical → Davi Skin — wrapped each shell around entities that handled federal money, changed her own legal identity to break the paper trail, then sold the stock through CEDE & Co. street name and four Bermuda nominees, liquidating $6.39M offshore below every disclosure threshold. The pipeline ran from a 29 Dec 1995 Nevada incorporation to the 2008 offshore sale, with the concealment — backdated filings, swapped identities, a renewed judgment — still running in 2023: a quarter-century enterprise.

$6.39MSecurities liquidated offshore
$49.3MMedicare billing veneer
$4.8MCARES Act relief, same orbit
85.7%Family bloc, never aggregated
21 yrsZero FBARs · $0 gains reported
3Legal identities, one office
Scroll to explore the evidence v0.4.0
$6.39M
Securities liquidated offshore
$49.3M
Medicare revenue veneer (Genesis)
85.7%
Family bloc, never aggregated
36
Sequential CEDE certificates
4×3.97%
LOM Bermuda nominees
21 yrs
Zero FBARs · $0 gains reported
00

Understanding the Mechanics — Background

Read this first. What follows is not a simple theft. It is a sophisticated securities-fraud and stock-laundering scheme whose moving parts span five professional disciplines at once — securities law, corporate bankruptcy, federal tax and FBAR reporting, offshore private banking, and SEC disclosure mechanics — engineered so that no single regulator ever sees the whole. Following it takes a working grasp of each. The cards below make the machine legible; the full securities-fraud primer explains every concept in plain language.

The thesis, in one sentence. A corporate securities attorney sits at the center as the kingpin of a shell factory — using the trust and access of securities-counsel services to launder private stock into tradeable public shares, loot the corporate assets of the companies she takes over, and defraud the entrepreneurs who hired her — while the offshore proceeds are kept beyond the reach of the IRS. Every concept here, and every section that follows, is a part she pulled to make that work.

Five plain-language concepts make this fraud legible — for judges, investigators, and the public. Each is a lever the enterprise pulled in turn.

CEDE & Co. / DTC

CEDE & Co. is the nominee of the Depository Trust Company — the world's largest securities depository ($50T+). Brokers hold your beneficial interest; DTC holds the master certificates. A "deposit" converts a paper certificate into tradeable book-entry form. Depositing 36 sequential certificates (2029–5323) made private, hidden stock publicly sellable; the sequence proves a single controlled source.

CUSIP

A CUSIP is the 9-character "fingerprint" of a public security. It turns stock into an official asset class institutions and foreign entities can hold. Running worthless private Tele-Lawyer stock through public shells gave the hidden position a CUSIP — real market value with no legitimate business behind it.

Regulation S

Reg S lets issuers sell to foreign investors without SEC registration; the shares resell into the U.S. after a holding period. The abuse: transfer stock to offshore nominees in Bermuda (LOM), wait out the restriction, and collect proceeds offshore, untaxed, while the shares trade freely onshore.

The shell-selling model

Why pay $250K–$500K for a corporate shell? To sell a hidden position. Swap private shares into a listed shell, then sell into the market. The seller wins twice — cash for the shell and a retained hidden position later liquidated offshore. It is, functionally, stock laundering.

read the full securities-fraud primer shell companies · reverse mergers · Reg S & opinion letters · CEDE/DTC · §1145 · SOX · qui tam · RICO · FBAR
Primer · concepts underlying the transformation pipeline below

The Scheme at a Glance — Hover Any Step

The entire pipeline on one strip — each box is an entity or a move, each arrow is how the same insider stock travels to the next hop, ending at the terminal pump-and-dump. Hover (or tap) any box for what happened and when; hover the arrows for how the stock moved between them. The scroll-driven diagram further down walks the same chain step by step.

Shell / parking entity Operational veneer Offshore / nominee channel
1Tele-Lawyer, Inc.from May 1989 · private NV
1:1 spin-off →
2MW Medical, Inc.11 Mar 1998 · CIK 1059577
153:1 reverse split
3Dynamic → Legal Access Tech.12 Jun 2001 · CIK 878146
5 × 13G, same day
4Family Bloc Concealment18 Jun 2001
Ch.11 reconcentration
5MW Medical — Chapter 1122 Jan 2002 · 02-bk-01090 (D. Ariz.)
rename · CIK retained
6Davi Skin, Inc.24 Jun 2004 · CIK 1059577
→ DTC street name // → Bermuda
7Channel 1 — CEDE & Co. (Cane's Shares)2004–2007 · from Dynamic
8Channel 2 — Wallace's $200k Note → LOM3 Apr 2007 · Bermuda

Enterprise genealogy — Tele-Lawyer → Davi Skin, with the offshore channels

The shell factory — a genealogy of concealment

One entity issues the stock; another dumps it. Everything between — the reverse mergers, the renamings, the manufactured bankruptcy, the §1145 shell sales, the offshore nominees — is engineered for a single purpose: to conceal who owns the stock and to loot the companies of the entrepreneurs who built them.

This diagram is the "six years of concealing that ownership" drawn out in full. Each box moves control one hop further from the visible record while keeping it firmly in Cane's hands; each arrow is a corporate event — issuance, spin-off, merger, bankruptcy, name change, transfer — chosen because it severs a link in the chain of title.

The sophistication is the point. The forethought, the discipline of controlling every entity at every step, and the practiced removal of management and outside shareholders mark this as a designed system, not opportunism — pursued with apparent indifference to breaking essentially every federal securities, tax, bankruptcy, and wire-fraud law in its path.

