SEC v. PowerTradersPress.com, Inc.; Elite Stock Research, Inc.; Erik Matz; Ronald Hardy; Anthony Vassallo; Stephanie Lee, et al., Southern District of New York (July 12, 2017) — Complaint

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 
 
SECURITIES AND EXCHANGE 
COMMISSION,      
  
                Plaintiff,     
  v.     
      
POWERTRADERSPRESS.COM, INC., ELITE 
STOCK RESEARCH, INC., ERIK MATZ, 
RONALD HARDY, ANTHONY VASSALLO, 
STEPHANIE LEE, JEFFREY CHARTIER, 
LAWRENCE D. ISEN, ROBERT GLECKMAN, 
MICHAEL WATTS, BRIAN HEEPKE, 
DENNIS J. VERDEROSA, EMIN COHEN, 
SERGIO RAMIREZ, ASHLEY ANTOS, 
              
    
                            Defendants, 
             and 
 
HERMANN MATZ, JOSEPH MATZ, 
BRITTNEY BALLESTAS, MELISSA 
KURTZKE, JANINE ACOSTA, TYPE A 
PARTNERS, INC., STRATEGIC CAPITAL 
MARKETS, INC., MARKETBYTE LLC, SNAP 
OR TAP PRODUCTIONS, LLC, DACONA 
FINANCIAL LLC, 
TRADEMASTERSPRO.COM, INC., 
MYSTREETRESEARCH.COM, INC., 
REVOLVING VENTURES LLC, 
TRADEMASTERS CONSULTING, INC., BIG 
LITTLE CONSULTING, INC., BCBALL, INC., 
GABRON TRANSPORT CORP., PTP 
CONSTRUCTION CORP., TERRYVILLE 
SYSTEMS, INC., MKKMMKKM, INC., TREK 
PARTNERS LLC, RKRG, INC., PRICE POINT 
CONSULTING, INC., DJV ENTERPRISES, 
INC., LEECORP, INC., SOCCERSERGE, INC., 
ANTOS, INC.,  
 
                                            Relief Defendants. 
  
  
 
 
 
       Case No. _____________ 
 
 
COMPLAINT 
 
JURY TRIAL DEMANDED 
 

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Plaintiff Securities and Exchange Commission (the “Commission”), for its Complaint 
against Defendants PowerTradersPress.com, Inc., Elite Stock Research, Inc., Erik Matz, Ronald 
Hardy, Anthony Vassallo, Stephanie Lee, Jeffrey Chartier, Lawrence D. Isen, Robert Gleckman, 
Michael Watts, Brian Heepke, Dennis J. Verderosa, Emin Cohen, Sergio Ramirez, and Ashley 
Antos, and Relief Defendants Hermann Matz, Joseph Matz, Brittney Ballestas, Melissa Kurtzke, 
Janine Acosta, Type A Partners, Inc., Strategic Capital Markets, Inc., Marketbyte LLC, Snap or 
Tap Productions,  LLC, Dacona Financial LLC, TradeMastersPro.com, Inc., 
MyStreetResearch.com, Inc., Revolving Ventures LLC, TradeMasters Consulting, Inc., Big 
Little Consulting, Inc., BCBall, Inc., Gabron Transport Corp., PTP Construction Corp., 
Terryville Systems, Inc., MKKMMKKM, Inc., Trek Partners LLC, RKRG, INC., Price Point 
Consulting, Inc., DJV Enterprises, Inc., Leecorp, Inc., Soccerserge, Inc., and Antos, Inc., alleges 
as follows: 
SUMMARY OF ALLEGATIONS 
1. Defendants engaged in a series of widespread and ongoing fraudulent schemes, 
beginning in at least March 2013, to manipulate the price and volume of at least four microcap 
securities that reaped at least $14 million in illicit proceeds while causing more than $10 million 
in losses to over one hundred victims.   
2. The fraud began with the acquisition of large blocks of microcap shares by the 
schemes’ orchestrators, including Stephanie Lee, Jeffrey Chartier, Lawrence D. Isen, Robert 
Gleckman, and Michael Watts ( “Orchestrator Defendants”).  The Orchestrator Defendants then 

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 hired two “boiler rooms”
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 to fraudulently promote, or “pump,” the securities.  Erik Matz and 
Ronald Hardy controlled one boiler room operating primarily under the name Power Traders 
Press.com,  Inc. (“Power Traders Press”), and Anthony Vassallo controlled the boiler room 
operating primarily under the name Elite Stock Research Inc. (“Elite Stock Research”).  The 
Orchestrator Defendants paid Power Traders Press and Elite Stock Research in cash and often 
large blocks of the securities that the boiler rooms were hired to promote.    
3. Power Traders Press’s and Elite Stock Research’s manipulative conduct included  
“marking-the-close” and executing “matched” and “wash” trades that were designed to 
artificially raise the securities’ market prices and trading volumes, and give the false appearance 
of active trading.   
4. Power Traders Press and Elite Stock Research then engaged in large-scale 
promotional campaigns touting these securities, typically targeting the vulnerable – elderly and 
unsophisticated investors.  Power Traders Press’s and Elite Stock Research’s boiler room “sales” 
personnel, including Erik Matz, Hardy, Vassallo, Heepke, Verderosa, Cohen, Ramirez, and 
Antos (“Boiler Room Defendants”),  contacted hundreds of individuals across the United States 
seeking to induce investment in these securities, often by employing high-pressure tactics such as 
threatening potential investors and flooding them with emails and phone calls.   
5. The Boiler Room Defendants fraudulently promoted these securities, soliciting 
victims to purchase them while failing to disclose that Elite Stock Research’s and Power Traders 
Press’s sole reason for aggressively soliciting investment in these securities was the boiler 
                                                 
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  “‘Boiler room’ activity consists essentially of offering to customers securities of certain 
issuers in large volume by means of an intensive selling campaign through numerous salesmen 
by telephone or direct mail, without regard to the suitability to the needs of the customer, in such 
a manner as to induce a hasty decision to buy the security being offered without disclosure of the 
material facts about the issuer.”  SEC v. R.J. Allen & Assocs., Inc., 386 F. Supp. 866, 874 (S.D. 
Fla. 1974).
 

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rooms’ plans to profit from the victims’ purchases.  Indeed, Power Traders Press, Elite Stock 
Research, and the Boiler Room Defendants were compensated for promoting these securities, 
and they and/or their co-Defendants owned the stock they were promoting and intended to match 
the victims’ purchases with sales that continued to artificially inflate the price and produced 
fraudulent profits for themselves ( referred to as “scalping”). 
6. Rather than disclose these material facts, the Boiler Room Defendants 
fraudulently promoted these securities to victims as solid investments, often making material 
misstatements to victims, including that the securities were “guaranteed winners” and were a 
“buy of a lifetime.”  Certain Boiler Room Defendants also affirmatively misrepresented their 
credentials and the nature of their compensation. 
7. As a result of these fraudulent schemes, Elite Stock Research, Power Traders 
Press, the Orchestrator Defendants, and the Boiler Room Defendants were able to “pump” the 
price of these securities such that they realized millions of dollars in illegal proceeds when they 
sold, or “dumped,” these securities at artificially high prices.  Meanwhile, the unsuspecting 
victims lost millions.       
VIOLATIONS AND RELIEF SOUGHT 
8. By virtue of the conduct alleged herein, Defendants have violated Section 10(b) 
of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 
thereunder [17 C.P.R. § 240.10b-5], Section 9(a)(1) of the Exchange Act [15 U.S.C. § 78i(a)(1)], 
Section 9(a)(2) of the Exchange Act [15 U.S.C. § 78i(a)(2)], Section 15(a) of the Exchange Act 
[15 U.S.C. § 78o(a)], and/or Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 
U.S.C. § 77q(a)].   

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9. The Court should permanently enjoin Defendants from violating the securities 
laws; order all Defendants and Relief Defendants, on a joint and several basis, to disgorge their 
ill-gotten gains, together with prejudgment interest; order all Defendants to pay civil money 
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)]; impose a penny stock bar pursuant to 
Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and 21(d)(6) of the Exchange Act [15 
U.S.C. § 78u(d)(6)]; enter an officer-and-director bar against Jeffrey Chartier pursuant to Section 
20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 
U.S.C. § 78u(d)(2)]; and order any other relief the Court may deem just and appropriate.   
JURISDICTION AND VENUE 
10. The Court possesses jurisdiction over this action pursuant to Sections 20(b), 20(d) 
and Section 22(a) of the Securities Act [15 U.S.C. § 77t(b), 77t(d), and 77v(a)], and Sections 
21(d) and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), and 78aa]. 
11. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15 
U.S.C. §§ 77v(a)], and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)] because certain 
of the transactions, acts, practices and courses of conduct constituting the violations alleged 
herein occurred within the Eastern District of New York.  Among other things, Power Traders 
Press’s and Elite Stock Research’s principal place of business while the schemes alleged in this 
Complaint took place was in the Eastern District of New York, and certain Defendants reside in 
this District. 
12. In connection with the conduct alleged in this Complaint, Defendants, directly or 
indirectly, singly or in concert with others, have contacted investors in dozens of states, 
including Arizona, California, Florida, Massachusetts, Ohio, Oregon, Pennsylvania, Tennessee, 

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and Texas, made the use of the means or instrumentalities of interstate commerce, and made use 
of the means or instruments of transportation or communication in interstate commerce, and of 
the mails and of the facilities of a national securities exchange to carry out the unlawful conduct 
alleged in this Complaint.  
DEFENDANTS  
I. The Orchestrator Defendants 
 
13. Jeffrey Chartier, age 53, is a resident of Tampa, Florida.  From approximately 
1997 to 2009, Chartier was associated with a number of broker-dealers, and worked in various 
capacities, including as a registered representative.  During this time, Chartier held Series 7 and 
63 licenses.  Chartier obtained a Series 31 license in 1998 and a Series 24 license in 2004.  
Chartier serves as President and a Director of National Waste Management Holdings, Inc.  
(“NWMH”), and as a Director of CES Synergies, Inc (“CESX”) – companies involved in the 
pump-and-dump schemes alleged in this Complaint. 
14. Robert Gleckman, age 52, is a resident of Tarzana, California.  From 
approximately 1988 to 1999, Gleckman was a registered representative associated with different 
broker-dealers.  During that time, Gleckman held Series 7 and 63 licenses.  Gleckman is an 
orchestrator of at least one of the pump-and-dump schemes alleged in this Complaint.      
15. Lawrence D. Isen, age 63, is a resident of San Diego, California.  From 
approximately 1987 to 1995, Isen was associated with three different broker-dealers as a 
registered representative, including one with Gleckman.  During that time, Isen held Series 7, 24, 
and 63 licenses.  On May 18, 1995, the Commission barred Isen from associating with any 
broker or dealer for violations of the antifraud provisions of the Federal securities laws, and on 
November 16, 2000, Isen was convicted by a jury in the United States District Court for the 

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Southern District of New York of conspiracy to commit securities fraud and wire fraud.  On 
December 19, 2001, Isen was sanctioned by the Commission for violations of Section 17(a) of 
the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder based on 
the conduct underlying his criminal conviction.  On December 20, 2007, Isen was sanctioned by 
the Commission and permanently enjoined from violating Sections 5(a), 5(c), 17(a)(2), and 
17(a)(3) of the Securities Act in SEC v. Isen, No. 07-CV-11386 (S.D.N.Y. Dec. 19, 2007).  Isen 
is an orchestrator of at least two of the pump-and-dump schemes alleged in this Complaint. 
16. Stephanie Lee, age 46, is a resident of Saint Petersburg, Florida.  From 
approximately 1997 to 2011, Lee was associated with a number of broker-dealers, and worked in 
various capacities, including as a registered representative, in back office operations, as a trader, 
and in compliance.  During this time, Lee held Series 7 and 63 licenses.  In 2000, she also 
obtained Series 24 and 55 licenses.  Lee is an orchestrator of at least two of the pump-and-dump 
schemes alleged in this Complaint. 
17. Michael Watts, age 61, is a resident of Sugar Land, Texas.  From approximately 
1988 to 1999, Watts was a registered representative at several broker-dealers.  During that time, 
Watts held Series 3, 7, and 63 licenses.  On June 19, 2000, Watts was sanctioned and suspended 
by the National Association of Broker Dealers.  On February 17, 2017, the Commission charged 
Watts with violating Sections 17(a)(1) and 17(a)(3) of the Securities Act, Sections 10(b) and 
13(d) of the Exchange Act and Rules 10b-5 and 13d-1 thereunder, and with aiding and abetting 
violations of Sections 5(a) and 5(c) of the Securities Act in SEC v. Watts, No. 7-CV-00539 (S.D. 
Tex. Feb. 17, 2017).  Watts is an orchestrator of at least one of the pump-and-dump schemes 
alleged in this Complaint. 
 

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II. The Boiler Room Defendants 
18. Power Traders Press is a New York entity incorporated on November 4, 2014.  
Power Traders Press has been known by several aliases, including TradeMastersPro.com, Inc. 
(“Trade Masters Pro”), Dacona Financial LLC (“Dacona Financial”), and 
MyStreetResearch.com, Inc. (“MyStreetResearch.com”).  Between mid-2014 and the present, 
Power Traders Press has operated as a boiler room.  During the relevant period, Power Traders 
Press promoted a number of microcap securities including, but not limited to, NWMH, CESX, 
Hydrocarb Energy Corp. (“HECC”), Intelligent Content Enterprises, Inc. (“ICEIF”), First Choice 
Healthcare Solutions Inc. (“FCHS”), Nemus Bioscience Inc. (“NMUS”), Algae Dynamics Corp. 
(“ADYNF”), Tiger Reef Inc. (“TGRR”) f/k/a/ Blue Water Bar & Grill, Inc. (“BWBG”), Grilled 
Cheese Truck Inc. (“GRLD”), Globe Net Wireless Corp. (“GNTW”), International Western 
Petroleum Inc. (“INWP”), NuGene International Inc (“NUGN”), PTC Therapeutics Inc. 
(“PTCT”), SPYR Inc. (“SPYR”), Staffing 360 Solutions, Inc. (“STAF”), and Renewable Energy 
& Power Inc. (“RBNW”).  Erik Matz and Ronald Hardy manage the boiler room, set salaries, 
and make hiring decisions.  Erik Matz serves as a signatory on a bank account in the name of 
Power Traders Press and its alias Dacona Financial.  Power Traders Press has never been 
registered with the Commission in any capacity. 
19. Elite Stock Research is a New York entity incorporated on August 12, 2013.  
Elite Stock Research is controlled by Anthony Vassallo, who serves as its President and chief 
executive officer, and Vassallo has authority over its trading and bank accounts.  Between at 
least 2014 and 2016, Elite Stock Research operated as a boiler room.  During the relevant period, 
Elite Stock Research promoted a number of microcap securities including, but not limited to, 
CESX, HECC, FCHS, NMUS, Industrial Nanotech Inc. (“INTK”), and NuLife Sciences Inc. 

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f/k/a Smoofi, Inc. (“SMFI”).  Elite Stock Research has never been registered with the 
Commission in any capacity. 
20. Ashley Antos, age 26, is a resident of Central Islip, NY.  Antos worked at Elite 
Stock Research from approximately January 2014 to September 2015, and later worked at Power 
Traders Press until at least January 2017.  At all times relevant to this Complaint, Antos was not 
registered with the Commission in any capacity. 
21. Emin Cohen, age 33, is a resident of Coram, New York.  Cohen has worked at 
Power Traders Press since approximately August 2014.  At all times relevant to this Complaint, 
Cohn was not registered with the Commission in any capacity.    
22. Ronald Hardy, age 42, is a resident of Port Jefferson, New York.  From 
approximately 1995 to 2009, Hardy was associated with a number of broker-dealers as a 
registered representative.  During that time, Hardy held Series 7 and 63 licenses.  On August 10, 
2009, the United States District Court for the Southern District of Florida permanently enjoined 
Hardy from future violations of Section 17(a) of the Securities Act and Section 10(b) of the 
Exchange Act and Rule 10b-5 thereunder in SEC v. Aura Financial Services, Inc., No. 09-CV-
21592 (S.D. Fla. June 11, 2009).  On September 2, 2009, Hardy was barred by the Commission 
from association with any broker or dealer pursuant to Section 15(b)(6) of the Exchange Act as a 
result of the conduct underlying the Aura Financial Services action.  Between approximately 
January and June 2014, Hardy worked at Elite Stock Research and, since mid-2014, he has 
controlled Power Traders Press with Erik Matz.  At all times relevant to this Complaint, Hardy 
was not registered with the Commission in any capacity. 
23. Brian Heepke, age 36, is a resident of Farmingdale, New York.  Heepke was 
associated with a registered broker-dealer from 2013 to 2014.  Heepke worked at Elite Stock 

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Research from approximately January 2014 to November 2015, when he left to work at Power 
Traders Press, where is currently employed.  At all times relevant to this Complaint, Heepke was 
not registered with the Commission in any capacity. 
24. Erik Matz, age 44, is a resident of Hicksville, New York.  From approximately 
1996 to 2006, Erik Matz was associated with a number of broker-dealers as a registered 
representative and has held Series 7 and 63 licenses.  On February 20, 2007, Erik Matz was 
barred from the brokerage industry in all capacities for engaging in excessive trading and 
churning in customer accounts in violation of Section 10(b) of the Securities Exchange Act of 
1934, Rule 10b-5 thereunder, and NASD Rules 2310(a), 2120, and 2110.  Dep’t of Enforcement 
v. Matz, 2007 WL 1434907, at *1 (NASDR) (Feb. 20, 2007).  Between approximately February 
and June 2014, Erik Matz worked at Elite Stock Research, and since mid-2014, he has controlled 
Power Traders Press along with Hardy.  At all times relevant to this Complaint, Erik Matz was 
not registered with the Commission in any capacity.  
25. Sergio Ramirez, age 44, is a resident of East Meadow, New York.  Ramirez has 
never been registered with the Commission in any capacity.  Ramirez worked at Elite Stock 
Research from approximately February to July 2014, when he left to work at Power Traders 
Press, where he is currently employed.  At all times relevant to this Complaint, Ramirez was not 
registered with the Commission in any capacity. 
26. Anthony Vassallo, age 54, is a resident of Smithtown, New York.  From 
approximately 1988 to 1994, Vassallo worked for a number of broker-dealers as a registered 
representative.  During that time, Vassallo held Series 7 and 63 licenses.  On May 26, 1995, the 
United States District Court for the Southern District of New York permanently enjoined 
Vassallo from violations of the registration, antifraud, and penny stock provisions of the Federal 

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securities laws in SEC v. Olsen Laboratories, Inc., No. 94-CV-06280 (S.D.N.Y. May 26, 1995).  
In a related administrative proceeding, on June 13, 1995, Vassallo consented to an order barring 
him from association with a broker, dealer, investment adviser, municipal securities dealer or 
investment company and barring him from participating in a penny stock offering.  On July 12, 
2013, Vassallo was sanctioned by the State of Connecticut Department of Banking for violations 
of the antifraud and registration requirements of the State of Connecticut.  Vassallo has 
controlled the Elite Stock Research boiler room since approximately January 2014.  At all times 
relevant to this Complaint, Vassallo was not registered with the Commission in any capacity. 
27. Dennis J. Verderosa, age 66, is a resident of Coram, NY.  Verderosa passed the 
Series 63 exam in 1996.  Verderosa worked at Elite Stock Research from approximately January 
to May 2014, when he left to work at Power Traders Press.  At all times relevant to this 
Complaint, Verderosa was not registered with the Commission in any capacity. 
RELIEF DEFENDANTS 
28. Janine Acosta, age 51, is a resident of Freeport, New York.  Acosta served as a 
secretary and administrative assistant at Power Traders Press.  Acosta received at least $70,000 
in proceeds from the Federal securities law violations alleged in this Complaint, including 
payments from Power Traders Press bank accounts in which such proceeds were held, in 
exchange for no consideration and without any legitimate claim to those funds. 
29. Antos Inc. is a New York entity, incorporated on September 16, 2016.  Ashley 
Antos is  listed as the contact who will accept process for Antos Inc., and he endorses checks 
written by Power Traders Press to this entity.  Antos Inc. received at least $7,500 in proceeds 
from the Federal securities law violations alleged in this Complaint, including payments from 

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Power Traders Press bank accounts in which such proceeds were held, in exchange for no 
consideration and without any legitimate claim to those funds. 
30. Brittney Ballestas, age 25, is a resident of North Bellmore, NY.  Power Traders 
Press used a brokerage account held by Ballestas to engage in manipulative trading as part of the 
Federal securities law violations alleged in this Complaint.  Ballestas received at least $50,000 in 
proceeds from the Federal securities law violations alleged in this Complaint, including 
payments from Power Traders Press bank accounts in which such proceeds were held and the 
proceeds of Power Traders Press’s manipulative trading, in exchange for no consideration and 
without any legitimate claim to those funds. 
31. BCBall, Inc. (“BCBall”) is a New York entity incorporated by Ballestas on 
September 8, 2016.  Ballestas is President of BCBall and is the sole signatory on BCBall’s bank 
accounts.  BCBall received at least $227,000 in proceeds from the Federal securities law 
violations alleged in this Complaint, including payments from Marketbyte LLC and Trade 
Masters Pro.com, Inc. bank accounts in which such proceeds were held, in exchange for no 
consideration and without any legitimate claim to those funds. 
32. Big Little Consulting, Inc. (“Big Little Consulting”) is a New York entity 
incorporated on June 16, 2016.  Joseph Matz is the President of Big Little Consulting.  Big Little 
Consulting, Inc. received at least $2,049,250 in proceeds from the Federal securities law 
violations alleged in this Complaint, including payments from Marketbyte LLC bank accounts in 
which such proceeds were held, in exchange for no consideration and without any legitimate 
claim to those funds.
 
 
33. Dacona Financial LLC (“Dacona Financial”) is a Wyoming entity incorporated 
on March 22, 2013, and is an alias of Power Traders Press.  Dacona Financial shares the same 

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address as Power Traders Press, and Power Traders Press’s telephone lines are registered to 
Dacona Financial.  Erik Matz is a signatory on the Dacona Financial bank account.  Dacona 
Financial was administratively dissolved by the state of Wyoming as of May 9, 2015, for a tax 
delinquency.  Dacona Financial received at least $1,100,000 in proceeds from the Federal 
securities law violations alleged in this Complaint, including payments from Marketbyte LLC 
and Type A Partners, Inc. accounts in which such proceeds were held and the proceeds of Power 
Traders Press’s manipulative trading, in exchange for no consideration and without any 
legitimate claim to those funds. 
34. DJV Enterprises, Inc. (“DJV Enterprises”) is a New York entity incorporated by 
Verderosa on January 6, 2015.  Verderosa is President of DJV Enterprises and is the sole 
signatory on the entity’s bank account.  DJV Enterprises received at least $75,400 in proceeds 
from the Federal securities law violations alleged in this Complaint, including payments from 
Power Traders Press accounts in which such proceeds were held, in exchange for no 
consideration and without any legitimate claim to those funds. 
35. Gabron Transport Corp. (“Gabron”) is a New York entity incorporated on April 
17, 2015.  Hardy is the President of Gabron and is a signatory on its bank account.  Gabron 
received at least $147,000 in proceeds from the Federal securities law violations alleged in this 
Complaint, including payments from Power Traders Press accounts in which such proceeds were 
held, in exchange for no consideration and without any legitimate claim to those funds. 
36. Melissa Kurtzke, age 29, is a resident of Franklin Square, New York.  Power 
Traders Press used a brokerage account held by Kurtzke to engage in manipulative trading as 
part of the Federal securities law violations alleged in this Complaint.  Kurtzke received at least 
$60,000 in proceeds from the Federal securities law violations alleged in this Complaint, 

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including payments from Dacona Financial accounts in which such proceeds were held and the 
proceeds of Kurtzke’s manipulative trading, in exchange for no consideration and without any 
legitimate claim to those funds. 
37. Leecorp, Inc. (“Leecorp”) is a New York entity, incorporated on August 25, 
2016.  Cohen endorsed checks written by Power Traders Press to this entity.  Leecorp received at 
least $48,900 in proceeds from the Federal securities law violations alleged in this Complaint, 
including payments from Power Traders Press accounts in which such proceeds were held, in 
exchange for no consideration and without any legitimate claim to those funds. 
38. Marketbyte LLC (“Marketbyte”) is a California entity incorporated on January 
25, 2000.  Isen is the President of Marketbyte and a signatory on its bank accounts.  Isen used 
Marketbyte in at least two of the boiler room schemes, to, among other things, facilitate 
payment, including through the transfer of shares, to the Elite Stock Research and Power Traders 
Press boiler rooms.  Marketbyte received at least $286,000 in proceeds from the Federal 
securities law violations alleged in this Complaint, including the proceeds of Isen’s manipulative 
trading, in exchange for no consideration and without any legitimate claim to those funds. 
39. Hermann Matz, age 71, is a resident of Hicksville, New York.  Hermann Matz is 
the father of Erik Matz.  Power Traders Press used a brokerage account held by Hermann Matz 
to engage in manipulative trading as part of the Federal securities law violations alleged in this 
Complaint.  Hermann Matz received at least $205,000 in proceeds from the Federal securities 
law violations alleged in this Complaint, including payments from Type A Partners, Inc. 
accounts in which such proceeds were held and the proceeds of Power Traders Press’s 
manipulative trading, in exchange for no consideration and without any legitimate claim to those 
funds. 

