COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

August 14, 2011

Via e-mail to: Via fax to: chairmanoffice@sec.gov (202) 772-9200

To:

Honorable Mary Schapiro Chairman Securities and Exchange Commission 100 F Street, N.W. Washington, D.C. 20549 Jaime R. Escalona, Leader of COVISAL
1) In reference to the Administrative Claim submitted by Stanfords victims to the Office of the General Counsel at the SEC. 2) Enclosed copy of letter sent by COVISAL to SIPCs Board of Directors dated August 10, 2011, in reference to the SECs request to SIPC to begin the Liquidation of the Stanford Group Company under SIPA.

From: Subject:

Dear Chairman Schapiro, We non-US citizens victims of the pyramidal fraud perpetrated by R. Allen Stanford, gathered to defend our rights in the Coalicin Vctimas de Stanford Amrica Latina (COVISAL), respectfully address you to remind you that six (06) months have passed since the individual submission of our Administrative Claims Standard Form 95 at the Office of the General Counsel of the Securities and Exchange Commission (SEC). These claims were submitted before the statute of limitation deadline (February 16, 2011), in accordance with the Federal Tort Claims Act (FTCA), and still we have not received a response. Additionally COVISAL wishes to express its indignation for the SECs discriminatory decision that included only the clients of the Stanford Group Company (SGC) in the United States with brokerage accounts at the SGC USA and certificates of deposit (CDs) from the Stanford International Bank Limited (SIBL) for a Securities Investor Protection Act (SIPA) coverage, and excluded more than 80% of the total Stanfords victims, defrauded with the same CDs from SIBL.

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It is inexplicable that the SEC, after incorporating the arguments in its Analysis of June 15, 2011, concluding that the corporate structure of the Stanfords entities should be ignored because it was part of the Ponzi scheme and that the fictitious CDs from SIBL were the vehicle to defraud in the same manner all 27,977 Stanford victims, would make a political decision contrary to its legal analysis, separating the SGC USA from the rest of the Stanford companies with the sole purpose of providing clients of the SGC USA a privileged status. According to evidence from the SECs reports on the Stanford Case, this Agency violated its sacred mission of protecting the investors for more than ten (10) years and now ironically the SEC is determined to exclude thousands of innocent families from an economic relief families left unprotected because of the SECs gross negligence. For the reasons expressed above, we beg the SEC to reconsider this unjust and arbitrary exclusion. We are certain that this decision is not the way for the SEC to recover its credibility and trust of domestic and international public investor. This request is discussed at great length in the letter addressed to the SIPCs Board of Directors, which we have enclosed in this letter. We appreciate your attention and prompt response. Yours truly,
For COVISAL:

/s/Jaime Escalona

Jaime R. Escalona
Leader, Coalicin Vctimas de Stanford Amrica Latina (COVISAL) Twitter: @COVISAL http://es.scribd.com/jaenrodes jaenrodes@gmail.com victimasdestanford@gmail.com TEXAS: (512) 377 9255 (512) 377 6133

Enclosure.

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COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

August 10, 2011
Via e-mail to: Via Fax to:

OJonhson@saul.com (202) 295 6742

Honorable Orlan Johnson Chairman Securities Investor Protection Corporation c/o Saul Ewing LLP 1919 Pennsylvania Avenue, N.W. , Suite 550 Washington, DC 20006-3434 Subject: In Reference to the SECs request dated June 15, 2011 that SIPC begin a liquidation of the Stanford Group Company (SGC) under SIPA. Dear Mr. Johnson, I, Jaime R. Escalona, U.S. citizen with passport No. xxxxxxxxx, founder and leader of the Coalicin Vctimas de Stanford Amrica Latina (COVISAL), created to defend the rights of the non-US victims, respectfully request that you consider COVISALs arguments before you vote for or against the liquidation of the Stanford Group Company (SGC) under the Securities Investor Protection Act (SIPA). This liquidation will force the Securities Investor Protection Corporation (SIPC) to provide an economic relief up to $500,000 to those investors with brokerage accounts at the SGC and certificates of deposit (CDs) from the Stanford International Bank Limited (SIBL) purchased through the SGC, and will exclude more than 80% of the total Stanfords victims from the SIPA coverage.
I am enclosing the documents that identify me: Affidavit - Enclosure A, Letter of Authorization Enclosure B, and Power of Attorney Enclosure C.

