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December 30, 2018

The Honorable Edgardo Ramos
and c/o Ms. Jazmin Rivera, Courtroom Deputy Clerk

Nancy Brown, Attorney for the SEC
SEC v Honig et al

Joe Dixon
Attorney for Phillip Frost ("Frost') and Opko Health, Inc. ("Opko")
Pederson v Frost et al

Other individual agents of the SEC
Individual agents of the DOJ
Individual members of the news media
Other interested individuals

RE: SEC v Honig et al (SDNY: 18 Civ. 08175)

Dear Honorable Judge Ramos,

1. This is an open letter to you regarding the proposed settlement of charges against Phillip Frost
and Opko in the matter of SEC v Honig et al. I strongly urge you to reject the proposed
settlements for the following reasons:
(a) The proposed settlements are against the interests of the People of the United States.
(b) The proposed settlements do not require any admission of wrong-doing by Frost.
(c) The proposed settlements do not impose an officer / director ban on Frost.
(d) The propose settlements do not impose adequate penalties on Frost or Opko.

2. Billionaire Frost is the leader of a white-collar criminal gang that specializes in market
manipulation and securities fraud, especially pump and dump securities frauds. (see attachment:
"The Frost Gang: A Vertically Integrated Criminal Organization")

3. I have been personally impacted by the Frost gang's pump and dump (P&D) securities fraud
operation at BioZone / CoCrystal ("Company A" in the SEC complaint). I initiated a lawsuit
against Frost, Opko, SEC defendant Brian Keller and CoCrystal in December of 2017. (see
attachment: Amended Complaint in Pederson v Frost et al, Minnesota Federal District Court,
Court File No. 17-cv-5580 (WMW/BRT)). The case is currently pending at the 8th Circuit Court
of Appeals (Pederson v Frost et al, Court File No. 18-3195). I have spent about 15,000 hours
investigating the Frost gang.

4. The proposed settlements are a continuation of timid and weak enforcement efforts by the
SEC against Frost and his gang. I filed an SEC whistleblower complaint against Frost and
BioZone in late 2013 when I first became aware of the P&D fraud at BioZone. I filed a related
whistleblower complaint against Musclepharm Corporation ("MSLP") when I became aware of
MSLP's role in the BioZone P&D. (see Amended Complaint in Pederson v Frost at paragraphs -
217-238) I continued to provide the SEC with voluminous information about the Frost gang and
the BioZone P&D. The SEC was investigating MSLP for separate violations. MSLP announced
a settlement with the SEC. The proposed settlement did not address the role of MSLP in the
BioZone P&D. I protested to the SEC and the settlement was delayed. On August 24, 2015,
SEC whistleblower Chief Sean McKessy took the unusual step of calling me personally to say
that the whistleblower office would not take action on my whistleblower complaints. Then the
SEC settled with MSLP without addressing MSLP's role in the BioZone P&D. I have requested
the SEC Office of the Inspector General to open an investigation into this matter.

5. On November 9, 2014 (before the McKessy phone call), I came into contact with DOJ agents
(FBI and US Attorneys) who were investigating the Frost gang. On October 6, 2015 (after the
McKessy phone call), I came into contact with an SEC agent who began an investigation into the
BioZone P&D and the Frost gang. I have continued to supply these Federal agents with
information up to the present and they are being bcc'd on this letter.

6. Because the SEC has taken so long to bring charges against the Frost gang for the BioZone
P&D, the Frost gang has been able to carry out new P&D securities frauds at a number of other
companies over the last couple of years.

7. The SEC did not bring charges against Frost and his gang until September 7, 2018 - just
weeks before the five-year statute of limitation on the BioZone P&D was about to expire.

8. The allegations and evidence laid out in SEC v Honig support criminal charges against Frost
and others.

9. The DOJ has not yet publicly brought charges against Frost and his gang for the BioZone
P&D despite the passing of the five-year statute of limitations. There is some chance that
deferred prosecution agreements or sealed complaints may exist.

10. SEC v Honig does not include charges against MSLP for their actions described in the
Amended Complaint in Pederson v Frost. MSLP should disgorge about $1,782,877 of illegal
profits from the BioZone P&D fraud.

11. SEC v Honig does not include charges against Opko for illegal sales of BZNE shares as
described in the Amended Complaint in Pederson v Frost at paragraph 150. Opko should
disgorge about $350,500 of illegal profits from the sale of these shares.
12. Frost should disgorge about $1,177,345 of illegal profits from the sale of BZNE shares as
described in the Amended Complaint in Pederson v Frost at paragraph 149.

13. Evidence of Frost's wrong-doing includes that which is described in the SEC complaint,
other documentary evidence, testimony from cooperating witnesses, and testimony from
witnesses who are not compromised by involvement in Frost's frauds. Frost should be either be
required to publicly admit his wrong-doing, or the SEC should make proofs of his wrong-doing
in open court.

14. Frost was the key fraudster in the BioZone P&D securities fraud. Frost was key in the
fraudulent takeover of BioZone. In spite of Honig's and Brauser's sketchy backgrounds, the
presence of Frost provided the apparent credibility necessary for the fraudulent takeover. The
use of Frost's IVAX building played a role in the fraudulent takeover. Conducting meetings in
Frost's private office space played a role. Frost's false promise of funding played a huge role.
The use of Frost's reputation in the materially misleading John Ford articles was essential to the
BioZone P&D fraud. Frost and Opko looted BioZone's assets before the P&D. Frost knowingly
and willingly participated in these fraudulent activities and profited from them.

15. The Frost gang is continuing its illegal operations up to the present moment. SEC
enforcement actions, including the present case, have had negligible (if any) deterrent effect on
Frost and his gang.

16. The fraudulent and illegal actions of Phillip Frost have hurt many people, including me.
Frost should be held fully and publicly accountable for his wrong-doing.

17. The contents of this email are posted on the web at:

18. The Amended Compliant in Pederson v Frost is posted on the web at:

Lee Pederson
2126 Lyndale Ave S #6
Minneapolis, MN 55405