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40. Joseph Matz, age 39, is a resident of Hicksville, New York.  Joseph Matz is the 
brother of Erik Matz.  Joseph Matz received at least $964,000 in proceeds from the Federal 
securities law violations alleged in this Complaint, including payments from Marketbyte 
accounts in which such proceeds were held, in exchange for no consideration and without any 
legitimate claim to those funds. 
41. MKKMMKKM, Inc. (“MKKMMKKM”) is a New York entity incorporated on 
October 6, 2014.  Kurtzke is the sole signatory on MKKMMKKM’s bank account.  
MKKMMKKM received at least $130,000 in proceeds from the Federal securities law violations 
alleged in this Complaint, including payments from Dacona Financial accounts in which such 
proceeds were held, in exchange for no consideration and without any legitimate claim to those 
funds. 
42. MyStreetResearch.com, Inc. (“MyStreetResearch.com”) is a New York entity 
incorporated on August 17, 2016.  It is an alias of Power Traders Press.  MyStreetResearch.com 
shares an office address with Power Traders Press, and MyStreetRearch.com, Inc., shares a 
phone number with Power Traders Press’s alias, Trade Masters Pro.  MyStreetResearch.com 
received at least $78,000 in proceeds from the Federal securities law violations alleged in this 
Complaint, including payments from Marketbyte accounts in which such proceeds were held, in 
exchange for no consideration and without any legitimate claim to those funds. 
43. Price Point Consulting, Inc. (“Price Point Consulting”) is a New York entity 
incorporated on August 1, 2016.  Heepke has endorsed checks written by Power Traders Press to 
this entity.  Price Point Consulting received at least $10,500 in proceeds from the Federal 
securities law violations alleged in this Complaint, including payments from Power Traders 

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Press accounts in which such proceeds were held, in exchange for no consideration and without 
any legitimate claim to those funds.  
44. PTP Construction Corp. (“PTP Construction”) is a New York entity 
incorporated on June 25, 2015.  Hardy is President of PTP Construction and is the sole signatory 
on the entity’s bank account.  PTP Construction received at least $181,750 in proceeds from the 
Federal securities law violations alleged in this Complaint, including payments from Power 
Traders Press accounts in which such proceeds were held, in exchange for no consideration and 
without any legitimate claim to those funds. 
45. Revolving Ventures LLC (“Revolving Ventures”) is a Wyoming entity, 
incorporated on May 12, 2016.  Hardy is the sole member of Revolving Ventures, and the sole 
signatory on its bank account.  Revolving Ventures LLC received at least $441,000 in proceeds 
from the Federal securities law violations alleged in this Complaint, including payments from 
Trade Masters Pro and Marketbyte accounts in which such proceeds were held, in exchange for 
no consideration and without any legitimate claim to those funds. 
46. RKRG Inc. (“RKRG”) is a New York entity incorporated on October 3, 2014.  
Hardy’s spouse is a signatory on the RKRG bank account.  RKRG received at least $76,900 in 
proceeds from the Federal securities law violations alleged in this Complaint, including 
payments from Power Traders Press accounts in which such proceeds were held, in exchange for 
no consideration and without any legitimate claim to those funds. 
47. Snap or Tap Productions, LLC (“Snap or Tap Productions”) is a California 
entity incorporated on January 27, 2011.  Gleckman is the President of Snap or Tap Productions 
and the sole signatory on its bank account.  Snap or Tap Productions realized at least $174,000 in 
proceeds from the Federal securities law violations alleged in this Complaint, including the 

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proceeds of Gleckman’s manipulative trading, in exchange for no consideration and without any 
legitimate claim to those funds. 
48. Soccerserge, Inc. (“Soccerserge”) is a New York entity incorporated on August 
22, 2016.  Ramirez endorses checks written by Power Traders Press to this entity.  Soccerserge 
received at least $6,945 in proceeds from the Federal securities law violations alleged in this 
Complaint, including payments from Power Traders Press accounts in which such proceeds were 
held, in exchange for no consideration and without any legitimate claim to those funds. 
49. Strategic Capital Markets, Inc. (“Strategic Capital Markets”) is a Florida entity 
incorporated on August 23, 2013.  Lee incorporated Strategic Capital Markets, and Lee served as 
Strategic Capital Markets’ initial Secretary, with Chartier serving as President.  Lee has also 
served as Strategic Capital Markets’ Vice President during the relevant period.   Lee and Chartier 
had authority over a trading account in the name of Strategic Capital Markets that they used for 
manipulative trading in connection with at least two of the pump-and-dump schemes alleged in 
this Complaint.  Strategic Capital Markets realized at least $1,485,000 in proceeds from the 
Federal securities law violations alleged in this Complaint, including the proceeds of Lee’s and 
Chartier’s manipulative trading, in exchange for no consideration and without any legitimate 
claim to those funds.   
50. TradeMastersPro.com, Inc. (“Trade Masters Pro”) is a New York entity 
incorporated on April 28, 2016, and it is an alias of Power Traders Press.  Trade Masters Pro 
shares the same address as Dacona Financial and Power Traders Press, and the phone lines used 
by Trade Masters Pro are registered to Power Traders Press’s alias, Dacona Financial.  Trade 
Masters Pro received at least $1,440,300 in proceeds from the Federal securities law violations 

18 
 
alleged in this Complaint, including payments from Marketbyte accounts in which such proceeds 
were held, in exchange for no consideration and without any legitimate claim to those funds. 
51. Trademasters Consulting Inc. (“Trademasters Consulting”) is a New York 
entity, incorporated on June 14, 2016.  Hardy is the President of Trademasters Consulting and 
the sole signatory on its bank account.  Trademasters Consulting received at least $302,500 in 
proceeds from the Federal securities law violations alleged in this Complaint, including 
payments from Marketbyte accounts in which such proceeds were held, in exchange for no 
consideration and without any legitimate claim to those funds. 
52. Type A Partners, Inc. (“Type A Partners”) is a Florida entity incorporated on 
September 5, 2013.  Lee incorporated Type A Partners, and Lee serves as its President and 
Secretary.  Lee had authority over the Type A Partners’ trading accounts that he used for 
manipulative trading in connection with at least two of the schemes alleged in this Complaint.  
Type A Partners realized at least $3,000,000 in proceeds from the Federal securities law 
violations alleged in this Complaint, including the proceeds of Lee’s manipulative trading, in 
exchange for no consideration and without any legitimate claim to those funds. 
53. Terryville Systems, Inc. (“Terryville Systems”) is a New York entity 
incorporated on December 1, 2015.  Hardy is President of Terryville Systems and is the sole 
signatory on its bank account.  Terryville Systems received at least $90,000 in proceeds from the 
Federal securities law violations alleged in this Complaint, including payments from Marketbyte 
accounts in which such proceeds were held, in exchange for no consideration and without any 
legitimate claim to those funds. 
54. Trek Partners LLC (“Trek Partners”) is a Nevada entity incorporated on 
September 21, 2015.  Watts serves as President of Geoserve Marketing LLC, a member of Trek 

19 
 
Partners, and is a signatory on Geoserve Marketing LLC’s bank account.  Trek Partners received 
at least $100,000 in proceeds from the Federal securities law violations alleged in this 
Complaint, including payments from Power Traders Press accounts in which such proceeds were 
held, in exchange for no consideration and without any legitimate claim to those funds. 
ISSUERS 
55. CES Synergies, Inc. ( “CESX”) is a Florida corporation headquartered in Crystal 
Springs, Florida.  CESX’s common stock (ticker symbol “CESX”) is registered under 12(g) of 
the Exchange Act, and is currently quoted on the OTC Link.  During the pump-and-dump 
scheme alleged in this Complaint, CESX’s securities qualified as a “penny stock” because they 
did not meet any of the exceptions from the definition of a “penny stock,” as defined by Section 
3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder.  Among other things, the securities 
were equity securities: (1) that were not an “NMS stock,” as defined in 17 C.F .R . § 
242.600(b)(47); (2) traded below five dollars per share during the relevant period; (3) whose 
issuer had net tangible assets and average revenue below the thresholds of Rule 3a51-1(g)(1); 
and (4) did not meet any of the other exceptions from the definition of “penny stock” contained 
in Rule 3a51-1 under the Exchange Act. 
56. National Waste Management Holdings, Inc. (“NWMH”) is a Florida 
corporation headquartered in Hernando, Florida.  NWMH’s common stock (ticker symbol 
“NWMH”) is registered under 12(g) of the Exchange Act, and is currently quoted on the OTC 
Link.  During the pump-and-dump scheme alleged in this Complaint, NWMH’s securities 
qualified as a “penny stock” because they did not meet any of the exceptions from the definition 
of a “penny stock,” as defined by Section 3(a)(51) of the Exchange Act and Rule 3a51-1 
thereunder.  Among other things, the securities were equity securities: (1) that were not an “NMS 

20 
 
stock,” as defined in 17 C.F .R . § 242.600(b)(47); (2) traded below five dollars per share during 
the relevant period; (3) whose issuer had net tangible assets and average revenue below the 
thresholds of Rule 3a51-1(g)(1); and (4) did not meet any of the other exceptions from the 
definition of “penny stock” contained in Rule 3a51-1 under the Exchange Act. 
57. Hydrocarb Energy, Corp. f/k/a Duma Energy Corp. (“DUMA”) was a Nevada 
corporation headquartered in Houston, Texas.  HECC’s common stock (ticker symbol “HECC”) 
was previously registered under 12(g) of the Exchange Act, and was previously quoted on the 
OTC Link using the ticker symbol (“HECCQ”).   On April 16, 2016, HECC filed for Chapter 11 
bankruptcy protection, and later amended its filing to Chapter 7.  Following the bankruptcy, the 
stock traded under the ticker symbol “HECCQ.”  On June 22, 2017, an initial decision of an 
administrative law judge dated April 5, 2017 revoking, pursuant to Exchange Act Section 12(j), 
the registration of each class of securities of HECC became final.  During the pump-and-dump 
scheme alleged in this Complaint, HECC’s securities qualified as a “penny stock” because they 
did not meet any of the exceptions from the definition of a “penny stock,” as defined by Section 
3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder.  Among other things, the securities 
were equity securities: (1) that were not an “NMS stock,” as defined in 17 C.F .R . § 
242.600(b)(47); (2) traded below five dollars per share during the relevant period; (3) whose 
issuer had net tangible assets and average revenue below the thresholds of Rule 3a51-1(g)(1); 
and (4) did not meet any of the other exceptions from the definition of “penny stock” contained 
in Rule 3a51-1 under the Exchange Act. 
58. Intelligent Content Enterprises Inc. (“ICEIF”), currently known as Novicius 
Corp., is a corporation incorporated under the laws of Ontario, Canada with its principal place of 
business in Toronto, Ontario.  ICEIF’s common stock is registered under 12(g) of the Exchange 

21 
 
Act, and during the scheme alleged herein, was quoted on the OTC Link under the ticker symbol 
“ICEIF.”  During the pump-and-dump scheme alleged in this Complaint, ICEIF’s securities 
qualified as a “penny stock” because they did not meet any of the exceptions from the definition 
of a “penny stock,” as defined by Section 3(a)(51) of the Exchange Act and Rule 3a51-1 
thereunder.  Among other things, the securities were equity securities: (1) that were not an “NMS 
stock,” as defined in 17 C.F .R . § 242.600(b)(47); (2) traded below five dollars per share during 
the relevant period; (3) whose issuer had net tangible assets and average revenue below the 
thresholds of Rule 3a51-1(g)(1); and (4) did not meet any of the other exceptions from the 
definition of “penny stock” contained in Rule 3a51-1 under the Exchange Act. 
GLOSSARY OF TERMS USED IN THIS COMPLAINT 
59. A “buy limit” order is an order to purchase a security at or below a certain price.  
Instead of paying market price for the security, the buyer sets the price that he or she is willing to 
pay for a certain number of shares.  The buyer is guaranteed to pay that price or less because the 
order is executed only when the seller’s price matches the amount set by the buyer.  If the 
specified price is never met, the order is not filled. 
60. “Marking-the-close” is a form of market manipulation that involves attempting to 
influence the closing price of a security by executing purchase or sale orders at or near the close 
of normal trading hours.  Such activity can artificially inflate or depress the closing price for the 
security. 
61. A “matched trade” is an order to buy or sell securities that is entered with 
knowledge that a matching order on the opposite side of the transaction has been or will be 
entered for the purpose of (1) creating a false or misleading appearance of active trading in any 
publicly traded security; or (2) creating a false or misleading appearance with respect to the 

22 
 
market for any such security. 
62. “Scalping” is a fraudulent practice of promoting third parties to purchase a 
security without disclosing that the promoter had some financial interest in that security, such as 
receiving compensation from the issuer for promoting the security, or owning that security and 
then selling it contemporaneous with the promotional activity to profit from the market activity 
that follows the promotion.   
63. A “sell limit” order is an order to sell a security at or above a certain price.  
Instead of taking market price for a security, the seller sets the price at which he or she is willing 
to sell a certain number of shares.  The seller is guaranteed to sell at or above the specified price 
because the order is executed only when a buyer matches the seller’s price.  If the specified price 
is never matched, the order is not filled. 
64. A “wash sale” is an order to buy or sell securities resulting in no change of 
beneficial ownership for the purpose of (1) creating a false or misleading appearance of active 
trading in any publicly traded security; or (2) creating a false or misleading appearance with 
respect to the market for any such security.   
FACTUAL ALLEGATIONS 
 
I. Overview Of The Boiler Rooms’ Operations 
 Elite Stock Research’s Boiler Room Operations A.
65. Elite Stock Research was incorporated in August 2013, and during the relevant 
period, it operated out of its headquarters in Plainview, New York.  Vassallo is the chief 
executive officer of Elite Stock Research, and he controls its operations.  Vassallo has trading 
authority over the Elite Stock Research brokerage accounts and signatory authority over Elite 
Stock Research’s bank account.  The Orchestrator Defendants, including Lee, paid Vassallo in 

23 
 
cash for his services.  Vassallo also received proceeds from the sale of securities promoted by the 
firm.  Between January 2014 and January 2016, Vassallo received more than $250,000 in checks 
and direct withdrawals from Elite Stock Research’s bank account. 
66. According to its website, Elite Stock Research provides investors with “top 
quality trade recommendations and . . . research that you can trust.”  However, Elite Stock 
Research operated as a boiler room, employing numerous individuals and using 19 different 
telephone lines, to artificially increase the price of certain microcap securities via manipulative 
trading and strong-arm, fraudulent promotional campaigns (“pump” or “pumping”).  From 2014 
until at least 2015, Elite Stock Research pumped at least two securities, CESX and HECC, 
through aggressive promotional activity and executed hundreds of manipulative trades, including 
matched and wash trades, to artificially inflate the price of the securities that Elite Stock 
Research was paid to promote.  During this time period, the firm received more than $1 million 
in illegal trading profits.  
67. Elite Stock Research employed Erik Matz, Hardy, Heepke, Verderosa, Ramirez, 
and Antos as “sales” personnel to aggressively promote securities as part of the fraudulent 
schemes alleged in this Complaint.  Between 2014 and 2015, these Defendants called numerous 
victims promoting at least CESX and HECC in furtherance of the pump-and-dump schemes and 
employed many of the strong-arm, fraudulent promotional tactics alleged in this Complaint.   
68. In addition, Heepke engaged in at least one wash trade of CESX, and Vassallo 
executed at least 17 matched trades with Elite Stock Research’s victims in furtherance of the 
pump-and-dump schemes alleged in this Complaint.  
69. Between 2014 and 2015, Elite Stock Research paid Erik Matz, Hardy, Heepke, 
Verderosa, Ramirez, and Antos more than $448,000 in salary and commissions.  

24 
 
70. At all times relevant to this Complaint, Elite Stock Research, Erik Matz, Hardy, 
Heepke, Vassallo, Verderosa, Ramirez, and Antos were not registered in any capacity with the 
Commission.  Nonetheless, Erik Matz, Hardy, Heepke, Vassallo, Verderosa, Ramirez, and Antos 
were acting as brokers engaged in the business of effecting transactions in securities for the 
accounts of others.  At all relevant times, they directly solicited potential investors to purchase 
securities, provided advice concerning the value of such securities, the advisability of investing 
in these securities, and received transaction-based compensation from the promotion of such 
securities.   
B. Power Traders Press’s Boiler Room Operations 
71. In early to mid-2014, Erik Matz and Hardy founded Power Traders Press after 
leaving Elite Stock Research.  Since at least 2014, Power Traders Press operates its boiler room 
out of its headquarters in Melville, New York.  Erik Matz and Hardy control its operations.  Erik 
Matz has trading authority over Power Traders Press’s brokerage account at Broker-Dealer A 
and signatory authority over two of its bank accounts.  Hardy has signatory authority over one of 
Power Traders Press’s bank accounts.  Erik Matz and Hardy manage the hiring and payment of 
Power Traders Press’s employees.  Erik Matz and/or Hardy have also been the primary contacts 
with the Orchestrator Defendants who hired Power Traders Press to promote certain securities, 
and they have coordinated payments between the Orchestrator Defendants and Power Traders 
Press. 
72. The Orchestrator Defendants pay Power Traders Press in cash deposited to bank 
accounts controlled by Erik Matz and Hardy (or their affiliates), and through shares of the 
securities that Power Traders Press has been paid to promote.  Erik Matz and Hardy transfer 
these trading profits into bank accounts that they (or their affiliates) controlled, and, at times, 
they withdrew large sums of cash from Power Traders Press’s bank accounts.  Between 2014 and 

25 
 
the present, Matz and Hardy have transferred $3.9 million in profits from their fraudulent trading 
to accounts that they control.  
73. As of December 2015, Power Traders Press’s website claimed it offered “top 
notch, detailed, unbiased financial research,” and on its affiliated website, 
MyStreetResearch.com, it claims to provide “unbiased stock recommendations that are accurate, 
detailed and objective.”  However, Power Traders Press operates as a boiler room, employing 
over 20 individuals to pump microcap securities via manipulative trading and strong-arm, 
fraudulent promotional activity.  Since at least 2014, Power Traders Press inflated the prices of at 
least four securities, NWMH, CESX, HECC, and ICEIF, through aggressive promotional activity 
– including using over 20 telephone lines to make hundreds of thousands of calls – and executing 
hundreds of manipulative trades – including matched trades, wash trades, and by marking-the-
close – to artificially inflate the price of the securities that Power Traders Press has been paid to 
promote.  During this time period, Power Traders Press has received at least $11 million in 
fraudulent proceeds, including more than $5 million in trading profits and at least $6 million in 
cash payments for promoting these securities. 
74.  Power Traders Press has used at least 14 trading accounts to execute the 
manipulative trades.  Power Traders Press and its aliases such as Dacona Financial own certain 
of these accounts; others are registered in the names of individuals including Erik Matz, Antos, 
Hermann Matz, Kurtzke, Ballestas, and a relative of Heepke, but Power Traders Press controls 
these accounts, as they have been frequently accessed from Internet Protocol (“IP”) addresses 
registered to Power Traders Press and/or its aliases.  
75.  Power Traders Press employees Antos, Cohen, Heepke, Ramirez, and Verderosa 
as “sales” personnel to aggressively promote securities as part of the pump-and-dump schemes 

26 
 
alleged in this Complaint.  Since 2014, Antos, Cohen, Heepke, Ramirez, and Verderosa have 
called numerous victims, including sometimes from their personal cell phones, promoting at least 
NWMH, CESX, HECC, and ICEIF in furtherance of the pump-and-dump schemes and 
employed many of the strong-arm, fraudulent promotional activity alleged in this Complaint.   
76. In addition, on numerous occasions, Antos, Heepke, and Erik Matz signed into 
their personal trading accounts through IP addresses registered to Dacona Financial, an alias of 
Power Traders Press, to engage in matched and wash trades of the securities promoted by Power 
Traders Press.   
77. Since 2014, Power Traders Press has paid Antos, Cohen, Heepke, Ramirez, and 
Verderosa at least $850,000 in salary and commissions. 
78. At all times relevant to this Complaint, Power Traders Press, Antos, Cohen, 
Heepke, Ramirez, and Verderosa, were not registered in any capacity with the Commission.  
Nonetheless, Antos, Cohen, Heepke, Ramirez, and Verderosa were acting as brokers engaged in 
the business of effecting transactions in securities for the accounts of others.  At all relevant 
times, they directly solicited potential investors to purchase securities, provided advice 
concerning the value of such securities and the advisability of investing in these securities, and 
received transaction-based compensation. 
II. The CESX Scheme 
79. CESX, formerly known as Green Living Concepts, Inc., was formed in 2010 and 
is headquartered in Crystal Springs, Florida.  On November 1, 2013, Chartier was appointed 
Director of CESX, a position he still holds.  CESX identified Lee as an investor contact in 
several press releases during the relevant period. 

27 
 
A. Lee and Chartier Acquired CESX Shares  
80. On or around September 2013, Strategic Capital Markets,  Lee, and Chartier began 
accumulating large quantities of CESX stock, including 1,925,000 restricted shares from CESX.  
81. In December 2013, Lee and Chartier opened a brokerage account in the name of 
Strategic Capital Markets at Broker-Dealer A  and, in January 2014, Lee opened a second account 
at Broker-Dealer A  in the name of Type A Partners.  Between January and March 2014, Lee and 
Chartier deposited more than 600,000 shares of CESX into the Strategic Capital Markets and 
Type A Partners accounts at Broker-Dealer A . 
82.   On January 2, 2014, Lee e-mailed Broker-Dealer A  regarding the deposit of 
CESX shares, copying Chartier, and asked “what else is needed to get the stock cleared and the 
shares into the account so we can start putting some limit orders in and get the stock trading?”  
On March 14, 2014, Defendant Lee again e-mailed Broker-Dealer A and pressed the brokerage 
to deposit the shares quickly because “[w]e are starting a program and [would] be putting many 
orders in.”   
B.  In March 2014, Lee Engaged Elite Stock Research to Inflate CESX’s Stock 
Price 
83. In March 2014, Lee, through Type A Partners, entered into an agreement with 
Vassallo, through Elite Stock Research, to raise “investor-awareness” concerning CESX.  
Pursuant to the agreement, Type A Partners gave Elite Stock Research 250,000 shares of CESX.  
In April 2014, Vassallo deposited 225,000 of the CESX shares into an account in the name of 
Elite Stock Research at Broker-Dealer A .   
84. In the months leading up to March 2014, there was little, if any, trading in CESX 
stock.  On March 12, 2014, the closing price of CESX was $1.35 per share. 

28 
 
85.   In March 2014, Elite Stock Research’s trading account, controlled by Vassallo, 
executed a series of matched trades in CESX, sometimes involving Strategic Capital Markets, an 
entity controlled by Lee and Chartier, for the purpose of fraudulently generating market activity 
and inflating the price of CESX.  For example:  
a. On March 21, 2014, at 2:36 p.m., Elite Stock Research purchased 50,000 
shares of CESX for $1.00 per share, and, at 2:46 p.m., Strategic Capital 
Markets sold 50,000 shares of CESX for $0.97 per share.  Over the next 
several days, Elite Stock Research engaged in numerous purchases and 
sales to drive up the price of CESX, and on March 26 and 27, 2014, Elite 
Stock Research engaged in several matched sales of these shares with its 
victims.  This manipulative trading activity resulted in a fraudulent 
increase in the price of CESX stock and, by close of trading on March 27, 
2014, CESX’s stock had risen to $2.40 per share. 
b. On April 8, 2014, between 9:22 a.m. and 2:02 p.m., Elite Stock Research 
entered 12 separate limit orders resulting in the purchase of 18,700 shares 
of CESX for between $2.15 and $2.47 per share.  On the same date, 
between 9:18 a.m. and 2:33 p.m., Elite Stock Research entered nine 
separate limit orders resulting in the sale of a total of 54,225 shares of 
CESX for between $2.00 and $2.45 per share.  
86. When engaging in this trading of CESX stock, Elite Stock Research, Vassallo, 
Lee, and Chartier knew, or were reckless in not knowing, that this closely coordinated trading in 
a thinly traded stock in accounts they controlled had no economic purpose, but was entered into 

29 
 
for the purpose of creating a false appearance of active trading and/or raising CESX’s price to 
fraudulently induce others to trade in CESX stock as part of their scheme to defraud investors.   
87. Elite Stock Research’s manipulative trading was also coordinated with a 
fraudulent, strong-arm promotional campaign by Elite Stock Research that often targeted senior 
citizens and unsophisticated investors to purchase CESX.  Elite Stock Research aggressively 
called victims to pressure them to purchase CESX.  For example, Elite Stock Research called 
Victim A 29 times between March and April 2014, including three times on April 14, 2014, the 
date on which Victim A purchased 12,500 shares of CESX.   
88. Vassallo and Hardy directly solicited victims while coordinating trading through 
Elite Stock Research’s trading account.    For example, between March and May 2014,
 
Hardy 
persuaded Victim B  to invest almost $100,000 in CESX.  On March 27, 2014, after speaking 
with Hardy, Victim B purchased 5,600 shares of CESX at 3:26 p.m., and, at the same time, 
Vassallo, through Elite Stock Research, sold 5,600 shares of CESX, followed by additional sales 
by Elite Stock Research that day that totaled 26,600 shares and yielded $59,848 in trading 
proceeds.    
89. While promoting CESX to Victim B, Hardy failed to disclose that Elite Stock 
Research had a financial interest in CESX.  Hardy knew, or was reckless in not knowing, that his 
firm had such a financial interest and the purpose of his promotional activity was to inflate the 
price of CESX stock while his firm was selling it for a profit.  Elite Stock Research also paid 
Hardy for these solicitations.   
90. Hardy’s omissions were material because they concealed his and Elite Stock 
Research’s self-interests in recommending CESX stock, information a reasonable investor would 
want to know when deciding whether to purchase CESX stock. 