May 1989 — mergerJun 12, 2001 · 153:1DAI / LATI operating subsspun out · Mar 1998§1145 shells → insiders1-for-500 rebrandchannel 2 · Wallace's $200k note → 4 LOMchannel 1 · Cane's shares · Dynamic → CEDETele-Lawyer — Private NV Corp (May 1989, Cane private entity) Cane's private Nevada corporation (her founder/CEO vehicle from May 1989). The merger into Dynamic was signed 28 Nov 2000; Tele-Lawyer holders later took 5,354,997 post-split LATI shares (91.6%) — Cane alone 2,871,051 (48.7%) + 50,000 options. The seed equity the whole pipeline exists to monetize. Tele-Lawyer Private NV CorpMay 1989 Cane private entityDynamic Assoc. — CIK 878146 · Public (Jul 20, 1989, NV shell · CUSIP) Dynamic Associates (inc. 20 Jul 1989; SIC 6770 blank-check) claimed $30M raised but documented $8.6M, filing 134 SEC documents with no operations. On 12 Jun 2001 Tele-Lawyer reverse-merged in (8-K 0001075793-01-500140); a 153:1 split wiped 99.35% of the float (75M → 490,096 public shares); renamed LATI. Dynamic Assoc. CIK 878146 · PublicJul 20, 1989 NV shell · CUSIPLATI — 153:1 reverse split (Jun 12, 2001, 85.7% family bloc) Dynamic Associates (inc. 20 Jul 1989; SIC 6770 blank-check) claimed $30M raised but documented $8.6M, filing 134 SEC documents with no operations. On 12 Jun 2001 Tele-Lawyer reverse-merged in (8-K 0001075793-01-500140); a 153:1 split wiped 99.35% of the float (75M → 490,096 public shares); renamed LATI. LATI 153:1 reverse splitJun 12, 2001 85.7% family blocGenesis Health — Medicare $49.3M Genesis Health Medicare $49.3MP&H Industries — sold ~$5M P&H Industries sold ~$5MMicrothermia — device tech Microthermia device techMW Medical — Ch.11 BK · §1145 (Dec 1997 / 2002, Wallace sole creditor) Board voted Chapter 11 on 29 Nov 2001 (three directors resigned that day); filed 22 Jan 2002. Wallace, sole secured creditor on $615,871 of notes, converted $375,000 → 74,000,000 shares at $0.005 (77.4%). §1145 then distributed five no-op shells to insiders — MW Asia (95% Sim), MW Europe (Drummond), NW S. America (Brown), MW Fitness & Microwave Debtor (Wallace) — sold $250K–$500K each (Beardmore: $250K for MW Asia). MW Medical Ch.11 BK · §1145Dec 1997 / 2002 Wallace sole creditorMW Asia — 95% Grace Sim MW Asia 95% Grace SimMW Europe — Dean Drummond MW Europe Dean DrummondNW S. America — Tyler Brown NW S. America Tyler BrownMW Fitness — Wallace · $250–500K MW Fitness Wallace · $250–500KDavi Skin — 1-for-500 split (Jun 24, 2004, CIK 1059577 · 36 CEDE certs) MW Medical (CIK 1059577 retained) rebranded Davi Skin on 24 Jun 2004 with outside investors Parrish Medley and Carlo Mondavi as cover — marks for a shell-liquidation scheme. A 1-for-500 reverse split (far past the earlier 153:1) re-concentrated the float. Wallace CEO, Cane director, Sim CFO — the terminal liquidation vehicle. Davi Skin 1-for-500 splitJun 24, 2004 CIK 1059577 · 36 CEDE certsCEDE & Co. — DTC street name (2004–2007, 2,249,825 sh) Cane's shares — traced Dynamic → MW Medical → Davi Skin via the 1:1 spin-off — placed into CEDE & Co. / DTC street name: 36 sequential certificates (Nos. 2029–5323), 2,249,825 shares. One certificate, No. 5304 (5 Mar 2007), moved 946,085 — 16% of the float. Wallace showed only 100 shares (cert 5064) on the register. CEDE & Co. DTC street name2004–2007 2,249,825 shArch Ltd. — 3.97% · LOM (Apr 3, 2007, 573,847 sh) A separate operation, structuring different stock: Wallace asserted a fictitious $200,000 Davi Skin note (already resolved in the bankruptcy) and on 3 Apr 2007 converted it to 2,295,388 shares — certs 5309–5312, exactly 573,847 (3.97%) each — to four LOM nominees at 27 Reid Street, Hamilton: Arch (5309), Hepburn (5310), Chloe (5311), Sunshine (5312). Combined 15.88%, zero Schedule 13D. Arch Ltd. 3.97% · LOMApr 3, 2007 573,847 shHepburn Hldgs — 3.97% · LOM (Apr 3, 2007, 573,847 sh) A separate operation, structuring different stock: Wallace asserted a fictitious $200,000 Davi Skin note (already resolved in the bankruptcy) and on 3 Apr 2007 converted it to 2,295,388 shares — certs 5309–5312, exactly 573,847 (3.97%) each — to four LOM nominees at 27 Reid Street, Hamilton: Arch (5309), Hepburn (5310), Chloe (5311), Sunshine (5312). Combined 15.88%, zero Schedule 13D. Hepburn Hldgs 3.97% · LOMApr 3, 2007 573,847 shSunshine Ltd. — 3.97% · LOM (Apr 3, 2007, 573,847 sh) A separate operation, structuring different stock: Wallace asserted a fictitious $200,000 Davi Skin note (already resolved in the bankruptcy) and on 3 Apr 2007 converted it to 2,295,388 shares — certs 5309–5312, exactly 573,847 (3.97%) each — to four LOM nominees at 27 Reid Street, Hamilton: Arch (5309), Hepburn (5310), Chloe (5311), Sunshine (5312). Combined 15.88%, zero Schedule 13D. Sunshine Ltd. 3.97% · LOMApr 3, 2007 573,847 shThe Chloe Grp — 3.97% · LOM (Apr 3, 2007, 573,847 sh) A separate operation, structuring different stock: Wallace asserted a fictitious $200,000 Davi Skin note (already resolved in the bankruptcy) and on 3 Apr 2007 converted it to 2,295,388 shares — certs 5309–5312, exactly 573,847 (3.97%) each — to four LOM nominees at 27 Reid Street, Hamilton: Arch (5309), Hepburn (5310), Chloe (5311), Sunshine (5312). Combined 15.88%, zero Schedule 13D. The Chloe Grp 3.97% · LOMApr 3, 2007 573,847 sh

Davi Skin — The Pump-and-Dump

Davi Skin is where the stock was finally sold. It is the terminal entity of the whole pipeline — the public listing the laundered shares were walked toward for years, then dumped into the market. The mechanics are written in the certificate register: on 5 March 2007, certificate 5304 moved 946,085 shares — 16% of the float — into CEDE & Co. / DTC street name in a single deposit; 29 days later, on 3 April 2007, certificates 5309–5312 placed 2,295,388 shares with four Bermuda LOM nominees at exactly 3.97% each. Together the enterprise controlled 4,545,213 shares — 76.69% of the free float and roughly 89% of trading volume, liquidated across 2007–08 for $6,385,033 into Bank of Bermuda and N.T. Butterfield.

The setup, though, was years in the making. It begins where the pipeline begins: Cane issued herself the controlling block of the shell2,871,051 shares (48.7%) of Dynamic Associates / Legal Access Technologies in June 2001 — then spent six years concealing that ownership. The block was layered through corporate re-skins (Dynamic → MW Medical → Davi Skin, the reporting CIK travelling intact), masked behind a legal name and gender change (Michael A. Cane → Kyleen E. Cane), and finally split into DTC street name and offshore nominees — while federal filings were signed under a name that was no longer legal and the same ownership was misrepresented to courts and federal authorities. By the time the certificates were placed for sale, the controlling owner had been erased from the visible record. What follows is what was sold, and how it was placed.

