Broker-Dealer Litigation - Greenberg Traurig LLP

Q.1.c(ii)
In re Chiaese, Release No. 64932, 2011 SEC LEXIS 2496 (July 20, 2011).
The Commission accepted an offer of settlement from Chiaese, a registered
representative of a registered broker-dealer and a principal member and the controlling person of
an unregistered investment adviser. In a prior criminal proceeding, Chiaese pleaded guilty to one
count of fraud. The criminal indictment alleged that Chiaese defrauded investors of
approximately $2.4 million in money and property. The Commission barred Chiaese from
association and from participating in any offering of penny stock.
In re Ryan, Release No. 65173, 2011 SEC LEXIS 2930 (Aug. 19, 2011).
Q.1.c(ii)
The Commission accepted an offer of settlement from Ryan, a former registered
representative of a registered broker-dealer and owner and sole managing member of an
unregistered company (the “Company”). In an earlier action in federal district court, Ryan
pleaded guilty to one count of securities fraud in violation of Sections 10(b) and 32 of the
Securities Exchange Act of 1934, Rule 10b-5 thereunder, and Title 18 of the United States Code,
Section 2. The criminal indictment alleged that Ryan offered and sold investors purported
contracts with the Company pursuant to which the Company promised to pay a guaranteed fixed
rate of interest. To create the appearance of legitimacy, Ryan falsely represented to investors
that, among other things, the Company was a substantial Manhattan-based financial services
firm. Ryan sent investors false account statements and diverted investor funds for personal use.
The Commission barred him from association.
In re Bjork, Release No. 65520, 2011 SEC LEXIS 3536 (Oct. 7, 2011).
Q.1.c(ii)
The Commission accepted an offer of settlement from Bjork, a former executive officer
of a registered investment adviser and a former registered representative associated with
registered broker-dealers. In an earlier proceeding brought by the Commission, a federal district
court entered a final judgment by consent against Bjork, permanently enjoining him from
violating or aiding and abetting violations of the antifraud provisions of the federal securities
laws. The Commission’s complaint alleged that Bjork offered and sold interests in investments
that he never made, commingled investor money, failed to provide financial statements to
investors and transferred money to affiliates without disclosing the transactions to investors. The
Commission barred Bjork from association.
In re Garcia, Release No. 65981, 2011 SEC LEXIS 4415 (Dec. 15, 2011).
Q.1.c(ii)
The Commission accepted an offer of settlement from Garcia, a securities lending
representative of a registered broker-dealer. In a related criminal proceeding in federal district
court, Garcia pleaded guilty to one count of conspiracy to commit securities fraud. He was
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