30 
 
91. Between March and May 2014, Elite Stock Research and Strategic Capital 
Markets executed more than 250 trades in CESX in an effort to artificially inflate the trading 
volume and price of the security, and Elite Stock Research and Strategic Capital Markets 
dumped more than 550,000 shares of CESX, generating millions of dollars in fraudulent profits. 
92. This and other trading involving Elite Stock Research had dramatic effects on 
CESX’s price and market volume.  On March 26, 2014, for example, CESX closed at $2.10 per 
share on trading volume of 78,840, an increase in volume of 1,300 percent from the previous 
day.  
C. In Mid-2015, Lee Also Engaged Power Traders Press to Inflate CESX   
93. Beginning in mid-2015, Lee paid Power Traders Press $195,000 to, among other 
things, promote CESX stock.    
94. By mid-2015, Power Traders Press, including Verderosa, solicited victims, 
including Victim C and Victim D, to purchase CESX, and closely coordinated those purchases 
with sales of CESX stock by Lee and Power Traders Press.  For example, on August 26, 2015, 
Verderosa called Victim D  at 10:22 a.m., and at 10:25 a.m., Victim D  began purchasing shares of 
CESX.  Similarly, Power Traders Press called Victim C  at 9:59 a.m. and spoke with him until 
approximately 10:11 a.m.  At 10:15 a.m., Victim C  began purchasing shares of CESX.  Victim C 
and Victim D purchased a total of 90,000 shares of CESX on August 26, 2015, representing 
more than 23 percent of the shares traded on that day.  On the same day, Power Traders Press 
and Type A Partners sold 125,500 shares of CESX, reaping profits of over $110,000.   
95. To induce Victim D to purchase CESX securities between June 2015 and August 
2016, Verderosa – who was the sole Power Traders Press employee who solicited Victim D  – 
falsely claimed that the stocks recommended by Power Traders Press, including CESX, were 

31 
 
“guaranteed winners,” and that, if Victim D followed his advice, Victim D would make “a 
million dollars by Christmas.”   
96. When making these statements, Verderosa knew, or was reckless in not knowing, 
that these statements were not true.  Further, Verderosa never told Victim D that Power Traders 
Press had a financial interest in the shares of CESX or that the firm was selling the shares at the 
same time that he was inducing the victims to purchase those same shares. Power Traders Press 
also compensated Verderosa for promoting CESX stock. 
97. The misrepresentations and omissions by Verderosa were material because they 
concerned the potential profitability of the stock and concealed his and the firm’s self-interest in 
recommending CESX stock, information a reasonable investor would want to know when 
deciding whether to purchase CESX stock. 
D.  Lee, Chartier, Vassallo, Elite Stock Research, and Power Traders Press 
Recognized Over $1.9 Million in Illegal Profits Selling CESX Shares 
98. Lee’s, Chartier’s, Vassallo’s, Elite Stock Research’s, and Power Traders Press’s 
manipulative trading and fraudulent promotional activity resulted in an artificial and significant 
increase in CESX’s share price.  Between March 21 and May 20, 2014, for example, the price of 
CESX increased from $1.50 to $2.30 per share, before plummeting to a price of $0.20 per share 
by the end of June 2014.  And between August 12 and September 14, 2015, the price of CESX 
increased from $0.60 to $1.97 per share, before dropping to a price of $0.38 per share by the end 
of December 2015.   
99. Once the price of the stock was artificially inflated, Lee, Chartier, Vassallo, Elite 
Stock Research, and Power Traders Press dumped their shares into the market, generating 
millions of dollars in illegal profits.  Between March and May 2014, Lee, Chartier, and Vassallo 
reaped over $1 million in CESX trading profits.  Between August and September 2015, Lee and 

32 
 
Power Traders Press generated more than $15,000 and $167,000, respectively, in illegal trading 
profits in CESX.  In total, between 2014 and 2015, Lee, Chartier, Vassallo, Elite Stock Research, 
and Power Traders Press realized more than $1.9 million in illicit trading profits, by selling more 
than 1.8 million shares of CESX.  
III. The NWMH Scheme  
100. NWMH, formerly known as Kopjaggers, Inc. (“Kopjaggers”), was incorporated 
in 2010 for the purpose of raising capital to buy and sell artwork.  In 2014, Kopjaggers created a 
subsidiary that entered into a reverse merger with a waste management company, Sand/Land of 
Florida Enterprises, Inc., changed its name to NWMH, effected a five-to-one forward stock split, 
and ceased all operations related to buying and selling artwork.   
101. In June 2014, effective on the closing date of the reverse merger, Defendant 
Chartier was appointed a Director,  and in June 2015, he became President of NWMH. 
 Lee and Chartier Acquired NWMH Shares A.
102. Between 2014 and 2016, Lee and Chartier acquired more than 3.8 million shares 
of NWMH through private stock purchase agreements with NWMH.  In exchange for some of 
these shares, Lee and Chartier agreed to provide “investor relations” services to the company 
through Strategic Capital Markets, an entity that they controlled.  Also, in June 2014, Chartier 
entered into a stock purchase agreement with Kopjaggers Consulting LLC, whereby Chartier 
purchased more than 1.9 million shares of NWMH for $29,235.      
103. Lee and Chartier deposited the NWMH shares into accounts at Broker-Dealer A  
in the names of Type A Partners, Strategic Capital Markets, and Chartier. 

33 
 
 Lee and Chartier Engaged Power Traders Press to Inflate NWMH’s Stock B.
Price 
104. In early 2015, Lee and Chartier engaged Power Traders Press to promote NWMH.  
For its services, Power Traders Press received more than one million shares of NWMH, which it 
obtained through stock purchase agreements with Strategic Capital Markets, Type A Partners, 
and through private transactions with shareholders in which Lee acted as the “purchasers’ 
representative.”  Power Traders Press received these NWMH shares at little or no cost.   
105. Power Traders Press deposited its NWMH shares into brokerage accounts at 
Broker-Dealer A in the names of Power Traders Press, Dacona Financial, and Hermann Matz.   
106. In the months leading up to February 2015, there was little trading in NWMH.  In 
December 2014 and January 2015, for example, there was a total trading volume of only 21,800 
shares in NWMH.   
107. Starting in February 2015, Power Traders Press and Stephanie Lee began 
manipulative trading in NMWH, through accounts in the name of Dacona Financial, Kurtzke, 
Hermann Matz, Type A Partners, and others.  In February 2015 alone, NMWH’s total trading 
volume ballooned to 733,172 shares. 
108. In all, from February 2015 to February 2016, Power Traders Press, through 
brokerage accounts in the names of Hermann Matz and Kurtzke, purchased over 2.4 million 
shares of NMWH and sold over three million shares of NMWH using hundreds of small-lot 
transactions, buy and sell limit orders, and matched and wash trades for the sole purpose of 
fraudulently generating market activity and inflating NWMH’s share price.  For example:  
a. On February 9, 2015, at 3:01 pm., Power Traders Press, through Hermann 
Matz’s brokerage account, purchased 4,500 shares of NWMH for $1.00 

34 
 
per share, and, at the same time, it sold 4,500 shares of NMWH for $1.00 
per share through Kurtzke’s brokerage account.   
b. On February 10, 2015, at 9:39 a.m., Power Traders Press, through 
Kurtzke’s brokerage account, bought 8,300 shares of NWMH for $1.00 
per share, and, at the same time, Lee, through Type A Partners’ account, 
sold the same number of shares at the same price.   
c. On March 23, 2015, at 2:15 p.m., Power Traders Press, through Hermann 
Matz’s account, sold 4,500 shares of NWMH for $1.62 per share and, at 
the same time, Power Traders Press, through Kurtzke’s account, purchased 
the same number of shares at the same exact price.   
109. When engaging in this trading of NWMH stock, Power Traders Press and Lee 
knew, or were reckless in not knowing, that this closely coordinated trading involving a thinly 
traded stock in accounts that they controlled had no economic purpose, but was entered into for 
the purpose of creating a false appearance of active trading and/or raising NWMH’s price to 
fraudulently induce others to trade in NWMH stock as part of their scheme to defraud investors.  
110. Power Traders Press’s and Lee’s manipulative trading was also coordinated with 
a fraudulent, strong-arm promotional campaign by Power Traders Press, including by Erik Matz, 
Heepke, and Verderosa, that targeted senior citizens and unsophisticated investors to purchase 
NWMH stock.   
111. From February 2015 until February 2016, Power Traders Press, Erik Matz, 
Heepke, and Verderosa called numerous victims to purchase NWMH stock, and the victims’ 
purchases were often matched with sales by certain Defendants in furtherance of the scheme.  
For example:  

35 
 
a. On February 13, 2015, Erik Matz spoke with Victim E  at 11:25 a.m., 
12:27 p.m., and 12:58 p.m.  At 12:53 p.m. and 12:57 p.m., in two 
transactions, Victim E purchased a total of 10,000 shares of NMWH.  
Also at 12:53 p.m. and 12:57 p.m., Power Traders Press, through Hermann 
Matz’s and Kurtzke’s accounts, almost exactly matched Victim E’s 
purchase, with each account selling 5,000 shares of NWMH for the same 
price.    
b. On March 25, 2015, at 10:02 a.m., Power Traders Press called Victim F, 
who at 10:19 a.m. purchased 36,950 shares of NWMH for $1.64 per share.  
Then at 2:27 p.m., Power Traders Press called Victim G who, between 
2:29 p.m. and 3:16 p.m., purchased 13,050 shares of NWMH for between 
$1.65 and $1.67 per share.  On this same day, Lee, Chartier, and Power 
Traders Press purchased and sold more than 125,000 shares of NMWH. 
c. From June to September 2015, Verderosa persuaded Victim D  to purchase 
over 200,000 shares of NMWH.  Power Traders Press and Verderosa 
coordinated many of Victim D’s purchases with sales of NMWH from 
accounts under Power Traders Press’s and Lee’s control.  For example, on 
June 26, 2015, Power Traders Press called Victim D  several times, and at 
12:31 p.m., Victim D purchased 5,000 shares of NWMH for $1.73 per 
share.  On or about that same time,  Lee, through Type A Partners, sold 
5,000 shares of NMWH for $1.73 per share.  Also on this day, Power 
Traders Press, through Hermann Matz’s and Kurtzke’s accounts, sold over 
10,000 shares of NMWH.      

36 
 
d. On November 16, 2015, at 9:28 a.m., Heepke called Victim H  who, at 
9:42 a.m., while still on the phone with Heepke, placed a limit order to 
purchase 21,500 shares of NWMH for $1.24 per share.  Only minutes 
later, at 9:56 a.m., Power Traders Press, through the Hermann Matz and 
Kurtzke accounts, engaged in a matched trade of 2,900 shares of NWMH 
at a price of $1.27 per share.    
112. When promoting NWMH stock to Victims D, E, F, G, and H, Power Traders 
Press, Heepke, Erik Matz, and Verderosa failed to disclose that Power Traders Press had a 
financial interest in NWMH.  Power Traders Press, Heepke, Erik Matz, and Verderosa knew, or 
were reckless in not knowing, that Power Traders Press had such a financial interest and the 
purpose of their promotional activity was to inflate the price of NWMH stock while the firm was 
selling it for a profit.  Lee, Chartier, and/or Power Traders Press paid Heepke, Erik Matz, and 
Verderosa for promoting NWMH stock.  
113. These omissions were material because they concealed Power Traders Press’s, 
Heepke’s, Erik Matz’s, and Verderosa’s self-interests in recommending NWMH stock, 
information a reasonable investor would want to know when deciding whether to purchase 
NWMH stock. 
114. Antos was also working for Power Traders Press at the time, and she made 
material misstatements to investors when promoting NWMH.  In or around December 2015, 
Antos promoted NWMH to Victim I by stating that the price of NWMH would increase to 
between $3.00 and $5.00 per share.  On January 20, 2016, Victim I purchased 1,000 shares of 
NWMH.  

37 
 
115. When making this statement, Antos knew, or was reckless in not knowing, that it 
was not possible to guarantee that a stock will increase in price.  Further, Antos knew that Power 
Traders Press paid her to promote NWMH and other microcap stocks in which the firm had a 
financial interest, such that she could not have not reasonably or genuinely believed that his 
statement to Victim I was true.   
116. Antos’s misstatement was material because it concerned the expected value of 
NWMH’s stock, information a reasonable investor would want to know when deciding whether 
to purchase NWMH stock. 
117. While Power Traders Press was pumping NWMH stock, Lee and Chartier were 
conducting their own promotional activity for NWMH through Internet television programs and 
news releases.  For example, an Internet television program featuring Chartier disseminated three 
newsletters about his appearances from February to April 2015.  In addition, a NWMH press 
release, issued on March 5, 2015, identified Lee as NWMH’s investor contact.  
118. In addition, in October 2015, Strategic Capital Markets paid $10,000 to an 
investor relations firm, and on November 16, 2015, NWMH issued a press release announcing its 
financial results for the third quarter of 2015 and providing a business update.  On that day, at 
9:28 a.m., Power Traders Press called Victim H  who, at 9:42 a.m., while still on the phone with 
Power Traders Press, placed a limit order to purchase more than 21,500 shares of NWMH for 
$1.24 per share.  Only minutes later, at 9:56 a.m., Power Traders Press, through the Hermann 
Matz and Kurtzke accounts, sold 2,900 shares of NWMH at a price of $1.27 per share.   
119. As a result of this promotional activity and manipulative trading on November 16, 
2015, NWMH’s trading volume was 338,625 shares, an increase of 1,375 percent from the 

38 
 
previous day, and between November 16 and November 18, 2015, the price of NWMH increased 
from $1.22 to $1.41 per share.   
120. Furthermore, Chartier and Lee communicated regularly with Erik Matz and 
Power Traders Press throughout the time Power Traders Press was pumping NWMH stock.  On 
several occasions, these communications corresponded with matched trading among these 
parties.  For example, on September 30, 2015, Chartier and Power Traders Press exchanged 
phone calls at 2:35 p.m. and 2:37 p.m.  That same day, Power Traders Press, through Kurtzke  ’s 
account, and Lee and Chartier, through Strategic Capital Markets’ account, engaged in matched 
trading with Power Traders Press’s victims’ purchases of NWMH, including a matched trade 
between Victims J and K and Strategic Capital Markets at 3:13 p.m.  
121. When engaging in this trading of NWMH stock, Power Traders Press, Lee, and 
Chartier knew, or were reckless in not knowing, that this closely coordinated trading involving a 
thinly traded stock in accounts that they controlled had no economic purpose, but was entered 
into for the purpose of creating a false appearance of active trading and/or raising N WMH’s 
price to fraudulently induce others to trade in NWMH stock as part of the scheme to defraud 
investors.  
 Lee, Chartier, and Power Traders Press Recognized Over $5 Million in C.
Illegal Profits Selling NWMH Shares 
122. Between February 1, 2015 and February 5, 2016, Lee, Chartier, and Power 
Traders Press, realized over $5 million in fraudulent trading profits through the sale of over 3.6 
million shares of NWMH.   
123. Between February 2015 and February 5, 2016, NWMH’s share price fluctuated 
between $0.99 and $1.85.  By the end of February 2016, however, the scheme had concluded, 
and NWMH’s share price plummeted to $0.45 per share.  

39 
 
IV. The HECC Scheme 
124. At all relevant times, HECC, formerly known as Duma Energy Corp., was an oil-
and-gas company headquartered in Houston, Texas, and traded on the OTC Bulletin Board.  
Between 2010 and 2016, Watts’s brother controlled HECC and served as its chairman, chief 
executive officer, and chief financial officer.    
A. In 2014, Isen, Watts, and Gleckman Acquired HECC Shares  
125. In mid-2014, Watts and Gleckman acquired large blocks of HECC shares through 
entities that they controlled.  Geoserve Marketing LLC (“Geoserve Marketing”), which was 
controlled solely by Watts, and Snap or Tap Productions, which was controlled solely by 
Gleckman, acquired HECC shares via consulting agreements with HECC.  Isen assisted 
Gleckman in depositing HECC shares into Gleckman’s brokerage account, and also acquired 
shares for himself via a June 1, 2014 agreement between Isen’s entity, Marketbyte, and Geoserve 
Marketing.   
B.  Isen, Watts, and Gleckman Engaged Power Traders Press to Inflate HECC’s 
Stock Price 
126. Starting in or about August 2014, Watts, through Geoserve Marketing, engaged 
Power Traders Press to promote HECC’s stock through several agreements whereby Geoserve 
Marketing gave 625,000 HECC shares and $660,000 to Power Traders Press in exchange for the 
firm’s consulting services.  In addition, Gleckman paid Power Traders Press approximately 
$350,000 for purported “PR services” related to HECC stock.  Isen also facilitated Power 
Traders Press’s receipt and deposit of HECC shares into brokerage accounts at Broker-Dealer A. 
 Isen, Watts, Gleckman, and Power Traders Press Fraudulently Promoted C.
and Manipulated the Price of HECC Stock 
127. Between approximately mid-2014 and February 2016, Power Traders Press, 
through Verderosa and others, engaged in a fraudulent campaign to promote HECC stock that 

40 
 
involved calls to thousands of potential victims, and it artificially inflated the price of HECC 
through matched and wash trades designed to make it appear that the stock was actually trading 
at a higher price and volume.     
128.   Trading records reflect over 100 examples of Power Traders Press’s matched or 
washed trades in HECC shares.  For example, on October 14, 2015, between 9:34 a.m. and 3:03 
p.m., Power Traders Press, through Hermann Matz’s account, entered 15 orders to purchase a 
total of 7,000 shares of HECC and five orders to sell a total of 7,000 shares of HECC. 
129. Watts also engaged in washed trading of HECC through two brokerage accounts 
that he controlled.  For example, on June 12, 2014, at 3:53 p.m., Watts sold 800 shares of HECC 
for $4.15 per share through an account held at Broker-Dealer B.  Three minutes later, Watts 
purchased 105 shares for $4.24 per share through an account held at Broker-Dealer C. 
130. When engaging in this trading of HECC stock, Power Traders Press and Watts 
knew, or were reckless in not knowing, that this closely coordinated trading involving a thinly 
traded stock in accounts that they controlled had no economic purpose, but was entered into for 
the purpose of creating a false appearance of active trading and/or raising HECC’s price to 
fraudulently induce others to trade in HECC stock as part of the scheme to defraud investors. 
131. This manipulative trading of HECC stock was coordinated with a fraudulent 
promotional campaign by Power Traders Press, including through Antos, Heepke, Hardy, and 
Verderosa.  For example:  
a. On September 9, 2015, Verderosa called Victim D  and spoke with her from 
11:04 to 11:11 a.m.  At 11:08 a.m., Victim D purchased 4,100 shares of 
HECC for $1.52 a share while – at the same time – Power Traders Press 
sold the same amount of shares at the exact price from the Kurtzke account.   

41 
 
b. In November 2015, Hardy called Victim L and recommended HECC.  On 
November 16, 2015, Hardy wrote to Victim L, “As per our discussion 
definitely get some HECC limit $1.03. Let me know how much you pick up.  
I like to keep good notes, so I know exactly how much were [sic] making 
you.”  Victim L responded: “I put a limit order in for 1000 shares at $1.03.  
I’ll pick up a couple more thousand shares tomorrow too.  I need to shift 
some funds into my trading account.”  That same day, Power Traders Press, 
through the Hermann Matz and Kurtzke accounts, bought 44,400 shares of 
HECC and sold 36,800 shares of HECC. 
c. On November 24, 2015, at 9:27 a.m., Heepke called Victim H and spoke 
with him until 9:51 a.m.  Between 9:51 a.m. and 12:29 p.m., Victim H  
purchased 55,000 shares of HECC for between $0.99 and $1.00 per share.  
At the same time, between 9:30 a.m. and 3:59 p.m., Power Traders Press, 
through the Hermann Matz and Kurtzke accounts, purchased and sold more 
than 50,000 shares of HECC.  The next day, Victim H purchased an 
additional 25,800 HECC shares for between $1.24 and $1.38 per share, and 
the Hermann Matz and Kurtzke accounts purchased and sold over 40,000 
shares for between $1.04 and $1.39 per share.  
d. On December 17, 2015, Antos called Victim M, after which Victim M 
purchased 5,000 shares of HECC for between $1.65 and $1.68 per share.  
On the same date, Power Traders Press, through the Hermann Matz and 
Kurtzke accounts, engaged in seven separate transactions in HECC, 

42 
 
including at 3:34 p.m., when Kurtzke bought 1,300 shares for $1.67 per 
share and Hermann Matz sold 1,300 shares of HECC for $1.67 per share. 
132. While promoting HECC stock and, in some cases, ensuring the precise amount of 
stock that their victims’ purchased, Power Traders Press, Antos, Heepke, Hardy, and Verderosa 
knew, or were reckless in not knowing, that Power Traders Press was engaging in manipulative 
trading in the same stock they were promoting.  These Defendants knew, or were reckless in not 
knowing, that Power Traders Press paid them for promoting HECC stock, that the purpose of 
their promotional activity was to create market activity for HECC as well as inflate the price, 
and, on many occasions, contemporaneously sell it for a profit.  These Defendants failed to 
disclose Power Trader Press’ financial interests in HECC to Victims D, H, L, and M.  Power 
Traders Press also compensated Antos, Heepke, Hardy, and Verderosa for promoting HECC 
stock.  
133. These omissions by Power Traders Press, Antos, Heepke, Hardy, and Verderosa 
were material because they concealed their and the firm’s self-interests in recommending HECC 
stock, information a reasonable investor would want to know when deciding whether to purchase 
HECC stock. 
134. Power Traders Press, Erik Matz, Watts, and Gleckman also coordinated its HECC 
sales with Power Traders Press’ fraudulent promotional campaign.  From August 2014 through 
February 2016, trading records reveal dozens of examples where accounts controlled by Watts 
and Gleckman sold HECC shares at the same time that Power Traders Press was engaging in a 
fraudulent promotional campaign, including sales that coordinated with Verderosa’s solicitations 
of Victim D.  For example:  

43 
 
a. On August 31, 2015, at 2:00 p.m., Power Traders Press called Victim E , 
who, at 2:20 p.m., placed a buy limit order to purchase 450 shares of HECC 
for $1.75 per share.  At 2:39 p.m., Erik Matz spoke with Watts.  Shortly 
thereafter, at 3:01 p.m., Watts sold 600 shares of HECC at the same time 
and price that Victim E purchased HECC shares.      
b. On August 31, 2015, at 2:53 p.m., Power Traders Press called Victims N 
and O who placed a buy limit order to purchase 5,000 shares of HECC.  
Within an hour, at approximately 3:51 p.m., Gleckman sold 5,000 shares of 
HECC to Victims N and O for $1.77 per share. 
144. When engaging in this trading of HECC stock, Power Traders Press, Watts, 
Gleckman, and Matz knew, or were reckless in not knowing, that this closely coordinated trading 
in a thinly traded stock through accounts they controlled had no economic purpose, but was 
entered into for the purpose of creating a false appearance of active trading and/or raising the 
price of HECC’s stock to fraudulently induce others to trade in HECC stock as part of the 
scheme to defraud investors. 
135. By April 2016, following this manipulative trading campaign, the share price of 
HECC ultimately dropped to less than $0.10 per share.  During this time, Power Traders Press 
actively dissuaded victims from selling their HECC stock.  For example, on April 11, 2016, 
when Victim E expressed concerned that the share price of HECC was $0.07 and his investment 
had lost 96.13 percent of its value, Erik Matz wrote, “HECC is def. recoverable . . . [they] are 
still sitting on 3 million barrels in proven reserves or $120 mill at today[‘]s oil prices... IMO this 
may be the buy of a lifetime down here.”   