The anomaly, dated
  1. 25 Nov 2003Court order D308221: Michael Allan → Kyleen Elisabeth — name & gender change
  2. May 2004Divorce / property transfer to Susan Eiselman — still under Cane's control
  3. 10 May 2004Annual meeting approves the 500-for-1 reverse split
  4. 24 Jun 2004MW Medical renamed Davi Skin (DAVN); SIC pivots to 2844 (cosmetics)
  5. 20 Jul 2004SC 14F1 change-of-control · Wallace convertible note $570,775.30
  6. 15 Sep 2004S-8 + opinion of counsel (McDonald · Carano · Wilson)
  7. 2004–200736 sequential CEDE & Co. certs (Nos. 2029–5323) → 2,249,825 sh into DTC
  8. 23 May 200510-QSB Reg S — units sold to four foreign investors
  9. 2005–2006SEC staff comment letters challenge the Reg S issuances
  10. 5 Mar 2007Cert 5304 deposits 946,085 shares — 16% of float in one deposit
  11. 3 Apr 2007Certs 5309–5312 → four LOM Bermuda nominees · 2,295,388 sh
  12. Jan–Nov 2008DAVN trading window: 11 volume dislocations, 1 confirmed control event
  13. 27 Aug 2012Final EDGAR filing · registration REVOKED
Price & volume — the dump pump-and-dump details day-by-day chart
$0.00$0.05$0.10$0.15JanFebMarAprMayJunJulAugSepOctNov

Across 120 trading sessions in 2008 the close collapses from $0.19 to $0.003 while volume erupts through eleven dislocations — sessions where volume runs ≥ 3× the trailing-30 median alongside a double-digit move; one is confirmed by a control event within three weeks. Hover any bar for that day's close and volume, or tap the chart for the full pump-and-dump detail. The June–September 2007 sell-off, run through the CEDE and LOM channels, generated approximately $6,385,033 in proceeds into the Bermuda accounts before the shell was abandoned.

Certificate placement — what was staged, then sold

The certificate register records the operation in two halves. From 2004 through 2007, thirty-six sequential deposits (certificates 2029–5323) walked 2,249,825 shares into CEDE & Co. / DTC street name — the block quietly staged for sale. The placement then accelerated in the weeks before the offshore transfer: on 5 March 2007, certificate 5304 moved 946,085 shares — sixteen percent of the float — into DTC in a single deposit (→ shareholder register, CEDE & Co., p. 3); twenty-nine days later, on 3 April 2007, certificates 5309–5312 placed 2,295,388 shares with four LOM Bermuda nomineesArch (5309), Hepburn (5310), Chloe (5311), and Sunshine (5312) — at exactly 3.97% each, a hair under the five-percent line that would have forced a Schedule 13D disclosure of identity, source of funds, and purpose. None of it was disclosed.

The same window is where the frame shows. Behind the Hepburn Holdings block, Wallace — claiming she had breast cancer — pressed the relator to serve as trustee for her daughter, drawing him into the paperwork for the Chloe / Hepburn offshore nominee. She emailed him for his Social Security number “for the form 3 filing … for your davi shares,” and, in the 2008 sale window, used a consulting-agreement pretext to harvest Kenn Gordon’s home address and Social Security number “to issue shares from transfer agent” — manufacturing a paper trail to implicate others in the offshore structure, not placing a genuine block. The record fixes the two real placements and their recipients; tying any single 2008 trading session to a specific block would take trade-level DTC withdrawal data the corpus does not hold. Every placement, filing, and email is laid out by date against the 2008 price and volume in the day-by-day chart.

The filing agent — shared, then switched at the dump
LATI · CIK 878146Davi Skin · 1059577Kyleen Cane · 114403020012004200720102012

For years a single EDGAR filer — 0001255294, Cane O'Neill Taylor / Cane Clark — prepared the filings for LATI (878146), for Davi Skin and its MW Medical predecessor (1059577), and for Cane's own Schedule 13D (CIK 1144030): the filer-agent overlap that ties the entities to one office (Cane Clark was registered agent for 202 Nevada entities). Then the fingerprint is scrubbed. Cane Clark's last Davi filing of record is 14 May 2007; the 2007 10-QSBs move to Vintage Filings (CIK 1144204), the FY2007 10-KSB and Q1 2008 10-QSB to Baum Law Firm (CIK 1173473 · La Jolla, CA), and — right before the July 2008 dump — to Format Inc. /FA/ (CIK 1137091), which filed the Q2 2008 10-Q (Acc. 0001137091-08-000436, 14 Aug 2008). That filer was later renamed twice and is today Power Solutions International, Inc. (201 Mittel Drive, Wood Dale, IL 60191). LATI, after toggling agents in 2005–06, simply went dark.

precrime_score · structural risk, from EDGAR filings alone — no narrative input

The dump could have been predicted. A "precrime" model scores each EDGAR entity from its submission record alone — form types, cadence, filing agents, name history, blank-check shells, parked insider stock. By the eve of the 2007 dump, Davi Skin's lineage had already tripped a stack of these flags: a blank-check shell reverse-merged and renamed, a reporting CIK recycled through two re-skins, a manufactured Chapter 11, a single filing agent across "unrelated" issuers — then that filing agent switched right before the sale. Enough structural signal preceded the dump that the model would have flagged it.

That is the investigative lever for a regulator or government contractor: precrime can't see the off-EDGAR cert deposits, but it pinpoints which entities and which date windows to act on — so a subpoena to the transfer agent or to the DTC / CEDE & Co. depository can pull the certificate-level records that EDGAR never shows, at the moment they matter. It turns a firehose of filings into a short, dated, prioritized watchlist. Precrime flags the factory; the targeted subpoena retrieves the final sale.

score(e) = Σh∈H wh · 𝟙[ h fires on e ]      wh ∈ {2, 3}
flag(e)  = 1   ⟺   nsig(e) ≥ 2   ∧   score(e) ≥ τ   (τ = 3)

16 heuristics (name-recycling, shell-reactivation, reverse-merger chain, filer-agent overlap, going-dark blackout, Reg-S issuance, opinion-letter, calibrated sub-5% positions …) each cast a weighted vote; a lone signal is never flagged. Max score 38. On the model's validation set it fired a mean of 6.6 years before any public action. The same heuristics would have surfaced Davi Skin by 2004 and LATI as early as 1996 — years before the 2007 dump. No enforcement has ever followed against either.

T1 · score ≥ 10 · daily T2 · 6–9 · weekly T3 · 3–5 · quarterly
28/38
Davi Skin · CIK 1059577 · 12 signals · Tier 1
≥24/38
LATI / Dynamic · CIK 878146 · Tier 1 · trips 1996

The full precrime analysis

The complete model, the entity genealogy, the per-case findings for both Cane CIKs, and the related accessions are combined on a single companion page:

Structural scoring of SEC EDGAR submissions · forward signal, not an adjudicated finding
01

The Transformation Pipeline

Now start at the beginning. You've seen the terminal dump and how the certificates were placed; the rest of this report goes back to the start and walks the chain that produced it, one hop at a time. Follow the stock. The scheme begins by concealing who controls a private company — Tele-Lawyer, where the Cane family held the equity outside any SEC scrutiny. When that private stock is taken public, control is split across the family in a Family Bloc — five same-day SC 13G filings (18 Jun 2001). Each holder was individually over 5% (Cane 48.7%, Shirley Cane ~5.35%, the Mekelburgs ~31.65%) and disclosed that stake — but the filings concealed that the five were one coordinated group under Cane, a §13(d)(3) group that together held 85.7% and was required to file as a bloc. From there the same shares are walked through a chain of shells — Dynamic, MW Medical, and finally Davi Skin, the terminal entity: the public listing where the laundered stock is pumped and dumped and the proceeds routed offshore. Read the diagram below as that journey, hop by hop.

