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DESIST AND REFRAIN ORDER
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State of California - Department of Business Oversight
STATE OF CALIFORNIA
BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY
DEPARTMENT OF BUSINESS OVERSIGHT
TO: Lawrence Eugene Freeman
Yeshilkoy Insurance Services, Inc.
2604B El Camino Real, #357
Carlsbad, CA 92008
and
132 El Camino Real, Suite F.
Encinitas, CA 92024
Structured Marketing, LLC
132 El Camino Real, Suite F.
Encinitas, CA 92024
and
1117 Elliot Park Ave.
Las Vegas, NV 89032
DESIST AND REFRAIN ORDER
(For Violations of Sections 25110 and 25401 of the Corporations Code)
The Commissioner of Business Oversight (“Commissioner”) finds that:
1. Yeshilkoy Insurance Services, Inc. (“Yeshilkoy”) is a suspended California
corporation with its last known addresses at 2604B El Camino Real, #357, Carlsbad, CA 92008, and
132 El Camino Real, Suite F., Encinitas, CA 92024.
2. Structured Marketing, LLC, (“Structured Marketing”) is a revoked Nevada limited
liability company with its last known addresses at 132 El Camino Real, Suite F., Encinitas, CA
92024, and 1117 Elliot Park Ave., Las Vegas, NV 89032.
3. Lawrence Eugene Freeman (“Freeman”), a Resident Insurance Producer licensed by
the California Department of Insurance, was the President and Chief Executive Officer of Yeshilkoy,
and the manager of Structured Marketing.
4. Beginning in or about 2007, Yeshilkoy, Structured Marketing, and Freeman offered or
sold securities, in the form of promissory notes or investment contracts, in the State of California.
5. The purported purpose of the securities offering was to raise funds from investors in
order to purchase life insurance policies from individual policyholders, pay the insurance premiums,
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DESIST AND REFRAIN ORDER
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State of California - Department of Business Oversight
sell the life insurance policies, collect the life insurance settlement payouts, and pay the investors.
6. These securities were offered or sold in this state in issuer transactions. The
Department of Business Oversight has not issued a permit or other form of qualification authorizing
any person to offer or sell the securities, described above, in this state.
7. In connection with the offer or sale of these securities, Yeshilkoy, Structured
Marketing, and Freeman made an untrue statement of material fact to investors, including,
guaranteeing payments of their principal investment amount plus interest within a specified period of
time. Investors have not received their principal investment amount, and have received none or only a
portion of their interest payments.
8. In connection with the offer or sale of these securities, Structured Marketing, and
Freeman made an untrue statement of material fact to at least one investor, including, that this was a
no risk investment.
Based on the foregoing findings, the Commissioner is of the opinion that the promissory notes
or investment contracts offered or sold by Yeshilkoy Insurance Services, Inc., Structured Marketing,
LLC, and Lawrence Eugene Freeman are securities subject to qualification under the Corporate
Securities Law of 1968 and are being or have been offered or sold without first being qualified in
violation of Corporations Code section 25110.
Pursuant to Corporations Code section 25532, Yeshilkoy Insurance Services, Inc., Structured
Marketing, LLC, and Lawrence Eugene Freeman are ordered to desist and refrain from the further
offer and sale of securities in California, including but not limited to promissory notes and investment
contracts, unless such sale has been qualified under the Corporate Securities Law of 1968 or unless
such security or transaction is exempt or not subject to qualification.
Furthermore, the Commissioner is of the opinion that the securities offered or sold by
Yeshilkoy Insurance Services, Inc., Structured Marketing, LLC, and Lawrence Eugene Freeman were
offered or sold in this state by means of written or oral communications which included an untrue
statement of a material fact or omitted to state a material fact necessary in order to make the
statements made, in the light of the circumstances under which they were made, not misleading, in
violation of Corporations Code section 25401, subdivision (b).
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DESIST AND REFRAIN ORDER
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State of California - Department of Business Oversight
Pursuant to Corporations Code section 25532, Yeshilkoy Insurance Services, Inc., Structured
Marketing, LLC, and Lawrence Eugene Freeman are hereby ordered to desist and refrain from
offering or selling any security in the State of California by means of any written or oral
communication which includes an untrue statement of material fact or omits to state a material fact
necessary in order to make the statements made, in the light of the circumstances under which they
were made, not misleading.
These Orders are necessary, in the public interest, for the protection of investors, and
consistent with the purposes, policies, and provisions of the Corporate Securities Law of 1968.
Dated: June 16, 2015
San Diego, CA
JAN LYNN OWEN
Commissioner of Business Oversight
By
MARY ANN SMITH
Deputy Commissioner
Enforcement Division
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