44 
 
136.  Although Erik Matz controlled Power Traders Press, he failed to tell Victim E 
that the firm paid him for promoting HECC stock or that the firm had a financial interest in the 
stock.    
137. When soliciting Investor E, Erik Matz knew, or was reckless in not knowing, that 
HECC was not the “buy of a lifetime,” and that he was promoting HECC stock because he was 
compensated for promoting the stock.  Erik Matz controlled Power Traders Press, a boiler room 
used as part of the scheme to defraud investors that was manipulating the share price of HECC, 
and he was paid to promote the security.  Erik Matz did not reasonably or genuinely believe that 
his statement was true.   
138. Erik Matz’s misrepresentations and omissions were material because they 
involved the expected profitability of HECC and concealed his and Power Traders Press’s self-
interests in recommending HECC stock, information a reasonable investor would want to know 
when deciding whether to purchase HECC stock.  
 Watts, Isen, Gleckman, and Power Traders Press Received Over $2 Million D.
in Illegal Profits Selling HECC Shares 
139. Power Traders Press’s, Antos’s, Hardy’s, Gleckman’s, Isen’s, Erik Matz’s, 
Verderosa’s, and Watts’s fraudulent promotional activity and manipulative trading artificially 
inflated the share price of HECC.  For example, between April 10, 2015, and December 9, 2015, 
HECC stock increased from $0.45 per share to $1.83 per share, with a peak price of $2.53 on 
November 30, 2015, before HECC filed for bankruptcy and the share price dropped to $0.01 per 
share by mid-2016.   
140. While the price of HECC stock was fraudulently inflated, Watts, Isen, Gleckman, 
Power Traders Press, and Erik Matz sold a significant amount of their shares into the market, 
generating a substantial profit.  In addition to receiving more than $1 million in cash 

45 
 
compensation from Geoserve Marketing and Gleckman, Power Traders Press realized 
approximately $175,000 in illegal trading profits by selling 175,000 shares of HECC between 
March and August 2015.  Between 2014 and 2016, Watts realized over $800,000 in HECC 
trading profits; Gleckman and his entity Snap or Tap Productions realized approximately 
$675,000 in HECC trading profits; and Isen and his entity Marketbyte realized over $350,000 in 
HECC trading profits.  Erik Matz realized approximately $13,000 in trading profits by selling 
almost 25,000 shares of HECC between November 2015 and January 2016.  Collectively, Watts, 
Isen, Gleckman, Power Traders Press, and Erik Matz realized over $2 million in fraudulent 
trading profits in HECC. 
V. The ICEIF Scheme 
141. ICEIF is a publicly traded OTC issuer headquartered in Toronto, Ontario.  
According to its press statements, ICEIF is an “emergent Media and Internet company that 
focuses on the experience of the website user.”   
 Isen Directed ICEIF Trades to Generate Money for Promotional Scheme  A.
142. In early 2016, Isen coordinated the trading of large quantities of ICEIF shares in 
Canadian brokerage accounts in the names of several foreign entities.   Canadian Resident A  
holds trading authority over several of these accounts.  Initially, Isen sought to trade directly in 
the accounts controlled by Canadian Resident A, but on March 2, 2016, Broker-Dealer D denied 
Canadian Resident A’s request to add Isen as an authorized trader.  Denied direct trading 
authority,  Isen, through Canadian Resident A, instead directed several trades in ICEIF that 
resulted in enormous profits.   
 Isen Engaged Power Traders Press to Inflate ICEIF’s Stock Price B.
144. Between February 25, 2016, and March 4, 2016, Isen and Power Traders Press 
exchanged drafts of an ICEIF company profile in preparation for Power Traders Press to promote 

46 
 
ICEIF stock.  Isen paid Power Traders Press for its promotional activities from his trading profits 
in the Canadian accounts.  On March 16, 2016, bank accounts in the name of Canadian Resident 
A paid $224,690 to Isen’s entity, Marketbyte.  On March 17, 2016, Isen wired $76,500 to Power 
Traders Press and $126,000 to Power Traders Press’s affiliate Joseph Matz.  Other examples of 
this payment stream include: 
a. On March 22, 2106, Canadian Resident A paid Marketbyte $45,460 and 
on March 23, 2016, Isen wired $40,950 to Joseph Matz. 
b. On March 30, 2016, Canadian Resident A paid Marketbyte $43,260 and 
on March 31, 2016, Isen wired $39,000 to Power Traders Press. 
c. On or about April 6, 2016, Canadian Resident A paid Marketbyte $46,960 
and on April 7, 2016, Marketbyte wired $42,300 to Joseph Matz. 
d. This pattern of weekly payments in varying amounts between Isen’s entity 
Marketbyte and Power Traders Press and its affiliates continued through at 
least September 2016.  On average, Marketbyte’s payments to Power 
Traders Press and its affiliates amounted to approximately 90 percent of 
the payments Marketbyte received from Canadian Resident A. 
145. ICEIF was a thinly traded stock before Power Traders Press’s promotional 
campaign began.  In the two weeks leading up to March 7, 2016, its total trading volume was 
less than 2,000 shares.   
146. Beginning on March 7, 2016, shortly after being was engaged by Isen, Power 
Traders Press began using at least five brokerage accounts to manipulate ICEIF’s stock price and 
volume, including accounts in the names of Hermann Matz, Kurtzke, Ballestas, and Antos.   
Power Traders Press controlled these five accounts, and on March 7, 2016, began purchasing and 

47 
 
selling large blocks of ICEIF stock on the open market.  On March 7, 2016, the trading volume 
of ICEIF spiked to 158,169 shares. 
147. Between March 7, 2016 and July 25, 2016, Power Traders Press purchased more 
than 600,000 shares of ICEIF stock and sold more than 550,000 shares of ICEIF in hundreds of 
separate transactions.  Power Traders Press’s trades included repeated purchases and sales of 
ICEIF in small lots, matched trades with its victims’ purchases, and wash trades to artificially 
inflate the price of the stock.   
148. For example, by March 2016, Victim H gave Heepke the login information for 
Victim H’s online brokerage account.  On March 7, 2016, at 1:23 p.m., Heepke, logged into 
Victim H brokerage account from an IP address registered to Power Traders Press.  At 1:28 p.m., 
1:33 p.m., and 1:35 p.m., Heepke placed limit orders in Victim H’s account, resulting in the 
purchase of 9,600 shares of ICEIF for over $11,000 in Victim H’s account.  At 2:15 p.m., 
Heepke placed an additional limit order in Victim H’s account to buy 5,995 shares of ICEIF for 
$1.45 per share.  Simultaneously, Power Traders Press, through the Hermann Matz account, 
placed a limit order to sell 6,000 shares of ICEIF at 2:16 p.m.  At 2:16 p.m., Victim H purchased 
5,995 shares of ICEIF from Hermann Matz. 
149. Power Traders Press also artificially inflated the price of ICEIF by marking-the-
close, buying shares near the close of the market at 4:00 p.m., and executing matched trading 
between the firm and Antos.  For example, on June 7, 2016, Power Traders Press, through 
Kurtzke’s account, made the following purchases of ICEIF near the 4:00 p.m. close, resulting in 
an substantial increase in the closing price of the stock: 
 
 

48 
 
Time Quantity Price 
3:42:38 p.m. 2,000 shares $1.9577 
3:48:07 p.m. 2,800 shares $2.0500 
3:59:38 p.m. 500 shares $2.2000 
3:59:41 p.m. 100 shares $2.3000 
3:59:46 p.m. 100 shares $2.3000 
3:59:49 p.m. 800 shares $2.2770 
 
150. Antos engaged in matched trading in ICEIF.  On September 19, 2016, at 9:46 
a.m., Power Traders Press, through Ballestas’ brokerage account, purchased 459 shares of ICEIF 
at $0.48 per share and Antos sold 459 shares of ICEIF at $0.48 per share.     
151. When engaging in this trading of ICEIF stock, Power Traders Press and Antos 
knew, or were reckless in not knowing, that this closely coordinated trading in a thinly traded 
stock through accounts they controlled had no economic purpose, but was entered into for the 
purpose of creating a false appearance of active trading and/or raising the price of ICEIF’s stock 
to fraudulently induce others to trade in ICEIF stock as part of the scheme to defraud investors. 
152. At the start of the manipulation scheme, on March 7, 2016, Power Traders Press, 
including Heepke, Verderosa, Ramirez, and Cohen, also began a fraudulent, strong-arm 
promotional campaign to promote the sale of ICEIF stock to potential investors.  For example:   
a. On March 10, 2016, a Power Traders Press representative using a fake 
name, “John Gold,” called Victim N .  “Gold” followed up with an e-mail 
recommending ICEIF, telling Victim N to “put a limit to buy this one at 
$1.63 you’ll be glad you did.”  Victim N responded that he bought 1,000 
shares at $1.65. 
b. On April 29, 2016, Verderosa e-mailed Victim O regarding ICEIF and 
told her that his clients “are building BIG positions in this” and that she 
should contact him “BEFORE you buy it I will explain when you call!” 

49 
 
c. On May 27, 2016, Ramirez called Victim P .  Ramirez told Victim P  to 
purchase ICEIF, and, while on the phone with Ramirez, Victim P 
purchased 5,000 shares of ICEIF at $2.13 per share.  
d. On July 25, 2016, while on the phone with Cohen, Victim Q purchased 
6,000 shares of ICEIF for $0.90 a share at the same time that Power 
Traders Press, through the Hermann Matz account, sold the same amount 
of shares at the same price.  
e. On August 17, 2016, Cohen called Victim R  six times between 8:34 a.m. 
and 10:29 a.m. at which time Victim R purchased 5,000 shares of ICEIF.   
153. Power Traders Press also employed strong-arm tactics to induce investors to 
purchase and hold ICEIF stock.  For example, Heepke told one victim who called to complain 
about ICEIF’s value, “I am tired of hearing from you.  Do you have any rope at home?  If so tie a 
knot and hang yourself or get a gun and blow your head off.”  
154. Power Traders Press, Heepke, Verderosa, Ramirez, and Cohen never told Victims 
N, O, P. Q, and R that Power Traders Press had a financial interest in the shares of ICEIF, that 
the firm was selling ICEIF shares at the same time that they were inducting these victims to 
purchase those same shares, or that Powers Traders Press paid Heepke Verderosa, Ramirez, and 
Cohen received compensation for promoting ICEIF stock. 
155. The omissions of Power Traders Press, Heepke, Verderosa, Ramirez, and Cohen 
were material because they concealed their self-interests in recommending ICEIF stock, 
information a reasonable investor would want to know when deciding whether to purchase 
ICEIF stock. 

50 
 
156. In addition to omitting material facts from their promotional activity, Power 
Traders Press, Ramirez and Cohen made material misrepresentations to investors as part of their 
aggressive cold-calling campaign.  
157. In or around April 2016, when encouraging Victim P to purchase ICEIF, Ramirez 
misrepresented that Power Traders Press was paid based on the sale of its “advisory services,” 
and failed to disclose that he received transaction-based compensation.   
158. When making these misstatements and failing to disclose material information, 
Ramirez knew, or was reckless in not knowing, that he was misleading Victim P.  During the 
relevant period, Ramirez received periodic paychecks from Power Traders Press that, at least at 
times, expressly indicated that the payment was for “commissions.” 
159. In September 2016, Cohen, using the alias “Ian Grant,” misrepresented to Victim 
R that “I put Twitter out as an OTC 8 years ago,” and claimed that ICEIF had “all the makings 
that a Twitter has and then some.”  Cohen also mispresented to Victim R that “Disney [had] 
bought into ICEIF” and that it “had agreed to pick up 442,570 shares,” and that “with Disney 
backing them [ICEIF] now has got a lot of potential to go to two [dollars] very quickly.”  Cohen, 
who was 33 years old at the time, also claimed that he had 21 years of brokerage experience.   
160. When making these statements, Cohen knew, or was reckless in not knowing, that 
his statements about Twitter and Disney were not true.   He also used a false name to conceal his 
true identify from those he was defrauding.  Finally, he was only 33 years old at the time of his 
calls, and thus could not have reasonably worked as a broker for 21 years.  
161. Cohen’s and Ramirez’s misrepresentations were material because they concerned 
the nature, investment returns, and Cohen’s, Ramirez’s, and Power Traders Press’s self-interests 

51 
 
in recommending ICEIF stock, information a reasonable investor would want to know when 
deciding whether to purchase NWMH stock.  
162. Throughout Power Traders Press’s promotion of ICEIF stock in 2016, Isen 
communicated frequently with Power Traders Press by calling and emailing Erik Matz about the 
trading activity.  For example, on May 18, 2016, Isen sent Erik Matz the record of an internet 
chat involving discussions about increasing the price of ICEIF shares, and “confirm[ing] the 
limit” price of ICEIF sales.    
 The ICEIF Scheme Generated More Than $7.8 Million in Illegal Profits C.
163.  From March 7 to September 15, 2016, the share price of ICEIF fluctuated 
between $0.91 and $2.29 per share and, on some days, more than 50 percent of the trading 
volume in ICEIF was attributable to Power Traders Press’s promotional activity.  At the end of 
this promotional activity, the share price plummeted.  By January 2017, ICEIF closed at $0.11 a 
share.    
164. From March 7 to at least September 15, 2016, Isen reported that trading from 
various brokerage accounts generated at least $7.8 million in trading profits from the sale of over 
5 million shares of ICEIF.   
165. Between March 16, 2016 and December 15, 2016, Canadian Resident A wired 
Isen more than $3.5 million generated from ICEIF trading profits during Power Traders Press’s 
promotion of the stock.   
166. During this same time, Isen paid Power Traders Press and its affiliates at least 
$3.5 million generated from ICEIF trading profits in Canada.   
167. Isen, through Marketbyte, diverted these payments to multiple bank accounts, 
including the following entities controlled by Hardy:  Trademasters Consulting, Revolving 
Ventures, Terryville Systems, and Gabron.  Isen, through Marketbyte, also funneled additional 

52 
 
payments to other Power Traders Press affiliates, including Joseph Matz and his entity Big Little 
Consulting, Ballestas and her entity BC Ball, Inc. Mystreetresearch.com Inc., and 
Trademasterspro.com. 
FIRST CLAIM FOR RELIEF 
 
Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) Thereunder 
 
(Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, Hardy, 
Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 
 
168. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
169. By engaging in the acts and conducts alleged in this Complaint, Power Traders 
Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik 
Matz, Vassallo, Verderosa, and Watts, in connection with the purchase or sale of securities, 
directly or indirectly, singly or in concert, by the use of the means or instrumentalities of 
interstate commerce, or of the mails, or of the facilities of a national securities exchange, with 
scienter, have employed devices, schemes, and artifices to defraud, and have engaged in 
transactions, acts, practices, and courses of business which operated as a fraud or deceit. 
170. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 
Watts, directly or indirectly, singly or in concert, have violated, and unless enjoined will 
continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) 
and (c) thereunder [17 C.F.R. § 240.10b-5(a) and (c)].  
 
 
 

53 
 
SECOND CLAIM FOR RELIEF 
Violations of Section 10(b) and Rule 10b-5(b) of the Exchange Act 
(Power Traders Press, Elite Stock Research, Antos,  
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa) 
 
171. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
172. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, in connection with the purchase or 
sale of securities, directly and indirectly, singly or in concert, by use of the means or 
instrumentalities of interstate commerce, or of the mails, or of the facilities of a national 
securities exchange as alleged in this Complaint, knowingly, willfully or recklessly made untrue 
statements of material facts and omitted to state material facts necessary in order to make the 
statements made, in the light of the circumstances under which they were made, not misleading. 
173. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly violated, and, 
unless enjoined, will to continue to violate, Section 10(b) and Rule 10b-5(b) of the Exchange Act 
[15 U.S.C. § 78j(b), and 17 C.F.R. § 240.10b-5(b)]. 
THIRD CLAIM FOR RELIEF 
Violations of Sections 17(a)(1) of the Securities Act 
 (Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, 
Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 
174. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
175. From at least March 2013 through the present, Power Traders Press, Elite Stock 
Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, 

54 
 
Verderosa, and Watts, directly or indirectly, singly or in concert, in the offer and sale of any 
securities, by the use of the means and instruments of transportation and communication in 
interstate commerce and of the mails, knowingly or with reckless disregard for the truth  
employed devices, schemes or artifices to defraud. 
176. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 
Watts, directly or indirectly, singly or in concert, have violated, and unless enjoined  will 
continue to violate, Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]. 
FOURTH CLAIM FOR RELIEF 
Violations of Section 17(a)(3) of the Securities Act 
(Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen,  
Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 
 
177. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
178. From at least March 2013 through the present, Power Traders Press, Elite Stock 
Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, 
Verderosa, and Watts, directly or indirectly, singly or in concert, in the offer or sale of any 
securities by the use of any means or instruments of transportation or communication in 
interstate commerce or by use of the mails, negligently engaged in transactions, practices and 
courses of business which operated or would have operated as a fraud or deceit upon the 
purchasers and prospective purchasers of such securities. 
179. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 

55 
 
Watts, directly or indirectly, singly or in concert, have violated and unless enjoined will continue 
to violate Sections 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)]. 
FIFTH CLAIM FOR RELIEF 
 
Violations of Section 17(a)(2) of the Securities Act 
 
(Power Traders Press, Elite Stock Research, Antos,  
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa) 
 
180. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
181. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly, knowingly 
or recklessly, singly or in concert in the offer or sale of securities, by use of the means or 
instruments of transportation or communication in interstate commerce and by the use of the 
mails, in the offer or sale of securities, with scienter have obtained money or property by means 
of untrue statements of material facts and omissions to state material facts necessary to make the 
statements made, in the light of the circumstances under which they were made, not misleading. 
182. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly violated, and, 
unless enjoined, will continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 
77q(a)(2)]. 
SIXTH CLAIM FOR RELIEF 
 
Violations of Section 15(a) of the Exchange Act 
 
(Antos, Cohen, Hardy, Heepke, Erik Matz, Ramirez, Vassallo, and Verderosa) 
 
183. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein.  

56 
 
184. From certain times starting as early March 2013 through the present, Antos, 
Cohen, Hardy, Heepke, Erik Matz, Ramirez, Vassallo, and Verderosa, while acting as brokers 
engaged in the business of effecting transactions in securities for the account of others made use 
of the mails or the means or instrumentalities of interstate commerce to effect transactions in, or 
to induce or attempt to induce the purchase or sale of, a security without being registered in 
accordance with Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)]. 
185. By reason of the foregoing, Antos, Cohen, Hardy, Heepke, Erik Matz, Ramirez, 
Vassallo, and Verderosa have violated and, unless enjoined, will continue to violate, Section 
15(a) of the Exchange Act [15 U.S.C. § 78o(a)]. 
SEVENTH CLAIM FOR RELIEF 
 
Violations of Section 9(a)(1) of the Exchange Act 
 
(Power Traders Press, Elite Stock Research, Antos, Chartier,  
Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts) 
 
186. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
187. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 
Chartier, Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts, directly or indirectly, singly 
or in concert, by use of the means or instruments of transportation or communication in, or the 
means or instrumentalities of, interstate commerce or by the use of the mails, knowingly or 
recklessly, and for the purpose of creating a false or misleading appearance of active trading in 
securities or a false or misleading appearance with respect to the market for such securities, (a) 
have effected transactions in such securities which involved no change in the beneficial 
ownership thereof; (b) have entered an order or orders for the purchase of such securities with 
the knowledge that an order or orders of substantially the same size, at substantially the same 

57 
 
time, and at substantially the same price, for the sale of any such securities, had been or would be 
entered by or for themselves or different parties; and/or (c) have entered, are entering, or are 
about to enter an order or orders for the sale of such securities with the knowledge that an order 
or orders of substantially the same size, at substantially the same time, and at substantially the 
same price, for the purchase of such securities had been or would be entered by or for themselves 
or different parties. 
188. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 
Chartier, Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts, have violated, are violating, 
and unless restrained and enjoined, will again violate Section 9(a)(1) of the Exchange Act [15 
U.S.C. §78i(a)(1)]. 
EIGHTH CLAIM FOR RELIEF 
 
Violations of Section 9(a)(2) of the Exchange Act 
 
(Power Traders Press and Elite Stock Research) 
  
189. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
190. From at least March 2013 through the present, Power Traders Press and Elite 
Stock Research, directly or indirectly, by the use of the mails or any means or instrumentality of 
interstate commerce, or of any facility of any national securities exchange, with specific intent, 
effected, alone or with other persons, a series of transactions in a security other than a 
government security or in connection with any security-based swap agreement with respect to 
such security creating actual or apparent active trading in such security, for the purpose of 
inducing the purchase or sale of such security by others. 

58 
 
191. By reason of the foregoing, Power Traders Press and Elite Stock Research, have 
violated, are violating, and unless restrained and enjoined, will again violate Section 9(a)(2) of 
the Exchange Act [15 U.S.C. § 78i(a)(2)]. 
NINTH CLAIM FOR RELIEF 
 
Unjust Enrichment 
(Antos Inc., BCBall, Big Little Consulting, Dacona Financial,  
DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM,  
MyStreetResearch.com, Price Point Consulting, PTP Construction,  
Revolving Ventures, RKRG, Snap or Tap Productions, Soccerserge,  
Strategic Capital Markets, Terryville Systems, TradeMasters Consulting, 
TradeMastersPro.com, Trek Partners, Type A Partners,  
Acosta, Ballestas, Kurtzke, Hermann Matz, and Joseph Matz) 
 
192. The Commission realleges and incorporates by reference each and every 
allegation contained in paragraphs 1 through 167 as if fully set forth herein. 
193. 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.” 
194. As alleged in this Complaint, Antos Inc., BCBall, Big Little Consulting, Dacona 
Financial, DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM, 
MyStreetResearch.com, Price Point Consulting, PTP Construction, Revolving Ventures, RKRG, 
Snap or Tap Productions, Soccerserge, Strategic Capital Markets, Terryville Systems, 
TradeMasters Consulting, TradeMastersPro.com, Trek Partners, Type A Partners, Acosta, 
Ballestas, Kurtzke, Hermann Matz, and Joseph Matz received funds and property that were the 
proceeds, or are traceable to the proceeds, of the Defendants’ Federal securities law violations 
that are alleged in this Complaint.  Antos Inc., BCBall, Big Little Consulting, Dacona Financial, 

59 
 
DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM, MyStreetResearch.com, Price 
Point Consulting, PTP Construction, Revolving Ventures, RKRG, Snap or Tap Productions, 
Soccerserge, Strategic Capital Markets, Terryville Systems, TradeMasters Consulting, 
TradeMastersPro.com, Trek Partners, Type A Partners, Acosta, Ballestas, Kurtzke, Hermann 
Matz, and Joseph Matz had no legitimate claims to these proceeds, and gave no consideration in 
exchange for receipt of those funds. 
195. Antos Inc., BCBall, Big Little Consulting, Dacona Financial, DJV Enterprises, 
Gabron, Leecorp, Marketbyte, MKKMMKKM, MyStreetResearch.com, Price Point Consulting, 
PTP Construction, Revolving Ventures, RKRG, Snap or Tap Productions, Soccerserge, Strategic 
Capital Markets, Terryville Systems, TradeMasters Consulting, TradeMastersPro.com, Trek 
Partners, Type A Partners, Acosta, Ballestas, Kurtzke, Hermann Matz, and Joseph Matz obtained 
the funds and property alleged above as part of and in furtherance of the Federal securities law 
violations alleged in this Complaint and under circumstances in which it is not just, equitable, or 
conscionable for them to retain the funds and property.  They were unjustly enriched. 
PRAYER FOR RELIEF 
WHEREFORE, the Commission respectfully requests that this Court issue a Final 
Judgment: 
I. 
 Finding that Defendants each violated the Federal securities laws and rules promulgated 
thereunder as alleged against them in this Complaint. 
II. 
 Permanently enjoining Defendants and their agents, servants, employees and attorneys 
and all persons in active concert or participation with them who receive actual notice of the 
injunction by personal service or otherwise, and each of them, directly or indirectly, from 

60 
 
committing future violations of each of the Federal securities laws and rules promulgated 
thereunder pursuant to Sections 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and/or Section 
21(d) of the Exchange Act [15 U.S.C. § 78u(d)] 
III. 
 Ordering all Defendants and Relief Defendants to disgorge, on a joint and several basis, 
any and all ill-gotten gains they received as a result of the violations of the Federal securities 
laws alleged herein and the rules promulgated thereunder that are alleged in this Complaint, plus 
prejudgment interest thereon, pursuant to Section 21(d)(5) of the Exchange Act [15 U.S.C. § 
78u(d)(5)]. 
IV. 
 Ordering all 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)]. 
V. 
 Ordering all Defendants to be barred from participation in any offering of a penny stock, 
pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and/or Section 21(d)(6) of 
the Exchange Act [15 U.S.C. § 78u(d)(6)]. 
VI. 
 Ordering Chartier,  pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 
and/or Section 21(d)(2) of the Exchange Act [15 U.S.C.§ 78u(d)(2)], to be barred from serving 
as an officer or director of any issuer that has a class of securities registered with the 
Commission pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l], or that is required to 
file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 

VII.
Granting 
such 
other 
and 
further 
relief 
as 
the 
Court 
may 
deem 
just 
and 
proper.
Dated: 
July 
12, 
2017 
Respectfully 
submitted,
~, 
/G 
~~ 
t~~'.~'r~~.,_.
Derek 
Bentsen 
(DB83b9)
UNITED 
STATES 
SECURITIES 
AND
EXCHANGE 
COMMISSION
100 
F 
St., 
N.E.
Washington, 
D.C. 
20549-5985
202-551-6426
BentsenD(a~sec.~ov
Matthew 
F. 
Scarlato 
(motion 
for 
admission
Pro 
Hac 
Vice 
pending)
UNITED 
STATES 
SECURITIES 
AND
EXCHANGE 
COMMISSION
100 
F 
St., 
N.E.
Washington, 
D.C. 
20544-5985
202-551-3749
scarlatom 
@sec.gov
James 
E. 
Smith 
(motion 
for 
admission 
Pro
Hac 
Vice 
pending)
UNITED 
STATES 
SECURITIES 
AND
EXCHANGE 
COMMISSION
100 
F 
St., 
N.E.
Washington, 
D.C. 
20549-59$5
202-551-5881
[email protected]
OF 
COUNSEL:
Scott 
W. 
Friestad
Amy 
Friedman
Cecilia 
Connor
Andrew 
Elliott
SECURITIES 
AND 
EXC~IAl~FGE
COMMISSION
100 
F 
St., 
N.E.
Washington, 
D.C. 
20549-5985
61

1 
 

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

 
SECURITIES AND EXCHANGE 
COMMISSION,      

  
                Plaintiff,     
  v.     
      
