UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934
Release No. 50424 / September 22, 2004

ACCOUNTING AND AUDITING ENFORCEMENT
Release No. 2107 / September 22, 2004

ADMINISTRATIVE PROCEEDING
File No. 3-11675

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest to issue an order temporarily suspending Daniel S. Lezak pursuant to Rule 102(e)(3) of the Commission's Rules of Practice against Daniel S. Lezak ("Lezak" or "Respondent").

II.

The Commission's public files disclose that:

A. Respondent, age 70, is a certified public accountant, but has allowed his license to lapse. Respondent was the Chairman, President and Chief Executive Officer of Madera International, Inc. ("Madera") from its inception in February 1994 until March 1996. Lezak remained a director of Madera until May 1996 and thereafter was employed by Madera as a consultant. In his role as a consultant, Lezak provided accounting services to Madera until December 1999. Respondent is a resident of Nevada.

B. Madera International, Inc., now defunct, was a Nevada corporation headquartered in Coral Gables, Florida. Its common stock was registered with the Commission pursuant to Section 12(g) of the Securities Exchange Act of 1934 ("Exchange Act"). On October 22, 2001, the registration of Madera's common stock was revoked pursuant to Section 12(j) of the Exchange Act.

III.

The Commission makes the following findings:

A. On September 19, 2001, the Commission brought an action in federal district court against Lezak and others alleging that he violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder; Section 13(b)(5) of the Exchange Act and Rules 13a-13, 13b2-1 and 13b2-2 thereunder; Section 13(a) of the Exchange Act and Rules 12b-20 and 13a-1 thereunder; and Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. SEC v. Madera International, Inc., Ramiro M. Fernandez-Moris and Daniel S. Lezak, U.S. District Court for the District of Columbia, Civil Action No. 01-1985 (JR).

B. On September 1, 2004, U.S. District Court Judge James Robertson granted the SEC's partial motion for summary judgment against Lezak and entered final judgment against Lezak permanently enjoining him from, directly or indirectly, violating Section 10(b) of the Exchange Act and Rule 10b-5 thereunder; Section 13(b)(5) of the Exchange Act and Rules 13b2-1 and 13b2-2 thereunder; Section 13(a) of the Exchange Act and Rules 12b-20 and 13a-1 thereunder; and Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act.

C. The Court found, among other things, that Lezak "knowingly falsified financial statements filed with the SEC. . . ." The Court also determined that "Lezak knowingly failed to implement a system of internal accounting controls at Madera to prevent the misuse of its funds." The Court also found that Lezak violated Exchange Act Rules 13b2-1 and 13b2-2 as a result of signing a management representation letter in connection with the March 31,1995 audit of Madera's financial statements which stated that, to the best of Lezak's knowledge and belief, "the company has satisfactory title to all owned assets including all assets shown on the financial statements . . . ."

IV.

Based on the foregoing, the Commission finds that Lezak has been enjoined and has been found to have violated provisions of the federal securities laws within the meaning of Rule 102(e)(3) of the Commission's Rules of Practice. In view of this finding the Commission deems it necessary and appropriate and in the public interest that Lezak be temporarily suspended from appearing or practicing before the Commission.

Accordingly, it is HEREBY ORDERED, effective immediately, that Lezak be and is hereby temporarily suspended from appearing or practicing before the Commission.

It is FURTHER ORDERED that Lezak may within thirty days after service of this Order file a petition with the Commission to lift the temporary suspension. If no petition is received by the Commission within thirty days after service of the Order, the suspension shall become permanent pursuant to Rule l02(e)(3)(ii).

If a petition is received within thirty days after service of this Order, the Commission shall either lift the temporary suspension, or set the matter down for a hearing at a time and place to be designated by the Commission, or both. If a hearing is ordered, following the hearing, the Commission may lift the suspension, censure the petitioner, or disqualify the petitioner from appearing or practicing before the Commission for a period of time or permanently pursuant to Rule 102(e)(3)(iii).

This Order shall be served upon Lezak personally or by certified mail at his last known address.

By the Commission.

http://www.sec.gov/litigation/admin/34-50424.htm