RECEIVER'S COMPLAINT NAMING STANFORD FINANCIAL GROUP ADVISORS AS RELIEF DEFENDANTS

April 15, 2009 Receiver Ralph S. Janvey files this Complaint to add as relief defendants a group of financial advisors formerly employed by Defendant Stanford Group Company ("SGC") and paid huge commissions, front-end loans, and other compensation for soliciting their clients to purchase fraudulent certificates of deposit from SGC's affiliate, Defendant Stanford International Bank, Ltd. ("SIB"). The U.S. Securities and Exchange Commission has alleged in its suit against Defendants that the CDs sold to Stanford customers were not genuine investments, but rather, part of a massive Ponzi scheme that defrauded investors out of billions of dollars. Receiver Janvey seeks to recover more than $40,000,000 transferred to 66 financial advisors in connection with the scheme.

The monies paid by Defendants to the financial advisors named herein (collectively, the "Relief Defendants") for the sale of CDs were not in payment for legitimate services rendered by Relief Defendants. The Defendants kept their fraudulent scheme going by using the Relief Defendants to lure new investors and then diverting the investors' funds to the Defendants' own illicit purposes. The commissions, loans, and other compensation paid to Relief Defendants came not from revenue generated by legitimate business activities, but from monies contributed by defrauded investors. Relief Defendants are in possession of assets traceable to Defendants' fraudulent scheme. Relief Defendants have no legitimate ownership interest in these assets; they necessarily hold the assets in trust for the Receivership Estate for the benefit of defrauded investors.

The Receiver names the following Stanford Financial Group advisors as Relief Defendants. Over just a two-year period, these financial advisors received commissions ranging in amounts from $2.6 million to $200,000, along with other incentive compensation, to promote the sales of CDs. The Relief Defendants are listed here in alphabetical order:

... Read the complete Complaint here.
31. Daniel Hernandez resides at 7260 S.W. 119th Court, Miami, FL, 33183. During the period relevant to this Complaint, Hernandez was employed by SGC as a financial advisor. Between January 2007 and January 2009, Hernandez received approximately $252,032 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well as other tainted Daniel Hernandez Business Card
"compensation" traceable to the fraud. Hernandez is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration

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38. Manuel Malvaez resides at 9200 Westheimer, #1502, Houston, TX, 77063. During the period relevant to this Complaint, Malvaez was employed by SGC as a financial advisor. Between January 2007 and January 2009, Malvaez received approximately $607,192 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well as other tainted Manuel Malvaez Business Card
"compensation" traceable to the fraud. Malvaez is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration

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46. David Nanes resides at 848 Brickell Key Drive, Apt. 801, Miami, FL, 33131. During the period relevant to this Complaint, Nanes was employed by SGC as a financial advisor. Between January 2007 and January 2009, Nanes received approximately $503,093 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well as other tainted "compensation" traceable to the fraud. Nanes is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Additional information: FINRA Registration

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52. Roberto A. Pena resides at 11420 S. Point Drive, Cooper City, FL, 33026. During the period relevant to this Complaint, Pena was employed by SGC as a financial advisor. Between January 2007 and January 2009, Pena received approximately $250,174 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well Roberto Peña Business Card
as other tainted "compensation" traceable to the fraud. Pena is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration
53. Saraminta Perez resides at 3901 S.W. 185th Avenue, Miramar, FL, 33029. During the period relevant to this Complaint, Perez was employed by SGC as a financial advisor. Between January 2007 and January 2009, Perez received approximately $369,319 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well Saraminta Perez Business Card
as other tainted "compensation" traceable to the fraud. Perez is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration
54. Tony Perez resides at 12707 Boheme Drive, #602, Houston, TX, 77024. During the period relevant to this Complaint, Perez was employed by SGC as a financial advisor. Between January 2007 and January 2009, Perez received approximately $2,261,269 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well Tony Perez Business Card
as other tainted "compensation" traceable to the fraud. Perez is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration

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56. Judith Quinones resides at 870 N.W. 115th Avenue, Plantation, FL, 33325. During the period relevant to this Complaint, Quinones was employed by SGC as a financial advisor. Between January 2007 and January 2009, Quinones received approximately $250,203 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well as other tainted Judith Quinones Business Card
"compensation" traceable to the fraud. Quinones is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration

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61. Rocky Roys (Rossana Roys) resides at 5402 China Doll Court, Houston, TX, 77041. During the period relevant to this Complaint, Roys was employed by SGC as a financial advisor. Between January 2007 and January 2009, Roys received approximately $1,243,886 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well as other tainted Rossana Roys Business Card
"compensation" traceable to the fraud. Roys is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Additional information: FINRA Registration

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69. Pete Vargas resides at 13120 S.W. 33rd Court, Fort Lauderdale, FL, 33330. During the period relevant to this Complaint, Vargas was employed by SGC as a financial advisor. Between January 2007 and January 2009, Vargas received approximately $837,211 in fraudulent commissions traceable to Defendants' fraudulent scheme, as well Pete Vargas Business Card
as other tainted "compensation" traceable to the fraud. Vargas is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate.
Additional information: FINRA Registration

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FURTHER COMPLAINT AGAINST FORMER STANFORD EMPLOYEES

Source.
3. Jeannette Aguilar: US$ 77,751 - SIBL CD Commissions; US$ 77,390 - SIBL Quarterly Bonuses; Total CD Proceeds = US$ 155,142. Jeannette Aguilar is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Jeannette Aguilar Business Card
5. Peggy Allen: US$ 1,566 - SIBL CD Commissions; US$ 99,716 - SIBL Quarterly Bonuses; Total CD Proceeds = US$ 101,282. Peggy Allen is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Additional information: FINRA Registration Peggy Allen Business Card
29. Oswaldo Bencomo: FINRA Registration
51. Irene Vilagut: Total Proceeds from Former Employee Investor's CD(s); US$ 100,761.73. Irene Vilagut is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Irene Vilagut Business Card
163. William Leighton: Total Proceeds from Former Employee Investor's CD(s); US$ 286,929. William Leighton is therefore in possession of assets that are the rightful property of and should be returned to the Receivership Estate. Additional information: FINRA Registration William Leighton Business Card
166. Humberto Lepage: FINRA Registration


FURTHER FORMER STANFORD EMPLOYEES

To be considered as further examples that there was no differentiation between each one of Stanford's companies and all Stanford companies must be consolidated as a "one company" under the protection of the SIPC/SIPA.
Mary L. Irizarry: Business Card - Assistant Vice President of Stanford Financial Group. Mary L. Irizarry Business Card
Oreste Tonarelli: Business Card - Executive Director of Stanford Financial Group. FINRA Registration Oreste Tonarelli Business Card
Oreste Tonarelli: Business Card - Director of Stanford Group Company. FINRA Registration Oreste Tonarelli Business Card

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AC wrote on October 2, 2011 at 07:22
Look at the business cards of Saraminta Perez and Judith Quinones. Both business cards have the same address: 201 South Biscayne Boulevard 21st Floor, Miami 33131 - USA.
However they have different company's name: Stanford Fiduciary Investor Services and Stanford Group Company (MEMBER FINRA/SIPC).

It is clear there was no differentiation between the components of the Stanford "Group of companies" and all Stanford companies must be consolidated as a "one company" under the protection of the SIPC/SIPA.
Joachin wrote on January 6, 2012 at 09:19
All Former Stanford Employees knew Stanford Bank was a Ponzi Scheme.
Look how many "Vice President" were in Stanford Fiduciary Investor Services! It seems the only position at Stanford's office were "Vice President". All they must go in prison together with Allen Stanford!