POWERTRADERSPRESS.COM, INC., ELITE 
STOCK RESEARCH, INC., ERIK MATZ, 
RONALD HARDY, ANTHONY VASSALLO, 
STEPHANIE LEE, JEFFREY CHARTIER, 
LAWRENCE D. ISEN, ROBERT GLECKMAN, 
MICHAEL WATTS, BRIAN HEEPKE, 
DENNIS J. VERDEROSA, EMIN COHEN, 
SERGIO RAMIREZ, ASHLEY ANTOS,               
    

                            Defendants, 
             and 
 

HERMANN MATZ, JOSEPH MATZ, 
BRITTNEY BALLESTAS, MELISSA 
KURTZKE, JANINE ACOSTA, TYPE A 
PARTNERS, INC., STRATEGIC CAPITAL 
MARKETS, INC., MARKETBYTE LLC, SNAP 
OR TAP PRODUCTIONS, LLC, DACONA 
FINANCIAL LLC, 
TRADEMASTERSPRO.COM, INC., 
MYSTREETRESEARCH.COM, INC., 
REVOLVING VENTURES LLC, 
TRADEMASTERS CONSULTING, INC., BIG 
LITTLE CONSULTING, INC., BCBALL, INC., 
GABRON TRANSPORT CORP., PTP 
CONSTRUCTION CORP., TERRYVILLE 
SYSTEMS, INC., MKKMMKKM, INC., TREK 
PARTNERS LLC, RKRG, INC., PRICE POINT 
CONSULTING, INC., DJV ENTERPRISES, 
INC., LEECORP, INC., SOCCERSERGE, INC., 
ANTOS, INC.,  
 
                                            Relief Defendants. 

  

  
 
 
 
       Case No. _____________ 
 
 
COMPLAINT 
 
JURY TRIAL DEMANDED 

 



2 
 

Plaintiff Securities and Exchange Commission (the “Commission”), for its Complaint 

against Defendants PowerTradersPress.com, Inc., Elite Stock Research, Inc., Erik Matz, Ronald 

Hardy, Anthony Vassallo, Stephanie Lee, Jeffrey Chartier, Lawrence D. Isen, Robert Gleckman, 

Michael Watts, Brian Heepke, Dennis J. Verderosa, Emin Cohen, Sergio Ramirez, and Ashley 

Antos, and Relief Defendants Hermann Matz, Joseph Matz, Brittney Ballestas, Melissa Kurtzke, 

Janine Acosta, Type A Partners, Inc., Strategic Capital Markets, Inc., Marketbyte LLC, Snap or 

Tap Productions, LLC, Dacona Financial LLC, TradeMastersPro.com, Inc., 

MyStreetResearch.com, Inc., Revolving Ventures LLC, TradeMasters Consulting, Inc., Big 

Little Consulting, Inc., BCBall, Inc., Gabron Transport Corp., PTP Construction Corp., 

Terryville Systems, Inc., MKKMMKKM, Inc., Trek Partners LLC, RKRG, INC., Price Point 

Consulting, Inc., DJV Enterprises, Inc., Leecorp, Inc., Soccerserge, Inc., and Antos, Inc., alleges 

as follows: 

SUMMARY OF ALLEGATIONS 

1. Defendants engaged in a series of widespread and ongoing fraudulent schemes, 

beginning in at least March 2013, to manipulate the price and volume of at least four microcap 

securities that reaped at least $14 million in illicit proceeds while causing more than $10 million 

in losses to over one hundred victims.   

2. The fraud began with the acquisition of large blocks of microcap shares by the 

schemes’ orchestrators, including Stephanie Lee, Jeffrey Chartier, Lawrence D. Isen, Robert 

Gleckman, and Michael Watts (“Orchestrator Defendants”).  The Orchestrator Defendants then 



3 
 

 hired two “boiler rooms”1 to fraudulently promote, or “pump,” the securities.  Erik Matz and 

Ronald Hardy controlled one boiler room operating primarily under the name Power Traders 

Press.com, Inc. (“Power Traders Press”), and Anthony Vassallo controlled the boiler room 

operating primarily under the name Elite Stock Research Inc. (“Elite Stock Research”).  The 

Orchestrator Defendants paid Power Traders Press and Elite Stock Research in cash and often 

large blocks of the securities that the boiler rooms were hired to promote.   

3. Power Traders Press’s and Elite Stock Research’s manipulative conduct included  

“marking-the-close” and executing “matched” and “wash” trades that were designed to 

artificially raise the securities’ market prices and trading volumes, and give the false appearance 

of active trading.   

4. Power Traders Press and Elite Stock Research then engaged in large-scale 

promotional campaigns touting these securities, typically targeting the vulnerable – elderly and 

unsophisticated investors.  Power Traders Press’s and Elite Stock Research’s boiler room “sales” 

personnel, including Erik Matz, Hardy, Vassallo, Heepke, Verderosa, Cohen, Ramirez, and 

Antos (“Boiler Room Defendants”), contacted hundreds of individuals across the United States 

seeking to induce investment in these securities, often by employing high-pressure tactics such as 

threatening potential investors and flooding them with emails and phone calls.   

5. The Boiler Room Defendants fraudulently promoted these securities, soliciting 

victims to purchase them while failing to disclose that Elite Stock Research’s and Power Traders 

Press’s sole reason for aggressively soliciting investment in these securities was the boiler 
                                                 
1  “‘Boiler room’ activity consists essentially of offering to customers securities of certain 
issuers in large volume by means of an intensive selling campaign through numerous salesmen 
by telephone or direct mail, without regard to the suitability to the needs of the customer, in such 
a manner as to induce a hasty decision to buy the security being offered without disclosure of the 
material facts about the issuer.”  SEC v. R.J. Allen & Assocs., Inc., 386 F. Supp. 866, 874 (S.D. 
Fla. 1974). 



4 
 

rooms’ plans to profit from the victims’ purchases.  Indeed, Power Traders Press, Elite Stock 

Research, and the Boiler Room Defendants were compensated for promoting these securities, 

and they and/or their co-Defendants owned the stock they were promoting and intended to match 

the victims’ purchases with sales that continued to artificially inflate the price and produced 

fraudulent profits for themselves (referred to as “scalping”). 

6. Rather than disclose these material facts, the Boiler Room Defendants 

fraudulently promoted these securities to victims as solid investments, often making material 

misstatements to victims, including that the securities were “guaranteed winners” and were a 

“buy of a lifetime.”  Certain Boiler Room Defendants also affirmatively misrepresented their 

credentials and the nature of their compensation. 

7. As a result of these fraudulent schemes, Elite Stock Research, Power Traders 

Press, the Orchestrator Defendants, and the Boiler Room Defendants were able to “pump” the 

price of these securities such that they realized millions of dollars in illegal proceeds when they 

sold, or “dumped,” these securities at artificially high prices.  Meanwhile, the unsuspecting 

victims lost millions.    

VIOLATIONS AND RELIEF SOUGHT 

8. By virtue of the conduct alleged herein, Defendants have violated Section 10(b) 

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

thereunder [17 C.P.R. § 240.10b-5], Section 9(a)(1) of the Exchange Act [15 U.S.C. § 78i(a)(1)], 

Section 9(a)(2) of the Exchange Act [15 U.S.C. § 78i(a)(2)], Section 15(a) of the Exchange Act 

[15 U.S.C. § 78o(a)], and/or Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 

U.S.C. § 77q(a)].   



5 
 

9. The Court should permanently enjoin Defendants from violating the securities 

laws; order all Defendants and Relief Defendants, on a joint and several basis, to disgorge their 

ill-gotten gains, together with prejudgment interest; order all Defendants to pay civil money 

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)]; impose a penny stock bar pursuant to 

Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and 21(d)(6) of the Exchange Act [15 

U.S.C. § 78u(d)(6)]; enter an officer-and-director bar against Jeffrey Chartier pursuant to Section 

20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 

U.S.C. § 78u(d)(2)]; and order any other relief the Court may deem just and appropriate.   

JURISDICTION AND VENUE 

10. The Court possesses jurisdiction over this action pursuant to Sections 20(b), 20(d) 

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

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

11. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15 

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

of the transactions, acts, practices and courses of conduct constituting the violations alleged 

herein occurred within the Eastern District of New York.  Among other things, Power Traders 

Press’s and Elite Stock Research’s principal place of business while the schemes alleged in this 

Complaint took place was in the Eastern District of New York, and certain Defendants reside in 

this District. 

12. In connection with the conduct alleged in this Complaint, Defendants, directly or 

indirectly, singly or in concert with others, have contacted investors in dozens of states, 

including Arizona, California, Florida, Massachusetts, Ohio, Oregon, Pennsylvania, Tennessee, 



6 
 

and Texas, made the use of the means or instrumentalities of interstate commerce, and made use 

of the means or instruments of transportation or communication in interstate commerce, and of 

the mails and of the facilities of a national securities exchange to carry out the unlawful conduct 

alleged in this Complaint.  

DEFENDANTS  

I. The Orchestrator Defendants 
 

13. Jeffrey Chartier, age 53, is a resident of Tampa, Florida.  From approximately 

1997 to 2009, Chartier was associated with a number of broker-dealers, and worked in various 

capacities, including as a registered representative.  During this time, Chartier held Series 7 and 

63 licenses.  Chartier obtained a Series 31 license in 1998 and a Series 24 license in 2004.  

Chartier serves as President and a Director of National Waste Management Holdings, Inc.  

(“NWMH”), and as a Director of CES Synergies, Inc (“CESX”) – companies involved in the 

pump-and-dump schemes alleged in this Complaint. 

14. Robert Gleckman, age 52, is a resident of Tarzana, California.  From 

approximately 1988 to 1999, Gleckman was a registered representative associated with different 

broker-dealers.  During that time, Gleckman held Series 7 and 63 licenses.  Gleckman is an 

orchestrator of at least one of the pump-and-dump schemes alleged in this Complaint.      

15. Lawrence D. Isen, age 63, is a resident of San Diego, California.  From 

approximately 1987 to 1995, Isen was associated with three different broker-dealers as a 

registered representative, including one with Gleckman.  During that time, Isen held Series 7, 24, 

and 63 licenses.  On May 18, 1995, the Commission barred Isen from associating with any 

broker or dealer for violations of the antifraud provisions of the Federal securities laws, and on 

November 16, 2000, Isen was convicted by a jury in the United States District Court for the 



7 
 

Southern District of New York of conspiracy to commit securities fraud and wire fraud.  On 

December 19, 2001, Isen was sanctioned by the Commission for violations of Section 17(a) of 

the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder based on 

the conduct underlying his criminal conviction.  On December 20, 2007, Isen was sanctioned by 

the Commission and permanently enjoined from violating Sections 5(a), 5(c), 17(a)(2), and 

17(a)(3) of the Securities Act in SEC v. Isen, No. 07-CV-11386 (S.D.N.Y. Dec. 19, 2007).  Isen 

is an orchestrator of at least two of the pump-and-dump schemes alleged in this Complaint. 

16. Stephanie Lee, age 46, is a resident of Saint Petersburg, Florida.  From 

approximately 1997 to 2011, Lee was associated with a number of broker-dealers, and worked in 

various capacities, including as a registered representative, in back office operations, as a trader, 

and in compliance.  During this time, Lee held Series 7 and 63 licenses.  In 2000, she also 

obtained Series 24 and 55 licenses.  Lee is an orchestrator of at least two of the pump-and-dump 

schemes alleged in this Complaint. 

17. Michael Watts, age 61, is a resident of Sugar Land, Texas.  From approximately 

1988 to 1999, Watts was a registered representative at several broker-dealers.  During that time, 

Watts held Series 3, 7, and 63 licenses.  On June 19, 2000, Watts was sanctioned and suspended 

by the National Association of Broker Dealers.  On February 17, 2017, the Commission charged 

Watts with violating Sections 17(a)(1) and 17(a)(3) of the Securities Act, Sections 10(b) and 

13(d) of the Exchange Act and Rules 10b-5 and 13d-1 thereunder, and with aiding and abetting 

violations of Sections 5(a) and 5(c) of the Securities Act in SEC v. Watts, No. 7-CV-00539 (S.D. 

Tex. Feb. 17, 2017).  Watts is an orchestrator of at least one of the pump-and-dump schemes 

alleged in this Complaint. 

 



8 
 

II. The Boiler Room Defendants 

18. Power Traders Press is a New York entity incorporated on November 4, 2014.  

Power Traders Press has been known by several aliases, including TradeMastersPro.com, Inc. 

(“Trade Masters Pro”), Dacona Financial LLC (“Dacona Financial”), and 

MyStreetResearch.com, Inc. (“MyStreetResearch.com”).  Between mid-2014 and the present, 

Power Traders Press has operated as a boiler room.  During the relevant period, Power Traders 

Press promoted a number of microcap securities including, but not limited to, NWMH, CESX, 

Hydrocarb Energy Corp. (“HECC”), Intelligent Content Enterprises, Inc. (“ICEIF”), First Choice 

Healthcare Solutions Inc. (“FCHS”), Nemus Bioscience Inc. (“NMUS”), Algae Dynamics Corp. 

(“ADYNF”), Tiger Reef Inc. (“TGRR”) f/k/a/ Blue Water Bar & Grill, Inc. (“BWBG”), Grilled 

Cheese Truck Inc. (“GRLD”), Globe Net Wireless Corp. (“GNTW”), International Western 

Petroleum Inc. (“INWP”), NuGene International Inc (“NUGN”), PTC Therapeutics Inc. 

(“PTCT”), SPYR Inc. (“SPYR”), Staffing 360 Solutions, Inc. (“STAF”), and Renewable Energy 

& Power Inc. (“RBNW”).  Erik Matz and Ronald Hardy manage the boiler room, set salaries, 

and make hiring decisions.  Erik Matz serves as a signatory on a bank account in the name of 

Power Traders Press and its alias Dacona Financial.  Power Traders Press has never been 

registered with the Commission in any capacity. 

19. Elite Stock Research is a New York entity incorporated on August 12, 2013.  

Elite Stock Research is controlled by Anthony Vassallo, who serves as its President and chief 

executive officer, and Vassallo has authority over its trading and bank accounts.  Between at 

least 2014 and 2016, Elite Stock Research operated as a boiler room.  During the relevant period, 

Elite Stock Research promoted a number of microcap securities including, but not limited to, 

CESX, HECC, FCHS, NMUS, Industrial Nanotech Inc. (“INTK”), and NuLife Sciences Inc. 



9 
 

f/k/a Smoofi, Inc. (“SMFI”).  Elite Stock Research has never been registered with the 

Commission in any capacity. 

20. Ashley Antos, age 26, is a resident of Central Islip, NY.  Antos worked at Elite 

Stock Research from approximately January 2014 to September 2015, and later worked at Power 

Traders Press until at least January 2017.  At all times relevant to this Complaint, Antos was not 

registered with the Commission in any capacity. 

21. Emin Cohen, age 33, is a resident of Coram, New York.  Cohen has worked at 

Power Traders Press since approximately August 2014.  At all times relevant to this Complaint, 

Cohn was not registered with the Commission in any capacity.    

22. Ronald Hardy, age 42, is a resident of Port Jefferson, New York.  From 

approximately 1995 to 2009, Hardy was associated with a number of broker-dealers as a 

registered representative.  During that time, Hardy held Series 7 and 63 licenses.  On August 10, 

2009, the United States District Court for the Southern District of Florida permanently enjoined 

Hardy from future violations of Section 17(a) of the Securities Act and Section 10(b) of the 

Exchange Act and Rule 10b-5 thereunder in SEC v. Aura Financial Services, Inc., No. 09-CV-

21592 (S.D. Fla. June 11, 2009).  On September 2, 2009, Hardy was barred by the Commission 

from association with any broker or dealer pursuant to Section 15(b)(6) of the Exchange Act as a 

result of the conduct underlying the Aura Financial Services action.  Between approximately 

January and June 2014, Hardy worked at Elite Stock Research and, since mid-2014, he has 

controlled Power Traders Press with Erik Matz.  At all times relevant to this Complaint, Hardy 

was not registered with the Commission in any capacity. 

23. Brian Heepke, age 36, is a resident of Farmingdale, New York.  Heepke was 

associated with a registered broker-dealer from 2013 to 2014.  Heepke worked at Elite Stock 



10 
 

Research from approximately January 2014 to November 2015, when he left to work at Power 

Traders Press, where is currently employed.  At all times relevant to this Complaint, Heepke was 

not registered with the Commission in any capacity. 

24. Erik Matz, age 44, is a resident of Hicksville, New York.  From approximately 

1996 to 2006, Erik Matz was associated with a number of broker-dealers as a registered 

representative and has held Series 7 and 63 licenses.  On February 20, 2007, Erik Matz was 

barred from the brokerage industry in all capacities for engaging in excessive trading and 

churning in customer accounts in violation of Section 10(b) of the Securities Exchange Act of 

1934, Rule 10b-5 thereunder, and NASD Rules 2310(a), 2120, and 2110.  Dep’t of Enforcement 

v. Matz, 2007 WL 1434907, at *1 (NASDR) (Feb. 20, 2007).  Between approximately February 

and June 2014, Erik Matz worked at Elite Stock Research, and since mid-2014, he has controlled 

Power Traders Press along with Hardy.  At all times relevant to this Complaint, Erik Matz was 

not registered with the Commission in any capacity.  

25. Sergio Ramirez, age 44, is a resident of East Meadow, New York.  Ramirez has 

never been registered with the Commission in any capacity.  Ramirez worked at Elite Stock 

Research from approximately February to July 2014, when he left to work at Power Traders 

Press, where he is currently employed.  At all times relevant to this Complaint, Ramirez was not 

registered with the Commission in any capacity. 

26. Anthony Vassallo, age 54, is a resident of Smithtown, New York.  From 

approximately 1988 to 1994, Vassallo worked for a number of broker-dealers as a registered 

representative.  During that time, Vassallo held Series 7 and 63 licenses.  On May 26, 1995, the 

United States District Court for the Southern District of New York permanently enjoined 

Vassallo from violations of the registration, antifraud, and penny stock provisions of the Federal 



11 
 

securities laws in SEC v. Olsen Laboratories, Inc., No. 94-CV-06280 (S.D.N.Y. May 26, 1995).  

In a related administrative proceeding, on June 13, 1995, Vassallo consented to an order barring 

him from association with a broker, dealer, investment adviser, municipal securities dealer or 

investment company and barring him from participating in a penny stock offering.  On July 12, 

2013, Vassallo was sanctioned by the State of Connecticut Department of Banking for violations 

of the antifraud and registration requirements of the State of Connecticut.  Vassallo has 

controlled the Elite Stock Research boiler room since approximately January 2014.  At all times 

relevant to this Complaint, Vassallo was not registered with the Commission in any capacity. 

27. Dennis J. Verderosa, age 66, is a resident of Coram, NY.  Verderosa passed the 

Series 63 exam in 1996.  Verderosa worked at Elite Stock Research from approximately January 

to May 2014, when he left to work at Power Traders Press.  At all times relevant to this 

Complaint, Verderosa was not registered with the Commission in any capacity. 

RELIEF DEFENDANTS 

28. Janine Acosta, age 51, is a resident of Freeport, New York.  Acosta served as a 

secretary and administrative assistant at Power Traders Press.  Acosta received at least $70,000 

in proceeds from the Federal securities law violations alleged in this Complaint, including 

payments from Power Traders Press bank accounts in which such proceeds were held, in 

exchange for no consideration and without any legitimate claim to those funds. 

29. Antos Inc. is a New York entity, incorporated on September 16, 2016.  Ashley 

Antos is listed as the contact who will accept process for Antos Inc., and he endorses checks 

written by Power Traders Press to this entity.  Antos Inc. received at least $7,500 in proceeds 

from the Federal securities law violations alleged in this Complaint, including payments from 



12 
 

Power Traders Press bank accounts in which such proceeds were held, in exchange for no 

consideration and without any legitimate claim to those funds. 

30. Brittney Ballestas, age 25, is a resident of North Bellmore, NY.  Power Traders 

Press used a brokerage account held by Ballestas to engage in manipulative trading as part of the 

Federal securities law violations alleged in this Complaint.  Ballestas received at least $50,000 in 

proceeds from the Federal securities law violations alleged in this Complaint, including 

payments from Power Traders Press bank accounts in which such proceeds were held and the 

proceeds of Power Traders Press’s manipulative trading, in exchange for no consideration and 

without any legitimate claim to those funds. 

31. BCBall, Inc. (“BCBall”) is a New York entity incorporated by Ballestas on 

September 8, 2016.  Ballestas is President of BCBall and is the sole signatory on BCBall’s bank 

accounts.  BCBall received at least $227,000 in proceeds from the Federal securities law 

violations alleged in this Complaint, including payments from Marketbyte LLC and Trade 

Masters Pro.com, Inc. bank accounts in which such proceeds were held, in exchange for no 

consideration and without any legitimate claim to those funds. 

32. Big Little Consulting, Inc. (“Big Little Consulting”) is a New York entity 

incorporated on June 16, 2016.  Joseph Matz is the President of Big Little Consulting.  Big Little 

Consulting, Inc. received at least $2,049,250 in proceeds from the Federal securities law 

violations alleged in this Complaint, including payments from Marketbyte LLC bank accounts in 

which such proceeds were held, in exchange for no consideration and without any legitimate 

claim to those funds.  

33. Dacona Financial LLC (“Dacona Financial”) is a Wyoming entity incorporated 

on March 22, 2013, and is an alias of Power Traders Press.  Dacona Financial shares the same 



13 
 

address as Power Traders Press, and Power Traders Press’s telephone lines are registered to 

Dacona Financial.  Erik Matz is a signatory on the Dacona Financial bank account.  Dacona 

Financial was administratively dissolved by the state of Wyoming as of May 9, 2015, for a tax 

delinquency.  Dacona Financial received at least $1,100,000 in proceeds from the Federal 

securities law violations alleged in this Complaint, including payments from Marketbyte LLC 

and Type A Partners, Inc. accounts in which such proceeds were held and the proceeds of Power 

Traders Press’s manipulative trading, in exchange for no consideration and without any 

legitimate claim to those funds. 

34. DJV Enterprises, Inc. (“DJV Enterprises”) is a New York entity incorporated by 

Verderosa on January 6, 2015.  Verderosa is President of DJV Enterprises and is the sole 

signatory on the entity’s bank account.  DJV Enterprises received at least $75,400 in proceeds 

from the Federal securities law violations alleged in this Complaint, including payments from 

Power Traders Press accounts in which such proceeds were held, in exchange for no 

consideration and without any legitimate claim to those funds. 

35. Gabron Transport Corp. (“Gabron”) is a New York entity incorporated on April 

17, 2015.  Hardy is the President of Gabron and is a signatory on its bank account.  Gabron 

received at least $147,000 in proceeds from the Federal securities law violations alleged in this 

Complaint, including payments from Power Traders Press accounts in which such proceeds were 

held, in exchange for no consideration and without any legitimate claim to those funds. 

36. Melissa Kurtzke, age 29, is a resident of Franklin Square, New York.  Power 

Traders Press used a brokerage account held by Kurtzke to engage in manipulative trading as 

part of the Federal securities law violations alleged in this Complaint.  Kurtzke received at least 

$60,000 in proceeds from the Federal securities law violations alleged in this Complaint, 



14 
 

including payments from Dacona Financial accounts in which such proceeds were held and the 

proceeds of Kurtzke’s manipulative trading, in exchange for no consideration and without any 

legitimate claim to those funds. 

37. Leecorp, Inc. (“Leecorp”) is a New York entity, incorporated on August 25, 

2016.  Cohen endorsed checks written by Power Traders Press to this entity.  Leecorp received at 

least $48,900 in proceeds from the Federal securities law violations alleged in this Complaint, 

including payments from Power Traders Press accounts in which such proceeds were held, in 

exchange for no consideration and without any legitimate claim to those funds. 

38. Marketbyte LLC (“Marketbyte”) is a California entity incorporated on January 

25, 2000.  Isen is the President of Marketbyte and a signatory on its bank accounts.  Isen used 

Marketbyte in at least two of the boiler room schemes, to, among other things, facilitate 

payment, including through the transfer of shares, to the Elite Stock Research and Power Traders 

Press boiler rooms.  Marketbyte received at least $286,000 in proceeds from the Federal 

securities law violations alleged in this Complaint, including the proceeds of Isen’s manipulative 

trading, in exchange for no consideration and without any legitimate claim to those funds. 