Each transformation moved the same insider stock one step closer to a tradeable, liquidatable asset — while the controlling identity was concealed at every hop. The reporting CIK travels intact from MW Medical through Davi Skin (CIK 1059577), so a single hidden shareholder register survives four corporate re-skins. The public listing itself was acquired through a blank-check shell carrying CIK 878146.

Shell / parking entity Operational veneer Offshore nominee layer
1
Tele-Lawyer, Inc.29 Dec 1995 · NV C23375-1995
Private Nevada incorporation. Cane is sole officer; stock issued to herself and family entirely outside SEC scrutiny — the seed position the entire pipeline exists to monetize.
Private equity originNV Corp.detail
1:1 spin-off →
2
MW Medical, Inc.11 Mar 1998 · CIK 1059577
Spun out of Dynamic Associates by a 1:1 distribution that mirrors the register into a reporting shell. Wallace CEO; counsel signs as "Michael A. Cane." Healthcare ops (Genesis, $49.3M Medicare) supply a commercial veneer.6
Operational cover + reporting CIK10-KSBdetail
153:1 reverse split
3
Dynamic → Legal Access Tech.12 Jun 2001 · CIK 878146
Tele-Lawyer reverse-merges into Dynamic Associates (SIC 6770 blank-check shell); renamed LATI. A 153:1 reverse split wipes out 99.35% of the public float; 5,354,997 shares (91.6%) land with the Tele-Lawyer holders.2
Reverse merger · public listing acquired8-K/Adetail
5 × 13G, same day
4
Family Bloc Concealment18 Jun 2001
Cane's own issuance: the Schedule 13D reporting Cane's 48.7% (2,871,051 sh) of the shell, signed "Michael A. Cane."3 On the same date, five Schedule 13G filings — Cane plus Shirley Cane and the Mekelburg bloc — brought coordinated family control to 85.7%, never aggregated or disclosed as a group.5
Reported 48.7% · actual 85.7%SC 13G ×5detail
Ch.11 reconcentration
5
MW Medical — Chapter 1122 Jan 2002 → plan 28 Jun 2002
Wallace engineers a sole-secured-creditor position over all assets, then converts debt to equity: 74,000,000 shares at $0.005 (74.1%) under the confirmed Joint Plan of Reorganization.12 A 1:500 reverse split resets the float. Outside equity is extinguished through the bankruptcy.11
Bankruptcy weaponized · In re MW Medical, 02-bk-01090 (Bankr. D. Ariz.)Ch. 11 Plandetail
rename · CIK retained
6
Davi Skin, Inc.24 Jun 2004 · CIK 1059577
The reorganized MW Medical shell is rebranded a skincare company — the CIK carries straight through. Wallace CEO, Cane Director, Sim CFO. A legitimate-looking venture (Medley / Mondavi capital) becomes the terminal liquidation vehicle.
Terminal vehicle primed10-KSBdetail
channel 1 → DTC street name
7
Channel 1 — CEDE & Co. (Cane's Shares)2004–2007 · DTC
Cane's shares, traced from Dynamic, into CEDE & Co. / DTC street name: 36 sequential certificates (Nos. 2029–5323), 2,249,825 shares — deposited 2004 (3 certs) · 2005 (9) · 2006 (14) · Jan–Jun 2007 (10). One certificate, No. 5304, deposited 5 Mar 2007, moved 946,085 shares (16% of float).35
Channel 1 · Cane's shares · DTCTransfer-Agent Reportdetail
separate operation · different stock
8
Channel 2 — Wallace's $200k Note → LOM3 Apr 2007 · Hamilton
A separate operation, structuring different stock. Wallace's fictitious $200,000 Davi Skin note31 converted to 2,295,388 shares, issued as four certificates on 3 Apr 2007 — 573,847 (3.97%) each: 5309 Arch, 5310 Hepburn, 5311 Chloe, 5312 Sunshine — to 27 Reid Street, Hamilton. Combined 15.88%, zero Schedule 13D; proceeds ~$6.39M offshore.
Channel 2 · Wallace's note · LOMShareholder Reportdetail

Expand any entity in the chain:

Dynamic / LATI MW Medical Davi Skin

Family Bloc — The Five Same-Day Filings 5

On a single 24-hour window, five "independent" reporting persons filed for the same issuer — each below a disclosure line, none disclosing a group. The fields that tie them to one office are bolded.

HolderAddressPhoneFiledShares% classFiling
Michael A. Caneself · principal Henderson NV 89014 (702) 312-6252 28 Jun 2001 2,871,051 48.7% SC 13D
Herb & Shirley Canemother & father Henderson NV 89014 29 Jun 2001 312,500 5.35% SC 13G
Brian Mekelburgsibling · Brian M. Cane Marina del Rey CA 29 Jun 2001 312,500 5.35% SC 13G
Myrna L. Mekelburgextended family Las Vegas NV 29 Jun 2001 600,000 10.27% SC 13G
Nancy Mekelburgsibling · Nancy M. Cane Pacific Palisades CA 29 Jun 2001 312,500 5.35% SC 13G
Reported across these 5 filings * 4,408,551 75.02% no group

* All five statements report the same 18 Jun 2001 event, were transmitted by a single EDGAR filer (0001075793, Cane Clark), and name the Cane office as the issuer — the through-line that ties the “independent” holders to one desk.

(702) 312-6252 — Cane's law-office line is the sole notice contact on the 13D; the 13G holders list none 89014 — Cane and her parents share the Henderson ZIP; "mother" Shirley Cane filed the same day 312,500 — three "unrelated" holders hold the identical block, consistent with equal allotment, not market purchases one EDGAR filer (0001075793, Cane Clark) submitted all five "independent" statements individual 48.7% sits just under the 50% control line; no joint-filing agreement was ever disclosed

The bloc's "Mekelburg" holders are Cane's siblings: Brian and Nancy Mekelburg appear in the family record as Brian M. Cane and Nancy M. Cane — Mekelburg is the siblings' married surname — and the Mekelburg Family Trust (executor Stuart Cane) holds more. The parents Herb & Shirley Cane filed the same day, three days after Cane herself.

Two operators, one enterprise — and the marks

Every entity from Dynamic to Davi Skin, and the SDI / Galaxy Gaming permutations, sat under the control of Kyleen Cane — the architect and kingpin. As the securities attorney, Cane alone held the legal authority and the expertise to build the scheme: she was counsel, beneficial owner, director, and EDGAR filer, and she dictated each corporate step. Jan Wallace was her agent and instrument — installed as CEO and the manufactured sole secured creditor to front the entities and execute the bankruptcies, but without the sophistication or the authority that only the lawyer commanded. They acted together at every hop — Cane directing, Wallace executing — and at times secretly: the outside names brought in for cover — Parrish Medley and Carlo Mondavi at Davi Skin, shell purchasers such as Beardmore ($250K for MW Asia) — were marks, unaware they were fronting or buying a vehicle already hollowed out and pre-positioned for liquidation. The same playbook that perfected the takeover then obscured the evidence: a backdated identity to sever the trail, CEDE & Co. to anonymize ownership, a bankruptcy to extinguish the shareholders who might ask questions, and a filing-agent switch as the dump began. The same machinery recurs in the related schemes, in chronological sequence — the Wallace identity infrastructure (from 1981), the Thomas & Wong attorney-escrow loan fraud (2002), United States v. DiScala (2012–2018), and the “Voters for Hillary” SuperPAC (2014). Every one of these threads is pleaded together in the filed qui tam complaintUnited States ex rel. Phillips v. Cane et al., No. 1:26-CV-21948-LFL (S.D. Fla.).

