STIPULATION TO RELEASE DEFENDANT DAVID B. KAPLAN'S PASSPORTS AFTER ENTRY OF FINAL JUDGMENTS AND TRANSFER OF FROZEN ASSETS

MIRANDA DU, District Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties, as follows:

1. On May 20, 2016, the Court granted the Motion for Temporary Restraining Order by Plaintiff United States Securities and Exchange Commission and ordered Defendant David B. Kaplan to surrender his passports (USA and St. Kitts/Nevis) to the Clerk of the Court. (ECF No. 14 § VII.)

2. On May 27, 2016, the Clerk of the Court received Defendant's 2 passports and secured them in the Court's vault. (ECF No. 18.)

3. On June 9, 2016, the Court entered an Agreed Order of Preliminary Injunction, directing the Clerk of the Court to retain Defendant's passports until the conclusion of this litigation. (ECF No. 23 § V.)

4. On January 8, 2018, the parties filed Stipulations for Entry of Final Judgments, which asked this Court to enter final judgments against Defendants and Relief Defendants pursuant to settlement agreements among the parties. (ECF Nos. 95-98.)

5. On January 8, 2018, the Court entered Final Judgments against Defendants and Relief Defendants. (ECF Nos. 103-106.) The Final Judgments directed various financial institutions to transfer the entire balance of certain frozen accounts to the SEC within three days after being served with a copy of the Final Judgments.

6. As of January 31, 2018, all identified financial institutions had transferred the frozen funds to the SEC.

7. The Final Judgments having been entered and the SEC having received the frozen funds, the parties now respectfully request that the Clerk of the Court be directed to return the aforementioned passports to Defendant David B. Kaplan.

IT IS SO ORDERED.