COVISALs arguments:
All (without exclusion) have the right to receive an economic relief.

The non-US Stanford victims gathered in COVISAL feel indignant about the Securities and Exchange Commissions (SEC) discriminatory decision that included only the clients of the SGC USA with brokerage accounts at the SGC USA and CDs from SIBL for a SIPA coverage, and excluded more than 80% of the total Stanfords victims, defrauded with the same CDs.
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COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

It is inexplicable that the SEC, after incorporating in its Analysis of June 15, 2011 the arguments concluding that the corporate structure of the Stanfords entities should be ignored because it was part of the Ponzi scheme and that the fictitious CDs from SIBL were the vehicle to defraud all 27,977 Stanford victims in the same manner, would make a political decision contrary to its legal analysis, separating the SGC USA from the rest of the Stanford companies with the sole purpose of providing clients of the SGC USA a privileged status. To expand on this information, please read the Analysis of Securities Investor Protection Act Coverage for Stanford Group Company, elaborated by the SEC Date: June 15, 2011; at the following link:
http://stanfordfinancialreceivership.com/documents/SEC_SIPA_Analysis.pdf

Before I put forward the facts that support our argument, we would like to inform you of the following:

What is COVISAL?
As a result of the civil complaint presented by the Securities and Exchange Commission (SEC), which froze the funds of the CDs issued by the Stanford International Bank Limited in Antigua (SIBL) and all the assets related to R. Allen Stanford and his companies, non-US victims quickly formed the Coalicin Vctimas de Stanford Amrica Latina (COVISAL), directed by its founder and leader Mr. Jaime R. Escalona.

COVISAL is an organization administered by three (03) victims, in which only account holders of the CDs participate. The nature of COVISALs work is research, information and dissemination. It was created with the intention to gather the 23,597 non-US victims, distributed in 112 countries around the world, who represent more than 84.34% of the total Stanford victims. Our objective is to fight for the recovery of the money that was stolen by R. Allen Stanford. To expand on this information, please access the following link: http://es.scribd.com/doc/52189704/

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COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

Profile of the Non-US victims members of COVISAL: The majority of affected victims are modest people; many are elderly, ill or close to retirement - desperate because of our devastating economic situation due to the loss of our savings. Of the 27,977 Stanfords victims, 16,797 are from Latin American countries lacking a social security system to guarantee a dignified old age, that in order to preserve their patrimony from devaluations, high inflation and the arbitrary decisions from their governments, purchased these CDs to ensure a monthly income to cover their medical and retirement living expenses.
See the following link to access the charts Geographic Location of the 27,977 Victims And The Amount of Their Investments: http://es.scribd.com/doc/35205418/

Facts:
The Stanford Financial Group (SFG) was a brand name that fraudulently gathered all of the Stanford companies and operated in the US stock market as an illegal high risk fund of an illegal unregistered investment company in violation of the Investment Company Act. SFG sold unregistered CDs in and from the United States violating the U.S. Securities Act; these CDs were issued by a foreign Bank not registered in the United States, which is also a blatant violation of the Investment Company Act. The Receiver Ralph Janvey, in his response to the Antigua Liquidators Receivers Response to the Antiguan Liquidators December 3 Supplemental Brief, stated the following: o Corporate separateness was not respected within the Stanford empire. the Stanford entities were operated in a highly interconnected fashion, with a core objective of selling fraudulent SIBL CDs. all of the Stanford entities, SIBL included, were part of the same Ponzi scheme, puppets of the same puppeteer.

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COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

