SEC v. Francis Biller; Raymond Dove; Chester Alvarez; Troy Gran-Brooks; Justin Plaizier; Lia Patricia Sepulveda Salazar, et al., No. 1:22-cv-01406, Southern District of New York (Mar. 17, 2022) — Complaint

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,
   Plaintiff,
 v.

FRANCIS BILLER, RAYMOND DOVE,
CHESTER ALVAREZ, TROY GRAN-
BROOKS AND JUSTIN PLAIZIER,

   Defendants, and

LIA PATRICIA SEPULVEDA
SALAZAR, EDWARD LOPEZ
GIRALDO, EDWARD CLARKE AND
SHREDDERZ INTERNATIONAL
CORP.,

                                     Relief Defendants.

Civil Action No. 22-CV-____

JURY TRIAL DEMANDED

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the
following against defendants Francis Biller (“Biller”), Raymond Dove (“Dove”), Chester
Alvarez ( “Alvarez”), Troy Gran-Brooks (“Gran-Brooks”), and Justin Plaizier (“Plaizier” and
collectively, the “Defendants”) and relief defendants Lia Patricia Sepulveda Salazar, Edward
Lopez Giraldo, Edward Clarke, and Shredderz International Corp. (collectively, the “Relief
Defendants”):
SUMMARY
1. This is a securities fraud enforcement action.  From at least January 2016 through
at least July 2018 (“the “Relevant Period”), the Defendants schemed to operate a call center in
Medellin, Colombia through which they used high pressure sales tactics fraudulently to sell the
stocks of numerous small United States-based public companies to United States investors.  Such

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call centers are colloquially known as “boiler rooms.”  Defendants’ sales tactics included making
false or misleading statements about their own roles in promoting the stock they were touting,
and about the companies whose stock they were touting.  Companies that issue stock to the
public are often called “issuers.”
2. Defendants were hired by groups of people who controlled the stock of the issuers
whose stock they were touting.  These groups of people (called “control groups”) owned a
significant percentage of the issuers’ stock that had been deposited with a broker-dealer and was
thus available to be traded in the public markets (called “the float”).  Defendants explicitly
catered to control groups that controlled the float of the issuers, so that both the defendants and
their clients would profit to the greatest extent from the boiler room’s efforts.  The control
groups unlawfully concealed their control of the float, by breaking up their stock into small
blocks owned by foreign nominee companies they directed, and failing to file disclosures that
would have revealed that all of those smaller blocks were under their common control.  The
control groups wanted to sell the stock they owned in order to make a significant profit.  The
control groups used Defendants’ boiler room both to create demand from investors so they would
have buyers for their shares, and to increase the price of the stock, thereby increasing their
profits.
3. During the Relevant Period, Defendants’ boiler room promoted the stock of at
least 18 issuers, in coordination with control groups who were dumping their shares of those
issuers.  The demand created by Defendants’ misleading promotions enabled control groups to
sell millions of shares of stock, which generated over $58 million in trading proceeds for the
control groups.  The stock of many of these issuers was thinly traded in the market when it was
not being touted in one of the Defendants’ promotional campaigns, so investors who purchased

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these shares at Defendants’ urging often had difficulty finding buyers when trying to sell their
shares once Defendants’ promotions were over.
4. Defendants’ fraudulent scheme involved promoting the stock of Oroplata
Resources, Inc. (“Oroplata”), Garmatex Holdings Ltd. (“Garmatex”) and PureSnax International,
Inc. (“PureSnax”), in addition to many other issuers’ securities.  To promote these issuers’
shares, Defendants pretended to be affiliated with various non-existent financial advisory firms.
Defendants made up legitimate-sounding names for these phony financial advisory firms and
also created legitimate-looking websites for them.  When making telephone calls, Defendants
routinely used spoofed phone numbers to show area codes that made it appear as if they were
calling from the United States rather than Colombia.  When calling and emailing unsuspecting
investors, Defendants also used false names, made false or misleading statements about the
prospects of the companies whose stock they were touting, and failed to disclose that they were
acting in coordination with control groups that were dumping their securities into the market.
5. Defendants aggressively touted Oroplata, Garmatex, PureSnax, and other issuers’
stock to prospective investors, including elderly retail investors, using high-pressure sales tactics
during telephone calls.  Defendants made misleading statements about the issuers’ prospects as
investments and about the Defendants’ own claimed stock-picking successes.  In actuality,
Defendants called investors to persuade them to purchase these stocks so the Defendants’ control
group clients could sell their holdings of these stocks for a profit and so the Defendants could
collect a share (often more than half) of the sales proceeds.  Defendants also sent email and text
messages that attempted to convince the investors to hold the stocks even when their prices were
declining.  Then, after selling several issuers’ stocks, Defendants routinely shut down whatever

4
financial advisory firm name they had been using, and started over with new names, phone
numbers, and websites, touting a new group of issuers’ stocks to a different group of investors.
6. Defendant Alvarez, in addition to calling potential investors to tout the stocks
being promoted by Defendants’ boiler room, frequently engaged in manipulative trading in
issuers’ securities near the start of each promotional campaign.  As detailed below in relation to
his trading in Garmatex, Aureus, Inc. (“Aureus”), and Proto Script Pharmaceutical Corp.
(“Proto”), Alvarez would often place a series of small buy orders to give the appearance of
trading activity and to drive up quoted sales prices of an issuer’s shares both before the
Defendants’ boiler room began promoting those shares or early in that promotional activity.
7. For their efforts in promoting sales of their control group clients’ stock, the
Defendants were paid from the trading proceeds generated by the control groups’ sales.  They
typically charged their control group clients up to 65% of the trading proceeds attributed to the
boiler room’s sales efforts.
8. The Defendants’ victims, including elderly retail investors who invested their
retirement savings based on the Defendants’ material misrepresentations and omissions, were left
holding nearly worthless investments while the Defendants and their clients profited by dumping
their shares.
VIOLATIONS
9. As a result of the conduct alleged herein, Defendants violated, and unless
restrained and enjoined will continue to violate, Section 17(a) of the Securities Act of 1933
(“Securities Act”), and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
and Rule 10b-5 thereunder, and Alvarez also violated, and unless restrained and enjoined will
continue to violate, Section 9(a)(2) of the Exchange Act.

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NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
10. The Commission seeks a permanent injunction against the Defendants, enjoining
them from engaging in the transactions, acts, practices, and courses of business alleged in this
Complaint, disgorgement of all ill-gotten gains from the unlawful conduct set forth in this
Complaint together with prejudgment interest pursuant to Section 21(d)(7) of the Exchange Act
[15 U.S.C. §78u(d)(7)], civil penalties 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)], orders barring the
Defendants from participating in any offering of a penny stock, pursuant to Section 20(g) of the
Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of the Exchange Act [15 U.S.C. §78u(d)] and
such other relief as the Court may deem appropriate.
JURISDICTION AND VENUE
11. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. §77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act
[15 U.S.C. §§78u(d), 78u(e), and 78aa].
12. Venue lies in this District pursuant to Section 22(a) of the Securities Act
[15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C. §78aa].  Certain of the acts,
practices, transactions and courses of business alleged in this Complaint occurred within the
Eastern District of New York, and were accomplished, directly or indirectly, by making use of
means or instrumentalities of transportation or communication in interstate commerce, or the
mails.  For example, during the R elevant Period,  Defendants called individuals who reside in the
Eastern District of New York, and individuals who reside in the Eastern District of New York
purchased the stock of Oroplata, Garmatex, and PureSnax during the Relevant Period.
DEFENDANTS
13. Francis Jason Dean Biller (“Biller”), age 52, is a Canadian citizen and a resident

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of Medellin, Colombia.  On February 16, 2000, the British Columbia Securities Commission
barred Biller from participation in the securities industry for a period of 10 years, including
participating in any investor relations activities, and he was ordered to pay administrative
penalties of $300,000.  In a separate criminal case filed in the British Columbia Supreme Court,
Biller pled guilty in April 2005 to four counts of theft and fraud relating to his sales of
investments and in September 2005, was sentenced to 3 years in prison.  On October 12, 2005,
the Ontario Securities Commission, among other remedies, permanently barred Biller from
trading in securities (with several exceptions for personal accounts) and permanently barred him
from serving as a director or officer of a company registered with the Ontario Securities
Commission.
14. Raymond Christopher Dove, (“Dove”), age 43, is a Canadian citizen and a
resident of Japan.
15. Chester Bruce Alvarez (“Alvarez”), age 37, is a United States citizen and a
resident of Medellin, Colombia, and of Oakland Park, Florida.
16. Troy Gran-Brooks (“Gran-Brooks”), age 31, is a Canadian citizen and a resident
of either Medellin, Colombia, or Canada.
17. Justin Plaizier (“Plaizier”), age unknown, is a Dutch citizen and a resident of
either Medellin, Colombia, or Canada.
RELIEF DEFENDANTS
18. Lia Patricia Sepulveda Salazar (“Salazar” aka Patricia Biller), age 49, is the wife
of Biller and is a Colombian citizen residing in Medellin, Colombia.  Salazar, or accounts under
her control or for her benefit, received at least $3 million that was proceeds of Defendants’
illegal conduct.
19. Edward Lopez Giraldo (“Giraldo”), age 43, is a family member of Salazar and is a

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Colombian citizen residing in Medellin, Colombia.  Defendants, directly or indirectly,
transferred at least $2 million to Giraldo, or accounts under his control or for his benefit, that
were proceeds of Defendants’ illegal conduct.
20. Edward Thomas Clarke (“Clarke”), age 75, is a family member of Biller and/or
Salazar and is a Canadian citizen residing in British Columbia, Canada.  Defendants, directly or
indirectly, transferred at least $630,000 to Clarke, or accounts under his control or for his benefit,
that were proceeds of Defendants’ illegal conduct.
21. Shredderz International Corp. (“Shredderz”) was incorporated by Dove in June
2016 in the Federation of Saint Kitts and Nevis.  Dove is its sole officer and director.
Defendants, directly or indirectly, transferred the net amount of at least $1,645,000 to Shredderz,
or accounts under its control or for its benefit, that were proceeds of Defendants’ illegal conduct.
RELATED PARTIES
22. During the Relevant Period, Oroplata described itself as a company involved in
lithium resource exploration and development.  Oroplata’s stock (Ticker: ORRP) was quoted on
OTC Link (previously, “Pink Sheets”), operated by OTC Markets Group, Inc.  Oroplata was
incorporated in Nevada in 2011 and during the Relevant Period, was based in the Dominican
Republic.

23. Garmatex, formerly known as Oaxaca Resources Corp., described itself as a
company that developed and supplied engineered fabric technology.   During portions of the
Relevant Period, Garmatex’s stock (Ticker: GRMX) was quoted on OTC Link.  Garmatex was
incorporated in Nevada in 2014.
24. During the Relevant Period, PureSnax described its business as focused on
developing and selling healthy snacks to consumers.  PureSnax’s stock (Ticker: PSNX) was
quoted on OTC Link during the Relevant Period.  PureSnax was a New Jersey corporation that

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was incorporated in 2011 and during the Relevant Period was headquartered in Woodbridge,
New Jersey.
BACKGROUND
25. “Penny Stock,” as used herein, generally refers to a security issued by a small
company that trades at less than $5 per share.
26. An “issuer” is a company whose securities are publicly traded.  An “affiliate” of
an issuer is a person or entity that, directly or indirectly through one or more intermediaries,
controls, is controlled by, or is under common control with, such issuer (i.e., a control person).
“Control” means the power to direct management and policies of the company in question.
Typically, affiliates include officers, directors and controlling shareholders,  but any person who
is under “common control” with, or has common control of, an issuer is also an affiliate.  As
used herein, the term “control group” means a group that collectively is an “affiliate” of an
issuer.
27. The control groups who hired Defendants’ boiler room were “affiliates” of the
issuers whose stock they hired Defendants to promote in part because the control groups
typically controlled those issuers’ float.  Stock held by an affiliate of an issuer is restricted stock.
Absent an exemption under the federal securities laws and rules, restricted stock cannot be
legally offered or sold to the public unless a securities registration statement has been filed with
the Commission (for an offer) or is in effect (for a sale).  A registration statement contains
important information about an issuer’s business operations, financial condition, results of
operation, risk factors, and management.  It also discloses any person or group who is the
beneficial owner of more than 5% of the company’s securities.  The control groups did not file
registration statements for the sales of stock that they hired the Defendants to promote.
28. Instead of making public disclosures about their control over the issuers’ float,

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Defendants’ control group clients took a number of steps to conceal their ownership of the float.
First, the control groups divided the issuers’ stock into blocks of under 5% each (a threshold for
reporting ownership in registration statements, which is also used by many broker-dealers when
evaluating deposits of stock into brokerage accounts).  Second, they orchestrated the transfer of
those blocks of less than 5% to multiple foreign companies under their control or whose nominee
owners agreed to act at their direction.  Third, the control groups employed three foreign trading
platforms whose primary business purpose was to facilitate illegal securities transactions in
United States securities markets by providing a layer of disguise to their control group clients.
The control groups sold their stock through brokerage accounts maintained by at least three
fraudulent trading platforms: Wintercap SA (“Wintercap”), Blacklight SA (“Blacklight”) and the
Bajic-Taneja Platform (collectively, the “Foreign Platforms”).
1

29. “Pump-and-dump” schemes typically involve company shareholders touting, or
“pumping,” (or paying others to tout or “pump”) a company’s stock through false and misleading
statements or through manipulative trading, for the purpose of creating market demand into
which those same shareholders sell, or “dump,” their shares.
FACTS
DEFENDANTS’ BOILER ROOM IN COLOMBIA
30. Beginning sometime before January 2016, Defendants Biller and Dove began
operating a boiler room in Colombia.  The primary business of Defendants’ boiler room was to
convince United States and Canadian investors to buy the stocks of the companies whose shares
were being sold by the Defendants’ control group clients.  While the number of employees

1
 The three trading platforms and their operators were charged in separate cases.  The Wintercap platform, operated
by Roger Knox and his associates, was charged in SEC v. Knox, No. 18-cv-12058 (D. Mass., filed Oct. 2, 2018).
The Bajic-Taneja and Blacklight platforms were charged in SEC v. Bajic, et al., No. 20-cv-0007 (S.D.N.Y., filed
Jan. 2, 2020).

