SEC v. RONALD E. FILORAMO, No. 0:23-cv-61858, Southern District of Florida (Sept. 28, 2023) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
SECURITIES AND EXCHANGE COMMISSION,

  Plaintiff,
v.

RONALD E. FILORAMO,

  Defendant.
                      /

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

Plaintiff Securities and Exchange Commission (“Commission”) alleges as follows:
I.  Introduction

1. This  case  concerns  a  multi-year  fraud  by Ronald  E.  Filoramo,  a  registered
representative and investment adviser representative associated with a dually-registered financial
services   firm. Between February   2017 and   October   2021, Filoramo   misappropriated
approximately $761,000 from two long-standing brokerage customers.
2. Filoramo  represented  that  he  would  invest  the  customers’  funds  in  securities  he
recommended.  Specifically,  Filoramo  recommended  to  the  customers  that  they  purchase  bonds
from Filoramo’s purported   client.      Instead   of   investing   his   customers’   funds,   Filoramo
misappropriated the money for his personal benefit, namely for gambling and related expenses.
3. To conceal his fraud, Filoramo instructed his customers to send their funds directly
to the client that was purportedly liquidating his bond position.  Filoramo created fake documents
that purported to show the bond purchases. In fact, the customers unknowingly transferred their
funds to bank accounts controlled by one of Filoramo’s friends who, in turn, transferred the funds
to  a  bank  account  controlled  by  Filoramo. No  bonds  were  ever  purchased,  and  Filoramo  spent

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almost all the money, mainly at casinos.
4. By engaging in the conduct described herein, the Defendant directly violated 17(a)
of  the  Securities  Act  of  1933  (“Securities  Act”)  [15  U.S.C.  § 77q(a)],  Section  10(b)  of  the
Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder
[17 C.F.R. §§ 240.10b-5]. The Commission seeks injunctive relief, disgorgement and prejudgment
interest, and civil penalties against the Defendant.
II.  Defendant
5. Filoramo, 54, is a resident of Coral Springs, Florida. From April 2011 to May 2023,
when he was terminated, Filoramo was a registered representative associated with a broker-dealer
and investment adviser registered with the Commission.
III.  Jurisdiction and Venue
6. This  Court  has  jurisdiction  over  this  action  pursuant  to  Sections  20(b),  20(d)(1),
and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)] and Sections 21(d)(1),
and 27 of the Exchange Act [15 U.S.C. §§ 78u(d)(1), and 78aa].
7. This  Court  has  personal  jurisdiction  over  Defendant  and  venue  is  proper  in  this
Court because Filoramo resides in this district, transacted business in this district, and many of the
acts, practices, and courses of business constituting the violations alleged herein occurred within
the Southern District of Florida.
8. Filoramo has, directly or indirectly, made use of the means and instrumentalities of
interstate commerce, of the mails, or of the facilities of a national securities exchange in connection
with the acts, transactions, practices, and courses of business alleged in this Complaint, and will
continue to do so unless enjoined.

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IV.  Facts
9. From February    2017    through    October    2021, Filoramo misappropriated
approximately   $761,000   from   two   long-standing   brokerage   customers   (the   “Customers”).
Filoramo misappropriated approximately $61,444 from Customer A, a husband and wife, in one
transaction.    Filoramo misappropriated approximately  $700,000  from  Customer  B,  an  elderly
investor who controlled several accounts for his wife, children, and grandchildren.
10. The Customers’  brokerage  accounts  at  issue  were  maintained  at  a  Commission
registered broker-dealer and investment adviser.
11. Beginning  in  February  2017, Filoramo  started  recommending  to  these  two  long-
standing customers that that they invest in certain bonds purportedly owned by a wealthy client of
Filoramo who,  according  to  Filoramo,  wanted  to  liquidate  his  position  in  each  bond.    Filoramo
would  represent  to  the  Customers  that  the  bonds   were  high-yielding. Because  the  bonds  were
purportedly  owned  by  Filoramo’s  client,  Filoramo  instructed  the  Customers  to  make  their
investments  directly  to  that  client.    The  Customers  invested  in  the  purported  bonds by  either
directing that funds be wired from their brokerage accounts at Filoramo’s employer, or by sending
personal checks or wires to a bank account either held in the name of Filoramo’s friend or an entity
owned and controlled by Filoramo’s friend.
12. In fact, Filoramo never purchased any bonds for the Customers, and the third-party
accounts were owned and controlled by a friend of Filoramo. After the Customers transferred their
money  to  the  third-party  accounts,  Filoramo’s  friend  transferred  almost  all  of  their  money  to
Filoramo’s personal bank account either by wire or check.    Filoramo, in turn, used this money to
make numerous, large cash withdrawals, many of which occurred at casinos.

