SEC v. THE MILAN GROUP, INC.; THE MILAN TRADING GROUP, INC.; FRANK L. PAVLICO III; BRYNEE K. BAYLOR; BAYLOR & JACKSON, P.L.L.C.; MIA C. BALDASSARI, et al., No. 3:07-cr-00052-JMM, District of Columbia (Dec. 6, 2011) — Complaint

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
SECURITIES 
AND EXCHANGE COMMISSION, 
100 F Street, N.E. 
Washington, DC 20549, 
Plaintiff, 
v. 
THE MILAN GROUP, INC., alkla THE MILAN 
TRADING 
GROUP, INC. 
113 Upland Terrace, Clarks Summit, P A 18411, 
FRANK L. PA VLICO III, a/k/a FRANK LORENZO 
113 Upland Terrace, Clarks Summit, P A 18411, 
BRYNEE K. BAYLOR 
13121 Riviera Terrace, Silver Spring, MD 20904, and 
BAYLOR & JACKSON, P.L.L.C. 
2607 24th Street, Suite 1, N.W., Washington, DC 20008 
Defendants, 
and 
MIA C .. BALDASSARI 
522 Shirley Lane, Dunmore P A 18512, 
ELMO BALDASSARI 
1360 Wyoming Avenue, Scranton, PA 18509, 
BRETT A. COOPER 
229 Carriage Hill Drive, Moorestown, New Jersey 08057, 
GLOBAL FUNDING SYSTEMS LLC 
12 Debrosses Street, New York, NY 10013, 
GPH HOLDINGS, LLC 
Case: 1: 11-cv-02132 
Assigned 
To: Collyer, Rosemary M. 
Assign. Date: 11/30/2011 
Description: TRO/PI 
COMPLAINT 
SECURITIES· 
FRAUD 
JURY TRIAL DEMANDED 

211 North Main Street, Lewiston, Utah 84320, 
DAWN R. JACKSON 
5705 Hillmeade Road, Bowie, MD 20720, 
PATRICK T. LEWIS 
570 South 250 East, Richmond, Utah 84333, 
SUSAN C. KEVRA-SHINER, a/k/a SUSAN C. KEVRA : 
748 Grove Street, AvocaPA 18641, 
THE LAW OFFICE OF SUSAN C. KEVRA 
748 Grove Street, Avoca PA 18641 
1 . Defendants. 
COMPLAINT 
Plaintiff Securities and Exchange Commission ("CommIssion") alleges as follows: 
SUMMARY 
1. From at least August 2010 and continuing to the date of the filing of this Complaint, 
defendants Frank L. Pavlico, III, a/kIa Frank Lorenzo, ("Pavlico") and Brynee K. Baylor 
("Baylor") _and entities they control, including defendants The Milan Group, Inc., a/k/a The 
Milan Trading Group, Inc., 
("Milan") and Baylor & Jackson, P.L.L.C. ("B&J"), conducted a 
"Prime Bank" scheme that defrauded at least thirteen investors out of approximately $2.1 
million. 
2. 
Pavlico and Baylor lured investors into the scheme by offering them extraordinary 
returns. In at least one instance, 
Pavlico offered returns of up to twenty times the original 
investment within forty-five days. Investors were told that the investment involved 
no risk and 
that their principal would 
be returned if a successful bank instrument transaction was not 
completed. Baylor cloaked these offers 
in legitimacy by acting through her capacity as a 
2 