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working in the boiler room varied between 2016 and 2018, there were often at least 10 people
working there, including each of the Defendants.  Biller and Dove charged their clients up to
65% of the trading proceeds “captured” by their control group clients (that is, the aggregate
proceeds of stock sales by the control group to investors contacted by the boiler room).
31. Biller and Dove worked together as the leaders of the boiler room.  They
marketed the boiler room’s services to individuals who represented various control groups,
persuading them to hire the boiler room to sell particular companies’ stock.  Biller and Dove also
functioned as “closers” or “loaders” in the boiler room.  That means that once one of their junior
employees ( sometimes called “openers”) got an investor interested in the boiler room’s purported
financial advisory organization, or persuaded an investor to purchase a small amount of a
company’s stock, Biller or Dove would then call that investor to try to persuade him/her to
purchase more of that security, or another security being promoted by the boiler room.
32. Alvarez was one of the employees who served as an “opener.”  As described in
more detail below, Alvarez also engaged in manipulative trading in the stocks Defendants were
preparing to promote, in order to encourage investors to purchase those shares.  Alvarez’s
purchases of shares of stocks, which were then promoted by the boiler room, helped to increase
the issuers’ stock price before the promotional campaigns began, and in the first few weeks of
the promotional campaigns.
33. In the spring of 2018, Biller and Dove were looking for a new source of clients
who had stock that could be promoted by their boiler room.  Dove had previously partnered with
an individual (referred to herein as “Person A”) in a number of other pump and dump deals.
2
  In

2
 Person A was previously charged by the Commission and by the U.S. Attorney’s Office for the Eastern District of
New York for his participation in various securities fraud schemes.  That case is ongoing.

11
the spring of 2018, Person A introduced the Defendants to an individual (“Person B”) who
purported to be looking for a boiler room to promote several issuers’ stocks.  Unbeknownst to
Person A and the Defendants, Person B was working in an undercover capacity with law
enforcement officials and recorded his communications with Person A and the Defendants.
34. On April 18, 2018, Dove, Person A, and Person B discussed the potential for
Defendants’ boiler room to be hired by Person B and his associates.  Person B claimed that his
associates controlled about 30 million shares of an issuer’s stock, which was almost the entire
float.  During the call, Dove described the past success of Defendants’ boiler room, stating:
“Over the last two years, we’ve probably done 15 deals, and not a single one lasted for more than
two months. Now that being said, the smallest number raised on any of those transactions . . .
would have been like 3.5 million.  And those were the deals that lasted the longest. We’ve done
upwards of 10 million dollars on a deal in six weeks.”  The participants in the call also discussed
how the boiler room would be paid and Dove explained that, for their promotional services, his
group charged “a straight 65% of all captured sales” or in other words, “if week one we sell
$500,000 worth of stock, then it’s 65% of that.”
35. On that call, Dove also emphasized how important it was for his clients to control
all of an issuer’s float so that both his boiler room and the control group client would make the
most money.  Dove said, “Well, if they are gonna sell . . . Everyone . . . It would have to be
100% controlled,” and further commented, “that’s why we need to know what’s actually in the
float out there against us.  If that’s a big number, then it probably won’t be worth starting.”
36. On that same call, Dove also described that the boiler room likes to have two
deals to sell at about the same time.  As he explained: “What we want to do is we want to have
another one ready within six to eight weeks while the first one is still up and we’ll have created

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some kind of a story where the people can’t buy the first one but because they are already so up
on the first one, they trust us. They’ll dump a lot more into the second one. We call it a Deal B.
Deal B typically we get more back than a Deal A.  So with the deal platter we sell . . . we want
two deals to have the best rate of success . . . .”
37. Dove also told Person B what his boiler room did to cover its tracks after the
promotions for Deals A and B were finished.  He explained that after those two deals are done,
“we basically need to, you know, reinvent . . . you know, create a new company name and all
that stuff, and then go into the next two.” (emphasis added).  This method of operation meant
that the boiler room could not be located by disgruntled investors who lost money on the
investments recommended by Defendants after their promotions were over.
38. About a month later, on May 16, 2018, Person B visited Defendants’ boiler room
in Medellin, Colombia, so that he could see the operation for himself.  While he was there,
Person B met with Alvarez and Person A, and then met separately with Biller, Dove, and Person
A.
39. During those meetings, which Person B recorded on video, Alvarez explained to
Person B the telephone pitch that the boiler room employees typically make to potential
investors.  He described his role as generating leads for the “loaders” (Biller and Dove).  Alvarez
stated that he would pretend to be from an investor relations firm and would tell the potential
investor that his firm had recommended another security that had done very well and that they
had another deal coming up soon.
40. Alvarez also told Person B that Defendants routinely set up the websites for their
fictitious investor relations firms, so that the firms “would look like a real company” if investors
checked on them, and they would take the websites down immediately after the promotion

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ended, so that investors could not complain to it (when they lost money on their investments).
41. Alvarez explained that the boiler room had not in fact recommended the prior
securities that had done well in the market—the Defendants just chose a stock that had
performed well and took credit for it.  Alvarez would then encourage the potential investor to put
money into his or her brokerage account and would then have a dialogue to build rapport with
the potential investor.  Alvarez also told Person B that the boiler room employees told potential
investors that their investor relations firm was in Naples, Florida, which they chose because it
was an affluent area.
42. During the meeting among Biller, Dove, Person A, and Person B, Biller described
Dove as his partner in the boiler room and emphasized to Person B that he wanted to establish a
relationship where they promoted multiple deals over time so that he could keep his employees
working steadily.  Biller pressed Person B for a $150,000 advance payment in order to reserve
the boiler room exclusively for Person B’s prospective deals.
43. During these meetings, Dove showed Person B the website of the fake investor
relations firm the boiler room was claiming to be part of at that time.  He explained how the fake
company added to the credibility of Defendants’ pitch if investors questioned where they
worked.
44. When Person B asked Dove to describe the typical pitch to an investor, Dove
explained that he would say: “Go into your trading account and buy the stock now!  Here’s our
history.  Here’s what we’ve done before.  We normally do three deals a year.  Our average
trading return over the past eight years has been about 300%.  Well, our last one did 1,800%.  So
right now, take a position.  How much do you have available in your trading account right now?
Open it up...click the buy tab.  Here’s the symbol.  Buy it!”  Dove added,  “It’s really that

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simple.”
45. Biller added that it was often part of his pitch to tell investors that the stocks he
was promoting would be listed on NASDAQ in about another three months.  Biller knew, or was
reckless or negligent in not knowing, that those statements were false.  In describing his pitch to
Person B, Biller implied that he did not actually believe that these companies would be able to
uplist to the NASDAQ exchange (which would have required a significant price increase as well
as lengthy and costly application and due diligence processes).
46. Biller also explained to Person B that he would always use false names when
talking to investors.  As an example, he said that currently he was telling investors he was a
doctor who frequently appeared on television and added, “I tell them, ‘I’ll send you a copy of my
book.  I’m scheduled to be on CNN again in mid-August.’”
47. When Person B asked whether investors were often upset when they lost money
on the stocks the boiler room had convinced them to buy, Dove replied: “Well, our phone lines
are gonna be shut off . . . Remember, we reinvent ourselves every two deals . . . So we get them
in the first deal, which is doing well (Deal A), and then we get them in the second deal, then
there comes the day when we have to turn the phone lines off.”  He added, “We have new phone
lines ready to go, new company website, everything” so when the next deal starts, the
Defendants have a new set of leads and they are not calling the same people again.  “Rinse and
repeat . . . We get new leads coming in on a daily basis . . . We just got 250 today.”
48. In bragging about past deals to Person B, Dove and Biller specifically mentioned
their involvement in promoting “ PSNX, PSNP . . . and ORRP,” and explained that “200 people
[investors] on a deal is enough to generate two million bucks . . . typically we will have 600 buys
and we could do six to ten million” (meaning that they could generate $6-10 million in sales on a

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particular stock).  Biller claimed that the boiler room had generated $100 million of sales over its
history.
49. The following examples illustrate in greater detail how Defendants’ conduct in
selling particular issuers’ securities followed the general scheme that Biller, Dove, and Alvarez
described to Person B.
EXAMPLE 1:  THE OROPLATA PUMP AND DUMP
50. One of the issuers that Dove and Biller told Person B they promoted was ORRP
(the ticker for Oroplata).   Defendants promoted Oroplata contemporaneously with sales made by
their control group clients as described below.
The Control Group’s Trading In Oroplata
51. By April 2016, a control group (the “ORRP Control Group”) owned 100% of the
float of Oroplata.  As described generally in paragraph 28 above, the ORRP Control Group
divided Oroplata’s stock into blocks of less than 5% of Oroplata’s total number of shares
outstanding, and transferred the ownership of those blocks of stock into at least seven foreign
nominee entities such that each nominee owned, on paper, less than 5% of Oroplata’s shares.
52. The ORRP Control Group’s stock was then deposited into brokerage accounts and
sold by the three Foreign Platforms—who were all acting at the direction of the ORRP Control
Group, and in particular at the direction of Luis Carrillo (“Carrillo”)
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, who was a member of the
ORRP Control Group.
53. Collectively, between February 2016 and September 2016, the Foreign Platforms
sold Oroplata stock into the demand created by Defendants’ boiler room for trading proceeds of

3
 Carrillo was previously charged by the Commission for his participation in various securities fraud schemes.  See
SEC v. Carrillo, et al., No. 21-cv-11272 (D. Mass., filed Aug.4, 2021).

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approximately $13.1 million.
Defendants Promoted Oroplata Stock
54. From on or about June 6, 2016, through at least September 2016, Defendants’
boiler room promoted Oroplata stock.  At that time, Defendants were using the names Market
Wi$e Report or Winford Report for their phony investor relations firm.  Thus, the boiler room’s
employees told prospective investors that they worked for Market Wi$e Report or Winford
Report.
55. Numerous investors bought Oroplata shares during at least August and September
2016 because they were encouraged to do so by people who identified themselves as calling
from Market Wi$e Report.  Francis Jonson was the false name being used by Biller at the time
for his boiler room work.  Biller, using the name of Francis Jonson, encouraged Investor #1 to
consider purchasing shares of Oroplata and told Investor #1 that he was able to get numerous
investors in at $0.90 and out at “well above 2 dollars” a share.
56. Investor #2 purchased shares in Oroplata as well as other stocks promoted by
Defendants’ boiler room, including PureSnax.  From about May through August 2016,
Investor #2 spoke, and exchanged emails, with a person who identified himself as a Market Wi$e
Report representative named Tomas Beneth.  Tomas Beneth was a false name used at the time by
Defendant Gran-Brooks.  Investor #2 also spoke to Biller, who was using the name Francis
Jonson, at least twice and received emails from him.  “Jonson” told Investor #2 that he was one
of the heads of Market Wi$e Report and led her to believe that Market Wi$e was a financial
advisory firm in Florida.  “Jonson” also told Investor #2 that the people working at Market Wi$e
Report had themselves invested in the stocks they were encouraging her to buy.  On the basis of
her conversations with Gran-Brooks and Biller, Investor #2 bought at least 26,500 shares of
Oroplata at an average price of $0.93 per share on June 6 and 7, 2016.  She also bought shares of

17
several other companies promoted by defendants during that time period, including PureSnax.  In
her discussions with Gran-Brooks, Investor #2 made it clear to Gran-Brooks that she needed her
investment savings to pay for surgery she was scheduled to undergo in the summer of 2016.
57. Gran-Brooks acted negligently, recklessly, or knowingly when he made numerous
false statements to convince Investor #2 to buy shares of Oroplata, PureSnax, and other
companies, including statements that he guaranteed she would not lose money, that he always
made sure his family owned the stocks he was encouraging Investor #2 to buy, and that he had
much bigger positions in the stocks than Investor #2 was buying so she should not worry.
Trading In Oroplata During Defendants’ Promotions
58. Before June 2016, there was little trading in Oroplata.  Starting in June 2016,
there was a significant increase in both the volume and price of Oroplata shares as illustrated in
the graph below.  Between the first trade in Oroplata on February 24, 2016, and June 6, 2016,
there were only 10 trading days when any purchases or sales of Oroplata stock were reported.
On these 10 days, the average trading volume was less than 5,200 shares per day with an average
closing price of approximately $0.44 per share.  Starting on June 6, 2016 and continuing through
September 2016, the average volume of Oroplata trading was over 700,000 shares per day.
Average closing prices increased throughout June to a peak in mid-July 2016 before decreasing
again, as shown in the chart below.