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13. The following table sets forth the transactions underlying Filoramo’s misconduct:
Date of Transfer Customer Amount Transferred to
Third Party
Amount Transferred to
Filoramo
2/11/2017 Customer B $100,000.00  $100,000.00
3/9/2017 Customer B $85,000.00  $85,000.00
3/24/2017 Customer B $38,000.00  $38,000.00
10/4/2017 Customer B $37,500.00  $37,500.00
10/5/2017 Customer B $37,500.00  $37,500.00
3/12/2018 Customer B $84,000.00  $83,000.00
9/11/2018 Customer B $30,000.00  $30,000.00
10/1/2018 Customer B $61,000.00  $61,000.00
4/17/2019 Customer B $60,350.00  $60,350.00
10/21/2020 Customer A $61,443.90 $61,443.90
4/26/2021 Customer B $100,917.11  $100,000.00
10/12/2021 Customer B $71,216.64  $66,200.00
14. To further perpetrate the fraud, Filoramo provided the Customers with fraudulent
documentation for the bond purchases, including screenshots from the broker-dealer’s order entry
system and internal analyses of bonds.
15. In early 2023, Filoramo’s wife contacted his employer concerned about Filoramo’s
whereabouts. This prompted his employer to review Filoramo’s customers’ transactions.  As part
of  its  investigation,  Filoramo’s  employer  identified  the  transactions  above  and  terminated
Filoramo.
V.  Claims For Relief

COUNT I
Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(a)

16. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
17. Between February  2017  and  October  2021, Filoramo,  in  connection  with  the
purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce,

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or  of  the  mails,  or  of any facility  of  a  national  securities  exchange,  directly  and  indirectly,
knowingly or severely recklessly used and employed devices, schemes, and artifices to defraud.
18. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-
5(a) thereunder [17 C.F.R. § 240.10b-5(a)].
COUNT II
Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(b)
19. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
20. Between February  2017  and  October  2021, Filoramo,  in  connection  with  the
purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce,
or  of  the  mails,  or  of any facility  of  a  national  securities  exchange,  directly  and  indirectly,
knowingly  or  severely  recklessly made  untrue  statements  of  material  fact  and  omitted  to  state
material  facts  necessary  in  order  to  make  the  statements  made,  in  light  of  the  circumstances  in
which they were made, not misleading.
21. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-
5(b) thereunder [17 C.F.R. § 240.10b-5(b)].
COUNT III
Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(c)
22. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
23. Between February  2017  and  October  2021, Filoramo,  in  connection  with  the
purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce,
or  of  the  mails,  or  of any facility  of  a  national  securities  exchange,  directly  and  indirectly,

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knowingly or severely recklessly engaged in acts, practices and courses of business which have
operated, are now operating, and will operate as a fraud and deceit upon any person.
24. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-
5(c) thereunder [17 C.F.R. § 240.10b-5(c)]
COUNT IV
Violations of Section 17(a)(1) of the Securities Act
25. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
26. Between February  2017  and  October  2021, Filoramo,  in  the  offer  and  sale  of
securities,  by  the  use  of  means  or instruments  of  transportation  or  communication  in  interstate
commerce, or  by  use  of  the  mails,  directly  or  indirectly,  knowingly  or  severely  recklessly
employed devices, schemes and artifices to defraud.
27. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)].
COUNT V
Violations of Section 17(a)(2) of the Securities Act
28. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
29. Between February  2017  and  October  2021, Filoramo,  in  the  offer  and  sale  of
securities,  by  the  use  of  means  or instruments  of  transportation  or  communication  in  interstate
commerce, or by use of the mails, directly or indirectly, negligently obtained money or property
by means of untrue statements of material fact and by omitting to state material facts necessary in
order to make the statements made, in light of the circumstances under which they were made, not
misleading.