39. Hermann Matz, age 71, is a resident of Hicksville, New York.  Hermann Matz is 

the father of Erik Matz.  Power Traders Press used a brokerage account held by Hermann Matz 

to engage in manipulative trading as part of the Federal securities law violations alleged in this 

Complaint.  Hermann Matz received at least $205,000 in proceeds from the Federal securities 

law violations alleged in this Complaint, including payments from Type A Partners, Inc. 

accounts in which such proceeds were held and the proceeds of Power Traders Press’s 

manipulative trading, in exchange for no consideration and without any legitimate claim to those 

funds. 



15 
 

40. Joseph Matz, age 39, is a resident of Hicksville, New York.  Joseph Matz is the 

brother of Erik Matz.  Joseph Matz received at least $964,000 in proceeds from the Federal 

securities law violations alleged in this Complaint, including payments from Marketbyte 

accounts in which such proceeds were held, in exchange for no consideration and without any 

legitimate claim to those funds. 

41. MKKMMKKM, Inc. (“MKKMMKKM”) is a New York entity incorporated on 

October 6, 2014.  Kurtzke is the sole signatory on MKKMMKKM’s bank account.  

MKKMMKKM received at least $130,000 in proceeds from the Federal securities law violations 

alleged in this Complaint, including payments from Dacona Financial accounts in which such 

proceeds were held, in exchange for no consideration and without any legitimate claim to those 

funds. 

42. MyStreetResearch.com, Inc. (“MyStreetResearch.com”) is a New York entity 

incorporated on August 17, 2016.  It is an alias of Power Traders Press.  MyStreetResearch.com 

shares an office address with Power Traders Press, and MyStreetRearch.com, Inc., shares a 

phone number with Power Traders Press’s alias, Trade Masters Pro.  MyStreetResearch.com 

received at least $78,000 in proceeds from the Federal securities law violations alleged in this 

Complaint, including payments from Marketbyte accounts in which such proceeds were held, in 

exchange for no consideration and without any legitimate claim to those funds. 

43. Price Point Consulting, Inc. (“Price Point Consulting”) is a New York entity 

incorporated on August 1, 2016.  Heepke has endorsed checks written by Power Traders Press to 

this entity.  Price Point Consulting received at least $10,500 in proceeds from the Federal 

securities law violations alleged in this Complaint, including payments from Power Traders 



16 
 

Press accounts in which such proceeds were held, in exchange for no consideration and without 

any legitimate claim to those funds.  

44. PTP Construction Corp. (“PTP Construction”) is a New York entity 

incorporated on June 25, 2015.  Hardy is President of PTP Construction and is the sole signatory 

on the entity’s bank account.  PTP Construction received at least $181,750 in proceeds from the 

Federal securities law violations alleged in this Complaint, including payments from Power 

Traders Press accounts in which such proceeds were held, in exchange for no consideration and 

without any legitimate claim to those funds. 

45. Revolving Ventures LLC (“Revolving Ventures”) is a Wyoming entity, 

incorporated on May 12, 2016.  Hardy is the sole member of Revolving Ventures, and the sole 

signatory on its bank account.  Revolving Ventures LLC received at least $441,000 in proceeds 

from the Federal securities law violations alleged in this Complaint, including payments from 

Trade Masters Pro and Marketbyte accounts in which such proceeds were held, in exchange for 

no consideration and without any legitimate claim to those funds. 

46. RKRG Inc. (“RKRG”) is a New York entity incorporated on October 3, 2014.  

Hardy’s spouse is a signatory on the RKRG bank account.  RKRG received at least $76,900 in 

proceeds from the Federal securities law violations alleged in this Complaint, including 

payments from Power Traders Press accounts in which such proceeds were held, in exchange for 

no consideration and without any legitimate claim to those funds. 

47. Snap or Tap Productions, LLC (“Snap or Tap Productions”) is a California 

entity incorporated on January 27, 2011.  Gleckman is the President of Snap or Tap Productions 

and the sole signatory on its bank account.  Snap or Tap Productions realized at least $174,000 in 

proceeds from the Federal securities law violations alleged in this Complaint, including the 



17 
 

proceeds of Gleckman’s manipulative trading, in exchange for no consideration and without any 

legitimate claim to those funds. 

48. Soccerserge, Inc. (“Soccerserge”) is a New York entity incorporated on August 

22, 2016.  Ramirez endorses checks written by Power Traders Press to this entity.  Soccerserge 

received at least $6,945 in proceeds from the Federal securities law violations alleged in this 

Complaint, including payments from Power Traders Press accounts in which such proceeds were 

held, in exchange for no consideration and without any legitimate claim to those funds. 

49. Strategic Capital Markets, Inc. (“Strategic Capital Markets”) is a Florida entity 

incorporated on August 23, 2013.  Lee incorporated Strategic Capital Markets, and Lee served as 

Strategic Capital Markets’ initial Secretary, with Chartier serving as President.  Lee has also 

served as Strategic Capital Markets’ Vice President during the relevant period.   Lee and Chartier 

had authority over a trading account in the name of Strategic Capital Markets that they used for 

manipulative trading in connection with at least two of the pump-and-dump schemes alleged in 

this Complaint.  Strategic Capital Markets realized at least $1,485,000 in proceeds from the 

Federal securities law violations alleged in this Complaint, including the proceeds of Lee’s and 

Chartier’s manipulative trading, in exchange for no consideration and without any legitimate 

claim to those funds.   

50. TradeMastersPro.com, Inc. (“Trade Masters Pro”) is a New York entity 

incorporated on April 28, 2016, and it is an alias of Power Traders Press.  Trade Masters Pro 

shares the same address as Dacona Financial and Power Traders Press, and the phone lines used 

by Trade Masters Pro are registered to Power Traders Press’s alias, Dacona Financial.  Trade 

Masters Pro received at least $1,440,300 in proceeds from the Federal securities law violations 



18 
 

alleged in this Complaint, including payments from Marketbyte accounts in which such proceeds 

were held, in exchange for no consideration and without any legitimate claim to those funds. 

51. Trademasters Consulting Inc. (“Trademasters Consulting”) is a New York 

entity, incorporated on June 14, 2016.  Hardy is the President of Trademasters Consulting and 

the sole signatory on its bank account.  Trademasters Consulting received at least $302,500 in 

proceeds from the Federal securities law violations alleged in this Complaint, including 

payments from Marketbyte accounts in which such proceeds were held, in exchange for no 

consideration and without any legitimate claim to those funds. 

52. Type A Partners, Inc. (“Type A Partners”) is a Florida entity incorporated on 

September 5, 2013.  Lee incorporated Type A Partners, and Lee serves as its President and 

Secretary.  Lee had authority over the Type A Partners’ trading accounts that he used for 

manipulative trading in connection with at least two of the schemes alleged in this Complaint.  

Type A Partners realized at least $3,000,000 in proceeds from the Federal securities law 

violations alleged in this Complaint, including the proceeds of Lee’s manipulative trading, in 

exchange for no consideration and without any legitimate claim to those funds. 

53. Terryville Systems, Inc. (“Terryville Systems”) is a New York entity 

incorporated on December 1, 2015.  Hardy is President of Terryville Systems and is the sole 

signatory on its bank account.  Terryville Systems received at least $90,000 in proceeds from the 

Federal securities law violations alleged in this Complaint, including payments from Marketbyte 

accounts in which such proceeds were held, in exchange for no consideration and without any 

legitimate claim to those funds. 

54. Trek Partners LLC (“Trek Partners”) is a Nevada entity incorporated on 

September 21, 2015.  Watts serves as President of Geoserve Marketing LLC, a member of Trek 



19 
 

Partners, and is a signatory on Geoserve Marketing LLC’s bank account.  Trek Partners received 

at least $100,000 in proceeds from the Federal securities law violations alleged in this 

Complaint, including payments from Power Traders Press accounts in which such proceeds were 

held, in exchange for no consideration and without any legitimate claim to those funds. 

ISSUERS 

55. CES Synergies, Inc. (“CESX”) is a Florida corporation headquartered in Crystal 

Springs, Florida.  CESX’s common stock (ticker symbol “CESX”) is registered under 12(g) of 

the Exchange Act, and is currently quoted on the OTC Link.  During the pump-and-dump 

scheme alleged in this Complaint, CESX’s securities qualified as a “penny stock” because they 

did not meet any of the exceptions from the definition of a “penny stock,” as defined by Section 

3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder.  Among other things, the securities 

were equity securities: (1) that were not an “NMS stock,” as defined in 17 C.F.R. § 

242.600(b)(47); (2) traded below five dollars per share during the relevant period; (3) whose 

issuer had net tangible assets and average revenue below the thresholds of Rule 3a51-1(g)(1); 

and (4) did not meet any of the other exceptions from the definition of “penny stock” contained 

in Rule 3a51-1 under the Exchange Act. 

56. National Waste Management Holdings, Inc. (“NWMH”) is a Florida 

corporation headquartered in Hernando, Florida.  NWMH’s common stock (ticker symbol 

“NWMH”) is registered under 12(g) of the Exchange Act, and is currently quoted on the OTC 

Link.  During the pump-and-dump scheme alleged in this Complaint, NWMH’s securities 

qualified as a “penny stock” because they did not meet any of the exceptions from the definition 

of a “penny stock,” as defined by Section 3(a)(51) of the Exchange Act and Rule 3a51-1 

thereunder.  Among other things, the securities were equity securities: (1) that were not an “NMS 



20 
 

stock,” as defined in 17 C.F.R. § 242.600(b)(47); (2) traded below five dollars per share during 

the relevant period; (3) whose issuer had net tangible assets and average revenue below the 

thresholds of Rule 3a51-1(g)(1); and (4) did not meet any of the other exceptions from the 

definition of “penny stock” contained in Rule 3a51-1 under the Exchange Act. 

57. Hydrocarb Energy, Corp. f/k/a Duma Energy Corp. (“DUMA”) was a Nevada 

corporation headquartered in Houston, Texas.  HECC’s common stock (ticker symbol “HECC”) 

was previously registered under 12(g) of the Exchange Act, and was previously quoted on the 

OTC Link using the ticker symbol (“HECCQ”).   On April 16, 2016, HECC filed for Chapter 11 

bankruptcy protection, and later amended its filing to Chapter 7.  Following the bankruptcy, the 

stock traded under the ticker symbol “HECCQ.”  On June 22, 2017, an initial decision of an 

administrative law judge dated April 5, 2017 revoking, pursuant to Exchange Act Section 12(j), 

the registration of each class of securities of HECC became final.  During the pump-and-dump 

scheme alleged in this Complaint, HECC’s securities qualified as a “penny stock” because they 

did not meet any of the exceptions from the definition of a “penny stock,” as defined by Section 

3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder.  Among other things, the securities 

were equity securities: (1) that were not an “NMS stock,” as defined in 17 C.F.R. § 

242.600(b)(47); (2) traded below five dollars per share during the relevant period; (3) whose 

issuer had net tangible assets and average revenue below the thresholds of Rule 3a51-1(g)(1); 

and (4) did not meet any of the other exceptions from the definition of “penny stock” contained 

in Rule 3a51-1 under the Exchange Act. 

58. Intelligent Content Enterprises Inc. (“ICEIF”), currently known as Novicius 

Corp., is a corporation incorporated under the laws of Ontario, Canada with its principal place of 

business in Toronto, Ontario.  ICEIF’s common stock is registered under 12(g) of the Exchange21 
 

Act, and during the scheme alleged herein, was quoted on the OTC Link under the ticker symbol 

“ICEIF.”  During the pump-and-dump scheme alleged in this Complaint, ICEIF’s securities 

qualified as a “penny stock” because they did not meet any of the exceptions from the definition 

of a “penny stock,” as defined by Section 3(a)(51) of the Exchange Act and Rule 3a51-1 

thereunder.  Among other things, the securities were equity securities: (1) that were not an “NMS 

stock,” as defined in 17 C.F.R. § 242.600(b)(47); (2) traded below five dollars per share during 

the relevant period; (3) whose issuer had net tangible assets and average revenue below the 

thresholds of Rule 3a51-1(g)(1); and (4) did not meet any of the other exceptions from the 

definition of “penny stock” contained in Rule 3a51-1 under the Exchange Act. 

GLOSSARY OF TERMS USED IN THIS COMPLAINT 

59. A “buy limit” order is an order to purchase a security at or below a certain price.  

Instead of paying market price for the security, the buyer sets the price that he or she is willing to 

pay for a certain number of shares.  The buyer is guaranteed to pay that price or less because the 

order is executed only when the seller’s price matches the amount set by the buyer.  If the 

specified price is never met, the order is not filled. 

60. “Marking-the-close” is a form of market manipulation that involves attempting to 

influence the closing price of a security by executing purchase or sale orders at or near the close 

of normal trading hours.  Such activity can artificially inflate or depress the closing price for the 

security. 

61. A “matched trade” is an order to buy or sell securities that is entered with 

knowledge that a matching order on the opposite side of the transaction has been or will be 

entered for the purpose of (1) creating a false or misleading appearance of active trading in any 

publicly traded security; or (2) creating a false or misleading appearance with respect to the 



22 
 

market for any such security. 

62. “Scalping” is a fraudulent practice of promoting third parties to purchase a 

security without disclosing that the promoter had some financial interest in that security, such as 

receiving compensation from the issuer for promoting the security, or owning that security and 

then selling it contemporaneous with the promotional activity to profit from the market activity 

that follows the promotion.   

63. A “sell limit” order is an order to sell a security at or above a certain price.  

Instead of taking market price for a security, the seller sets the price at which he or she is willing 

to sell a certain number of shares.  The seller is guaranteed to sell at or above the specified price 

because the order is executed only when a buyer matches the seller’s price.  If the specified price 

is never matched, the order is not filled. 

64. A “wash sale” is an order to buy or sell securities resulting in no change of 

beneficial ownership for the purpose of (1) creating a false or misleading appearance of active 

trading in any publicly traded security; or (2) creating a false or misleading appearance with 

respect to the market for any such security.   

FACTUAL ALLEGATIONS 
 

I. Overview Of The Boiler Rooms’ Operations 

 Elite Stock Research’s Boiler Room Operations A.

65. Elite Stock Research was incorporated in August 2013, and during the relevant 

period, it operated out of its headquarters in Plainview, New York.  Vassallo is the chief 

executive officer of Elite Stock Research, and he controls its operations.  Vassallo has trading 

authority over the Elite Stock Research brokerage accounts and signatory authority over Elite 

Stock Research’s bank account.  The Orchestrator Defendants, including Lee, paid Vassallo in 



23 
 

cash for his services.  Vassallo also received proceeds from the sale of securities promoted by the 

firm.  Between January 2014 and January 2016, Vassallo received more than $250,000 in checks 

and direct withdrawals from Elite Stock Research’s bank account. 

66. According to its website, Elite Stock Research provides investors with “top 

quality trade recommendations and . . . research that you can trust.”  However, Elite Stock 

Research operated as a boiler room, employing numerous individuals and using 19 different 

telephone lines, to artificially increase the price of certain microcap securities via manipulative 

trading and strong-arm, fraudulent promotional campaigns (“pump” or “pumping”).  From 2014 

until at least 2015, Elite Stock Research pumped at least two securities, CESX and HECC, 

through aggressive promotional activity and executed hundreds of manipulative trades, including 

matched and wash trades, to artificially inflate the price of the securities that Elite Stock 

Research was paid to promote.  During this time period, the firm received more than $1 million 

in illegal trading profits.  

67. Elite Stock Research employed Erik Matz, Hardy, Heepke, Verderosa, Ramirez, 

and Antos as “sales” personnel to aggressively promote securities as part of the fraudulent 

schemes alleged in this Complaint.  Between 2014 and 2015, these Defendants called numerous 

victims promoting at least CESX and HECC in furtherance of the pump-and-dump schemes and 

employed many of the strong-arm, fraudulent promotional tactics alleged in this Complaint.   

68. In addition, Heepke engaged in at least one wash trade of CESX, and Vassallo 

executed at least 17 matched trades with Elite Stock Research’s victims in furtherance of the 

pump-and-dump schemes alleged in this Complaint.  

69. Between 2014 and 2015, Elite Stock Research paid Erik Matz, Hardy, Heepke, 

Verderosa, Ramirez, and Antos more than $448,000 in salary and commissions.  



24 
 

70. At all times relevant to this Complaint, Elite Stock Research, Erik Matz, Hardy, 

Heepke, Vassallo, Verderosa, Ramirez, and Antos were not registered in any capacity with the 

Commission.  Nonetheless, Erik Matz, Hardy, Heepke, Vassallo, Verderosa, Ramirez, and Antos 

were acting as brokers engaged in the business of effecting transactions in securities for the 

accounts of others.  At all relevant times, they directly solicited potential investors to purchase 

securities, provided advice concerning the value of such securities, the advisability of investing 

in these securities, and received transaction-based compensation from the promotion of such 

securities.  

B. Power Traders Press’s Boiler Room Operations 

71. In early to mid-2014, Erik Matz and Hardy founded Power Traders Press after 

leaving Elite Stock Research.  Since at least 2014, Power Traders Press operates its boiler room 

out of its headquarters in Melville, New York.  Erik Matz and Hardy control its operations.  Erik 

Matz has trading authority over Power Traders Press’s brokerage account at Broker-Dealer A 

and signatory authority over two of its bank accounts.  Hardy has signatory authority over one of 

Power Traders Press’s bank accounts.  Erik Matz and Hardy manage the hiring and payment of 

Power Traders Press’s employees.  Erik Matz and/or Hardy have also been the primary contacts 

with the Orchestrator Defendants who hired Power Traders Press to promote certain securities, 

and they have coordinated payments between the Orchestrator Defendants and Power Traders 

Press. 

72. The Orchestrator Defendants pay Power Traders Press in cash deposited to bank 

accounts controlled by Erik Matz and Hardy (or their affiliates), and through shares of the 

securities that Power Traders Press has been paid to promote.  Erik Matz and Hardy transfer 

these trading profits into bank accounts that they (or their affiliates) controlled, and, at times, 

they withdrew large sums of cash from Power Traders Press’s bank accounts.  Between 2014 and 



25 
 

the present, Matz and Hardy have transferred $3.9 million in profits from their fraudulent trading 

to accounts that they control.  

73. As of December 2015, Power Traders Press’s website claimed it offered “top 

notch, detailed, unbiased financial research,” and on its affiliated website, 

MyStreetResearch.com, it claims to provide “unbiased stock recommendations that are accurate, 

detailed and objective.”  However, Power Traders Press operates as a boiler room, employing 

over 20 individuals to pump microcap securities via manipulative trading and strong-arm, 

fraudulent promotional activity.  Since at least 2014, Power Traders Press inflated the prices of at 

least four securities, NWMH, CESX, HECC, and ICEIF, through aggressive promotional activity 

– including using over 20 telephone lines to make hundreds of thousands of calls – and executing 

hundreds of manipulative trades – including matched trades, wash trades, and by marking-the-

close – to artificially inflate the price of the securities that Power Traders Press has been paid to 

promote.  During this time period, Power Traders Press has received at least $11 million in 

fraudulent proceeds, including more than $5 million in trading profits and at least $6 million in 

cash payments for promoting these securities. 

74.  Power Traders Press has used at least 14 trading accounts to execute the 

manipulative trades.  Power Traders Press and its aliases such as Dacona Financial own certain 

of these accounts; others are registered in the names of individuals including Erik Matz, Antos, 

Hermann Matz, Kurtzke, Ballestas, and a relative of Heepke, but Power Traders Press controls 

these accounts, as they have been frequently accessed from Internet Protocol (“IP”) addresses 

registered to Power Traders Press and/or its aliases.  

75.  Power Traders Press employees Antos, Cohen, Heepke, Ramirez, and Verderosa 

as “sales” personnel to aggressively promote securities as part of the pump-and-dump schemes 



26 
 

alleged in this Complaint.  Since 2014, Antos, Cohen, Heepke, Ramirez, and Verderosa have 

called numerous victims, including sometimes from their personal cell phones, promoting at least 

NWMH, CESX, HECC, and ICEIF in furtherance of the pump-and-dump schemes and 

employed many of the strong-arm, fraudulent promotional activity alleged in this Complaint.   

76. In addition, on numerous occasions, Antos, Heepke, and Erik Matz signed into 

their personal trading accounts through IP addresses registered to Dacona Financial, an alias of 

Power Traders Press, to engage in matched and wash trades of the securities promoted by Power 

Traders Press.   

77. Since 2014, Power Traders Press has paid Antos, Cohen, Heepke, Ramirez, and 

Verderosa at least $850,000 in salary and commissions. 

78. At all times relevant to this Complaint, Power Traders Press, Antos, Cohen, 

Heepke, Ramirez, and Verderosa, were not registered in any capacity with the Commission.  

Nonetheless, Antos, Cohen, Heepke, Ramirez, and Verderosa were acting as brokers engaged in 

the business of effecting transactions in securities for the accounts of others.  At all relevant 

times, they directly solicited potential investors to purchase securities, provided advice 

concerning the value of such securities and the advisability of investing in these securities, and 

received transaction-based compensation. 

II. The CESX Scheme 

79. CESX, formerly known as Green Living Concepts, Inc., was formed in 2010 and 

is headquartered in Crystal Springs, Florida.  On November 1, 2013, Chartier was appointed 

Director of CESX, a position he still holds.  CESX identified Lee as an investor contact in 

several press releases during the relevant period. 



27 
 

A. Lee and Chartier Acquired CESX Shares  

80. On or around September 2013, Strategic Capital Markets, Lee, and Chartier began 

accumulating large quantities of CESX stock, including 1,925,000 restricted shares from CESX.  

81. In December 2013, Lee and Chartier opened a brokerage account in the name of 

Strategic Capital Markets at Broker-Dealer A and, in January 2014, Lee opened a second account 

at Broker-Dealer A in the name of Type A Partners.  Between January and March 2014, Lee and 

Chartier deposited more than 600,000 shares of CESX into the Strategic Capital Markets and 

Type A Partners accounts at Broker-Dealer A. 

82.   On January 2, 2014, Lee e-mailed Broker-Dealer A regarding the deposit of 

CESX shares, copying Chartier, and asked “what else is needed to get the stock cleared and the 

shares into the account so we can start putting some limit orders in and get the stock trading?”  

On March 14, 2014, Defendant Lee again e-mailed Broker-Dealer A and pressed the brokerage 

to deposit the shares quickly because “[w]e are starting a program and [would] be putting many 

orders in.”   

B.  In March 2014, Lee Engaged Elite Stock Research to Inflate CESX’s Stock 
Price 

83. In March 2014, Lee, through Type A Partners, entered into an agreement with 

Vassallo, through Elite Stock Research, to raise “investor-awareness” concerning CESX.  

Pursuant to the agreement, Type A Partners gave Elite Stock Research 250,000 shares of CESX.  

In April 2014, Vassallo deposited 225,000 of the CESX shares into an account in the name of 

Elite Stock Research at Broker-Dealer A.   

84. In the months leading up to March 2014, there was little, if any, trading in CESX 

stock.  On March 12, 2014, the closing price of CESX was $1.35 per share. 



28 
 

85.   In March 2014, Elite Stock Research’s trading account, controlled by Vassallo, 

executed a series of matched trades in CESX, sometimes involving Strategic Capital Markets, an 

entity controlled by Lee and Chartier, for the purpose of fraudulently generating market activity 

and inflating the price of CESX.  For example:  

a. On March 21, 2014, at 2:36 p.m., Elite Stock Research purchased 50,000 

shares of CESX for $1.00 per share, and, at 2:46 p.m., Strategic Capital 

Markets sold 50,000 shares of CESX for $0.97 per share.  Over the next 

several days, Elite Stock Research engaged in numerous purchases and 

sales to drive up the price of CESX, and on March 26 and 27, 2014, Elite 

Stock Research engaged in several matched sales of these shares with its 

victims.  This manipulative trading activity resulted in a fraudulent 

increase in the price of CESX stock and, by close of trading on March 27, 

2014, CESX’s stock had risen to $2.40 per share. 

b. On April 8, 2014, between 9:22 a.m. and 2:02 p.m., Elite Stock Research 

entered 12 separate limit orders resulting in the purchase of 18,700 shares 

of CESX for between $2.15 and $2.47 per share.  On the same date, 

between 9:18 a.m. and 2:33 p.m., Elite Stock Research entered nine 

separate limit orders resulting in the sale of a total of 54,225 shares of 

CESX for between $2.00 and $2.45 per share.  

86. When engaging in this trading of CESX stock, Elite Stock Research, Vassallo, 

Lee, and Chartier knew, or were reckless in not knowing, that this closely coordinated trading in 

a thinly traded stock in accounts they controlled had no economic purpose, but was entered into 



29 
 

for the purpose of creating a false appearance of active trading and/or raising CESX’s price to 

fraudulently induce others to trade in CESX stock as part of their scheme to defraud investors.   

87. Elite Stock Research’s manipulative trading was also coordinated with a 

fraudulent, strong-arm promotional campaign by Elite Stock Research that often targeted senior 

citizens and unsophisticated investors to purchase CESX.  Elite Stock Research aggressively 

called victims to pressure them to purchase CESX.  For example, Elite Stock Research called 

Victim A 29 times between March and April 2014, including three times on April 14, 2014, the 

date on which Victim A purchased 12,500 shares of CESX.   