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59. During Defendants’ promotion of Oroplata between June 6 and August 15, 2016,
the price of the stock ranged from $0.93 to $1.91.  By the end of September 2016, the stock’s
price had dropped to $0.545, and the price continued to fall, trading in a range between $0.10
and $0.20 per share into 2017, and eventually dropping below that.  Investors who purchased
Oroplata on the Defendants’ urging and held their shares lost significant sums of money.
EXAMPLE 2: THE PURESNAX PUMP AND DUMP
60. Another one of the issuers that Dove and Biller told Person B they sold was
PSNX (the ticker for PureSnax).  Defendants promoted PureSnax contemporaneously with sales
made by their control group clients as described below.
The Control Group’s Trading In PureSnax
61. By January 2016, a control group containing at least Carrillo (the “PSNX Control
Group”) controlled 100% of the float of PureSnax.  The PSNX Control Group divided
PureSnax’s stock into blocks of less than 5% of PureSnax’s total number of shares outstanding

19
and transferred the ownership of those blocks of stock to foreign nominee entities so each
nominee owned, on paper, less than 5% of PureSnax’s shares.
62. The PSNX Control Group’s stock was then deposited into brokerage accounts and
sold by two of the three Foreign Platforms, who were acting at the direction of the PSNX Control
Group, and in particular took trading directions from Carrillo.
63. Collectively, between March 2016 and September 2016, two of the Foreign
Platforms sold PureSnax stock into the demand created by Defendants’ boiler room for trading
proceeds of at least $1.4 million.
Defendants Promoted PureSnax
64. From at least mid-March through mid-July 2016, Defendants’ boiler room
promoted PureSnax stock.  Defendants’ PureSnax promotion overlapped with the time period of
their Oroplata promotion, and Defendants used the phony investor relations firm names of
Market Wi$e Report or Winford Report to conduct both promotions.  As in the Oroplata
promotion, the boiler room’s employees who were promoting PureSnax told prospective
investors that they worked for Market Wi$e Report or Winford Report.
65. Numerous investors bought PureSnax shares between March and July 2016
because they were encouraged to do so by people who identified themselves as calling from
Market Wi$e Report.  For example, Investor #1 purchased 20,000 shares of PureSnax at an
average price of $0.59 on April 11, 2016, after speaking with Biller, who identified himself as
Francis Jonson.  Investor #1 purchased an additional 90,000 shares of PureSnax at an average
price of $0.60 on April 15, 2016 after speaking with Biller (posing as Jonson) a second time.
Biller reassured Investor #1 after a price dip in PureSnax on May 10, 2016, that PureSnax was
not, as Investor #1 worried, “a house of cards that is starting t o tumble.”  Biller (posing as
Jonson) also sent out a promotional email on May 31, 2016, telling investors that “[y]our

20
patience is about to be rewarded” for investing in PureSnax and that “PSNX will be moving into
phase 2 over the next 2 to 3 business days.  We expect to see a dramatic increase in both volume
and share price appreciation.  The wait is over!”  Another email from Biller (as Francis Jonson)
on June 17, 2016, (after a decline in PureSnax’s price and trading volume) encouraged
Investor #1 to “Get PSNX on your screen now! . . . . You don’t get an opportunity like this
everyday, especially with a company expected to grow so large and so fast.  Drop everything
you’re doing now, because this could be the last time you see PSNX at this level with a breakout
potential.”  On Biller’s urging, Investor #1 held on to all of his PureSnax shares and ultimately
lost over $70,000.
66. Investor #2 purchased 7,000 shares of PureSnax between April 2 and 27, 2016
and ultimately purchased a total of 21,200 shares of PureSnax by July 6, 2016.  On the urging of
Gran-Brooks (posing as Beneth), Investor #2 held on to all of her PureSnax shares.  When
Investor #2 got nervous about drops in the price of PureSnax, Gran-Brooks told her that she
should not sell, and that the price would come back.  Gran-Brooks also told her that his sister
was invested in PureSnax, and he would not let her get hurt.  Gran-Brooks also told Investor #2
that Market Wi$e clients had to follow their program if they wanted information about other
stocks that would do well.  Gran-Brooks told investor #2 that following the program meant not
selling until they advised her to sell.  Investor #2 lost over $11,800 investing in PureSnax.
67. Investor #3 purchased PureSnax shares after being called by an individual
identifying himself as Richard van Geld from Market Wi$e Report and receiving follow-up calls
from people calling themselves Francis Jonson and Chris Sterling, claiming to be from the same
firm.  Richard van Geld was a name used by Justin Plaizier, and Chris Sterling was a name used
by Dove, when they called investors through Defendants’ boiler room.  Investor #3 initially

21
purchased PureSnax shares because Plaizier (posing as van Geld) told him that the shares would
increase in price in several days and would get to $1 or more.  Plaizier did not, however, tell
Investor #3 that the reason he knew PureSnax shares would increase in price is because he and
the boiler room employees were actively soliciting many investors to buy those shares.  In
context, Plaizier’s statements to Investor #3 were materially misleading and were made
negligently, recklessly, or knowingly.
68. Follow up calls from Dove (posing as Sterling) and Biller (posing as Jonson)
invited Investor #3 into Market Wi$e’s “inner circle” so that he could get investment advice
from them as leaders of Market Wi$e.  Biller and Dove emphasized to Investor #3 that in order
to be part of the “inner circle” he should not sell the stocks they advised him to buy until they
told him to sell, even if the price dropped.  To lull Investor #3 into holding onto PureSnax shares
in the face of declining share prices, Biller told Investor #3 that one price decline in PureSnax
stock was attributable to a large investor having to sell his shares to make a margin call on his
portfolio caused by a bad investment in a diamond mine.  Investor #3 followed their instructions
not to sell until told to do so for a period of time.  Between April 12, 2016 and September 27,
2016, Investor #3 bought a total of over 156,000 shares of PureSnax, spending over $65,800.
Investor #3 sold some of his PureSnax shares, recovering about $23,800 of his investment, but
the remaining stock is worthless.  Overall, Investor #3 lost approximately $42,000 on his
PureSnax investment and additionally lost over $100,000 on other stocks he purchased at the
urging of Plaizier, Biller, and Dove.
Trading In PureSnax During Defendants’ Promotions
69. Before early March 2016, there was little trading in PureSnax.  Beginning in early
March 2016, there was a significant increase in both the volume and price of PureSnax shares as
illustrated in the graph below.  Before March 10, 2016, there were only 11 days during 2016 on

22
which PureSnax trades were reported and its average trading volume was less than 3,800 shares
per day.  From March 10, 2016 until the end of July 2016, its average volume increased to
almost 110,000 shares per day.  The closing price of PureSnax stock rose from around $0.30
before the promotion to its highest closing price of $.804 and .805 on May 4 and 5, 2016.

70. During Defendants’ promotion of PureSnax, the price of the stock rose to a high
of $0.895 per share.  Once the Defendants’ boiler room stopped promoting PureSnax, the stock’s
price dropped quickly to below $0.01 per share by September 22, 2016.  Many investors who
purchased PureSnax on the Defendants’ urging thus lost significant sums of money.
EXAMPLE 3:  THE GARMATEX PUMP AND DUMP
71. During the spring of 2017, Defendants’ boiler room ran a promotional campaign
encouraging potential investors to purchase shares of Garmatex (whose ticker was GRMX).
Defendants promoted Garmatex contemporaneously with sales made by their control group
clients as described below.

23
The Control Group’s Trading In PureSnax
72. By March 2017, a control group composed of at least Carrillo (the “Garmatex
Control Group”) controlled nearly 90% of the float of Garmatex.  Following the pattern of
Oroplata and PureSnax, the Garmatex Control Group’s shares were divided into blocks of less
than 5% of Garmatex’s total number of shares outstanding, and transferred into at least six
foreign nominee entities such that each nominee o wned, on paper, less than 5% of Garmatex’s
shares.
73. In March and April 2017, those nominees’ stock was deposited into brokerage
accounts and sold by two of the three Foreign Platforms.  Wintercap took its trading directions
when selling Garmatex stock from Carrillo.  By May 15, 2017, the Garmatex Control Group had
sold every share that had been transferred to the Foreign Platforms.
74. Collectively, between March 2017 and May 2017, the Garmatex Control Group
sold at least 12.2 million shares of Garmatex stock into the demand created by Defendants’
boiler room, f  or trading proceeds of over $7,000,000.
Defendants Promoted Garmatex
75. From about mid-March to May 2017, Defendants’ boiler room promoted
Garmatex stock.  By the time of the Garmatex promotion, Defendants had stopped using the
name Market Wi$e Report for their phony investor relations firm.  By 2017, the Defendants had
begun using the name Global Stock Advantage.  Thus, the boiler room’s employees told
prospective investors that they worked for Global Stock Advantage.  False names used by the
people working in the Defendants’ boiler room in 2017 included Dr. Peter Phillips (used by
Biller), and Craig Morgan (used by Dove) and Sid Wexler.
76. Numerous investors bought Garmatex shares during March through May of 2017
after being solicited by callers who identified themselves as working for Global Stock

24
Advantage.  For example, Investor #4 began purchasing Garmatex shares on March 14, 2017,
after receiving an introductory call from a person going by the name of Sid Wexler, and more
detailed calls from persons using the names of Dr. Peter Phillips (who claimed to be a Ph.D. in
economics) and Craig Morgan.
77. Biller, claiming to be Dr. Peter Phillips, made numerous misrepresentations to
Investor #4 including that: 1) his firm, Global Stock Advantage (“GSA”), looked for and assisted
undervalued companies that could thrive on the NASDAQ stock exchange; 2) Phillips and
Morgan had left a large Canadian brokerage firm after 20 years to start GSA; 3) Garmatex was
about to announce big deals with a Fortune 500 company and an upholstery company that
supplied high-end car manufacturers; 4) Garmatex would be moving to the NASDAQ stock
exchange on July 7, 2017; 5) Morgan Stanley was arranging a private purchase of 4.25 million
shares of Garmatex; and 6) independent research firms had already valued Garmatex at $9 per
share.
78. Dove, claiming to be Craig Morgan, also made misrepresentations to Investor #4
including a representation that GSA only assisted companies that had revenue growth of 50% per
year and had a known product to execute a reverse merger and become public without an initial
public offering—implying that Garmatex was such a company.
79. Biller and Dove knew or were reckless or negligent in not knowing that their
statements were false or misleading when they were made.  They had no reason to believe that
Garmatex had any plans to move to the NASDAQ stock exchange, let alone that it would do so
in July 2017.  Nor did they disclose that they were promoting Garmatex on behalf of a control
group that was dumping its shares into the demand created by the Defendants’ promotion.
80. Investor #4 was an investment adviser nearing retirement who invested, and lost,

25
most of his retirement savings to Defendants’ fraudulent scheme.  Investor #4 purchased more
than 3 million shares of Garmatex for a total loss on his investment of over $2 million.
Trading In Garmatex During Defendants’ Promotions
81. Before March 2017, there was little trading in Garmatex shares.  In approximately
mid-March 2017, at about the same time that Carrillo orchestrated the deposit of the foreign
nominees’ shares into brokerage accounts, there was a significant increase in both the volume
and price of Garmatex shares as illustrated in the graph below.  Between February 7, 2017, and
March 10, 2017, the average daily volume of trading in Garmatex stock on those days when it
traded was less than 90,000 shares.  On the first day of the Defendants’ boiler room promotion,
March 14, 2017, volume spiked to over 5 million shares.  Between March 14, 2017, and May 2,
2017 (the last day that the Garmatex Control Group sold stock), the average volume was over
1.5 million shares per day.  The closing price of Garmatex stock rose from $0.40 before the
promotion to its highest closing price of $1.21 on March 23, 2017.

26
82. Once the Defendants’ boiler room stopped promoting Garmatex, the stock’s price
dropped to less than $0.20.  Many investors who had purchased Garmatex on the Defendants’
urging thus lost significant sums of money.
DEFENDANTS’ BOILER ROOM PROMOTED ADDITIONAL ISSUERS
83. Defendants’ boiler room promoted the stocks of numerous issuers that were sold
by their control group clients through the Foreign Platforms and otherwise.  The following chart
summarizes the stocks that were promoted by the Defendants and the trading proceeds that their
control group clients reaped by selling into the demand created by the Defendants’ fraudulent
conduct:

ALVAREZ’S MANIPULATIVE TRADES
84. In addition to calling potential investors to solicit their purchases of the securities
that were touted by Defendants’ boiler room, Alvarez also engaged in manipulative trading in
advance of, or early in, Defendants’ promotional activity that was designed to drive up reported
sales prices of the shares the Defendants were encouraging investors to buy.  Alvarez routinely

27
engaged in this manipulative trading on securities that were promoted by Defendants’ boiler
room.
85. Alvarez’s trading was funded, in part, by payments from the Defendants’ control
group clients, including Person A.  For example, on June 14, 2016, Person A wired $9,560 to a
firm controlled by his associate.  On the same day, the associate’s firm wired $9,500 directly into
Alvarez’s brokerage account.  Over the next seven days, Alvarez spent $9,500 to buy shares of
Oroplata, PureSnax, and two other securities then being promoted by Defendants’ boiler room.
86. Alvarez’s purchases of Aureus shares are illustrative of his manipulative trading.
Aureus shares began trading in the public markets on July 22, 2016.  Between July 22 and
August 3, 2016, there were few Aureus trades in the public markets and the average daily
volume of shares traded was under 20,000 shares a day.  On July 27, 2016, Alvarez purchased
101 shares of Aureus for $0.60 per share, an increase of 100% over the prior day’s closing price.
The price of Aureus increased again dramatically on July 29, 2016, such that its closing price of
$1.50 was almost $1 more than the prior day’s closing price of $0.583.  Alvarez traded in Aureus
again on the next day its shares traded: August 3, 2016.  On August 3, 2016, Alvarez bought 100
shares of Aureus at $2.48 per share, a 65% increase over the prior day’s closing price.  Alvarez
was the only purchaser in the market on August 3.  It is significant that Alvarez traded in 100
share blocks because only trades of 100 or more shares would be reported and visible to potential
investors in the market.  Alvarez’s trades in Aureus created the misleading impression that there
was legitimate market demand at the higher prices he was paying for Aureus shares, and were
designed to induce other people to invest.
87. Defendants’ boiler room began actively promoting Aureus shares on August 4,
2016.  Beginning on August 4, the number of daily trades in Aureus increased substantially.  For