Review the enterprise-scale RICO complaint against the enterprise

concentration_ratchet · insider / enterprise control of float, by stage

0%25%50%75%100% 50% control line 100%91.6%85.7%89.9%74.1%76.69%Tele-Lawyer153:1 merge13G bloc+ Wallace/SimCh.11 74MDavi

Public shareholders are crushed (99.35% of the float wiped at the 153:1 split) while enterprise control never drops below ~74%.

Sequence per the entity-transformation chain · SEC EDGAR CIK 878146 / CIK 1059577

Scheme Diagram — Figure 1–2 (Static)

The static companion to the animated pipeline above — the whole enterprise on one page. The scheme resolves into three CIK-coded entity chains (CIK 878146 · CIK 1059577 · CIK 13156), each a corporate lineage that carried the same insider stock forward under a new name. Click either panel to open the source figure67, or open the animated pipeline figure in its own tab.

Entity genealogy — one register, many re-skins

Read the diagram as genealogy, not a org-chart. A company on EDGAR is identified by a permanent CIK — a number that survives every rename, reverse split, and reverse merger. The scheme exploits that permanence: Chain 1 (CIK 878146) runs Tele-Lawyer → Dynamic Associates → Legal Access Technologies (LATI) — a private Cane-family company reverse-merged into a blank-check shell so the family's stock inherits a public listing. Chain 2 (CIK 1059577) runs MW Medical → Davi Skin — one reporting shell, spun from Dynamic by a 1:1 distribution that mirrors the shareholder register, then re-skinned into the terminal pump-and-dump vehicle. Chain 3 (CIK 13156) runs Secured Diversified Investment → Galaxy Gaming — the same operators recycling a second shell. Because the CIK travels intact, a single hidden shareholder register survives four corporate re-skins: the public-facing name changes, but the concentrated insider ownership underneath does not.

The concealed certificate trail — from private stock to offshore street name

Follow the certificates, not the names. The genealogy exists to move one block of insider stock from a private company nobody could scrutinize into anonymous, free-trading, liquidatable shares — while erasing where it came from at every hop. (1) Origin: Tele-Lawyer issues stock to Cane and family entirely outside SEC scrutiny — the seed position. (2) Public listing: the reverse merger into Dynamic and a 153:1 reverse split wipe 99.35% of the outside float, landing 91.6% with the Tele-Lawyer holders. (3) Group concealment: five same-day Schedule 13G filings (18 Jun 2001) split coordinated family control — 85.7% — into individually-disclosed stakes that were never aggregated as the §13(d)(3) group they were.5 (4) Reconcentration: the MW Medical Chapter 11 converts a Wallace-held note to 74,000,000 shares (74.1%) and extinguishes the outside equity that might ask questions.12 (5) Offshore placement: at Davi Skin a concealed $200,000 note is converted to 2,295,388 shares (15.9%) in four equal blocks to the LOM Bermuda nominees (certs 5309–5312), and 36 sequential CEDE & Co. certificate deposits move 2,249,825 shares into anonymous street name for liquidation offshore.35 Each step severs the certificate from its prior-entity provenance — the very thing the diagram reassembles.

Why shell cycling matters

The re-skinning is not cosmetic — it is the laundering mechanism itself. Every cycle does three things at once: it resets the float (a reverse split erases the outside holders on paper), it launders provenance (a new name and ticker detach today's shares from the fraud that created them), and — through an engineered bankruptcy — it extinguishes the outside shareholders who could testify to what happened. What emerges each time looks like a clean company with a new story, while the concentrated insider block rides the permanent CIK forward, one step closer to tradeable offshore cash. That is why the genealogy is the case: prove the lineage and the "unrelated" Bermuda nominees, the "clean" post-bankruptcy shell, and the "new" public company all resolve back to the same private Cane-family stock. The full narrative is pleaded in the qui tam complaint; the entity roster and CIK cross-reference sit on the EDGAR entities page .

02

Three Names, One Office — and a Family Built to Hide One Person

One person — admitted to the California Bar in 1979 as Michael A. Cane (No. 87106) — has used three legal names and, in Nevada, a separate professional name (Bar No. 5900). The change to "Kyleen E. Cane" was reported to the SEC as effective 28 Jun 2001, sixteen days after the reverse merger; it actually occurred by court order on 25 Nov 200323 and was recorded in Nov 2004.24 From 2019 to 2023 the "Cane" and "Castro" names ran concurrently from a single Las Vegas office (3273 E Warm Springs Rd), selected by forum — Castro to the Secretary of State, Cane to the courts. The backdated date was wired to EDGAR twice, each transmission a discrete wire-fraud act under 18 U.S.C. §1343.21

Michael A. Cane
1979 — 2003
Cal. Bar No. 87106. Reverse-merger counsel and EDGAR filing agent (filer 0001255294). The identity that performed the foundational conduct.
Kyleen E. Cane
claimed 2001 / actual 2003 →
Nev. Bar No. 5900. The identity named in the DOJ indictment United States v. DiScala (E.D.N.Y.)40 and the civil RICO complaints.
K. E. Castro
2019 →
Used to form and maintain Nevada LLCs from the same office. The same person authored a 2024 UC Irvine Ph.D. dissertation as "Kyleen Elisabeth Castro."27

expand · three names, one person — the full record

The Résumé Pack — Cane → Castro (7 pp.)27

One document carries the through-line: the same career history — B.A. U.C. Irvine 1975, USC J.D. 1978 (Order of the Coif), the Tele-Lawyer / Legal Access Technologies companies, the 2024 U.C. Irvine Ph.D. — repeated verbatim from "Michael A. Cane" to "Kyleen E. Cane" to "Kyleen Elisabeth Castro." Page through all seven; the descriptions map each page.

Cane → Castro résumé side-by-side (7 pp.) 1 / —
loading page…
  1. 1Biographies (1 of 2) — “Michael A. Cane” vs “Kyleen E. Cane” (2001) Las Vegas Gaming director bios: same degrees, honors, companies.
  2. 2Biographies (2 of 2) — “Kyleen E. Cane” (2001) vs “Kyleen Elisabeth Castro” (2024 U.C. Irvine Ph.D. CV): the same credentials again.
  3. 3Credential-overlap table — every distinctive credential (B.A. U.C. Irvine 1975; J.D. USC 1978, Order of the Coif) recurs across all three names.
  4. 4The universe of Cane-controlled firms — the law-firm continuum (Wellman & Cane → Cane & Company …) at one Las Vegas address cluster.
  5. 5Identity field/value table — legal names, date of birth, California Bar No. 87106, other bar memberships.
  6. 6Composite forensic CV — Castro f/k/a Cane f/k/a Michael Allan Cane; concurrent Cane/Castro use 2019–2023 from one office; DOB Oct 22, 1954.
  7. 7Concurrent-use detail — Westward Law (2019) & DKM Development (2021) as “K E Castro”; World Series of Golf (2019) & the 2023 renewal affidavit as “Kyleen E. Cane.”
How the family concealed a single controlling person

The 85.7% family bloc was never filed as a group. Splitting one control position across related holders kept every individual filing under an aggregation trigger, so no Schedule 13D "group" was ever declared and the controlling person stayed invisible across the whole chain.