88. Vassallo and Hardy directly solicited victims while coordinating trading through 

Elite Stock Research’s trading account.  For example, between March and May 2014, Hardy 

persuaded Victim B to invest almost $100,000 in CESX.  On March 27, 2014, after speaking 

with Hardy, Victim B purchased 5,600 shares of CESX at 3:26 p.m., and, at the same time, 

Vassallo, through Elite Stock Research, sold 5,600 shares of CESX, followed by additional sales 

by Elite Stock Research that day that totaled 26,600 shares and yielded $59,848 in trading 

proceeds.   

89. While promoting CESX to Victim B, Hardy failed to disclose that Elite Stock 

Research had a financial interest in CESX.  Hardy knew, or was reckless in not knowing, that his 

firm had such a financial interest and the purpose of his promotional activity was to inflate the 

price of CESX stock while his firm was selling it for a profit.  Elite Stock Research also paid 

Hardy for these solicitations.   

90. Hardy’s omissions were material because they concealed his and Elite Stock 

Research’s self-interests in recommending CESX stock, information a reasonable investor would 

want to know when deciding whether to purchase CESX stock. 



30 
 

91. Between March and May 2014, Elite Stock Research and Strategic Capital 

Markets executed more than 250 trades in CESX in an effort to artificially inflate the trading 

volume and price of the security, and Elite Stock Research and Strategic Capital Markets 

dumped more than 550,000 shares of CESX, generating millions of dollars in fraudulent profits. 

92. This and other trading involving Elite Stock Research had dramatic effects on 

CESX’s price and market volume.  On March 26, 2014, for example, CESX closed at $2.10 per 

share on trading volume of 78,840, an increase in volume of 1,300 percent from the previous 

day.  

C. In Mid-2015, Lee Also Engaged Power Traders Press to Inflate CESX   

93. Beginning in mid-2015, Lee paid Power Traders Press $195,000 to, among other 

things, promote CESX stock.    

94. By mid-2015, Power Traders Press, including Verderosa, solicited victims, 

including Victim C and Victim D, to purchase CESX, and closely coordinated those purchases 

with sales of CESX stock by Lee and Power Traders Press.  For example, on August 26, 2015, 

Verderosa called Victim D at 10:22 a.m., and at 10:25 a.m., Victim D began purchasing shares of 

CESX.  Similarly, Power Traders Press called Victim C at 9:59 a.m. and spoke with him until 

approximately 10:11 a.m.  At 10:15 a.m., Victim C began purchasing shares of CESX.  Victim C 

and Victim D purchased a total of 90,000 shares of CESX on August 26, 2015, representing 

more than 23 percent of the shares traded on that day.  On the same day, Power Traders Press 

and Type A Partners sold 125,500 shares of CESX, reaping profits of over $110,000.   

95. To induce Victim D to purchase CESX securities between June 2015 and August 

2016, Verderosa – who was the sole Power Traders Press employee who solicited Victim D  – 

falsely claimed that the stocks recommended by Power Traders Press, including CESX, were 



31 
 

“guaranteed winners,” and that, if Victim D followed his advice, Victim D would make “a 

million dollars by Christmas.”   

96. When making these statements, Verderosa knew, or was reckless in not knowing, 

that these statements were not true.  Further, Verderosa never told Victim D that Power Traders 

Press had a financial interest in the shares of CESX or that the firm was selling the shares at the 

same time that he was inducing the victims to purchase those same shares. Power Traders Press 

also compensated Verderosa for promoting CESX stock. 

97. The misrepresentations and omissions by Verderosa were material because they 

concerned the potential profitability of the stock and concealed his and the firm’s self-interest in 

recommending CESX stock, information a reasonable investor would want to know when 

deciding whether to purchase CESX stock. 

D.  Lee, Chartier, Vassallo, Elite Stock Research, and Power Traders Press 
Recognized Over $1.9 Million in Illegal Profits Selling CESX Shares 

98. Lee’s, Chartier’s, Vassallo’s, Elite Stock Research’s, and Power Traders Press’s 

manipulative trading and fraudulent promotional activity resulted in an artificial and significant 

increase in CESX’s share price.  Between March 21 and May 20, 2014, for example, the price of 

CESX increased from $1.50 to $2.30 per share, before plummeting to a price of $0.20 per share 

by the end of June 2014.  And between August 12 and September 14, 2015, the price of CESX 

increased from $0.60 to $1.97 per share, before dropping to a price of $0.38 per share by the end 

of December 2015.   

99. Once the price of the stock was artificially inflated, Lee, Chartier, Vassallo, Elite 

Stock Research, and Power Traders Press dumped their shares into the market, generating 

millions of dollars in illegal profits.  Between March and May 2014, Lee, Chartier, and Vassallo 

reaped over $1 million in CESX trading profits.  Between August and September 2015, Lee and 



32 
 

Power Traders Press generated more than $15,000 and $167,000, respectively, in illegal trading 

profits in CESX.  In total, between 2014 and 2015, Lee, Chartier, Vassallo, Elite Stock Research, 

and Power Traders Press realized more than $1.9 million in illicit trading profits, by selling more 

than 1.8 million shares of CESX.  

III. The NWMH Scheme  

100. NWMH, formerly known as Kopjaggers, Inc. (“Kopjaggers”), was incorporated 

in 2010 for the purpose of raising capital to buy and sell artwork.  In 2014, Kopjaggers created a 

subsidiary that entered into a reverse merger with a waste management company, Sand/Land of 

Florida Enterprises, Inc., changed its name to NWMH, effected a five-to-one forward stock split, 

and ceased all operations related to buying and selling artwork.   

101. In June 2014, effective on the closing date of the reverse merger, Defendant 

Chartier was appointed a Director, and in June 2015, he became President of NWMH. 

 Lee and Chartier Acquired NWMH Shares A.

102. Between 2014 and 2016, Lee and Chartier acquired more than 3.8 million shares 

of NWMH through private stock purchase agreements with NWMH.  In exchange for some of 

these shares, Lee and Chartier agreed to provide “investor relations” services to the company 

through Strategic Capital Markets, an entity that they controlled.  Also, in June 2014, Chartier 

entered into a stock purchase agreement with Kopjaggers Consulting LLC, whereby Chartier 

purchased more than 1.9 million shares of NWMH for $29,235.      

103. Lee and Chartier deposited the NWMH shares into accounts at Broker-Dealer A 

in the names of Type A Partners, Strategic Capital Markets, and Chartier. 



33 
 

 Lee and Chartier Engaged Power Traders Press to Inflate NWMH’s Stock B.
Price 

104. In early 2015, Lee and Chartier engaged Power Traders Press to promote NWMH.  

For its services, Power Traders Press received more than one million shares of NWMH, which it 

obtained through stock purchase agreements with Strategic Capital Markets, Type A Partners, 

and through private transactions with shareholders in which Lee acted as the “purchasers’ 

representative.”  Power Traders Press received these NWMH shares at little or no cost.   

105. Power Traders Press deposited its NWMH shares into brokerage accounts at 

Broker-Dealer A in the names of Power Traders Press, Dacona Financial, and Hermann Matz.   

106. In the months leading up to February 2015, there was little trading in NWMH.  In 

December 2014 and January 2015, for example, there was a total trading volume of only 21,800 

shares in NWMH.   

107. Starting in February 2015, Power Traders Press and Stephanie Lee began 

manipulative trading in NMWH, through accounts in the name of Dacona Financial, Kurtzke, 

Hermann Matz, Type A Partners, and others.  In February 2015 alone, NMWH’s total trading 

volume ballooned to 733,172 shares. 

108. In all, from February 2015 to February 2016, Power Traders Press, through 

brokerage accounts in the names of Hermann Matz and Kurtzke, purchased over 2.4 million 

shares of NMWH and sold over three million shares of NMWH using hundreds of small-lot 

transactions, buy and sell limit orders, and matched and wash trades for the sole purpose of 

fraudulently generating market activity and inflating NWMH’s share price.  For example:  

a. On February 9, 2015, at 3:01 pm., Power Traders Press, through Hermann 

Matz’s brokerage account, purchased 4,500 shares of NWMH for $1.00 



34 
 

per share, and, at the same time, it sold 4,500 shares of NMWH for $1.00 

per share through Kurtzke’s brokerage account.   

b. On February 10, 2015, at 9:39 a.m., Power Traders Press, through 

Kurtzke’s brokerage account, bought 8,300 shares of NWMH for $1.00 

per share, and, at the same time, Lee, through Type A Partners’ account, 

sold the same number of shares at the same price.   

c. On March 23, 2015, at 2:15 p.m., Power Traders Press, through Hermann 

Matz’s account, sold 4,500 shares of NWMH for $1.62 per share and, at 

the same time, Power Traders Press, through Kurtzke’s account, purchased 

the same number of shares at the same exact price.   

109. When engaging in this trading of NWMH stock, Power Traders Press and Lee 

knew, or were reckless in not knowing, that this closely coordinated trading involving a thinly 

traded stock in accounts that they controlled had no economic purpose, but was entered into for 

the purpose of creating a false appearance of active trading and/or raising NWMH’s price to 

fraudulently induce others to trade in NWMH stock as part of their scheme to defraud investors.  

110. Power Traders Press’s and Lee’s manipulative trading was also coordinated with 

a fraudulent, strong-arm promotional campaign by Power Traders Press, including by Erik Matz, 

Heepke, and Verderosa, that targeted senior citizens and unsophisticated investors to purchase 

NWMH stock.   

111. From February 2015 until February 2016, Power Traders Press, Erik Matz, 

Heepke, and Verderosa called numerous victims to purchase NWMH stock, and the victims’ 

purchases were often matched with sales by certain Defendants in furtherance of the scheme.  

For example:  



35 
 

a. On February 13, 2015, Erik Matz spoke with Victim E  at 11:25 a.m., 

12:27 p.m., and 12:58 p.m.  At 12:53 p.m. and 12:57 p.m., in two 

transactions, Victim E purchased a total of 10,000 shares of NMWH.  

Also at 12:53 p.m. and 12:57 p.m., Power Traders Press, through Hermann 

Matz’s and Kurtzke’s accounts, almost exactly matched Victim E’s 

purchase, with each account selling 5,000 shares of NWMH for the same 

price.   

b. On March 25, 2015, at 10:02 a.m., Power Traders Press called Victim F, 

who at 10:19 a.m. purchased 36,950 shares of NWMH for $1.64 per share.  

Then at 2:27 p.m., Power Traders Press called Victim G who, between 

2:29 p.m. and 3:16 p.m., purchased 13,050 shares of NWMH for between 

$1.65 and $1.67 per share.  On this same day, Lee, Chartier, and Power 

Traders Press purchased and sold more than 125,000 shares of NMWH. 

c. From June to September 2015, Verderosa persuaded Victim D to purchase 

over 200,000 shares of NMWH.  Power Traders Press and Verderosa 

coordinated many of Victim D’s purchases with sales of NMWH from 

accounts under Power Traders Press’s and Lee’s control.  For example, on 

June 26, 2015, Power Traders Press called Victim D several times, and at 

12:31 p.m., Victim D purchased 5,000 shares of NWMH for $1.73 per 

share.  On or about that same time, Lee, through Type A Partners, sold 

5,000 shares of NMWH for $1.73 per share.  Also on this day, Power 

Traders Press, through Hermann Matz’s and Kurtzke’s accounts, sold over 

10,000 shares of NMWH.      



36 
 

d. On November 16, 2015, at 9:28 a.m., Heepke called Victim H who, at 

9:42 a.m., while still on the phone with Heepke, placed a limit order to 

purchase 21,500 shares of NWMH for $1.24 per share.  Only minutes 

later, at 9:56 a.m., Power Traders Press, through the Hermann Matz and 

Kurtzke accounts, engaged in a matched trade of 2,900 shares of NWMH 

at a price of $1.27 per share.   

112. When promoting NWMH stock to Victims D, E, F, G, and H, Power Traders 

Press, Heepke, Erik Matz, and Verderosa failed to disclose that Power Traders Press had a 

financial interest in NWMH.  Power Traders Press, Heepke, Erik Matz, and Verderosa knew, or 

were reckless in not knowing, that Power Traders Press had such a financial interest and the 

purpose of their promotional activity was to inflate the price of NWMH stock while the firm was 

selling it for a profit.  Lee, Chartier, and/or Power Traders Press paid Heepke, Erik Matz, and 

Verderosa for promoting NWMH stock.  

113. These omissions were material because they concealed Power Traders Press’s, 

Heepke’s, Erik Matz’s, and Verderosa’s self-interests in recommending NWMH stock, 

information a reasonable investor would want to know when deciding whether to purchase 

NWMH stock. 

114. Antos was also working for Power Traders Press at the time, and she made 

material misstatements to investors when promoting NWMH.  In or around December 2015, 

Antos promoted NWMH to Victim I by stating that the price of NWMH would increase to 

between $3.00 and $5.00 per share.  On January 20, 2016, Victim I purchased 1,000 shares of 

NWMH.  



37 
 

115. When making this statement, Antos knew, or was reckless in not knowing, that it 

was not possible to guarantee that a stock will increase in price.  Further, Antos knew that Power 

Traders Press paid her to promote NWMH and other microcap stocks in which the firm had a 

financial interest, such that she could not have not reasonably or genuinely believed that his 

statement to Victim I was true.   

116. Antos’s misstatement was material because it concerned the expected value of 

NWMH’s stock, information a reasonable investor would want to know when deciding whether 

to purchase NWMH stock. 

117. While Power Traders Press was pumping NWMH stock, Lee and Chartier were 

conducting their own promotional activity for NWMH through Internet television programs and 

news releases.  For example, an Internet television program featuring Chartier disseminated three 

newsletters about his appearances from February to April 2015.  In addition, a NWMH press 

release, issued on March 5, 2015, identified Lee as NWMH’s investor contact.  

118. In addition, in October 2015, Strategic Capital Markets paid $10,000 to an 

investor relations firm, and on November 16, 2015, NWMH issued a press release announcing its 

financial results for the third quarter of 2015 and providing a business update.  On that day, at 

9:28 a.m., Power Traders Press called Victim H who, at 9:42 a.m., while still on the phone with 

Power Traders Press, placed a limit order to purchase more than 21,500 shares of NWMH for 

$1.24 per share.  Only minutes later, at 9:56 a.m., Power Traders Press, through the Hermann 

Matz and Kurtzke accounts, sold 2,900 shares of NWMH at a price of $1.27 per share.   

119. As a result of this promotional activity and manipulative trading on November 16, 

2015, NWMH’s trading volume was 338,625 shares, an increase of 1,375 percent from the 



38 
 

previous day, and between November 16 and November 18, 2015, the price of NWMH increased 

from $1.22 to $1.41 per share.   

120. Furthermore, Chartier and Lee communicated regularly with Erik Matz and 

Power Traders Press throughout the time Power Traders Press was pumping NWMH stock.  On 

several occasions, these communications corresponded with matched trading among these 

parties.  For example, on September 30, 2015, Chartier and Power Traders Press exchanged 

phone calls at 2:35 p.m. and 2:37 p.m.  That same day, Power Traders Press, through Kurtzke’s 

account, and Lee and Chartier, through Strategic Capital Markets’ account, engaged in matched 

trading with Power Traders Press’s victims’ purchases of NWMH, including a matched trade 

between Victims J and K and Strategic Capital Markets at 3:13 p.m.  

121. When engaging in this trading of NWMH stock, Power Traders Press, Lee, and 

Chartier knew, or were reckless in not knowing, that this closely coordinated trading involving a 

thinly traded stock in accounts that they controlled had no economic purpose, but was entered 

into for the purpose of creating a false appearance of active trading and/or raising NWMH’s 

price to fraudulently induce others to trade in NWMH stock as part of the scheme to defraud 

investors.  

 Lee, Chartier, and Power Traders Press Recognized Over $5 Million in C.
Illegal Profits Selling NWMH Shares 

122. Between February 1, 2015 and February 5, 2016, Lee, Chartier, and Power 

Traders Press, realized over $5 million in fraudulent trading profits through the sale of over 3.6 

million shares of NWMH.   

123. Between February 2015 and February 5, 2016, NWMH’s share price fluctuated 

between $0.99 and $1.85.  By the end of February 2016, however, the scheme had concluded, 

and NWMH’s share price plummeted to $0.45 per share.  



39 
 

IV. The HECC Scheme 

124. At all relevant times, HECC, formerly known as Duma Energy Corp., was an oil-

and-gas company headquartered in Houston, Texas, and traded on the OTC Bulletin Board.  

Between 2010 and 2016, Watts’s brother controlled HECC and served as its chairman, chief 

executive officer, and chief financial officer.    

A. In 2014, Isen, Watts, and Gleckman Acquired HECC Shares  

125. In mid-2014, Watts and Gleckman acquired large blocks of HECC shares through 

entities that they controlled.  Geoserve Marketing LLC (“Geoserve Marketing”), which was 

controlled solely by Watts, and Snap or Tap Productions, which was controlled solely by 

Gleckman, acquired HECC shares via consulting agreements with HECC.  Isen assisted 

Gleckman in depositing HECC shares into Gleckman’s brokerage account, and also acquired 

shares for himself via a June 1, 2014 agreement between Isen’s entity, Marketbyte, and Geoserve 

Marketing.   

B.  Isen, Watts, and Gleckman Engaged Power Traders Press to Inflate HECC’s 
Stock Price 

126. Starting in or about August 2014, Watts, through Geoserve Marketing, engaged 

Power Traders Press to promote HECC’s stock through several agreements whereby Geoserve 

Marketing gave 625,000 HECC shares and $660,000 to Power Traders Press in exchange for the 

firm’s consulting services.  In addition, Gleckman paid Power Traders Press approximately 

$350,000 for purported “PR services” related to HECC stock.  Isen also facilitated Power 

Traders Press’s receipt and deposit of HECC shares into brokerage accounts at Broker-Dealer A. 

 Isen, Watts, Gleckman, and Power Traders Press Fraudulently Promoted C.
and Manipulated the Price of HECC Stock 

127. Between approximately mid-2014 and February 2016, Power Traders Press, 

through Verderosa and others, engaged in a fraudulent campaign to promote HECC stock that 



40 
 

involved calls to thousands of potential victims, and it artificially inflated the price of HECC 

through matched and wash trades designed to make it appear that the stock was actually trading 

at a higher price and volume.     

128.   Trading records reflect over 100 examples of Power Traders Press’s matched or 

washed trades in HECC shares.  For example, on October 14, 2015, between 9:34 a.m. and 3:03 

p.m., Power Traders Press, through Hermann Matz’s account, entered 15 orders to purchase a 

total of 7,000 shares of HECC and five orders to sell a total of 7,000 shares of HECC. 

129. Watts also engaged in washed trading of HECC through two brokerage accounts 

that he controlled.  For example, on June 12, 2014, at 3:53 p.m., Watts sold 800 shares of HECC 

for $4.15 per share through an account held at Broker-Dealer B.  Three minutes later, Watts 

purchased 105 shares for $4.24 per share through an account held at Broker-Dealer C. 

130. When engaging in this trading of HECC stock, Power Traders Press and Watts 

knew, or were reckless in not knowing, that this closely coordinated trading involving a thinly 

traded stock in accounts that they controlled had no economic purpose, but was entered into for 

the purpose of creating a false appearance of active trading and/or raising HECC’s price to 

fraudulently induce others to trade in HECC stock as part of the scheme to defraud investors. 

131. This manipulative trading of HECC stock was coordinated with a fraudulent 

promotional campaign by Power Traders Press, including through Antos, Heepke, Hardy, and 

Verderosa.  For example:  

a. On September 9, 2015, Verderosa called Victim D and spoke with her from 

11:04 to 11:11 a.m.  At 11:08 a.m., Victim D purchased 4,100 shares of 

HECC for $1.52 a share while – at the same time – Power Traders Press 

sold the same amount of shares at the exact price from the Kurtzke account.41 
 

b. In November 2015, Hardy called Victim L and recommended HECC.  On 

November 16, 2015, Hardy wrote to Victim L, “As per our discussion 

definitely get some HECC limit $1.03. Let me know how much you pick up.  

I like to keep good notes, so I know exactly how much were [sic] making 

you.”  Victim L responded: “I put a limit order in for 1000 shares at $1.03.  

I’ll pick up a couple more thousand shares tomorrow too.  I need to shift 

some funds into my trading account.”  That same day, Power Traders Press, 

through the Hermann Matz and Kurtzke accounts, bought 44,400 shares of 

HECC and sold 36,800 shares of HECC. 

c. On November 24, 2015, at 9:27 a.m., Heepke called Victim H and spoke 

with him until 9:51 a.m.  Between 9:51 a.m. and 12:29 p.m., Victim H 

purchased 55,000 shares of HECC for between $0.99 and $1.00 per share.  

At the same time, between 9:30 a.m. and 3:59 p.m., Power Traders Press, 

through the Hermann Matz and Kurtzke accounts, purchased and sold more 

than 50,000 shares of HECC.  The next day, Victim H purchased an 

additional 25,800 HECC shares for between $1.24 and $1.38 per share, and 

the Hermann Matz and Kurtzke accounts purchased and sold over 40,000 

shares for between $1.04 and $1.39 per share.  

d. On December 17, 2015, Antos called Victim M, after which Victim M 

purchased 5,000 shares of HECC for between $1.65 and $1.68 per share.  

On the same date, Power Traders Press, through the Hermann Matz and 

Kurtzke accounts, engaged in seven separate transactions in HECC, 



42 
 

including at 3:34 p.m., when Kurtzke bought 1,300 shares for $1.67 per 

share and Hermann Matz sold 1,300 shares of HECC for $1.67 per share. 

132. While promoting HECC stock and, in some cases, ensuring the precise amount of 

stock that their victims’ purchased, Power Traders Press, Antos, Heepke, Hardy, and Verderosa 

knew, or were reckless in not knowing, that Power Traders Press was engaging in manipulative 

trading in the same stock they were promoting.  These Defendants knew, or were reckless in not 

knowing, that Power Traders Press paid them for promoting HECC stock, that the purpose of 

their promotional activity was to create market activity for HECC as well as inflate the price, 

and, on many occasions, contemporaneously sell it for a profit.  These Defendants failed to 

disclose Power Trader Press’ financial interests in HECC to Victims D, H, L, and M.  Power 

Traders Press also compensated Antos, Heepke, Hardy, and Verderosa for promoting HECC 

stock.  

133. These omissions by Power Traders Press, Antos, Heepke, Hardy, and Verderosa 

were material because they concealed their and the firm’s self-interests in recommending HECC 

stock, information a reasonable investor would want to know when deciding whether to purchase 

HECC stock. 

134. Power Traders Press, Erik Matz, Watts, and Gleckman also coordinated its HECC 

sales with Power Traders Press’ fraudulent promotional campaign.  From August 2014 through 

February 2016, trading records reveal dozens of examples where accounts controlled by Watts 

and Gleckman sold HECC shares at the same time that Power Traders Press was engaging in a 

fraudulent promotional campaign, including sales that coordinated with Verderosa’s solicitations 

of Victim D.  For example:  



43 
 

a. On August 31, 2015, at 2:00 p.m., Power Traders Press called Victim E, 

who, at 2:20 p.m., placed a buy limit order to purchase 450 shares of HECC 

for $1.75 per share.  At 2:39 p.m., Erik Matz spoke with Watts.  Shortly 

thereafter, at 3:01 p.m., Watts sold 600 shares of HECC at the same time 

and price that Victim E purchased HECC shares.      

b. On August 31, 2015, at 2:53 p.m., Power Traders Press called Victims N 

and O who placed a buy limit order to purchase 5,000 shares of HECC.  

Within an hour, at approximately 3:51 p.m., Gleckman sold 5,000 shares of 

HECC to Victims N and O for $1.77 per share. 

144. When engaging in this trading of HECC stock, Power Traders Press, Watts, 

Gleckman, and Matz knew, or were reckless in not knowing, that this closely coordinated trading 

in a thinly traded stock through accounts they controlled had no economic purpose, but was 

entered into for the purpose of creating a false appearance of active trading and/or raising the 

price of HECC’s stock to fraudulently induce others to trade in HECC stock as part of the 

scheme to defraud investors. 

135. By April 2016, following this manipulative trading campaign, the share price of 

HECC ultimately dropped to less than $0.10 per share.  During this time, Power Traders Press 

actively dissuaded victims from selling their HECC stock.  For example, on April 11, 2016, 

when Victim E expressed concerned that the share price of HECC was $0.07 and his investment 

had lost 96.13 percent of its value, Erik Matz wrote, “HECC is def. recoverable . . . [they] are 

still sitting on 3 million barrels in proven reserves or $120 mill at today[‘]s oil prices… IMO this 

may be the buy of a lifetime down here.”   



44 
 

136.  Although Erik Matz controlled Power Traders Press, he failed to tell Victim E 

that the firm paid him for promoting HECC stock or that the firm had a financial interest in the 

stock.    

137. When soliciting Investor E, Erik Matz knew, or was reckless in not knowing, that 

HECC was not the “buy of a lifetime,” and that he was promoting HECC stock because he was 

compensated for promoting the stock.  Erik Matz controlled Power Traders Press, a boiler room 

used as part of the scheme to defraud investors that was manipulating the share price of HECC, 

and he was paid to promote the security.  Erik Matz did not reasonably or genuinely believe that 

his statement was true.   