28
example, while the highest volume in the prior month was about 85,000 shares traded on July 22,
2016, there were over 5.5 million shares traded on August 4, 2016.
88. While the Defendants’ boiler room was actively promoting Aureus throughout
August 2016, Alvarez continued to make small purchases of Aureus shares in 100 share blocks
on at least seven trading days,  at prices at or near the high point of the day’s price.  Alvarez’s
continued trades in Aureus created the misleading impression that there was market demand for
Aureus stock at the high prices he was paying for those shares, and were designed to induce
other people to invest.
89. Alvarez’s conduct in buying Garmatex shares was similar.  Between September
2016 and February 2017, there was little market trading in Garmatex shares.  In fact, Garmatex
shares only traded on 14 days within that five-month period.
90. On March 1, 2017, Alvarez purchased 100 Garmatex shares at a price of $0.77, a
$0.07 increase over the prior day’s closing price.  On March 2, 2017, Alvarez bought 200 shares
of Garmatex, again at a price of $0.77, which was the day’s high price.  On March 3, 2017,
Alvarez purchased 100 shares of Garmatex at a price of $0.78, just a penny under the day’s high
price of $0.79.  Alvarez’s trades in Garmatex created the misleading impression that there was
market demand for Garmatex stock at the higher prices he was paying for Garmatex shares, and
were designed to induce other people to invest.
91. When Defendants’ boiler room began actively promoting Garmatex, on or about
March 14, 2017, the volume of shares traded each day increased dramatically.  For example, on
March 13, 2017, about 160,000 Garmatex shares traded, whereas more than 5 million shares
traded on March 14 once Defendants began their promotion.
92. During the time period that Defendants’ boiler room was actively promoting

29
Garmatex in March and April 2017, Alvarez made additional trades to support the price of
Garmatex shares.  On at least 14 additional trading days during those two months, Alvarez
purchased Garmatex shares, in 100 share blocks, at prices that were at or near the high of each
day’s trading.
93. Alvarez’s trading in shares of Proto Script Pharmaceutical Corp. (“Proto”)
followed the same pattern.  Between June and November 2016, trading in Proto shares in the
market was very light.  In fact, Proto shares traded in the markets on only 12 days in that time
period.
94. On December 5, 2016, Alvarez purchased 100 shares of Proto at a price of $0.51
per share.  This was the only trade in the market that day and the price he paid was an increase of
about 62% over the prior trading day’s price.  There were no trades in Proto shares after
Alvarez’s trade until the Defendants’ boiler room began promoting Proto on or about December
14, 2016.  Alvarez’s trade thus set the starting price point for Defendants’ promotions of Proto
shares.  Alvarez’s trade in Proto was designed to create the misleading impression that there was
market demand at the higher prices he paid for Proto shares, and was designed to induce other
people to invest.
95. Once Defendants’ boiler room began promoting Proto, the volume increased
substantially, to over 2.5 million shares traded on December 15, 2016.  While the Defendants
were actively promoting Proto, in December 2016 and January 2017, Alvarez continued to make
additional purchases of Proto in 100 share blocks to support the price of Proto shares.  He made
those purchases on at least 16 trading days in December 2016 and January 2017, at prices at or
near the high price of the day, or at times when the price of his trade was an increase over the
then-current trading price.

30
DEFENDANTS RECEIVED PROCEEDS OF THE FRAUDULENT TRADES
96. Based on information presently available to the Commission, between January 1,
2016 and the present, Defendant Dove directly received payments totaling over $1.8 million that
represented his share of trading proceeds from the penny stocks promoted by Defendants’ boiler
room.  Defendant Alvarez received at least $89,484, while Defendant Gran-Brooks received at
least $469,968 and Defendant Plaizier received at least $112,254.  Those payments came from
the following sources:
Source Received by
Dove
Received by
Alvarez
Received by Gran-
Brooks
Received by
Plaizier
Wintercap SA
(foreign trading
platform)
$456,400  $176,404
Shredderz
International
 $72,000 $293,564 $112,254
Person A and his
associate
$1,347,143 $17,484
Total $1,803,543 $89,484 $469,968 $112,254
97. In addition to these cash payments, Biller and Dove received other items of value
from their control group clients.  For example, Wintercap, one of the trading platforms used by
Defendants’ control group clients, paid the equivalent of over $95,000 for a ski vacation in
Switzerland for Carrillo, Dove, Biller, and their families that lasted from December 27, 2017, to
January 5, 2018.  Wintercap charged these expenses to the account of Carrillo.  Similarly, on or
about January 17, 2018, Carrillo purchased a very expensive watch for Dove and shipped it to
him in Japan.
MONETARY TRANSFERS TO THE RELIEF DEFENDANTS
98. Defendants transferred or directed, directly or indirectly, millions of dollars of
trading proceeds from the fraudulent conduct described above to the Relief Defendants for no
legitimate purpose or consideration.  In particular, Defendant Biller appears to have directed his

31
share of the proceeds from Defendants’ boiler room to his wife and family members rather than
to accounts in his own name.
99. Based on information presently available to the Commission, on numerous dates
between January 1, 2016, and the present, Defendants’ control group clients and the foreign
trading platforms that they used transferred sums of money from trading proceeds in the stocks
promoted by Defendants’ boiler room: (a) to accounts in the name of, or for the benefit of,
Biller’s wife, Salazar; (b) to relief defendant Giraldo; (c) to relief defendant Clarke; and (d) to
Shredderz, a company owned by Dove.  The following chart shows the sources and amounts of
those transfers.  As shown below, Shredderz received $4,693,000 from Wintercap and paid out
$3,808,430 to individuals involved in Defendants’ fraudulent scheme.
Source Received by
Salazar
Received by
Giraldo
Received by
Clarke
Received by
Shredderz
Wintercap SA
(foreign trading
platform)
$110,000  $486,070 $4,693,000
Shredderz
International
$1,696,315 $1,158,235  ($3,808,430)
Person A and his
associate
$1,114,953 $777,552 $148,495
Carrillo $90,000 $140,000  $761,000
Total $3,011,268 $2,075,787 $634,565 $1,645,570

FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Section 17(a) of the Securities Act)
(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier)
100. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if
fully set forth herein.
101. By reason of the conduct described above, Defendants, in the offer or sale of
securities, by the use of the means or instrumentalities of interstate commerce or of the mails,
directly or indirectly, acting intentionally, knowingly, recklessly or negligently (i) employed

32
devices, schemes, or artifices to defraud; (ii) obtained money or property by means of any untrue
statement of a material fact or any omission to state a material fact necessary in order to make
the statements made, in light of circumstances under which they were made, not misleading; and
(iii) engaged in transactions, practices, or courses of business which operated or would operate as
a fraud or deceit upon any persons, including purchasers or sellers of the securities.
102. By reason of the conduct described above, Defendants violated Securities Act
Section 17(a) [15 U.S.C. §77q(a)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder)
(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier)
103. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if
fully set forth herein.
104. By reason of the conduct described above, Defendants, directly or indirectly, 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 any national securities exchange,
intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; (ii)
made any untrue statement of a material fact or omitted to state a material fact necessary in order
to make the statements made, in light of the circumstances under which they were made not
misleading; and (iii) engaged in acts, practices, or courses of business which operated or would
operate as a fraud or deceit upon any persons, including purchasers or sellers of the securities.
105. By reason of the conduct described above, Defendants violated Exchange Act
Section 10(b) [15 U.S.C. §78j(b)] and Rule 10b-5 [17 C.F.R. §240.10b-5] thereunder.

33
THIRD CLAIM FOR RELIEF
MANIPULATION OF SECURITIES PRICES
(Violation of Section 9(a)(2) of the Exchange Act)
(Defendant Alvarez)
106. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if
fully set forth herein.
107. By reason of the conduct described above, Alvarez effected, alone or with one or
more other persons, a series of transactions in at least one security that was not a government
security, that created actual or apparent active trading in that security, or raised or depressed the
price of that security, for the purpose of inducing the purchase or sale of that security by others.
108. By reason of the conduct described above, Alvarez violated Exchange Act Section
9(a)(2) [15 U.S.C. §78i(a)(2)].
FOURTH CLAIM FOR RELIEF
OTHER EQUITABLE RELIEF, INCLUDING UNJUST ENRICHMENT AND
CONSTRUCTIVE TRUST
(Relief Defendants)
109. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if
fully set forth herein.
110. Section 21(d)(5) of the Exchange Act [15 U.S.C. §78u(d)(5)] states, “In any
action or proceeding brought or instituted by the Commission under any provision of the
securities laws, the Commission may seek, and any Federal court may grant, any equitable relief
that may be appropriate or necessary for the benefit of investors.”
111. The Relief Defendants have received investor funds derived from the unlawful
acts, practices, and scheme of the Defendants under circumstances dictating that, in equity and
good conscience, they should not be allowed to retain such funds.
112. Further, specific property acquired by the Relief Defendants is traceable to
Defendants’ wrongful acts, and there is no reason in equity why the Relief Defendants should be

34
entitled to retain that property.
113. As a result, the Relief Defendants are liable for unjust enrichment and should be
required to return their ill-gotten gains, in an amount to be determined by the Court.  The Court
should also impose a constructive trust on property in the possession of the Relief Defendants
that is traceable to the Defendants’ wrongful acts.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
A. Permanently restrain the Defendants, their officers, agents, servants, employees
and attorneys, and those persons in active concert or participation with them who receive actual
notice of the injunction by personal service or otherwise, and each of them, from violating
Section 17(a) of the Securities Act [15 U.S.C. §77q], and Section 10(b) of the Exchange Act
[15 U.S.C. §78j(b)], and Rule 10b-5 thereunder [17 C.F.R. §240.10b-5]  ; and permanently
restrain Alvarez, his agents, servants, employees and attorneys and those persons in active
concert or participation with him who receive actual notice of the injunction by personal service
or otherwise, and each of them, from violating Section 9(a)(2) of the Exchange Act [15 U.S.C.
§78i(a)(2)];
B. Order the Defendants to disgorge, with prejudgment interest, all ill-gotten gains
obtained by reason of the unlawful conduct alleged in this Complaint pursuant to Section
21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)];
C. Order the Defendants to pay civil monetary penalties 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)];

35
D. Enter an order barring the Defendants from participating in any offering of a
penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of
the Exchange Act [15 U.S.C. §78u(d)];
E. Order the Relief Defendants to disgorge, with prejudgment interest, all ill-gotten
gains obtained by reason of the unlawful conduct alleged in the Complaint;
F. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
G. Grant such other and further relief as this Court may deem just and proper.
JURY DEMAND
The Commission demands a jury in this matter for all claims so triable.

DATED:  March 14, 2022
      Respectfully submitted,
                                           /s/ A licia Reed ________________________
      Alicia Reed (NY Bar No. 4913596)
      Kathleen Burdette Shields (Mass Bar No. 637438)*
        Jonathan R. Allen (Mass Bar No. 680729)*
      Amy Gwiazda (Mass Bar No. 663494)*
      SECURITIES AND EXCHANGE COMMISSION
      Boston Regional Office
      33 Arch St., 24th Floor
      Boston, MA 02110
Phone:  617-573-8904 (Shields)
Fax:  617-573-4590
[email protected]

*Not admitted in the U.S. District Court for the
Eastern District of New York

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
   Plaintiff, 
 v. 
 
FRANCIS BILLER, RAYMOND DOVE, 
CHESTER ALVAREZ, TROY GRAN-
BROOKS AND JUSTIN PLAIZIER,  
 
   Defendants, and 
 
LIA PATRICIA SEPULVEDA 
SALAZAR, EDWARD LOPEZ 
GIRALDO, EDWARD CLARKE AND 
SHREDDERZ INTERNATIONAL 
CORP., 
 
                                     Relief Defendants. 

 
 

Civil Action No. 22-CV-____  
 

JURY TRIAL DEMANDED 
 
 

 
COMPLAINT 

 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the 

following against defendants Francis Biller (“Biller”), Raymond Dove (“Dove”), Chester 

Alvarez (“Alvarez”), Troy Gran-Brooks (“Gran-Brooks”), and Justin Plaizier (“Plaizier” and 

collectively, the “Defendants”) and relief defendants Lia Patricia Sepulveda Salazar, Edward 

Lopez Giraldo, Edward Clarke, and Shredderz International Corp. (collectively, the “Relief 

Defendants”): 

SUMMARY  

1. This is a securities fraud enforcement action.  From at least January 2016 through 

at least July 2018 (“the “Relevant Period”), the Defendants schemed to operate a call center in 

Medellin, Colombia through which they used high pressure sales tactics fraudulently to sell the 

stocks of numerous small United States-based public companies to United States investors.  Such 

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call centers are colloquially known as “boiler rooms.”  Defendants’ sales tactics included making 

false or misleading statements about their own roles in promoting the stock they were touting, 

and about the companies whose stock they were touting.  Companies that issue stock to the 

public are often called “issuers.” 