o In the Stanford Case as in Castleberry v. Branscum, 721 S.W. 2d 270 (Tex. 1986); corporate fiction should be disregarded because it was used as a means of perpetrating the fraud, as a means of evading existing legal obligations and as a protection to perpetrate the crime. o Cash management for all of SFG, including SIBL, was handled in Houston the CD revenue money bypassed Antigua entirely SIBLs principal bank accounts were at two Houston Banks Trustmark and Bank of Houston. Money was transferred from entity to entity as needed, irrespective of legitimate business need. Ultimately, all of the fund transfers supported the Ponzi scheme in one way or another, or benefitted Allen Stanford personally. o SIB was a sham used by Stanford and his confederates to commit fraud Little activity occurred on Antigua (principally, the entertainment of high rollers.). To expand on this information, please read Receivers Response to the Antiguan Liquidators December 3 Supplemental Brief Case No.: 3:09-cv-00721-N. Document 61. Filed 12/17/2009; at the following link: http://www.stanfordfinancialreceivership.com/documents/16.pdf As is evident in the Report of the SECs Inspector General, Case No. OIG-526 dated March 31, 2010, because of gross negligence the SEC did not consider the red flags that appeared in the examinations performed on Stanford during the years 1997, 1998, 2002 and 2004; nor did they investigate the complaints that warned of the vertiginous growth of a pyramidal fraud. By violating its mandate to protect the investment public granted by the U.S. Congress under the Securities Exchange Act of 1934, the SEC caused very grave damages to thousands of innocent families around the world. To expand on this information, please read Report of Investigation United States Securities and Exchange Commission Office of Inspector General - Case No. OIG-526 - Investigation of the SECs Response to Concerns Regarding Robert Allen Stanfords Alleged Ponzi Scheme March 31, 2010; at the following link: http://www.sec.gov/news/studies/2010/oig-526.pdf

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COALICION VICTIMAS DE STANFORD AMERICA LATINA (COVISAL)

CONCLUSION In the judicial arena - it is evident that for twelve (12) years R. Allen Stanford outwitted the SEC by ensuring that the laws were not applied to stop him. During this period the SEC violated its sacred mission to protect the public investors and now ironically the SEC is determined to exclude thousands of innocent families from an economic relief families left unprotected because of the SECs gross negligence. COVISAL asks - Is this the road to recover its credibility and trust from the domestic and international public investors? In the political arena - we observe how the laws that govern the stock market in the United States become murky when the political prevails over the legal aspects. Is this the way to dispense justice? Petition of the non-US Stanford victims: COVISAL respectfully begs you to analyze all of the facets of the Stanford Case before you cast your vote in favor or against the SECs request, and consider that to exclude more than 80% of the total Stanford victims, as presented by the SEC in its analysis, from an economic relief violates the sacred legal principle that equality is equity for all. We pray to God that ethics prevails over the arbitrary and unjust decisions of the SEC, and that conscience is the instrument to impart justice in this social tragedy. God bless the tears of the thousands of innocent families - victims of a fraud that still continues! COVISAL cries out for justice before the world! I appreciate your kind attention. Sincerely yours,
/s/Jaime R. Escalona

Jaime R. Escalona
Leader, Coalicin Vctimas de Stanford Amrica Latina (COVISAL) jaenrodes@gmail.com victimasdestanford@gmail.com TEXAS: (512) 377 9255 (512) 377 6133

Enclosures: three (03) Exhibits A, B and C [10 pages only in original letters sent via FedEx to SIPCs Board of Directors]
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cc:

[Copy of letter without enclosures]: Stephen Harbeck, President and CEO of the SIPC; Josephine Wang, General Counsel and Secretary of the SIPC; Philip Carduck, Vice President Operations and Finance of the SIPC; Honorable Mary Schapiro, Chairman SEC; Honorable SEC Commissioners: Kathleen Casey, Elisse Walter, Luis Aguilar y Troy Paredes; Mark Cahn, General Counsel of the SEC; Michael Conley, Deputy Solicitor in the Appellate Group of the SEC; David Kotz, Inspector General SEC; Robert Khuzami, Director Division of Enforcement of the SEC; Carlo di Florio, Director OCIE of the SEC; Don Hoerl, Director in Charge SEC Regional Office, Fort Worth, Texas; Division of Trading and Markets of the SEC: Robert Cook, Director; Michael Macchiaroli, Associate Director; Thomas McGowan, Associate Deputy Director; U.S. Senators from the following Committees: Appropriations; Finance, Select on Ethics; Foreign Relations; Judiciary; Banking, Housing and Urban Affairs; Budget and Special on Aging; U.S. Representatives Committees: Appropriations; Financial Services; Ethics; Foreign Affairs; Judiciary; Energy and Commerce; Financial Services Subcommittees: Capital Markets & Government; Oversight and Investigations; Congress Budget Office (CBO). U.S. Government Accountability Office (GAO).

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