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30. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)].
COUNT VI
Violations of Section 17(a)(3) of the Securities Act
31. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.
32. Between February  2017  and  October  2021, Filoramo,  in  the  offer  and  sale  of
securities,  by  the  use  of  means  or instruments  of  transportation  or  communication  in  interstate
commerce, or  by  use  of  the  mails,  directly  or  indirectly,  negligently engaged  in  transactions,
practices,  and  courses  of  business  which  have  operated,  are  now  operating  or  will  operate  as  a
fraud and deceit upon the purchasers of such securities.
33. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably
likely to continue to violate, Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)].
VI. Relief Requested

WHEREFORE, the Commission respectfully requests the Court find that the Defendant
committed the violations of the federal securities laws alleged in this Complaint and:
A. Permanent Injunction
Enter an Order permanently restraining and enjoining Filoramo from, directly or indirectly,
violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the Exchange
Act [15 U.S.C. § 78j] and Rule 10b-5 thereunder [17 CFR § 240.10b-5].
B. Disgorgement and Prejudgment Interest
Issue an Order requiring Filoramo to disgorge all ill-gotten gains or proceeds received, with
prejudgment  interest  thereon,  resulting  from  the  acts  and/or  courses  of  conduct  alleged  in  this
Complaint.

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C. Civil Penalties
Issue an Order directing Filoramo to pay a civil monetary penalty pursuant to Section 20(d)
of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)].
D. Further Relief
Granting such other and further relief as this Court may deem just and appropriate.
VII. Retention of Jurisdiction
Further, the Commission respectfully requests that the Court retain jurisdiction over this
action  and  over  the  Defendant  in  order  to  implement  and  carry  out  the  terms  of  all  orders  and
decrees  that  may  hereby  be  entered,  or  to  entertain  any  suitable  application  or  motion  by  the
Commission for additional relief within the jurisdiction of this Court.
VIII. Jury Trial Demand
The  Commission  hereby  demands  a  trial  by  jury  on  any  and  all  issues  in  this  action  so
triable.
Respectfully submitted,

September 28, 2023           By: /s Teresa Verges
      Teresa Verges, Esq.
       Regional Trial Counsel
      Florida Bar No. 0997651
      Direct Dial: (305) 982-6376
      Email:  [email protected]

Brian Lechich, Esq.
      Trial Counsel
      Florida Bar No. 84419
      Direct Dial: (305) 416-6257
      Email: [email protected]

      Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
      801 Brickell Avenue, Suite 1950
      Miami, Florida 33131

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

CASE NO.  

SECURITIES AND EXCHANGE COMMISSION,  
         
  Plaintiff,    
v.         
         
RONALD E. FILORAMO,  
  
  Defendant. 
                     / 
 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF 
 

Plaintiff Securities and Exchange Commission (“Commission”) alleges as follows: 

I.  Introduction 
 

1. This case concerns a multi-year fraud by Ronald E. Filoramo, a registered 

representative and investment adviser representative associated with a dually-registered financial 

services firm. Between February 2017 and October 2021, Filoramo misappropriated 

approximately $761,000 from two long-standing brokerage customers.  

2. Filoramo represented that he would invest the customers’ funds in securities he 

recommended. Specifically, Filoramo recommended to the customers that they purchase bonds 

from Filoramo’s purported client.  Instead of investing his customers’ funds, Filoramo 

misappropriated the money for his personal benefit, namely for gambling and related expenses.   

3. To conceal his fraud, Filoramo instructed his customers to send their funds directly 

to the client that was purportedly liquidating his bond position.  Filoramo created fake documents 

that purported to show the bond purchases. In fact, the customers unknowingly transferred their 

funds to bank accounts controlled by one of Filoramo’s friends who, in turn, transferred the funds 

to a bank account controlled by Filoramo. No bonds were ever purchased, and Filoramo spent 

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almost all the money, mainly at casinos.  

4. By engaging in the conduct described herein, the Defendant directly violated 17(a) 

of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) of the 

Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder 

[17 C.F.R. §§ 240.10b-5]. The Commission seeks injunctive relief, disgorgement and prejudgment 

interest, and civil penalties against the Defendant. 

II.  Defendant  

5. Filoramo, 54, is a resident of Coral Springs, Florida. From April 2011 to May 2023, 

when he was terminated, Filoramo was a registered representative associated with a broker-dealer 

and investment adviser registered with the Commission.  