2. Defendants were hired by groups of people who controlled the stock of the issuers 

whose stock they were touting.  These groups of people (called “control groups”) owned a 

significant percentage of the issuers’ stock that had been deposited with a broker-dealer and was 

thus available to be traded in the public markets (called “the float”).  Defendants explicitly 

catered to control groups that controlled the float of the issuers, so that both the defendants and 

their clients would profit to the greatest extent from the boiler room’s efforts.  The control 

groups unlawfully concealed their control of the float, by breaking up their stock into small 

blocks owned by foreign nominee companies they directed, and failing to file disclosures that 

would have revealed that all of those smaller blocks were under their common control.  The 

control groups wanted to sell the stock they owned in order to make a significant profit.  The 

control groups used Defendants’ boiler room both to create demand from investors so they would 

have buyers for their shares, and to increase the price of the stock, thereby increasing their 

profits.     

3. During the Relevant Period, Defendants’ boiler room promoted the stock of at 

least 18 issuers, in coordination with control groups who were dumping their shares of those 

issuers.  The demand created by Defendants’ misleading promotions enabled control groups to 

sell millions of shares of stock, which generated over $58 million in trading proceeds for the 

control groups.  The stock of many of these issuers was thinly traded in the market when it was 

not being touted in one of the Defendants’ promotional campaigns, so investors who purchased 

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these shares at Defendants’ urging often had difficulty finding buyers when trying to sell their 

shares once Defendants’ promotions were over. 

4. Defendants’ fraudulent scheme involved promoting the stock of Oroplata 

Resources, Inc. (“Oroplata”), Garmatex Holdings Ltd. (“Garmatex”) and PureSnax International, 

Inc. (“PureSnax”), in addition to many other issuers’ securities.  To promote these issuers’ 

shares, Defendants pretended to be affiliated with various non-existent financial advisory firms.  

Defendants made up legitimate-sounding names for these phony financial advisory firms and 

also created legitimate-looking websites for them.  When making telephone calls, Defendants 

routinely used spoofed phone numbers to show area codes that made it appear as if they were 

calling from the United States rather than Colombia.  When calling and emailing unsuspecting 

investors, Defendants also used false names, made false or misleading statements about the 

prospects of the companies whose stock they were touting, and failed to disclose that they were 

acting in coordination with control groups that were dumping their securities into the market. 

5. Defendants aggressively touted Oroplata, Garmatex, PureSnax, and other issuers’ 

stock to prospective investors, including elderly retail investors, using high-pressure sales tactics 

during telephone calls.  Defendants made misleading statements about the issuers’ prospects as 

investments and about the Defendants’ own claimed stock-picking successes.  In actuality, 

Defendants called investors to persuade them to purchase these stocks so the Defendants’ control 

group clients could sell their holdings of these stocks for a profit and so the Defendants could 

collect a share (often more than half) of the sales proceeds.  Defendants also sent email and text 

messages that attempted to convince the investors to hold the stocks even when their prices were 

declining.  Then, after selling several issuers’ stocks, Defendants routinely shut down whatever 

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financial advisory firm name they had been using, and started over with new names, phone 

numbers, and websites, touting a new group of issuers’ stocks to a different group of investors. 

6. Defendant Alvarez, in addition to calling potential investors to tout the stocks 

being promoted by Defendants’ boiler room, frequently engaged in manipulative trading in 

issuers’ securities near the start of each promotional campaign.  As detailed below in relation to 

his trading in Garmatex, Aureus, Inc. (“Aureus”), and Proto Script Pharmaceutical Corp. 

(“Proto”), Alvarez would often place a series of small buy orders to give the appearance of 

trading activity and to drive up quoted sales prices of an issuer’s shares both before the 

Defendants’ boiler room began promoting those shares or early in that promotional activity.   

7. For their efforts in promoting sales of their control group clients’ stock, the 

Defendants were paid from the trading proceeds generated by the control groups’ sales.  They 

typically charged their control group clients up to 65% of the trading proceeds attributed to the 

boiler room’s sales efforts.     

8. The Defendants’ victims, including elderly retail investors who invested their 

retirement savings based on the Defendants’ material misrepresentations and omissions, were left 

holding nearly worthless investments while the Defendants and their clients profited by dumping 

their shares. 

VIOLATIONS 

9. As a result of the conduct alleged herein, Defendants violated, and unless 

restrained and enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 

(“Securities Act”), and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

and Rule 10b-5 thereunder, and Alvarez also violated, and unless restrained and enjoined will 

continue to violate, Section 9(a)(2) of the Exchange Act.       

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NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

10. The Commission seeks a permanent injunction against the Defendants, enjoining 

them from engaging in the transactions, acts, practices, and courses of business alleged in this 

Complaint, disgorgement of all ill-gotten gains from the unlawful conduct set forth in this 

Complaint together with prejudgment interest pursuant to Section 21(d)(7) of the Exchange Act 

[15 U.S.C. §78u(d)(7)], civil penalties 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)], orders barring the 

Defendants from participating in any offering of a penny stock, pursuant to Section 20(g) of the 

Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of the Exchange Act [15 U.S.C. §78u(d)] and 

such other relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 

11. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. §77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act 

[15 U.S.C. §§78u(d), 78u(e), and 78aa]. 

12. Venue lies in this District pursuant to Section 22(a) of the Securities Act 

[15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C. §78aa].  Certain of the acts, 

practices, transactions and courses of business alleged in this Complaint occurred within the 

Eastern District of New York, and were accomplished, directly or indirectly, by making use of 

means or instrumentalities of transportation or communication in interstate commerce, or the 

mails.  For example, during the Relevant Period, Defendants called individuals who reside in the 

Eastern District of New York, and individuals who reside in the Eastern District of New York 

purchased the stock of Oroplata, Garmatex, and PureSnax during the Relevant Period.  

DEFENDANTS 

13. Francis Jason Dean Biller (“Biller”), age 52, is a Canadian citizen and a resident 

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of Medellin, Colombia.  On February 16, 2000, the British Columbia Securities Commission 

barred Biller from participation in the securities industry for a period of 10 years, including 

participating in any investor relations activities, and he was ordered to pay administrative 

penalties of $300,000.  In a separate criminal case filed in the British Columbia Supreme Court, 

Biller pled guilty in April 2005 to four counts of theft and fraud relating to his sales of 

investments and in September 2005, was sentenced to 3 years in prison.  On October 12, 2005, 

the Ontario Securities Commission, among other remedies, permanently barred Biller from 

trading in securities (with several exceptions for personal accounts) and permanently barred him 

from serving as a director or officer of a company registered with the Ontario Securities 

Commission. 

14. Raymond Christopher Dove, (“Dove”), age 43, is a Canadian citizen and a 

resident of Japan. 

15. Chester Bruce Alvarez (“Alvarez”), age 37, is a United States citizen and a 

resident of Medellin, Colombia, and of Oakland Park, Florida. 

16. Troy Gran-Brooks (“Gran-Brooks”), age 31, is a Canadian citizen and a resident 

of either Medellin, Colombia, or Canada. 

17. Justin Plaizier (“Plaizier”), age unknown, is a Dutch citizen and a resident of 

either Medellin, Colombia, or Canada. 

RELIEF DEFENDANTS 

18. Lia Patricia Sepulveda Salazar (“Salazar” aka Patricia Biller), age 49, is the wife 

of Biller and is a Colombian citizen residing in Medellin, Colombia.  Salazar, or accounts under 

her control or for her benefit, received at least $3 million that was proceeds of Defendants’ 

illegal conduct.   

19. Edward Lopez Giraldo (“Giraldo”), age 43, is a family member of Salazar and is a 

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Colombian citizen residing in Medellin, Colombia.  Defendants, directly or indirectly, 

transferred at least $2 million to Giraldo, or accounts under his control or for his benefit, that 

were proceeds of Defendants’ illegal conduct.   

20. Edward Thomas Clarke (“Clarke”), age 75, is a family member of Biller and/or 

Salazar and is a Canadian citizen residing in British Columbia, Canada.  Defendants, directly or 

indirectly, transferred at least $630,000 to Clarke, or accounts under his control or for his benefit, 

that were proceeds of Defendants’ illegal conduct.   

21. Shredderz International Corp. (“Shredderz”) was incorporated by Dove in June 

2016 in the Federation of Saint Kitts and Nevis.  Dove is its sole officer and director. 

Defendants, directly or indirectly, transferred the net amount of at least $1,645,000 to Shredderz, 

or accounts under its control or for its benefit, that were proceeds of Defendants’ illegal conduct. 

RELATED PARTIES 

22. During the Relevant Period, Oroplata described itself as a company involved in 

lithium resource exploration and development.  Oroplata’s stock (Ticker: ORRP) was quoted on 

OTC Link (previously, “Pink Sheets”), operated by OTC Markets Group, Inc.  Oroplata was 

incorporated in Nevada in 2011 and during the Relevant Period, was based in the Dominican 

Republic. 

23. Garmatex, formerly known as Oaxaca Resources Corp., described itself as a 

company that developed and supplied engineered fabric technology.   During portions of the 

Relevant Period, Garmatex’s stock (Ticker: GRMX) was quoted on OTC Link.  Garmatex was 

incorporated in Nevada in 2014.   

24. During the Relevant Period, PureSnax described its business as focused on 

developing and selling healthy snacks to consumers.  PureSnax’s stock (Ticker: PSNX) was 

quoted on OTC Link during the Relevant Period.  PureSnax was a New Jersey corporation that 

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was incorporated in 2011 and during the Relevant Period was headquartered in Woodbridge, 

New Jersey.   

BACKGROUND 

25. “Penny Stock,” as used herein, generally refers to a security issued by a small 

company that trades at less than $5 per share.   

26. An “issuer” is a company whose securities are publicly traded.  An “affiliate” of 

an issuer is a person or entity that, directly or indirectly through one or more intermediaries, 

controls, is controlled by, or is under common control with, such issuer (i.e., a control person).  

“Control” means the power to direct management and policies of the company in question.  

Typically, affiliates include officers, directors and controlling shareholders, but any person who 

is under “common control” with, or has common control of, an issuer is also an affiliate.  As 

used herein, the term “control group” means a group that collectively is an “affiliate” of an 

issuer.  

27. The control groups who hired Defendants’ boiler room were “affiliates” of the 

issuers whose stock they hired Defendants to promote in part because the control groups 

typically controlled those issuers’ float.  Stock held by an affiliate of an issuer is restricted stock.  

Absent an exemption under the federal securities laws and rules, restricted stock cannot be 

legally offered or sold to the public unless a securities registration statement has been filed with 

the Commission (for an offer) or is in effect (for a sale).  A registration statement contains 

important information about an issuer’s business operations, financial condition, results of 

operation, risk factors, and management.  It also discloses any person or group who is the 

beneficial owner of more than 5% of the company’s securities.  The control groups did not file 

registration statements for the sales of stock that they hired the Defendants to promote.   

28. Instead of making public disclosures about their control over the issuers’ float, 

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Defendants’ control group clients took a number of steps to conceal their ownership of the float.  

First, the control groups divided the issuers’ stock into blocks of under 5% each (a threshold for 

reporting ownership in registration statements, which is also used by many broker-dealers when 

evaluating deposits of stock into brokerage accounts).  Second, they orchestrated the transfer of 

those blocks of less than 5% to multiple foreign companies under their control or whose nominee 

owners agreed to act at their direction.  Third, the control groups employed three foreign trading 

platforms whose primary business purpose was to facilitate illegal securities transactions in 

United States securities markets by providing a layer of disguise to their control group clients.  

The control groups sold their stock through brokerage accounts maintained by at least three 

fraudulent trading platforms: Wintercap SA (“Wintercap”), Blacklight SA (“Blacklight”) and the 

Bajic-Taneja Platform (collectively, the “Foreign Platforms”).1   

29. “Pump-and-dump” schemes typically involve company shareholders touting, or 

“pumping,” (or paying others to tout or “pump”) a company’s stock through false and misleading 

statements or through manipulative trading, for the purpose of creating market demand into 

which those same shareholders sell, or “dump,” their shares. 

FACTS 

DEFENDANTS’ BOILER ROOM IN COLOMBIA 

30. Beginning sometime before January 2016, Defendants Biller and Dove began 

operating a boiler room in Colombia.  The primary business of Defendants’ boiler room was to 

convince United States and Canadian investors to buy the stocks of the companies whose shares 

were being sold by the Defendants’ control group clients.  While the number of employees 

                                                           
1 The three trading platforms and their operators were charged in separate cases.  The Wintercap platform, operated 
by Roger Knox and his associates, was charged in SEC v. Knox, No. 18-cv-12058 (D. Mass., filed Oct. 2, 2018).  
The Bajic-Taneja and Blacklight platforms were charged in SEC v. Bajic, et al., No. 20-cv-0007 (S.D.N.Y., filed 
Jan. 2, 2020). 

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working in the boiler room varied between 2016 and 2018, there were often at least 10 people 

working there, including each of the Defendants.  Biller and Dove charged their clients up to 

65% of the trading proceeds “captured” by their control group clients (that is, the aggregate 

proceeds of stock sales by the control group to investors contacted by the boiler room). 

31. Biller and Dove worked together as the leaders of the boiler room.  They 

marketed the boiler room’s services to individuals who represented various control groups, 

persuading them to hire the boiler room to sell particular companies’ stock.  Biller and Dove also 

functioned as “closers” or “loaders” in the boiler room.  That means that once one of their junior 

employees (sometimes called “openers”) got an investor interested in the boiler room’s purported 

financial advisory organization, or persuaded an investor to purchase a small amount of a 

company’s stock, Biller or Dove would then call that investor to try to persuade him/her to 

purchase more of that security, or another security being promoted by the boiler room.   

