HARM TO THE GOVERNMENT AND THE PUBLIC

Elliot has admitted in prior sworn testimony that there are at least 200 employer/companies that have participated in a Sea Nine VEBA plan, and the IRS is aware of 205 such entities. Elliot and Sarva  continue today to promote Sea Nine VEBA plans, and Sea Nine appears to have obtained additional plan participants in 2012. And third parties with whom he has previously worked continue to recommend Sea Nine VEBA plans to certain of their customers.