Kyleen E. Cane
self · principal
48.7%
2,871,051 sh
Shirley Cane
mother
~5.35%
family holder
Mekelburg bloc
extended family
~31.65%
coordinated
85.7%
Coordinated family control of LATI / Davi Skin — Cane 48.7% + Shirley Cane ~5.35% + Mekelburg ~31.65% — held in pieces, never aggregated in any SEC filing. Each piece sits under a disclosure line; together they are a single voting bloc.5
The backdated identity, in sequence
03 JUL 1979

Admitted as "Michael A. Cane"

California Bar No. 87106 — the same membership record now reads "Kyleen Elisabeth Cane." A USC J.D. (1978, Order of the Coif) carried verbatim across every later name.26

Bar Record
12 JUN 2001

Reverse merger executed — as Michael A. Cane

Tele-Lawyer into Dynamic / LATI. The foundational securities transaction is performed under the Michael identity.3

SC 13D
28 JUN 2001 — CLAIMED

Reported name change to "Kyleen E. Cane"

The effective date later reported to the SEC — 16 days after the merger, and roughly 2.5 years before the actual court order.

backdated · not disclosed for 1,120 days
DEC 2002 – SEP 2003

Six LATI SOX certifications — "Michael A. Cane"

§302 / §906 certifications signed under the former identity, +533 to +809 days after the claimed change. SOX certs carry criminal liability under 18 U.S.C. §1350.25

10-KSB / SOX
25 AUG 2003

Buys a home as "Michael A. Cane"

15 Quail Hollow Drive, Henderson NV — $575,000, purchased under the Michael identity more than two years after the claimed change and three months before the actual order.

still "Michael" in 2003
25 NOV 2003 — ACTUAL

Court order changes name & gender

In re Michael Allan Cane, Case No. D308221, Dept. E (8th Jud. Dist. Ct., Clark County) — Michael Allan → Kyleen Elisabeth. Cane appeared as her own counsel, "Michael A. Cane, Esq., Bar No. 5900."23

Court Order
22 JUL 2004

Form 5 wired to EDGAR — backdated date

First SEC filing as "Kyleen E. Cane" carries the false June 2001 effective date (+1,120 days). An interstate wire transmission of a false statement — a §1343 predicate.21

Form 5
05 NOV 2004

Form 4 re-transmits the backdated identity

Signed "/s/ Kyleen Cane" and uploaded to EDGAR four days before the 2003 order was recorded (9 Nov 2004) — a second, independent §1343 wire.22

Form 4
24 MAY 2019

"K E Castro" appears — Westward Law, LLC

Nevada annual list filed as Manager "K E Castro" at 3273 E Warm Springs Rd — the earliest Castro filing of record. The concurrency begins.30

NV Annual List
04 JUN 2019

"Kyleen Cane" — World Series of Golf, LLC

Eleven days after the Castro filing, an annual list filed as "Kyleen Cane" — same office, different name.29

11 days apart · same addressNV Annual List
10 APR 2023

Sworn affidavit as "Kyleen E. Cane"

Renews a $4,888,924.78 judgment in Cane v. Phillips (No. A-16-743194-C); served by certified mail and filed electronically — mail (§1341) and wire (§1343) transmissions, sworn as Cane while Castro was active at the Secretary of State.41

mail + wire · Bar No. 5900Affidavit of Renewal
~2.5 yrs
The reported name-change date (28 Jun 2001) predates the actual court order (25 Nov 2003) by roughly two and a half years. Cane bought a home as "Michael A. Cane" in Aug 2003 and signed six LATI SOX certs as Michael through Sep 2003 — then wired the backdated date to EDGAR twice in 2004, each an independent §1343 predicate.
Efforts to conceal: litigation weaponized by forum-selected identity

Cane used two Nevada civil actions as cover and intimidation, filing and swearing as "Kyleen E. Cane" in court while simultaneously operating as "K E Castro" before the Secretary of State — a deliberate split that keeps the two paper trails from being joined.

Cane v. Dhillon
No. A-11-648485-C
filed 16 Sep 2011 · against the firm representing Phillips68
Cane v. Phillips
No. A-16-743194-C
filed 6 Sep 2016 — $4.8M default judgment (19 Jun 2017)42 entered while Cane was on federal pretrial release in U.S. v. DiScala (EDNY)39

The concealment reaches the household. Susan Eiselman — Cane's wife — has continued to live with Cane through the 2003 gender change and after; the 2004 transfer of the marital home, papered as a divorce settlement, functioned as a way to split and shield assets rather than an actual separation.

concurrent use · one office · 3273 e warm springs rd, las vegas nv 89120

filed as "K E Castro"
entity formation
Westward Law LLC (24 May 2019) · DKM Development LLC (16 Aug 2021)30
sworn as "Kyleen E. Cane"
litigation & oath
World Series of Golf LLC (4 Jun 2019) · affidavit, Cane v. Phillips (10 Apr 2023)29
Source: Cal. Bar No. 87106 · Nev. Bar No. 5900 · Clark County D308221 / Doc. 20041109:001972 · SEC EDGAR Acc. 0001255294-04-000216 & -000300 · NV SOS SilverFlume
03

What Regulators Saw vs. Reality

Every position was tuned to sit one notch under a disclosure line: 48.7% under the 50% control threshold; family kept un-aggregated; offshore nominees each under the 5% Schedule 13D trigger. The gaps are too precise to be accidental.

ownership_concealment · davi skin / lati — % of voting stock

reported — cane (sec)
48.7%
actual — family bloc
85.7%
enterprise (+ wallace/sim)
89.9%
public float (left over)
10.1%
dashed line = 50% control threshold
37×
Reported individual ownership (48.7%) understated the real coordinated family position (85.7%) by 37 points — the gap that kept a single controlling person invisible across the entire transformation chain.5
Source: 5 Schedule 13G filings, 18 Jun 2001 · Pacific Stock Transfer reports
04

The Calibrated Bermuda Nominees

On 3 Apr 2007, certificates 5309–5312 issued exactly 573,847 shares to four entities at one address — The LOM Building, 27 Reid Street, Hamilton. Each lands at 3.97%: just under the 5% reporting trigger. Identical share counts across four "unrelated" foreign entities do not occur in natural markets.

lom_nominee_calibration · each position vs. 5% schedule 13d threshold

arch ltd. — 5309
3.97%
hepburn holdings — 5310
3.97%
the chloe group — 5311
3.97%
sunshine ltd. — 5312
3.97%
dashed line = 5.00% disclosure trigger · bars scaled to threshold
Arch Ltd.
Cert 5309 · 03 Apr 2007
3.97%
573,847 sh
Hepburn Holdings Ltd.
Cert 5310 · 03 Apr 2007
3.97%
573,847 sh
The Chloe Group
Cert 5311 · 03 Apr 2007
3.97%
573,847 sh
Sunshine Ltd.
Cert 5312 · 03 Apr 2007
3.97%
573,847 sh
15.88%
Combined concealed beneficial ownership across the four LOM nominees — 2,295,388 shares — held through LOM Securities (Lines Overseas Management), later charged by the SEC for exactly this nominee-laundering model (SEC v. Lines, 07-cv-11566, SDNY).38

threshold_calibration · each position vs. its disclosure trigger

disclosure trigger Cane — individual 48.7% / 50% Arch Ltd. (5309) 3.97% / 5% Hepburn Hldgs (5310) 3.97% / 5% Sunshine Ltd. (5312) 3.97% / 5% The Chloe Grp (5311) 3.97% / 5%

Cane sits at 97.4% of the 50% control line; each LOM nominee at 79.4% of the 5% Schedule 13D trigger. Every position calibrated just under.