32. Alvarez was one of the employees who served as an “opener.”  As described in 

more detail below, Alvarez also engaged in manipulative trading in the stocks Defendants were 

preparing to promote, in order to encourage investors to purchase those shares.  Alvarez’s 

purchases of shares of stocks, which were then promoted by the boiler room, helped to increase 

the issuers’ stock price before the promotional campaigns began, and in the first few weeks of 

the promotional campaigns. 

33. In the spring of 2018, Biller and Dove were looking for a new source of clients 

who had stock that could be promoted by their boiler room.  Dove had previously partnered with 

an individual (referred to herein as “Person A”) in a number of other pump and dump deals.2  In 

                                                           
2 Person A was previously charged by the Commission and by the U.S. Attorney’s Office for the Eastern District of 
New York for his participation in various securities fraud schemes.  That case is ongoing. 

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the spring of 2018, Person A introduced the Defendants to an individual (“Person B”) who 

purported to be looking for a boiler room to promote several issuers’ stocks.  Unbeknownst to 

Person A and the Defendants, Person B was working in an undercover capacity with law 

enforcement officials and recorded his communications with Person A and the Defendants.     

34. On April 18, 2018, Dove, Person A, and Person B discussed the potential for 

Defendants’ boiler room to be hired by Person B and his associates.  Person B claimed that his 

associates controlled about 30 million shares of an issuer’s stock, which was almost the entire 

float.  During the call, Dove described the past success of Defendants’ boiler room, stating: 

“Over the last two years, we’ve probably done 15 deals, and not a single one lasted for more than 

two months. Now that being said, the smallest number raised on any of those transactions . . . 

would have been like 3.5 million.  And those were the deals that lasted the longest. We’ve done 

upwards of 10 million dollars on a deal in six weeks.”  The participants in the call also discussed 

how the boiler room would be paid and Dove explained that, for their promotional services, his 

group charged “a straight 65% of all captured sales” or in other words, “if week one we sell 

$500,000 worth of stock, then it’s 65% of that.” 

35. On that call, Dove also emphasized how important it was for his clients to control 

all of an issuer’s float so that both his boiler room and the control group client would make the 

most money.  Dove said, “Well, if they are gonna sell . . . Everyone . . . It would have to be 

100% controlled,” and further commented, “that’s why we need to know what’s actually in the 

float out there against us.  If that’s a big number, then it probably won’t be worth starting.” 

36. On that same call, Dove also described that the boiler room likes to have two 

deals to sell at about the same time.  As he explained: “What we want to do is we want to have 

another one ready within six to eight weeks while the first one is still up and we’ll have created 

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some kind of a story where the people can’t buy the first one but because they are already so up 

on the first one, they trust us. They’ll dump a lot more into the second one. We call it a Deal B.  

Deal B typically we get more back than a Deal A.  So with the deal platter we sell . . . we want 

two deals to have the best rate of success . . . .” 

37. Dove also told Person B what his boiler room did to cover its tracks after the 

promotions for Deals A and B were finished.  He explained that after those two deals are done, 

“we basically need to, you know, reinvent . . . you know, create a new company name and all 

that stuff, and then go into the next two.” (emphasis added).  This method of operation meant 

that the boiler room could not be located by disgruntled investors who lost money on the 

investments recommended by Defendants after their promotions were over. 

38. About a month later, on May 16, 2018, Person B visited Defendants’ boiler room 

in Medellin, Colombia, so that he could see the operation for himself.  While he was there, 

Person B met with Alvarez and Person A, and then met separately with Biller, Dove, and Person 

A.   

39. During those meetings, which Person B recorded on video, Alvarez explained to 

Person B the telephone pitch that the boiler room employees typically make to potential 

investors.  He described his role as generating leads for the “loaders” (Biller and Dove).  Alvarez 

stated that he would pretend to be from an investor relations firm and would tell the potential 

investor that his firm had recommended another security that had done very well and that they 

had another deal coming up soon.     

40. Alvarez also told Person B that Defendants routinely set up the websites for their 

fictitious investor relations firms, so that the firms “would look like a real company” if investors 

checked on them, and they would take the websites down immediately after the promotion 

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ended, so that investors could not complain to it (when they lost money on their investments).  

41. Alvarez explained that the boiler room had not in fact recommended the prior 

securities that had done well in the market—the Defendants just chose a stock that had 

performed well and took credit for it.  Alvarez would then encourage the potential investor to put 

money into his or her brokerage account and would then have a dialogue to build rapport with 

the potential investor.  Alvarez also told Person B that the boiler room employees told potential 

investors that their investor relations firm was in Naples, Florida, which they chose because it 

was an affluent area.   

42. During the meeting among Biller, Dove, Person A, and Person B, Biller described 

Dove as his partner in the boiler room and emphasized to Person B that he wanted to establish a 

relationship where they promoted multiple deals over time so that he could keep his employees 

working steadily.  Biller pressed Person B for a $150,000 advance payment in order to reserve 

the boiler room exclusively for Person B’s prospective deals. 

43. During these meetings, Dove showed Person B the website of the fake investor 

relations firm the boiler room was claiming to be part of at that time.  He explained how the fake 

company added to the credibility of Defendants’ pitch if investors questioned where they 

worked. 

44. When Person B asked Dove to describe the typical pitch to an investor, Dove 

explained that he would say: “Go into your trading account and buy the stock now!  Here’s our 

history.  Here’s what we’ve done before.  We normally do three deals a year.  Our average 

trading return over the past eight years has been about 300%.  Well, our last one did 1,800%.  So 

right now, take a position.  How much do you have available in your trading account right now?  

Open it up…click the buy tab.  Here’s the symbol.  Buy it!”  Dove added, “It’s really that 

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simple.” 

45. Biller added that it was often part of his pitch to tell investors that the stocks he 

was promoting would be listed on NASDAQ in about another three months.  Biller knew, or was 

reckless or negligent in not knowing, that those statements were false.  In describing his pitch to 

Person B, Biller implied that he did not actually believe that these companies would be able to 

uplist to the NASDAQ exchange (which would have required a significant price increase as well 

as lengthy and costly application and due diligence processes). 

46. Biller also explained to Person B that he would always use false names when 

talking to investors.  As an example, he said that currently he was telling investors he was a 

doctor who frequently appeared on television and added, “I tell them, ‘I’ll send you a copy of my 

book.  I’m scheduled to be on CNN again in mid-August.’” 

47. When Person B asked whether investors were often upset when they lost money 

on the stocks the boiler room had convinced them to buy, Dove replied: “Well, our phone lines 

are gonna be shut off . . . Remember, we reinvent ourselves every two deals . . . So we get them 

in the first deal, which is doing well (Deal A), and then we get them in the second deal, then 

there comes the day when we have to turn the phone lines off.”  He added, “We have new phone 

lines ready to go, new company website, everything” so when the next deal starts, the 

Defendants have a new set of leads and they are not calling the same people again.  “Rinse and 

repeat . . . We get new leads coming in on a daily basis . . . We just got 250 today.” 

48. In bragging about past deals to Person B, Dove and Biller specifically mentioned 

their involvement in promoting “PSNX, PSNP . . . and ORRP,” and explained that “200 people 

[investors] on a deal is enough to generate two million bucks . . . typically we will have 600 buys 

and we could do six to ten million” (meaning that they could generate $6-10 million in sales on a 

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particular stock).  Biller claimed that the boiler room had generated $100 million of sales over its 

history. 

49. The following examples illustrate in greater detail how Defendants’ conduct in 

selling particular issuers’ securities followed the general scheme that Biller, Dove, and Alvarez 

described to Person B.  

EXAMPLE 1:  THE OROPLATA PUMP AND DUMP 

50. One of the issuers that Dove and Biller told Person B they promoted was ORRP 

(the ticker for Oroplata).  Defendants promoted Oroplata contemporaneously with sales made by 

their control group clients as described below. 

The Control Group’s Trading In Oroplata 

51. By April 2016, a control group (the “ORRP Control Group”) owned 100% of the 

float of Oroplata.  As described generally in paragraph 28 above, the ORRP Control Group 

divided Oroplata’s stock into blocks of less than 5% of Oroplata’s total number of shares 

outstanding, and transferred the ownership of those blocks of stock into at least seven foreign 

nominee entities such that each nominee owned, on paper, less than 5% of Oroplata’s shares.  

52. The ORRP Control Group’s stock was then deposited into brokerage accounts and 

sold by the three Foreign Platforms—who were all acting at the direction of the ORRP Control 

Group, and in particular at the direction of Luis Carrillo (“Carrillo”)3, who was a member of the 

ORRP Control Group.  

53. Collectively, between February 2016 and September 2016, the Foreign Platforms 

sold Oroplata stock into the demand created by Defendants’ boiler room for trading proceeds of 

                                                           
3 Carrillo was previously charged by the Commission for his participation in various securities fraud schemes.  See 
SEC v. Carrillo, et al., No. 21-cv-11272 (D. Mass., filed Aug.4, 2021).   

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approximately $13.1 million. 

Defendants Promoted Oroplata Stock 

54. From on or about June 6, 2016, through at least September 2016, Defendants’ 

boiler room promoted Oroplata stock.  At that time, Defendants were using the names Market 

Wi$e Report or Winford Report for their phony investor relations firm.  Thus, the boiler room’s 

employees told prospective investors that they worked for Market Wi$e Report or Winford 

Report. 

55. Numerous investors bought Oroplata shares during at least August and September 

2016 because they were encouraged to do so by people who identified themselves as calling 

from Market Wi$e Report.  Francis Jonson was the false name being used by Biller at the time 

for his boiler room work.  Biller, using the name of Francis Jonson, encouraged Investor #1 to 

consider purchasing shares of Oroplata and told Investor #1 that he was able to get numerous 

investors in at $0.90 and out at “well above 2 dollars” a share.   

56. Investor #2 purchased shares in Oroplata as well as other stocks promoted by 

Defendants’ boiler room, including PureSnax.  From about May through August 2016, 

Investor #2 spoke, and exchanged emails, with a person who identified himself as a Market Wi$e 

Report representative named Tomas Beneth.  Tomas Beneth was a false name used at the time by 

Defendant Gran-Brooks.  Investor #2 also spoke to Biller, who was using the name Francis 

Jonson, at least twice and received emails from him.  “Jonson” told Investor #2 that he was one 

of the heads of Market Wi$e Report and led her to believe that Market Wi$e was a financial 

advisory firm in Florida.  “Jonson” also told Investor #2 that the people working at Market Wi$e 

Report had themselves invested in the stocks they were encouraging her to buy.  On the basis of 

her conversations with Gran-Brooks and Biller, Investor #2 bought at least 26,500 shares of 

Oroplata at an average price of $0.93 per share on June 6 and 7, 2016.  She also bought shares of 

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several other companies promoted by defendants during that time period, including PureSnax.  In 

her discussions with Gran-Brooks, Investor #2 made it clear to Gran-Brooks that she needed her 

investment savings to pay for surgery she was scheduled to undergo in the summer of 2016.   

57. Gran-Brooks acted negligently, recklessly, or knowingly when he made numerous 

false statements to convince Investor #2 to buy shares of Oroplata, PureSnax, and other 

companies, including statements that he guaranteed she would not lose money, that he always 

made sure his family owned the stocks he was encouraging Investor #2 to buy, and that he had 

much bigger positions in the stocks than Investor #2 was buying so she should not worry. 

Trading In Oroplata During Defendants’ Promotions 

58. Before June 2016, there was little trading in Oroplata.  Starting in June 2016, 

there was a significant increase in both the volume and price of Oroplata shares as illustrated in 

the graph below.  Between the first trade in Oroplata on February 24, 2016, and June 6, 2016, 

there were only 10 trading days when any purchases or sales of Oroplata stock were reported.  

On these 10 days, the average trading volume was less than 5,200 shares per day with an average 

closing price of approximately $0.44 per share.  Starting on June 6, 2016 and continuing through 

September 2016, the average volume of Oroplata trading was over 700,000 shares per day.  

Average closing prices increased throughout June to a peak in mid-July 2016 before decreasing 

again, as shown in the chart below. 

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59. During Defendants’ promotion of Oroplata between June 6 and August 15, 2016, 

the price of the stock ranged from $0.93 to $1.91.  By the end of September 2016, the stock’s 

price had dropped to $0.545, and the price continued to fall, trading in a range between $0.10 

and $0.20 per share into 2017, and eventually dropping below that.  Investors who purchased 

Oroplata on the Defendants’ urging and held their shares lost significant sums of money. 

EXAMPLE 2: THE PURESNAX PUMP AND DUMP 

60. Another one of the issuers that Dove and Biller told Person B they sold was 

PSNX (the ticker for PureSnax).  Defendants promoted PureSnax contemporaneously with sales 

made by their control group clients as described below.   

The Control Group’s Trading In PureSnax 

61. By January 2016, a control group containing at least Carrillo (the “PSNX Control 

Group”) controlled 100% of the float of PureSnax.  The PSNX Control Group divided 

PureSnax’s stock into blocks of less than 5% of PureSnax’s total number of shares outstanding 

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and transferred the ownership of those blocks of stock to foreign nominee entities so each 

nominee owned, on paper, less than 5% of PureSnax’s shares.   

62. The PSNX Control Group’s stock was then deposited into brokerage accounts and 

sold by two of the three Foreign Platforms, who were acting at the direction of the PSNX Control 

Group, and in particular took trading directions from Carrillo.    

63. Collectively, between March 2016 and September 2016, two of the Foreign 

Platforms sold PureSnax stock into the demand created by Defendants’ boiler room for trading 

proceeds of at least $1.4 million.  