III.  Jurisdiction and Venue 

6. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1), 

and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)] and Sections 21(d)(1), 

and 27 of the Exchange Act [15 U.S.C. §§ 78u(d)(1), and 78aa].   

7. This Court has personal jurisdiction over Defendant and venue is proper in this 

Court because Filoramo resides in this district, transacted business in this district, and many of the 

acts, practices, and courses of business constituting the violations alleged herein occurred within 

the Southern District of Florida.  

8. Filoramo has, directly or indirectly, made use of the means and instrumentalities of 

interstate commerce, of the mails, or of the facilities of a national securities exchange in connection 

with the acts, transactions, practices, and courses of business alleged in this Complaint, and will 

continue to do so unless enjoined. 

  

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IV.  Facts 

9. From February 2017 through October 2021, Filoramo misappropriated 

approximately $761,000 from two long-standing brokerage customers (the “Customers”). 

Filoramo misappropriated approximately $61,444 from Customer A, a husband and wife, in one 

transaction.  Filoramo misappropriated approximately $700,000 from Customer B, an elderly 

investor who controlled several accounts for his wife, children, and grandchildren. 

10. The Customers’ brokerage accounts at issue were maintained at a Commission 

registered broker-dealer and investment adviser. 

11. Beginning in February 2017, Filoramo started recommending to these two long-

standing customers that that they invest in certain bonds purportedly owned by a wealthy client of 

Filoramo who, according to Filoramo, wanted to liquidate his position in each bond.  Filoramo 

would represent to the Customers that the bonds were high-yielding. Because the bonds were 

purportedly owned by Filoramo’s client, Filoramo instructed the Customers to make their 

investments directly to that client.  The Customers invested in the purported bonds by either 

directing that funds be wired from their brokerage accounts at Filoramo’s employer, or by sending 

personal checks or wires to a bank account either held in the name of Filoramo’s friend or an entity 

owned and controlled by Filoramo’s friend. 

12. In fact, Filoramo never purchased any bonds for the Customers, and the third-party 

accounts were owned and controlled by a friend of Filoramo. After the Customers transferred their 

money to the third-party accounts, Filoramo’s friend transferred almost all of their money to 

Filoramo’s personal bank account either by wire or check.    Filoramo, in turn, used this money to 

make numerous, large cash withdrawals, many of which occurred at casinos.  

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13. The following table sets forth the transactions underlying Filoramo’s misconduct: 

Date of Transfer Customer Amount Transferred to 
Third Party 

Amount Transferred to 
Filoramo 

2/11/2017 Customer B $100,000.00  $100,000.00  
3/9/2017 Customer B $85,000.00  $85,000.00  
3/24/2017 Customer B $38,000.00  $38,000.00  
10/4/2017 Customer B $37,500.00  $37,500.00  
10/5/2017 Customer B $37,500.00  $37,500.00  
3/12/2018 Customer B $84,000.00  $83,000.00 
9/11/2018 Customer B $30,000.00  $30,000.00 
10/1/2018 Customer B $61,000.00  $61,000.00 
4/17/2019 Customer B $60,350.00  $60,350.00 
10/21/2020 Customer A $61,443.90 $61,443.90 
4/26/2021 Customer B $100,917.11  $100,000.00 
10/12/2021 Customer B $71,216.64  $66,200.00 

14. To further perpetrate the fraud, Filoramo provided the Customers with fraudulent 

documentation for the bond purchases, including screenshots from the broker-dealer’s order entry 

system and internal analyses of bonds.  

15. In early 2023, Filoramo’s wife contacted his employer concerned about Filoramo’s 

whereabouts. This prompted his employer to review Filoramo’s customers’ transactions.  As part 

of its investigation, Filoramo’s employer identified the transactions above and terminated 

Filoramo.   

V.  Claims For Relief 
 

COUNT I 

Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(a) 
 

16. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.  

17. Between February 2017 and October 2021, Filoramo, in connection with the 

purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce, 

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or of the mails, or of any facility of a national securities exchange, directly and indirectly, 

knowingly or severely recklessly used and employed devices, schemes, and artifices to defraud.  

18. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-

5(a) thereunder [17 C.F.R. § 240.10b-5(a)]. 

COUNT II 

Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(b) 

19. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint. 

