SEC v. Usee, Inc., et al.
Page 3 of 14Complaint
indirectly, made use of the means or instrumentalities of interstate commerce and/or the mails inconnection with the transactions described in this Complaint.8.
Venue is proper under Section 27 of the Exchange Act [15 U.S.C. § 78aa],because transactions, acts, practices and courses of business described below occurred within theNorthern District of Texas.
Usee, Inc. (“Usee”) was formed in 2008 and is a Texas corporation with aprinciple place of business in Little Elm, Texas.10.
Terry E. Wiese (“Terry”), age 64, resides in Little Elm, Texas. He formed Useewith his brother, Scott A. Wiese, in 2008 and serves as its Executive Vice President. Terrypersonally solicited new investors, sold securities on behalf of Usee, and made materialmisrepresentations about Usee’s fundraising and business prospects.11.
Scott A. Wiese, (“Wiese”) age 48, resides in Temecula, California and serves asUsee’s President and Chief Executive Officer. Scott personally solicited new investors, soldsecurities on behalf of Usee, and made material misrepresentations about Usee’s fundraising andbusiness prospects.
B. Relief Defendants
NFY Financial Consulting PLLC (“NFY”) was formed by Nail Yaldo a/k/a NeilYaldo in 2007 and is a Michigan corporation with its principal place of business in WestBloomfield, Michigan. It can be served through its registered agent for service of process, Mr.Nail Yaldo, 4273 McNay Ct., West Bloomfield, Michigan, 48323.
Case 3:12-cv-01325-M Document 1 Filed 04/30/12 Page 3 of 14 PageID 3