Defendants Promoted PureSnax 

64. From at least mid-March through mid-July 2016, Defendants’ boiler room 

promoted PureSnax stock.  Defendants’ PureSnax promotion overlapped with the time period of 

their Oroplata promotion, and Defendants used the phony investor relations firm names of  

Market Wi$e Report or Winford Report to conduct both promotions.  As in the Oroplata 

promotion, the boiler room’s employees who were promoting PureSnax told prospective 

investors that they worked for Market Wi$e Report or Winford Report. 

65. Numerous investors bought PureSnax shares between March and July 2016 

because they were encouraged to do so by people who identified themselves as calling from 

Market Wi$e Report.  For example, Investor #1 purchased 20,000 shares of PureSnax at an 

average price of $0.59 on April 11, 2016, after speaking with Biller, who identified himself as 

Francis Jonson.  Investor #1 purchased an additional 90,000 shares of PureSnax at an average 

price of $0.60 on April 15, 2016 after speaking with Biller (posing as Jonson) a second time.  

Biller reassured Investor #1 after a price dip in PureSnax on May 10, 2016, that PureSnax was 

not, as Investor #1 worried, “a house of cards that is starting to tumble.”  Biller (posing as 

Jonson) also sent out a promotional email on May 31, 2016, telling investors that “[y]our 

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patience is about to be rewarded” for investing in PureSnax and that “PSNX will be moving into 

phase 2 over the next 2 to 3 business days.  We expect to see a dramatic increase in both volume 

and share price appreciation.  The wait is over!”  Another email from Biller (as Francis Jonson) 

on June 17, 2016, (after a decline in PureSnax’s price and trading volume) encouraged 

Investor #1 to “Get PSNX on your screen now! . . . . You don’t get an opportunity like this 

everyday, especially with a company expected to grow so large and so fast.  Drop everything 

you’re doing now, because this could be the last time you see PSNX at this level with a breakout 

potential.”  On Biller’s urging, Investor #1 held on to all of his PureSnax shares and ultimately 

lost over $70,000.    

66. Investor #2 purchased 7,000 shares of PureSnax between April 2 and 27, 2016 

and ultimately purchased a total of 21,200 shares of PureSnax by July 6, 2016.  On the urging of 

Gran-Brooks (posing as Beneth), Investor #2 held on to all of her PureSnax shares.  When 

Investor #2 got nervous about drops in the price of PureSnax, Gran-Brooks told her that she 

should not sell, and that the price would come back.  Gran-Brooks also told her that his sister 

was invested in PureSnax, and he would not let her get hurt.  Gran-Brooks also told Investor #2 

that Market Wi$e clients had to follow their program if they wanted information about other 

stocks that would do well.  Gran-Brooks told investor #2 that following the program meant not 

selling until they advised her to sell.  Investor #2 lost over $11,800 investing in PureSnax.   

67. Investor #3 purchased PureSnax shares after being called by an individual 

identifying himself as Richard van Geld from Market Wi$e Report and receiving follow-up calls 

from people calling themselves Francis Jonson and Chris Sterling, claiming to be from the same 

firm.  Richard van Geld was a name used by Justin Plaizier, and Chris Sterling was a name used 

by Dove, when they called investors through Defendants’ boiler room.  Investor #3 initially 

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purchased PureSnax shares because Plaizier (posing as van Geld) told him that the shares would 

increase in price in several days and would get to $1 or more.  Plaizier did not, however, tell 

Investor #3 that the reason he knew PureSnax shares would increase in price is because he and 

the boiler room employees were actively soliciting many investors to buy those shares.  In 

context, Plaizier’s statements to Investor #3 were materially misleading and were made 

negligently, recklessly, or knowingly.   

68. Follow up calls from Dove (posing as Sterling) and Biller (posing as Jonson) 

invited Investor #3 into Market Wi$e’s “inner circle” so that he could get investment advice 

from them as leaders of Market Wi$e.  Biller and Dove emphasized to Investor #3 that in order 

to be part of the “inner circle” he should not sell the stocks they advised him to buy until they 

told him to sell, even if the price dropped.  To lull Investor #3 into holding onto PureSnax shares 

in the face of declining share prices, Biller told Investor #3 that one price decline in PureSnax 

stock was attributable to a large investor having to sell his shares to make a margin call on his 

portfolio caused by a bad investment in a diamond mine.  Investor #3 followed their instructions 

not to sell until told to do so for a period of time.  Between April 12, 2016 and September 27, 

2016, Investor #3 bought a total of over 156,000 shares of PureSnax, spending over $65,800.  

Investor #3 sold some of his PureSnax shares, recovering about $23,800 of his investment, but 

the remaining stock is worthless.  Overall, Investor #3 lost approximately $42,000 on his 

PureSnax investment and additionally lost over $100,000 on other stocks he purchased at the 

urging of Plaizier, Biller, and Dove. 

Trading In PureSnax During Defendants’ Promotions 

69. Before early March 2016, there was little trading in PureSnax.  Beginning in early 

March 2016, there was a significant increase in both the volume and price of PureSnax shares as 

illustrated in the graph below.  Before March 10, 2016, there were only 11 days during 2016 on 

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which PureSnax trades were reported and its average trading volume was less than 3,800 shares 

per day.  From March 10, 2016 until the end of July 2016, its average volume increased to 

almost 110,000 shares per day.  The closing price of PureSnax stock rose from around $0.30 

before the promotion to its highest closing price of $.804 and .805 on May 4 and 5, 2016. 

 

70. During Defendants’ promotion of PureSnax, the price of the stock rose to a high 

of $0.895 per share.  Once the Defendants’ boiler room stopped promoting PureSnax, the stock’s 

price dropped quickly to below $0.01 per share by September 22, 2016.  Many investors who 

purchased PureSnax on the Defendants’ urging thus lost significant sums of money. 

EXAMPLE 3:  THE GARMATEX PUMP AND DUMP 

71. During the spring of 2017, Defendants’ boiler room ran a promotional campaign 

encouraging potential investors to purchase shares of Garmatex (whose ticker was GRMX).  

Defendants promoted Garmatex contemporaneously with sales made by their control group 

clients as described below.   

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The Control Group’s Trading In PureSnax 

72. By March 2017, a control group composed of at least Carrillo (the “Garmatex 

Control Group”) controlled nearly 90% of the float of Garmatex.  Following the pattern of 

Oroplata and PureSnax, the Garmatex Control Group’s shares were divided into blocks of less 

than 5% of Garmatex’s total number of shares outstanding, and transferred into at least six 

foreign nominee entities such that each nominee owned, on paper, less than 5% of Garmatex’s 

shares.   

73. In March and April 2017, those nominees’ stock was deposited into brokerage 

accounts and sold by two of the three Foreign Platforms.  Wintercap took its trading directions 

when selling Garmatex stock from Carrillo.  By May 15, 2017, the Garmatex Control Group had 

sold every share that had been transferred to the Foreign Platforms.   

74. Collectively, between March 2017 and May 2017, the Garmatex Control Group 

sold at least 12.2 million shares of Garmatex stock into the demand created by Defendants’ 

boiler room, for trading proceeds of over $7,000,000. 

Defendants Promoted Garmatex 

75. From about mid-March to May 2017, Defendants’ boiler room promoted 

Garmatex stock.  By the time of the Garmatex promotion, Defendants had stopped using the 

name Market Wi$e Report for their phony investor relations firm.  By 2017, the Defendants had 

begun using the name Global Stock Advantage.  Thus, the boiler room’s employees told 

prospective investors that they worked for Global Stock Advantage.  False names used by the 

people working in the Defendants’ boiler room in 2017 included Dr. Peter Phillips (used by 

Biller), and Craig Morgan (used by Dove) and Sid Wexler. 

76. Numerous investors bought Garmatex shares during March through May of 2017 

after being solicited by callers who identified themselves as working for Global Stock 

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Advantage.  For example, Investor #4 began purchasing Garmatex shares on March 14, 2017, 

after receiving an introductory call from a person going by the name of Sid Wexler, and more 

detailed calls from persons using the names of Dr. Peter Phillips (who claimed to be a Ph.D. in 

economics) and Craig Morgan.   

77. Biller, claiming to be Dr. Peter Phillips, made numerous misrepresentations to 

Investor #4 including that: 1) his firm, Global Stock Advantage (“GSA”), looked for and assisted 

undervalued companies that could thrive on the NASDAQ stock exchange; 2) Phillips and 

Morgan had left a large Canadian brokerage firm after 20 years to start GSA; 3) Garmatex was 

about to announce big deals with a Fortune 500 company and an upholstery company that 

supplied high-end car manufacturers; 4) Garmatex would be moving to the NASDAQ stock 

exchange on July 7, 2017; 5) Morgan Stanley was arranging a private purchase of 4.25 million 

shares of Garmatex; and 6) independent research firms had already valued Garmatex at $9 per 

share.   

78. Dove, claiming to be Craig Morgan, also made misrepresentations to Investor #4 

including a representation that GSA only assisted companies that had revenue growth of 50% per 

year and had a known product to execute a reverse merger and become public without an initial 

public offering—implying that Garmatex was such a company.   

79. Biller and Dove knew or were reckless or negligent in not knowing that their 

statements were false or misleading when they were made.  They had no reason to believe that 

Garmatex had any plans to move to the NASDAQ stock exchange, let alone that it would do so 

in July 2017.  Nor did they disclose that they were promoting Garmatex on behalf of a control 

group that was dumping its shares into the demand created by the Defendants’ promotion. 

80. Investor #4 was an investment adviser nearing retirement who invested, and lost, 

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most of his retirement savings to Defendants’ fraudulent scheme.  Investor #4 purchased more 

than 3 million shares of Garmatex for a total loss on his investment of over $2 million. 

Trading In Garmatex During Defendants’ Promotions 

81. Before March 2017, there was little trading in Garmatex shares.  In approximately 

mid-March 2017, at about the same time that Carrillo orchestrated the deposit of the foreign 

nominees’ shares into brokerage accounts, there was a significant increase in both the volume 

and price of Garmatex shares as illustrated in the graph below.  Between February 7, 2017, and 

March 10, 2017, the average daily volume of trading in Garmatex stock on those days when it 

traded was less than 90,000 shares.  On the first day of the Defendants’ boiler room promotion, 

March 14, 2017, volume spiked to over 5 million shares.  Between March 14, 2017, and May 2, 

2017 (the last day that the Garmatex Control Group sold stock), the average volume was over 

1.5 million shares per day.  The closing price of Garmatex stock rose from $0.40 before the 

promotion to its highest closing price of $1.21 on March 23, 2017. 

 

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82. Once the Defendants’ boiler room stopped promoting Garmatex, the stock’s price 

dropped to less than $0.20.  Many investors who had purchased Garmatex on the Defendants’ 

urging thus lost significant sums of money. 

DEFENDANTS’ BOILER ROOM PROMOTED ADDITIONAL ISSUERS 

83. Defendants’ boiler room promoted the stocks of numerous issuers that were sold 

by their control group clients through the Foreign Platforms and otherwise.  The following chart 

summarizes the stocks that were promoted by the Defendants and the trading proceeds that their 

control group clients reaped by selling into the demand created by the Defendants’ fraudulent 

conduct: 

 

ALVAREZ’S MANIPULATIVE TRADES 

84. In addition to calling potential investors to solicit their purchases of the securities 

that were touted by Defendants’ boiler room, Alvarez also engaged in manipulative trading in 

advance of, or early in, Defendants’ promotional activity that was designed to drive up reported 

sales prices of the shares the Defendants were encouraging investors to buy.  Alvarez routinely 

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engaged in this manipulative trading on securities that were promoted by Defendants’ boiler 

room. 

85. Alvarez’s trading was funded, in part, by payments from the Defendants’ control 

group clients, including Person A.  For example, on June 14, 2016, Person A wired $9,560 to a 

firm controlled by his associate.  On the same day, the associate’s firm wired $9,500 directly into 

Alvarez’s brokerage account.  Over the next seven days, Alvarez spent $9,500 to buy shares of 

Oroplata, PureSnax, and two other securities then being promoted by Defendants’ boiler room. 

86. Alvarez’s purchases of Aureus shares are illustrative of his manipulative trading.  

Aureus shares began trading in the public markets on July 22, 2016.  Between July 22 and 

August 3, 2016, there were few Aureus trades in the public markets and the average daily 

volume of shares traded was under 20,000 shares a day.  On July 27, 2016, Alvarez purchased 

101 shares of Aureus for $0.60 per share, an increase of 100% over the prior day’s closing price.  

The price of Aureus increased again dramatically on July 29, 2016, such that its closing price of 

$1.50 was almost $1 more than the prior day’s closing price of $0.583.  Alvarez traded in Aureus 

again on the next day its shares traded: August 3, 2016.  On August 3, 2016, Alvarez bought 100 

shares of Aureus at $2.48 per share, a 65% increase over the prior day’s closing price.  Alvarez 

was the only purchaser in the market on August 3.  It is significant that Alvarez traded in 100 

share blocks because only trades of 100 or more shares would be reported and visible to potential 

investors in the market.  Alvarez’s trades in Aureus created the misleading impression that there 

was legitimate market demand at the higher prices he was paying for Aureus shares, and were 

designed to induce other people to invest. 

87. Defendants’ boiler room began actively promoting Aureus shares on August 4, 

2016.  Beginning on August 4, the number of daily trades in Aureus increased substantially.  For 

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example, while the highest volume in the prior month was about 85,000 shares traded on July 22, 

2016, there were over 5.5 million shares traded on August 4, 2016.  