Source: Pacific Stock Transfer, Active Shareholder Report, 13 Jul 200735
05

The Certificate Trail

36 sequential CEDE & Co. certificates deposited 2,249,825 shares into DTC over three years. Deposits accelerate into the 2007 promotional window — 70.6% of all volume — synchronized to the offshore nominee issuance.

cede_deposit_phases · shares deposited to dtc street name, by year

2004 jun–dec · 3 certs
21,950
2005 mar–dec · 9 certs
254,051
2006 feb–nov · 14 certs
385,439
2007 jan–jun · 10 certs
1,588,385
bars scaled to peak year · cert range 2029–5323

cumulative_deposits · shares into DTC street name, 2004–2007

00.5M1.0M1.5M2.0M cert 5304 · +946,085 2004200520062007

36 sequential CEDE & Co. certificates · 70.6% of all volume lands in the 2007 window; a single certificate (No. 5304) is the near-vertical step.

946,085
A single certificate — No. 5304, deposited 5 Mar 2007 — moved 946,085 shares, nearly double the entire non-enterprise shareholder pool and impossible from any retail source. 29 days later, certs 5309–5312 went to Bermuda. Of 2,249,825 shares deposited, only 335,960 remained by Jul 2007 — 85.1% sold through the CEDE & Co. / DTC street-name channel.35
Source: CEDE & Co. certificate register · Pacific Stock Transfer report (13 Jul 2007)
06

Built Around Entities That Handled Federal Money

The shells were not empty husks chosen at random — each iteration wrapped itself around a stream of federal funds to manufacture legitimacy. Medicare billings gave the reporting shell a commercial story; later vehicles in the same orbit drew pandemic relief. Federal money was the veneer that made a laundering pipeline look like a business.

$49.3M
Medicare billings — Genesis Health Mgmt, via Dynamic / LATI (CIK 878146)6
$4.8M
CARES Act / pandemic relief drawn in the SDI → Galaxy Gaming orbit (CIK 13156)
$6.39M
Securities proceeds liquidated through Davi Skin (CIK 1059577)
Genesis Health Management operated up to 26 geropsychiatric hospital units across four states (Louisiana, Arkansas, Mississippi, Tennessee) with 100% of operating revenue derived from Medicare billings — a real federal-payer footprint bolted onto a shell whose only purpose was to host a hidden share register.6 The same playbook — public shell + federal-money story — recurs in the Secure Diversified Investment chain.32

expand · Genesis / Medicare — the $49.3M False Claims engine, the Hunter & Spertell taint, and the offshore note pipe

Source: Dynamic / LATI 10-KSB filings (Genesis / Medicare) · SDI internal memoranda & bankruptcy record
07

Offshore Terminus

Davi Skin shares reached the market through two distinct channels. Channel 1 deposited insider stock into CEDE & Co. / DTC street name for sale. Channel 2 converted Wallace's Davi Skin promissory note — the Lahka $200k nominee conversion31 into 2,295,388 shares, issued as certs 5309–5312 and split 4 × 573,847 across the LOM entities. Proceeds settled into the LOM entities' own offshore bank accounts — not a neutral custodian; no FBAR was ever filed and no U.S. capital gain reported. The dump controlled roughly 89% of daily trading volume during the manipulation window.

two channels · one terminus

Channel 1 — CEDE & Co.
DTC street name
2,249,825 sh deposited · 1,913,865 sold (85.1%)
Channel 2 — Wallace note → LOM
Lahka $200k conversion
2,295,388 sh · 4 entities × 573,847 · certs 5309–5312

offshore accounts held by the LOM nominee entities

Bank of Bermuda Ltd.
Acct 1010-956504
LOM nominee account · Arch Ltd. · Hamilton, Bermuda
Bank of N.T. Butterfield
Acct 20.006.840.351501.100
LOM nominee account · Hepburn Holdings Ltd.
$6.39M
Est. illicit liquidation proceeds
~$72M
Estimated FBAR civil penalty exposure
21 yrs
Consecutive years, zero FBARs filed
76.69%
Enterprise control of free-trading float

volume_dominance · share of daily trading volume, manipulation window

0%25%50%75%100% enterprise · ~89% public float · ~11%

Illustrative of the manipulation window: the enterprise controlled roughly 89% of daily volume, public participation ~11%.

15 U.S.C. §78j(b) · Rule 10b-5 18 U.S.C. §1343 · wire fraud 18 U.S.C. §1956 / §1957 · laundering 31 U.S.C. §5324 · structuring 18 U.S.C. §152 · bankruptcy fraud 26 U.S.C. §7201 · tax evasion 31 U.S.C. §5314 · FBAR 18 U.S.C. §1962 · RICO
Statutes implicated by the documentary record
08

The Offshore Money Machine — and Zero Tax

Proceeds from 2,295,388 shares liquidated through four Bermuda nominees flowed to Bank of Bermuda and N.T. Butterfield. Six mechanisms kept $6.39M off every U.S. return.

1 · Offshore accounts

Proceeds settled directly into Bermuda banks — outside IRS visibility.

2 · No FBARs

Zero FBARs for 21 years; estimated civil penalty exposure exceeds ~$72M.

3 · No capital-gains reporting

No U.S. broker reporting; the sale never appeared on a U.S. tax return.

4 · Reg S fiction

Shares framed as sold to "foreign investors," proceeds argued to belong to foreign entities.

5 · §1145 tax-free spinouts

Subsidiary shells distributed to insiders without registration, sold for $250K–$500K each.

6 · Management-fee laundering

Genesis billed Medicare; fees diverted to structuring entities as "compensation."

$0
U.S. tax reported on $6.39M. Proceeds sat in Bank of Bermuda (1010-956504) and N.T. Butterfield (20.006.840.351501.100); no FBAR, no capital gain, no return.35
09

Wallace Perjury — Bankruptcy Court, 4 Nov 2013

In a sworn deposition during the Galaxy Gaming bankruptcy (CIK 13156), Jan Wallace was examined about offshore accounts.

