SEC v. Manny J. Shulman and David K. Hirschman (undisclosed control blocks, 2015)

Judgment entered

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The SEC's September 2015 case over Caribbean Pacific Marketing stock ended in final judgments against Manny Shulman and David Hirschman in the Southern District of Florida. Hirschman consented to a judgment on 27 October 2015, and on 22 August 2016 the court set the money: $269,300 in disgorgement, $34,198.95 in interest, and a $269,300 penalty on each man.

The record

What was ordered

Civil penalty

$539k

Disgorgement

$269k

Prejudgment interest

$34.2k

Total relief

$842k

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced on September 8, 2015 (litigation release 23337) a complaint filed on September 3, 2015 in the U.S. District Court for the Southern District of Florida against Shulman and Hirschman. The company itself, Caribbean Pacific Marketing, is a defunct Florida shell, not a defendant.

The complaint alleges that the company's 2012 registration statement did not disclose that Shulman, a securities fraud recidivist, controlled its day-to-day operations, or the role of William Reilly, a disbarred attorney and also a recidivist, although other people were listed as officers. It further alleges that from June to October 2012 the two sold stock privately and without registration to 18 investors for $271,500, told them the company would be a shell for a later reverse merger, and misappropriated most of the money. The charges include Sections 5 and 17(a) of the Securities Act and Rule 10b-5.

This library tags the matter as undisclosed control blocks; the record previously carried the reverse-merger tag and named the company as defendant. The allegations are unproven as to Hirschman. Shulman consented to injunctive relief, with disgorgement and a penalty to be set by the court later, so no amount is recorded.

Hirschman consented to a permanent injunction entered on 27 October 2015, with the money to be set later. On 22 August 2016 the court entered judgments on the SEC's motion against both men, making them jointly and severally liable for $269,300 in disgorgement and $34,198.95 in prejudgment interest and ordering a civil penalty of $269,300 against each, so $572,798.95 owed by each man in total. The stored figures count the joint disgorgement and interest once and add the two penalties, $538,600. The judgments resolve the SEC's claims over the unregistered offering and the misappropriation; the allegations about undisclosed control of the company are covered only in so far as these judgments incorporate them, which I could not confirm from the poorly scanned text.

For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Undisclosed control blocks — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2015-09-08 Litigation release published
2. 2015-10-27 Consent injunction entered against Hirschman (S.D. Fla.)
3. 2016-08-22 Final judgments setting disgorgement, interest and penalties entered against both defendants

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• Default/consent final judgment and permanent injunction as to David K. Hirschman (27 Oct 2015)
• Final judgment setting amounts against Manny J. Shulman (22 Aug 2016)
• Final judgment setting amounts against David K. Hirschman (22 Aug 2016)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.