88. While the Defendants’ boiler room was actively promoting Aureus throughout 

August 2016, Alvarez continued to make small purchases of Aureus shares in 100 share blocks 

on at least seven trading days, at prices at or near the high point of the day’s price.  Alvarez’s 

continued trades in Aureus created the misleading impression that there was market demand for 

Aureus stock at the high prices he was paying for those shares, and were designed to induce 

other people to invest. 

89. Alvarez’s conduct in buying Garmatex shares was similar.  Between September 

2016 and February 2017, there was little market trading in Garmatex shares.  In fact, Garmatex 

shares only traded on 14 days within that five-month period.     

90. On March 1, 2017, Alvarez purchased 100 Garmatex shares at a price of $0.77, a 

$0.07 increase over the prior day’s closing price.  On March 2, 2017, Alvarez bought 200 shares 

of Garmatex, again at a price of $0.77, which was the day’s high price.  On March 3, 2017, 

Alvarez purchased 100 shares of Garmatex at a price of $0.78, just a penny under the day’s high 

price of $0.79.  Alvarez’s trades in Garmatex created the misleading impression that there was 

market demand for Garmatex stock at the higher prices he was paying for Garmatex shares, and 

were designed to induce other people to invest. 

91. When Defendants’ boiler room began actively promoting Garmatex, on or about 

March 14, 2017, the volume of shares traded each day increased dramatically.  For example, on 

March 13, 2017, about 160,000 Garmatex shares traded, whereas more than 5 million shares 

traded on March 14 once Defendants began their promotion. 

92. During the time period that Defendants’ boiler room was actively promoting 

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Garmatex in March and April 2017, Alvarez made additional trades to support the price of 

Garmatex shares.  On at least 14 additional trading days during those two months, Alvarez 

purchased Garmatex shares, in 100 share blocks, at prices that were at or near the high of each 

day’s trading.   

93. Alvarez’s trading in shares of Proto Script Pharmaceutical Corp. (“Proto”) 

followed the same pattern.  Between June and November 2016, trading in Proto shares in the 

market was very light.  In fact, Proto shares traded in the markets on only 12 days in that time 

period. 

94. On December 5, 2016, Alvarez purchased 100 shares of Proto at a price of $0.51 

per share.  This was the only trade in the market that day and the price he paid was an increase of 

about 62% over the prior trading day’s price.  There were no trades in Proto shares after 

Alvarez’s trade until the Defendants’ boiler room began promoting Proto on or about December 

14, 2016.  Alvarez’s trade thus set the starting price point for Defendants’ promotions of Proto 

shares.  Alvarez’s trade in Proto was designed to create the misleading impression that there was 

market demand at the higher prices he paid for Proto shares, and was designed to induce other 

people to invest. 

95. Once Defendants’ boiler room began promoting Proto, the volume increased 

substantially, to over 2.5 million shares traded on December 15, 2016.  While the Defendants 

were actively promoting Proto, in December 2016 and January 2017, Alvarez continued to make 

additional purchases of Proto in 100 share blocks to support the price of Proto shares.  He made 

those purchases on at least 16 trading days in December 2016 and January 2017, at prices at or 

near the high price of the day, or at times when the price of his trade was an increase over the 

then-current trading price. 

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DEFENDANTS RECEIVED PROCEEDS OF THE FRAUDULENT TRADES 

96. Based on information presently available to the Commission, between January 1, 

2016 and the present, Defendant Dove directly received payments totaling over $1.8 million that 

represented his share of trading proceeds from the penny stocks promoted by Defendants’ boiler 

room.  Defendant Alvarez received at least $89,484, while Defendant Gran-Brooks received at 

least $469,968 and Defendant Plaizier received at least $112,254.  Those payments came from 

the following sources:  

Source Received by 
Dove 

Received by 
Alvarez 

Received by Gran-
Brooks 

Received by 
Plaizier 

Wintercap SA 
(foreign trading 
platform) 

$456,400  $176,404  

Shredderz 
International 

 $72,000 $293,564 $112,254 

Person A and his 
associate 

$1,347,143 $17,484   

Total $1,803,543 $89,484 $469,968 $112,254 

97. In addition to these cash payments, Biller and Dove received other items of value 

from their control group clients.  For example, Wintercap, one of the trading platforms used by 

Defendants’ control group clients, paid the equivalent of over $95,000 for a ski vacation in 

Switzerland for Carrillo, Dove, Biller, and their families that lasted from December 27, 2017, to 

January 5, 2018.  Wintercap charged these expenses to the account of Carrillo.  Similarly, on or 

about January 17, 2018, Carrillo purchased a very expensive watch for Dove and shipped it to 

him in Japan. 

MONETARY TRANSFERS TO THE RELIEF DEFENDANTS 

98. Defendants transferred or directed, directly or indirectly, millions of dollars of 

trading proceeds from the fraudulent conduct described above to the Relief Defendants for no 

legitimate purpose or consideration.  In particular, Defendant Biller appears to have directed his 

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share of the proceeds from Defendants’ boiler room to his wife and family members rather than 

to accounts in his own name. 

99. Based on information presently available to the Commission, on numerous dates 

between January 1, 2016, and the present, Defendants’ control group clients and the foreign 

trading platforms that they used transferred sums of money from trading proceeds in the stocks 

promoted by Defendants’ boiler room: (a) to accounts in the name of, or for the benefit of, 

Biller’s wife, Salazar; (b) to relief defendant Giraldo; (c) to relief defendant Clarke; and (d) to 

Shredderz, a company owned by Dove.  The following chart shows the sources and amounts of 

those transfers.  As shown below, Shredderz received $4,693,000 from Wintercap and paid out 

$3,808,430 to individuals involved in Defendants’ fraudulent scheme. 

Source Received by 
Salazar 

Received by 
Giraldo 

Received by 
Clarke 

Received by 
Shredderz 

Wintercap SA 
(foreign trading 
platform) 

$110,000  $486,070 $4,693,000 

Shredderz 
International 

$1,696,315 $1,158,235  ($3,808,430) 

Person A and his 
associate 

$1,114,953 $777,552 $148,495  

Carrillo $90,000 $140,000  $761,000 
Total $3,011,268 $2,075,787 $634,565 $1,645,570 

 
FIRST CLAIM FOR RELIEF 

FRAUD IN THE OFFER OR SALE OF SECURITIES 
(Violations of Section 17(a) of the Securities Act) 

(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier) 

100. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

101. By reason of the conduct described above, Defendants, in the offer or sale of 

securities, by the use of the means or instrumentalities of interstate commerce or of the mails, 

directly or indirectly, acting intentionally, knowingly, recklessly or negligently (i) employed 

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devices, schemes, or artifices to defraud; (ii) obtained money or property by means of any untrue 

statement of a material fact or any omission to state a material fact necessary in order to make 

the statements made, in light of circumstances under which they were made, not misleading; and 

(iii) engaged in transactions, practices, or courses of business which operated or would operate as 

a fraud or deceit upon any persons, including purchasers or sellers of the securities.   

102. By reason of the conduct described above, Defendants violated Securities Act 

Section 17(a) [15 U.S.C. §77q(a)]. 

SECOND CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES 

(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder) 
(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier) 

103. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

104. By reason of the conduct described above, Defendants, directly or indirectly, 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 any national securities exchange, 

intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; (ii) 

made any untrue statement of a material fact or omitted to state a material fact necessary in order 

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

misleading; and (iii) engaged in acts, practices, or courses of business which operated or would 

operate as a fraud or deceit upon any persons, including purchasers or sellers of the securities. 

105. By reason of the conduct described above, Defendants violated Exchange Act 

Section 10(b) [15 U.S.C. §78j(b)] and Rule 10b-5 [17 C.F.R. §240.10b-5] thereunder. 

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THIRD CLAIM FOR RELIEF 
MANIPULATION OF SECURITIES PRICES 

(Violation of Section 9(a)(2) of the Exchange Act) 
(Defendant Alvarez) 

106. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

107. By reason of the conduct described above, Alvarez effected, alone or with one or 

more other persons, a series of transactions in at least one security that was not a government 

security, that created actual or apparent active trading in that security, or raised or depressed the 

price of that security, for the purpose of inducing the purchase or sale of that security by others. 

108. By reason of the conduct described above, Alvarez violated Exchange Act Section 

9(a)(2) [15 U.S.C. §78i(a)(2)]. 

FOURTH CLAIM FOR RELIEF 
OTHER EQUITABLE RELIEF, INCLUDING UNJUST ENRICHMENT AND 

CONSTRUCTIVE TRUST 
(Relief Defendants) 

109. Paragraphs 1 through 99 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

110. Section 21(d)(5) of the Exchange Act [15 U.S.C. §78u(d)(5)] states, “In any 

action or proceeding brought or instituted by the Commission under any provision of the 

securities laws, the Commission may seek, and any Federal court may grant, any equitable relief 

that may be appropriate or necessary for the benefit of investors.” 

111. The Relief Defendants have received investor funds derived from the unlawful 

acts, practices, and scheme of the Defendants under circumstances dictating that, in equity and 

good conscience, they should not be allowed to retain such funds. 

112. Further, specific property acquired by the Relief Defendants is traceable to 

Defendants’ wrongful acts, and there is no reason in equity why the Relief Defendants should be 

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entitled to retain that property. 

113. As a result, the Relief Defendants are liable for unjust enrichment and should be 

required to return their ill-gotten gains, in an amount to be determined by the Court.  The Court 

should also impose a constructive trust on property in the possession of the Relief Defendants 

that is traceable to the Defendants’ wrongful acts. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court: 

A. Permanently restrain the Defendants, their officers, agents, servants, employees 

and attorneys, and those persons in active concert or participation with them who receive actual 

notice of the injunction by personal service or otherwise, and each of them, from violating 

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

[15 U.S.C. §78j(b)], and Rule 10b-5 thereunder [17 C.F.R. §240.10b-5]; and permanently 

restrain Alvarez, his agents, servants, employees and attorneys and those persons in active 

concert or participation with him who receive actual notice of the injunction by personal service 

or otherwise, and each of them, from violating Section 9(a)(2) of the Exchange Act [15 U.S.C. 

§78i(a)(2)];    

B. Order the Defendants to disgorge, with prejudgment interest, all ill-gotten gains 

obtained by reason of the unlawful conduct alleged in this Complaint pursuant to Section 

21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)]; 

C. Order the Defendants to pay civil monetary penalties 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)];  

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35 

D. Enter an order barring the Defendants from participating in any offering of a 

penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of 

the Exchange Act [15 U.S.C. §78u(d)]; 

E. Order the Relief Defendants to disgorge, with prejudgment interest, all ill-gotten 

gains obtained by reason of the unlawful conduct alleged in the Complaint; 

F. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and  

G. Grant such other and further relief as this Court may deem just and proper. 

JURY DEMAND 

The Commission demands a jury in this matter for all claims so triable. 

 

DATED:  March 14, 2022 

      Respectfully submitted, 

                                           /s/ Alicia Reed ________________________ 
      Alicia Reed (NY Bar No. 4913596) 
      Kathleen Burdette Shields (Mass Bar No. 637438)* 
        Jonathan R. Allen (Mass Bar No. 680729)* 
      Amy Gwiazda (Mass Bar No. 663494)* 
      SECURITIES AND EXCHANGE COMMISSION 
      Boston Regional Office 
      33 Arch St., 24th Floor 
      Boston, MA 02110 

Phone:  617-573-8904 (Shields)  
Fax:  617-573-4590 
[email protected]  

 
*Not admitted in the U.S. District Court for the 
Eastern District of New York 

Case 1:22-cv-01406   Document 1   Filed 03/14/22   Page 35 of 35 PageID #: 35

mailto:[email protected]

	COMPLAINT
	SUMMARY
	VIOLATIONS
	NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
	JURISDICTION AND VENUE
	DEFENDANTS
	RELIEF DEFENDANTS
	RELATED PARTIES
	BACKGROUND
	FACTS
	DEFENDANTS’ BOILER ROOM IN COLOMBIA
	EXAMPLE 1:  THE OROPLATA PUMP AND DUMP
	The Control Group’s Trading In Oroplata
	Defendants Promoted Oroplata Stock
	Trading In Oroplata During Defendants’ Promotions

	EXAMPLE 2: THE PURESNAX PUMP AND DUMP
	The Control Group’s Trading In PureSnax
	Defendants Promoted PureSnax
	Trading In PureSnax During Defendants’ Promotions

	EXAMPLE 3:  THE GARMATEX PUMP AND DUMP
	The Control Group’s Trading In PureSnax
	Defendants Promoted Garmatex
	Trading In Garmatex During Defendants’ Promotions

	DEFENDANTS’ BOILER ROOM PROMOTED ADDITIONAL ISSUERS
	ALVAREZ’S MANIPULATIVE TRADES
	DEFENDANTS RECEIVED PROCEEDS OF THE FRAUDULENT TRADES
	MONETARY TRANSFERS TO THE RELIEF DEFENDANTS

	FIRST CLAIM FOR RELIEF FRAUD IN THE OFFER OR SALE OF SECURITIES
	(Violations of Section 17(a) of the Securities Act)
	(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier)


	SECOND CLAIM FOR RELIEF FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
	(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder)
	(Defendants Biller, Dove, Alvarez, Gran-Brooks and Plaizier)


	THIRD CLAIM FOR RELIEF MANIPULATION OF SECURITIES PRICES
	(Violation of Section 9(a)(2) of the Exchange Act)
	(Defendant Alvarez)


	FOURTH CLAIM FOR RELIEF OTHER EQUITABLE RELIEF, INCLUDING UNJUST ENRICHMENT AND CONSTRUCTIVE TRUST
	(Relief Defendants)

	PRAYER FOR RELIEF
	JURY DEMAND