First — under oath
denial
denied maintaining any foreign bank accounts or offshore assets
Minutes later — same hearing
admission
admitted being signatory / beneficial holder on the Bank of N.T. Butterfield account(s) tied to one or two of the LOM nominees — Hepburn Holdings / Arch Ltd. — i.e., a portion of the proceeds, not the full $6,385,033
Denial then admission in the same proceeding — itself chargeable as perjury (18 U.S.C. §1621) and false declarations (§1623), tying Wallace directly to part of the offshore liquidation proceeds (the Hepburn / Arch LOM accounts).
10

The Patterns, Hiding in Plain Sight

The points below are allegations drawn from the documentary record — they have not been adjudicated. Read that way, the filings still show machine-detectable patterns across EDGAR that are consistent with a coordinated scheme and that anyone with automated detection could surface.

Coordinated 13G filings

Multiple filings on one date, each just below a threshold — a pattern consistent with undisclosed coordination.

Sequential certificates

Sequential numbers point to a single source even where the beneficial owner is not named.

Mathematical calibration

Four identical share counts (573,847 × 4) are highly improbable as independent market activity.

Bankruptcy-to-trading

A bankruptcy that extinguishes outside equity, followed immediately by share deposits — a sequence the record reflects.

~650
Analysis of ~24M SEC accessions reportedly surfaces roughly 650 similar entity clusters sharing the same signatures — same registered agent, incorporator, address, banks, nominee patterns. The Cane case reads as a template, not an anomaly. (analysis, not a primary-document finding)
11

Why No Regulator Caught This

  1. Institutional fragmentation. SEC, IRS, FinCEN, and state regulators each see fragments; none has full visibility.
  2. Filing volume. Millions of filings a year; without pattern detection, anomalies are invisible.
  3. Legal sophistication. An attorney designed structures to exploit the seams between securities, bankruptcy, and tax law.
  4. Offshore routing. Bermuda nominees and accounts provide legal obscurity even when domestic activity is flagged.
  5. Network connections. Associations alleged in offshore-leak datasets suggest infrastructure beyond a single fraud. (allegation/analysis)
12

Federal Laws, SEC Rules & Crimes

The documentary record implicates the following — every entry maps to conduct shown above.

Statute / RuleCrime / description
15 U.S.C. §78j(b) · Rule 10b-5Securities fraud — manipulation of Davi Skin shares, concealed beneficial ownership, fraudulent CEDE deposits
18 U.S.C. §1343Wire fraud — electronic transfer of $6.4M offshore via the DTC/CEDE nominee system; backdated identity wired to EDGAR
18 U.S.C. §1341Mail fraud — SEC filings and sworn affidavits with material misrepresentations sent through the mails
18 U.S.C. §1956 / §1957Money laundering — $6,385,033 routed through four Bermuda nominees into Bank of Bermuda and N.T. Butterfield
31 U.S.C. §5324Structuring — four LOM nominees each at exactly 573,847 sh (3.97%), calibrated below the 5% Schedule 13D trigger
18 U.S.C. §1962RICO — pattern of racketeering through the Cane–Wallace enterprise, 1995–2023
18 U.S.C. §152Bankruptcy fraud — manufactured sole-secured-creditor position; §1145 abuse to distribute shells to insiders
18 U.S.C. §1347Healthcare fraud — $49.3M Medicare billing via Genesis; management fees diverted to structuring entities
18 U.S.C. §1621 / §1623Perjury / false declarations — Wallace testimony (Nov. 4, 2013): denied, then admitted, offshore accounts in one proceeding
26 U.S.C. §7201Tax evasion — $6,385,033 unreported offshore income; zero FBARs filed for 21 years
SEC Rules 13d-1, 13d-2, 13g-1Failure to file / falsify Schedule 13D/G — 85.7% family bloc never aggregated; LOM bloc reported as “unrelated third parties”
Statutes & rules implicated by the documentary record · allegations
13

The Full Picture

What appears in SEC filings as routine corporate activity was an engineered pipeline: convert private stock into tradeable shares, concentrate ownership while reporting the opposite, extinguish outside holders through manufactured bankruptcy, and liquidate through calibrated offshore nominees — all below every disclosure threshold.

The mathematical precision — four nominees at exactly 3.97%, a 153:1 split calibrated to exact percentages, 36 sequential certificates from one source — is the signature of design, not coincidence — resting on 28 false SEC filings and 3 false SOX certifications across four CIKs: Dynamic/LATI (878146), MW Medical/Davi Skin (1059577), Sedona Software (1100131), and LVGI (1103993).
The same machinery, other arenas

Davi Skin was not isolated. The same operators ran the same plays — attorney-trust pass-throughs, manufactured creditor positions, offshore nominees, and a legal veneer over operational control — across the other documented arenas, in chronological sequence:

The Wallace identity infrastructure (from 1981) — four aliases and three Social Security numbers (two stolen from the deceased, one fabricated), each assigned a fraud function, with bankruptcy testimony of “no offshore accounts” contradicted by her own prior sworn testimony about Hepburn Holdings (Bermuda): the concealment layer beneath the whole enterprise.53

Genesis Health Management (1994–2001) — the federal-money engine that preceded the share-trafficking: Dynamic Associates billed Medicare directly through the geropsychiatric PPS exemption, generating ~$49.3M in management fees while a convicted Medicaid felon and an OIG-excluded doctor sat inside the controlled group and a Genesis-employee qui tam was disclosed once and then suppressed — with $3.28M of government money routed to offshore Reg S noteholders.56

MW Medical (1998–2004) — the shell Dynamic Associates spun off to its own shareholders in 1998 and Wallace ran, weaponized through a manufactured Chapter 11: a self-dealt secured note placed Wallace first in line, the §1145 plan made the reorganized shares free-trading, and the vehicle re-emerged as Davi Skin.57

Dynamic Associates / LATI (2001) — the blank-check shell (SIC 6770) reverse-merged into Legal Access Technologies: roughly $8.6M of noteholder debt converted to stock and a 153:1 reverse split handed the Cane family bloc ~91.6% of the float while the offshore pre-merger holders were diluted to near zero.58

Thomas & Wong (2002) — off the $250K sale of the MW Asia shell to Beardmore, Wallace induced a contractor to wire $1.5M into a Cane O'Neill attorney trust account for a bridge loan; three unauthorized diversions ran before any documents were signed and the gold-doré collateral never existed, yielding a $1.3M non-dischargeable judgment.53

SDI / Galaxy Gaming (2005–2008) — the same takeover-by-bankruptcy on Secured Diversified Investment: Cane Clark appeared as a petitioning creditor against its own client, an involuntary Chapter 11 and a 20:1 reverse split concentrated control, and the clean public shell was delivered to Galaxy Gaming holders.54

United States v. DiScala (2012–2018) — the only federal indictment naming Cane directly (E.D.N.Y., 2014): she held millions of free-trading shares in attorney escrow and released them on trading instructions across four shells generating $300M in artificial market cap. A 2014 wiretap caught her on price control; she was acquitted at the 2018 trial.51

The “Voters for Hillary” SuperPAC (2014) — formed 17 days before her indictment was unsealed, with Cane lending it $10,700. The PAC funneled $73,000 to CrossClick Media (XCLK) — a Cane Clark client penny stock — while PAC insiders controlled CrossClick: the same circular share-control structure in a campaign-finance wrapper.52