20. Between February 2017 and October 2021, Filoramo, in connection with the 

purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce, 

or of the mails, or of any facility of a national securities exchange, directly and indirectly, 

knowingly or severely recklessly made untrue statements of material fact and omitted to state 

material facts necessary in order to make the statements made, in light of the circumstances in 

which they were made, not misleading. 

21. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-

5(b) thereunder [17 C.F.R. § 240.10b-5(b)]. 

COUNT III 

Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5(c) 

22. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint. 

23. Between February 2017 and October 2021, Filoramo, in connection with the 

purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce, 

or of the mails, or of any facility of a national securities exchange, directly and indirectly, 

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knowingly or severely recklessly engaged in acts, practices and courses of business which have 

operated, are now operating, and will operate as a fraud and deceit upon any person. 

24. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-

5(c) thereunder [17 C.F.R. § 240.10b-5(c)] 

COUNT IV 

Violations of Section 17(a)(1) of the Securities Act 

25. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint.  

26. Between February 2017 and October 2021, Filoramo, in the offer and sale of 

securities, by the use of means or instruments of transportation or communication in interstate 

commerce, or by use of the mails, directly or indirectly, knowingly or severely recklessly 

employed devices, schemes and artifices to defraud. 

27. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]. 

COUNT V 

Violations of Section 17(a)(2) of the Securities Act 

28. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint. 

29. Between February 2017 and October 2021, Filoramo, in the offer and sale of 

securities, by the use of means or instruments of transportation or communication in interstate 

commerce, or by use of the mails, directly or indirectly, negligently obtained money or property 

by means of untrue statements of material fact and by omitting to state material facts necessary in 

order to make the statements made, in light of the circumstances under which they were made, not 

misleading. 

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30. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)]. 

COUNT VI 

Violations of Section 17(a)(3) of the Securities Act 

31. The Commission repeats and realleges Paragraphs 1 through 15 of this Complaint. 

32. Between February 2017 and October 2021, Filoramo, in the offer and sale of 

securities, by the use of means or instruments of transportation or communication in interstate 

commerce, or by use of the mails, directly or indirectly, negligently engaged in transactions, 

practices, and courses of business which have operated, are now operating or will operate as a 

fraud and deceit upon the purchasers of such securities. 

33. By reason of the foregoing, Filoramo violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)]. 

VI. Relief Requested 
 

WHEREFORE, the Commission respectfully requests the Court find that the Defendant 

committed the violations of the federal securities laws alleged in this Complaint and: 

A. Permanent Injunction 

Enter an Order permanently restraining and enjoining Filoramo from, directly or indirectly, 

violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the Exchange 

Act [15 U.S.C. § 78j] and Rule 10b-5 thereunder [17 CFR § 240.10b-5].  

B. Disgorgement and Prejudgment Interest 

Issue an Order requiring Filoramo to disgorge all ill-gotten gains or proceeds received, with 

prejudgment interest thereon, resulting from the acts and/or courses of conduct alleged in this 

Complaint.   

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C. Civil Penalties 

Issue an Order directing Filoramo to pay a civil monetary penalty pursuant to Section 20(d) 

of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 

78u(d)(3)]. 

D. Further Relief 

Granting such other and further relief as this Court may deem just and appropriate. 

VII. Retention of Jurisdiction 

Further, the Commission respectfully requests that the Court retain jurisdiction over this 

action and over the Defendant in order to implement and carry out the terms of all orders and 

decrees that may hereby be entered, or to entertain any suitable application or motion by the 

Commission for additional relief within the jurisdiction of this Court. 

VIII. Jury Trial Demand 

The Commission hereby demands a trial by jury on any and all issues in this action so 

triable. 

Respectfully submitted, 
 
September 28, 2023        By: /s Teresa Verges 
      Teresa Verges, Esq. 

      Regional Trial Counsel 
      Florida Bar No. 0997651 
      Direct Dial: (305) 982-6376 
      Email:  [email protected] 

Brian Lechich, Esq. 
      Trial Counsel 
      Florida Bar No. 84419 
      Direct Dial: (305) 416-6257 
      Email: [email protected] 
 
      Attorneys for Plaintiff 

SECURITIES AND EXCHANGE COMMISSION 
      801 Brickell Avenue, Suite 1950 
      Miami, Florida 33131     

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mailto:[email protected]
mailto:[email protected]

	COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
	I.  Introduction