138. Erik Matz’s misrepresentations and omissions were material because they 

involved the expected profitability of HECC and concealed his and Power Traders Press’s self-

interests in recommending HECC stock, information a reasonable investor would want to know 

when deciding whether to purchase HECC stock.  

 Watts, Isen, Gleckman, and Power Traders Press Received Over $2 Million D.
in Illegal Profits Selling HECC Shares 

139. Power Traders Press’s, Antos’s, Hardy’s, Gleckman’s, Isen’s, Erik Matz’s, 

Verderosa’s, and Watts’s fraudulent promotional activity and manipulative trading artificially 

inflated the share price of HECC.  For example, between April 10, 2015, and December 9, 2015, 

HECC stock increased from $0.45 per share to $1.83 per share, with a peak price of $2.53 on 

November 30, 2015, before HECC filed for bankruptcy and the share price dropped to $0.01 per 

share by mid-2016.   

140. While the price of HECC stock was fraudulently inflated, Watts, Isen, Gleckman, 

Power Traders Press, and Erik Matz sold a significant amount of their shares into the market, 

generating a substantial profit.  In addition to receiving more than $1 million in cash 



45 
 

compensation from Geoserve Marketing and Gleckman, Power Traders Press realized 

approximately $175,000 in illegal trading profits by selling 175,000 shares of HECC between 

March and August 2015.  Between 2014 and 2016, Watts realized over $800,000 in HECC 

trading profits; Gleckman and his entity Snap or Tap Productions realized approximately 

$675,000 in HECC trading profits; and Isen and his entity Marketbyte realized over $350,000 in 

HECC trading profits.  Erik Matz realized approximately $13,000 in trading profits by selling 

almost 25,000 shares of HECC between November 2015 and January 2016.  Collectively, Watts, 

Isen, Gleckman, Power Traders Press, and Erik Matz realized over $2 million in fraudulent 

trading profits in HECC. 

V. The ICEIF Scheme 

141. ICEIF is a publicly traded OTC issuer headquartered in Toronto, Ontario.  

According to its press statements, ICEIF is an “emergent Media and Internet company that 

focuses on the experience of the website user.”   

 Isen Directed ICEIF Trades to Generate Money for Promotional Scheme  A.

142. In early 2016, Isen coordinated the trading of large quantities of ICEIF shares in 

Canadian brokerage accounts in the names of several foreign entities.   Canadian Resident A  

holds trading authority over several of these accounts.  Initially, Isen sought to trade directly in 

the accounts controlled by Canadian Resident A, but on March 2, 2016, Broker-Dealer D denied 

Canadian Resident A’s request to add Isen as an authorized trader.  Denied direct trading 

authority, Isen, through Canadian Resident A, instead directed several trades in ICEIF that 

resulted in enormous profits.   

 Isen Engaged Power Traders Press to Inflate ICEIF’s Stock Price B.

144. Between February 25, 2016, and March 4, 2016, Isen and Power Traders Press 

exchanged drafts of an ICEIF company profile in preparation for Power Traders Press to promote 



46 
 

ICEIF stock.  Isen paid Power Traders Press for its promotional activities from his trading profits 

in the Canadian accounts.  On March 16, 2016, bank accounts in the name of Canadian Resident 

A paid $224,690 to Isen’s entity, Marketbyte.  On March 17, 2016, Isen wired $76,500 to Power 

Traders Press and $126,000 to Power Traders Press’s affiliate Joseph Matz.  Other examples of 

this payment stream include: 

a. On March 22, 2106, Canadian Resident A paid Marketbyte $45,460 and 

on March 23, 2016, Isen wired $40,950 to Joseph Matz. 

b. On March 30, 2016, Canadian Resident A paid Marketbyte $43,260 and 

on March 31, 2016, Isen wired $39,000 to Power Traders Press. 

c. On or about April 6, 2016, Canadian Resident A paid Marketbyte $46,960 

and on April 7, 2016, Marketbyte wired $42,300 to Joseph Matz. 

d. This pattern of weekly payments in varying amounts between Isen’s entity 

Marketbyte and Power Traders Press and its affiliates continued through at 

least September 2016.  On average, Marketbyte’s payments to Power 

Traders Press and its affiliates amounted to approximately 90 percent of 

the payments Marketbyte received from Canadian Resident A. 

145. ICEIF was a thinly traded stock before Power Traders Press’s promotional 

campaign began.  In the two weeks leading up to March 7, 2016, its total trading volume was 

less than 2,000 shares.   

146. Beginning on March 7, 2016, shortly after being was engaged by Isen, Power 

Traders Press began using at least five brokerage accounts to manipulate ICEIF’s stock price and 

volume, including accounts in the names of Hermann Matz, Kurtzke, Ballestas, and Antos.   

Power Traders Press controlled these five accounts, and on March 7, 2016, began purchasing and 



47 
 

selling large blocks of ICEIF stock on the open market.  On March 7, 2016, the trading volume 

of ICEIF spiked to 158,169 shares. 

147. Between March 7, 2016 and July 25, 2016, Power Traders Press purchased more 

than 600,000 shares of ICEIF stock and sold more than 550,000 shares of ICEIF in hundreds of 

separate transactions.  Power Traders Press’s trades included repeated purchases and sales of 

ICEIF in small lots, matched trades with its victims’ purchases, and wash trades to artificially 

inflate the price of the stock.   

148. For example, by March 2016, Victim H gave Heepke the login information for 

Victim H’s online brokerage account.  On March 7, 2016, at 1:23 p.m., Heepke, logged into 

Victim H brokerage account from an IP address registered to Power Traders Press.  At 1:28 p.m., 

1:33 p.m., and 1:35 p.m., Heepke placed limit orders in Victim H’s account, resulting in the 

purchase of 9,600 shares of ICEIF for over $11,000 in Victim H’s account.  At 2:15 p.m., 

Heepke placed an additional limit order in Victim H’s account to buy 5,995 shares of ICEIF for 

$1.45 per share.  Simultaneously, Power Traders Press, through the Hermann Matz account, 

placed a limit order to sell 6,000 shares of ICEIF at 2:16 p.m.  At 2:16 p.m., Victim H purchased 

5,995 shares of ICEIF from Hermann Matz. 

149. Power Traders Press also artificially inflated the price of ICEIF by marking-the-

close, buying shares near the close of the market at 4:00 p.m., and executing matched trading 

between the firm and Antos.  For example, on June 7, 2016, Power Traders Press, through 

Kurtzke’s account, made the following purchases of ICEIF near the 4:00 p.m. close, resulting in 

an substantial increase in the closing price of the stock: 

 

 



48 
 

Time Quantity Price 
3:42:38 p.m. 2,000 shares $1.9577 
3:48:07 p.m. 2,800 shares $2.0500 
3:59:38 p.m. 500 shares $2.2000 
3:59:41 p.m. 100 shares $2.3000 
3:59:46 p.m. 100 shares $2.3000 
3:59:49 p.m. 800 shares $2.2770 

 

150. Antos engaged in matched trading in ICEIF.  On September 19, 2016, at 9:46 

a.m., Power Traders Press, through Ballestas’ brokerage account, purchased 459 shares of ICEIF 

at $0.48 per share and Antos sold 459 shares of ICEIF at $0.48 per share.     

151. When engaging in this trading of ICEIF stock, Power Traders Press and Antos 

knew, or were reckless in not knowing, that this closely coordinated trading in a thinly traded 

stock through accounts they controlled had no economic purpose, but was entered into for the 

purpose of creating a false appearance of active trading and/or raising the price of ICEIF’s stock 

to fraudulently induce others to trade in ICEIF stock as part of the scheme to defraud investors. 

152. At the start of the manipulation scheme, on March 7, 2016, Power Traders Press, 

including Heepke, Verderosa, Ramirez, and Cohen, also began a fraudulent, strong-arm 

promotional campaign to promote the sale of ICEIF stock to potential investors.  For example:   

a. On March 10, 2016, a Power Traders Press representative using a fake 

name, “John Gold,” called Victim N.  “Gold” followed up with an e-mail 

recommending ICEIF, telling Victim N to “put a limit to buy this one at 

$1.63 you’ll be glad you did.”  Victim N responded that he bought 1,000 

shares at $1.65. 

b. On April 29, 2016, Verderosa e-mailed Victim O regarding ICEIF and 

told her that his clients “are building BIG positions in this” and that she 

should contact him “BEFORE you buy it I will explain when you call!” 



49 
 

c. On May 27, 2016, Ramirez called Victim P.  Ramirez told Victim P  to 

purchase ICEIF, and, while on the phone with Ramirez, Victim P 

purchased 5,000 shares of ICEIF at $2.13 per share.  

d. On July 25, 2016, while on the phone with Cohen, Victim Q purchased 

6,000 shares of ICEIF for $0.90 a share at the same time that Power 

Traders Press, through the Hermann Matz account, sold the same amount 

of shares at the same price.  

e. On August 17, 2016, Cohen called Victim R six times between 8:34 a.m. 

and 10:29 a.m. at which time Victim R purchased 5,000 shares of ICEIF.   

153. Power Traders Press also employed strong-arm tactics to induce investors to 

purchase and hold ICEIF stock.  For example, Heepke told one victim who called to complain 

about ICEIF’s value, “I am tired of hearing from you.  Do you have any rope at home?  If so tie a 

knot and hang yourself or get a gun and blow your head off.”  

154. Power Traders Press, Heepke, Verderosa, Ramirez, and Cohen never told Victims 

N, O, P. Q, and R that Power Traders Press had a financial interest in the shares of ICEIF, that 

the firm was selling ICEIF shares at the same time that they were inducting these victims to 

purchase those same shares, or that Powers Traders Press paid Heepke Verderosa, Ramirez, and 

Cohen received compensation for promoting ICEIF stock. 

155. The omissions of Power Traders Press, Heepke, Verderosa, Ramirez, and Cohen 

were material because they concealed their self-interests in recommending ICEIF stock, 

information a reasonable investor would want to know when deciding whether to purchase 

ICEIF stock. 



50 
 

156. In addition to omitting material facts from their promotional activity, Power 

Traders Press, Ramirez and Cohen made material misrepresentations to investors as part of their 

aggressive cold-calling campaign.  

157. In or around April 2016, when encouraging Victim P to purchase ICEIF, Ramirez 

misrepresented that Power Traders Press was paid based on the sale of its “advisory services,” 

and failed to disclose that he received transaction-based compensation.   

158. When making these misstatements and failing to disclose material information, 

Ramirez knew, or was reckless in not knowing, that he was misleading Victim P.  During the 

relevant period, Ramirez received periodic paychecks from Power Traders Press that, at least at 

times, expressly indicated that the payment was for “commissions.” 

159. In September 2016, Cohen, using the alias “Ian Grant,” misrepresented to Victim 

R that “I put Twitter out as an OTC 8 years ago,” and claimed that ICEIF had “all the makings 

that a Twitter has and then some.”  Cohen also mispresented to Victim R that “Disney [had] 

bought into ICEIF” and that it “had agreed to pick up 442,570 shares,” and that “with Disney 

backing them [ICEIF] now has got a lot of potential to go to two [dollars] very quickly.”  Cohen, 

who was 33 years old at the time, also claimed that he had 21 years of brokerage experience.   

160. When making these statements, Cohen knew, or was reckless in not knowing, that 

his statements about Twitter and Disney were not true.   He also used a false name to conceal his 

true identify from those he was defrauding.  Finally, he was only 33 years old at the time of his 

calls, and thus could not have reasonably worked as a broker for 21 years.  

161. Cohen’s and Ramirez’s misrepresentations were material because they concerned 

the nature, investment returns, and Cohen’s, Ramirez’s, and Power Traders Press’s self-interests 



51 
 

in recommending ICEIF stock, information a reasonable investor would want to know when 

deciding whether to purchase NWMH stock.  

162. Throughout Power Traders Press’s promotion of ICEIF stock in 2016, Isen 

communicated frequently with Power Traders Press by calling and emailing Erik Matz about the 

trading activity.  For example, on May 18, 2016, Isen sent Erik Matz the record of an internet 

chat involving discussions about increasing the price of ICEIF shares, and “confirm[ing] the 

limit” price of ICEIF sales.    

 The ICEIF Scheme Generated More Than $7.8 Million in Illegal Profits C.

163.  From March 7 to September 15, 2016, the share price of ICEIF fluctuated 

between $0.91 and $2.29 per share and, on some days, more than 50 percent of the trading 

volume in ICEIF was attributable to Power Traders Press’s promotional activity.  At the end of 

this promotional activity, the share price plummeted.  By January 2017, ICEIF closed at $0.11 a 

share.    

164. From March 7 to at least September 15, 2016, Isen reported that trading from 

various brokerage accounts generated at least $7.8 million in trading profits from the sale of over 

5 million shares of ICEIF.   

165. Between March 16, 2016 and December 15, 2016, Canadian Resident A wired 

Isen more than $3.5 million generated from ICEIF trading profits during Power Traders Press’s 

promotion of the stock.   

166. During this same time, Isen paid Power Traders Press and its affiliates at least 

$3.5 million generated from ICEIF trading profits in Canada.   

167. Isen, through Marketbyte, diverted these payments to multiple bank accounts, 

including the following entities controlled by Hardy:  Trademasters Consulting, Revolving 

Ventures, Terryville Systems, and Gabron.  Isen, through Marketbyte, also funneled additional 



52 
 

payments to other Power Traders Press affiliates, including Joseph Matz and his entity Big Little 

Consulting, Ballestas and her entity BC Ball, Inc. Mystreetresearch.com Inc., and 

Trademasterspro.com. 

FIRST CLAIM FOR RELIEF 
 

Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) Thereunder 
 

(Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, Hardy, 
Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 

 
168. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

169. By engaging in the acts and conducts alleged in this Complaint, Power Traders 

Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik 

Matz, Vassallo, Verderosa, and Watts, in connection with the purchase or sale of securities, 

directly or indirectly, singly or in concert, by the use of the means or instrumentalities of 

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

scienter, have employed devices, schemes, and artifices to defraud, and have engaged in 

transactions, acts, practices, and courses of business which operated as a fraud or deceit. 

170. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 

Watts, directly or indirectly, singly or in concert, have violated, and unless enjoined will 

continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) 

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

 

 

 



53 
 

SECOND CLAIM FOR RELIEF 

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

(Power Traders Press, Elite Stock Research, Antos,  
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa) 

 
171. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

172. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 

Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, in connection with the purchase or 

sale of securities, directly and indirectly, singly or in concert, by use of the means or 

instrumentalities of interstate commerce, or of the mails, or of the facilities of a national 

securities exchange as alleged in this Complaint, knowingly, willfully or recklessly made untrue 

statements of material facts and omitted to state material facts necessary in order to make the 

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

173. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly violated, and, 

unless enjoined, will to continue to violate, Section 10(b) and Rule 10b-5(b) of the Exchange Act 

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

THIRD CLAIM FOR RELIEF 

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

 (Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen, Gleckman, 
Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 

174. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

175. From at least March 2013 through the present, Power Traders Press, Elite Stock 

Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, 



54 
 

Verderosa, and Watts, directly or indirectly, singly or in concert, in the offer and sale of any 

securities, by the use of the means and instruments of transportation and communication in 

interstate commerce and of the mails, knowingly or with reckless disregard for the truth  

employed devices, schemes or artifices to defraud. 

176. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 

Watts, directly or indirectly, singly or in concert, have violated, and unless enjoined  will 

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

FOURTH CLAIM FOR RELIEF 

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

(Power Traders Press, Elite Stock Research, Antos, Chartier, Cohen,  
Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and Watts) 

 
177. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

178. From at least March 2013 through the present, Power Traders Press, Elite Stock 

Research, Antos, Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, 

Verderosa, and Watts, directly or indirectly, singly or in concert, in the offer or sale of any 

securities by the use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, negligently engaged in transactions, practices and 

courses of business which operated or would have operated as a fraud or deceit upon the 

purchasers and prospective purchasers of such securities. 

179. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Chartier, Cohen, Gleckman, Hardy, Heepke, Isen, Lee, Erik Matz, Vassallo, Verderosa, and 



55 
 

Watts, directly or indirectly, singly or in concert, have violated and unless enjoined will continue 

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

FIFTH CLAIM FOR RELIEF 
 

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

(Power Traders Press, Elite Stock Research, Antos,  
Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa) 

 
180. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

181. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 

Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly, knowingly 

or recklessly, singly or in concert in the offer or sale of securities, by use of the means or 

instruments of transportation or communication in interstate commerce and by the use of the 

mails, in the offer or sale of securities, with scienter have obtained money or property by means 

of untrue statements of material facts and omissions to state material facts necessary to make the 

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

182. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Cohen, Hardy, Heepke, Erik Matz, Ramirez, and Verderosa, directly and indirectly violated, and, 

unless enjoined, will continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 

77q(a)(2)]. 

SIXTH CLAIM FOR RELIEF 
 

Violations of Section 15(a) of the Exchange Act 
 

(Antos, Cohen, Hardy, Heepke, Erik Matz, Ramirez, Vassallo, and Verderosa) 
 

183. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein.  



56 
 

184. From certain times starting as early March 2013 through the present, Antos, 

Cohen, Hardy, Heepke, Erik Matz, Ramirez, Vassallo, and Verderosa, while acting as brokers 

engaged in the business of effecting transactions in securities for the account of others made use 

of the mails or the means or instrumentalities of interstate commerce to effect transactions in, or 

to induce or attempt to induce the purchase or sale of, a security without being registered in 

accordance with Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)]. 

185. By reason of the foregoing, Antos, Cohen, Hardy, Heepke, Erik Matz, Ramirez, 

Vassallo, and Verderosa have violated and, unless enjoined, will continue to violate, Section 

15(a) of the Exchange Act [15 U.S.C. § 78o(a)]. 

SEVENTH CLAIM FOR RELIEF 
 

Violations of Section 9(a)(1) of the Exchange Act 
 

(Power Traders Press, Elite Stock Research, Antos, Chartier,  
Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts) 

 
186. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

187. Since at least March 2013, Power Traders Press, Elite Stock Research, Antos, 

Chartier, Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts, directly or indirectly, singly 

or in concert, by use of the means or instruments of transportation or communication in, or the 

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

recklessly, and for the purpose of creating a false or misleading appearance of active trading in 

securities or a false or misleading appearance with respect to the market for such securities, (a) 

have effected transactions in such securities which involved no change in the beneficial 

ownership thereof; (b) have entered an order or orders for the purchase of such securities with 

the knowledge that an order or orders of substantially the same size, at substantially the same 



57 
 

time, and at substantially the same price, for the sale of any such securities, had been or would be 

entered by or for themselves or different parties; and/or (c) have entered, are entering, or are 

about to enter an order or orders for the sale of such securities with the knowledge that an order 

or orders of substantially the same size, at substantially the same time, and at substantially the 

same price, for the purchase of such securities had been or would be entered by or for themselves 

or different parties. 

188. By reason of the foregoing, Power Traders Press, Elite Stock Research, Antos, 

Chartier, Gleckman, Heepke, Lee, Erik Matz, Vassallo, and Watts, have violated, are violating, 

and unless restrained and enjoined, will again violate Section 9(a)(1) of the Exchange Act [15 

U.S.C. §78i(a)(1)]. 

EIGHTH CLAIM FOR RELIEF 
 

Violations of Section 9(a)(2) of the Exchange Act 
 

(Power Traders Press and Elite Stock Research) 
  
189. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

190. From at least March 2013 through the present, Power Traders Press and Elite 

Stock Research, directly or indirectly, by the use of the mails or any means or instrumentality of 

interstate commerce, or of any facility of any national securities exchange, with specific intent, 

effected, alone or with other persons, a series of transactions in a security other than a 

government security or in connection with any security-based swap agreement with respect to 

such security creating actual or apparent active trading in such security, for the purpose of 

inducing the purchase or sale of such security by others. 



58 
 

191. By reason of the foregoing, Power Traders Press and Elite Stock Research, have 

violated, are violating, and unless restrained and enjoined, will again violate Section 9(a)(2) of 

the Exchange Act [15 U.S.C. § 78i(a)(2)]. 

NINTH CLAIM FOR RELIEF 
 

Unjust Enrichment 

(Antos Inc., BCBall, Big Little Consulting, Dacona Financial,  
DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM,  
MyStreetResearch.com, Price Point Consulting, PTP Construction,  
Revolving Ventures, RKRG, Snap or Tap Productions, Soccerserge,  

Strategic Capital Markets, Terryville Systems, TradeMasters Consulting, 
TradeMastersPro.com, Trek Partners, Type A Partners,  

Acosta, Ballestas, Kurtzke, Hermann Matz, and Joseph Matz) 
 

192. The Commission realleges and incorporates by reference each and every 

allegation contained in paragraphs 1 through 167 as if fully set forth herein. 

193. 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.” 

194. As alleged in this Complaint, Antos Inc., BCBall, Big Little Consulting, Dacona 

Financial, DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM, 

MyStreetResearch.com, Price Point Consulting, PTP Construction, Revolving Ventures, RKRG, 

Snap or Tap Productions, Soccerserge, Strategic Capital Markets, Terryville Systems, 

TradeMasters Consulting, TradeMastersPro.com, Trek Partners, Type A Partners, Acosta, 

Ballestas, Kurtzke, Hermann Matz, and Joseph Matz received funds and property that were the 

proceeds, or are traceable to the proceeds, of the Defendants’ Federal securities law violations 

that are alleged in this Complaint.  Antos Inc., BCBall, Big Little Consulting, Dacona Financial, 



59 
 

DJV Enterprises, Gabron, Leecorp, Marketbyte, MKKMMKKM, MyStreetResearch.com, Price 

Point Consulting, PTP Construction, Revolving Ventures, RKRG, Snap or Tap Productions, 

Soccerserge, Strategic Capital Markets, Terryville Systems, TradeMasters Consulting, 

TradeMastersPro.com, Trek Partners, Type A Partners, Acosta, Ballestas, Kurtzke, Hermann 

Matz, and Joseph Matz had no legitimate claims to these proceeds, and gave no consideration in 

exchange for receipt of those funds. 

195. Antos Inc., BCBall, Big Little Consulting, Dacona Financial, DJV Enterprises, 

Gabron, Leecorp, Marketbyte, MKKMMKKM, MyStreetResearch.com, Price Point Consulting, 

PTP Construction, Revolving Ventures, RKRG, Snap or Tap Productions, Soccerserge, Strategic 

Capital Markets, Terryville Systems, TradeMasters Consulting, TradeMastersPro.com, Trek 

Partners, Type A Partners, Acosta, Ballestas, Kurtzke, Hermann Matz, and Joseph Matz obtained 

the funds and property alleged above as part of and in furtherance of the Federal securities law 

violations alleged in this Complaint and under circumstances in which it is not just, equitable, or 

conscionable for them to retain the funds and property.  They were unjustly enriched. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court issue a Final 

Judgment: 

I. 

 Finding that Defendants each violated the Federal securities laws and rules promulgated 

thereunder as alleged against them in this Complaint. 

II. 

 Permanently enjoining Defendants and their agents, servants, employees and attorneys 

and all persons in active concert or participation with them who receive actual notice of the 

injunction by personal service or otherwise, and each of them, directly or indirectly, from 



60 
 

committing future violations of each of the Federal securities laws and rules promulgated 

thereunder pursuant to Sections 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and/or Section 

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

III. 

 Ordering all Defendants and Relief Defendants to disgorge, on a joint and several basis, 

any and all ill-gotten gains they received as a result of the violations of the Federal securities 

laws alleged herein and the rules promulgated thereunder that are alleged in this Complaint, plus 

prejudgment interest thereon, pursuant to Section 21(d)(5) of the Exchange Act [15 U.S.C. § 

78u(d)(5)]. 

IV. 

 Ordering all 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)]. 

V. 

 Ordering all Defendants to be barred from participation in any offering of a penny stock, 

pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and/or Section 21(d)(6) of 

the Exchange Act [15 U.S.C. § 78u(d)(6)]. 

VI. 

 Ordering Chartier,  pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 

and/or Section 21(d)(2) of the Exchange Act [15 U.S.C.§ 78u(d)(2)], to be barred from serving 

as an officer or director of any issuer that has a class of securities registered with the 

Commission pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l], or that is required to 

file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)].VII.

Granting such other and further relief as the Court may deem just and proper.

Dated: July 12, 2017 Respectfully submitted,

~, /G ~~ t~~'.~'r~~.,_.
Derek Bentsen (DB83b9)
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION
100 F St., N.E.
Washington, D.C. 20549-5985
202-551-6426
BentsenD(a~sec.~ov

Matthew F. Scarlato (motion for admission
Pro Hac Vice pending)
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION
100 F St., N.E.
Washington, D.C. 20544-5985
202-551-3749
scarlatom @sec.gov

James E. Smith (motion for admission Pro
Hac Vice pending)
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION
100 F St., N.E.
Washington, D.C. 20549-59$5
202-551-5881
[email protected]

OF COUNSEL:

Scott W. Friestad
Amy Friedman
Cecilia Connor
Andrew Elliott
SECURITIES AND EXC~IAl~FGE
COMMISSION
100 F St., N.E.
Washington, D.C. 20549-5985

61