The customers allege that during the period of early 2019 through February 2021, the Registered Representative withheld material facts and recommended unsuitable, high-risk, speculative, illiquid investments and breached his fiduciary duty.

$546,000.00

Client alleged recommendations to invest in GWG was unsuitable.

$300,000.00

The customers allege that in August through September of 2020, the Registered Representative withheld material facts and recommended unsuitable, high-risk, speculative, illiquid investments and breached his fiduciary duty.

$598,955.00

During the period May 2019 through late 2021, the customer alleges that the Registred Representative recommended unsuitable, high-risk investments and breached fiduciary duty.

$150,000.00

I vehemently deny any wrongdoing and assert that the allegations are completely without merit. The investments about which the customer complained were suitable and were recommended based on the customer's objectives, goals and financial circumstances and were offered only after their review of all material documentation related to the investment. The customer confirmed that she not only received the requisite investment documentation/disclosures, but that she fully understood the characteristics and risks of the investments. At all times, I put the customer's interest first and I will vigorously defend this matter to the fullest extent of the law.

In November 2019 and December 2020, the customer alleges that the Registered Representative made a poor recommendation of a speculative, high risk illiquid investment.

$100,000.00

$32,500.00

I vehemently deny any wrongdoing and assert that the allegations are completely without merit. The investments about which the customer complained were suitable and were recommended based on the customer's objectives, goals and financial circumstances and were offered only after their review of all material documentation related to the investment. The customer confirmed that she not only received the requisite investment documentation/disclosures, but that she fully understood the characteristics and risks of the investments. At all times, I put the customer's interest first and I will vigorously defend this matter to the fullest extent of the law.

During the period 2012 through March 2017, the customer alleges that the Registered Representative misrepresented unsuitable investments.

$202,000.00

I vehemently deny any wrongdoing and assert that the allegations are completely without merit. The investments about which the customer complained were suitable and were recommended based on the customer's objectives, goals and financial circumstances and were offered only after their review of all material documentation related to the investment. The customer confirmed in writing that she not only received the requisite investment documentation/disclosures, but that she fully understood the characteristics and risks of the investments. At all times, I put the customer's interest first and I will vigorously defend this matter to the fullest extent of the law.