licensed attorney and by identifying herself and her Washingt;on, D.C. law finn, B&J, as counsel 
for Milan and engaging in the scheme through B&J. 
3. Pavlico and Baylor told investors both orally and in writing that Milan would use 
investor funds to 
"lease," "leverage," and "trade" foreign bank instruments, including "standby 
letters of credit" and "bank guarantees." The Milan investment, however, was entirely fictitious. 
Pavlico and Baylor provided investors with investment contracts and other documents that 
described the investment in vague and complex tenus. These documents were only legal-
sounding gibberish dotted with meaningless legal and financial tenns that were designed to 
deceive investors into believing they were participants 
in a legitimate investment. Contrary to 
their representations, Pavlico and Baylor never used investor funds to lease, leverage, or trade 
any purported foreign bank instruments. Instead, 
Pavlico and Baylor used investor money to 
purchase luxury cars such as a Range Rover and a Jaguar, make purchases at expensive 
restaurants and retailers including Jimmy Choo, pay for a trip to the Bahamas, pay other personal 
expenses, pay B&J business expenses, and make payments to the relief defendants. 
4. Pavlico and Baylor made numerous material misrepresentations to investors in 
furtherance 
of the scheme. Most importantly, Pavlico and Baylor lied to investors about the 
existence 
of the supposed investment and the use of investor funds. Baylor falsely claimed that 
she had been involved in prior successful transactions with Milan and that she had personally 
witnessed prior investors receive large 
'returns through B&J's attorney trust ("IOLTA") account 
consistent with Pavlico;s representations. B&J participated 
in and aided and abetted the scheme 
by acting as escrow agent for Milan pursuant to written agreements between B&J and investors 
that Baylor executed 
as B&J's managing partner. At least seven investors deposited at least 
3 

$1.65 million into B&J's IOLTA account. In addition, agreements with investors provided that 
investment profits 
would be shared among investors, Milan, and B&J. 
5. 
Pavlico and Baylor are continuing to deceive investors about the status of their 
purported investments. 
Pavlico and Baylor have sent investors dozens of emails describing the 
progress 
of the supposed transaction, and Baylor has sent investors notarized "Attorney 
Attestation" 
letters on B&J letterhead assuring them that the investment is legitimate and will be 
consummated soon. Pavlico and Baylor have also sent investors fictitious computer generated 
"screen shots" and copies of purported foreign bank instruments to deceive them into believing 
that Milan has acquired bank instruments. 
6. No transactions in securities offered or sold by or for the defendants have been 
registered with the Commission, 
or are eligible for an exemption from registration. 
7. None 
of the defendants were registered as broker-dealers, as is required for offering 
securities to investors in these circumstances. 
8. 
By virtue of their conduct, the defendants have engaged, and unless enjoined will 
continue to engage, in violations of, or aid and abet violations of Sections 5(a), 5(c) and 17(a) of 
the Securities Actof 1933 (the "Securities Act") [15 U.S.C. §§ 77e(a), 77e(c) and 77q(a)], 
Sections 10(b) and 15(a) 
of the Securities Exchange Act of 1934 (the "Exchange Act") [15 
U.S.C. §§ 78j(b) and 780(a)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereund.er. 
JURISDICTION AND VENUE 
9. The Commission brings this action, and this Court has jurisdiction over 
this action, pursuant to authority conferred 
by Sections 20(b) and 22(a) of the 
Securities Act [15 
U.S.C. §§ 77t(b) and 77v(a)] and Sections 21(d), 21(e) and 27 
of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e) and 78aa]. 
4 

10. This Court has personal jurisdiction over the defendants and venue is 
proper 
in the District of Columbia pursuant to Section 20(b) of the Securities Act [15 U.S.C. § 
77t(b)] and Section 27 
of the Exchange Act [15 U.S.C. § 78aa] because each defendant engaged 
in transactions, acts, practices, and courses 
of business constituting the violations alleged herein 
within this District and two 
of the defendants can be found and do business in this District. 
11. The defendants, directly and indirectly, have made use 
of the means and 
instrumentalities of interstate commerce, and the means and instruments of transportation and 
communication 
in interstate commerce, in connection with the transactions, acts, practices, and 
courses 
of business alleged in this Complaint. 
DEFENDANTS 
11. Frank L. Pavlico, III, a!kIaFrank Lorenzo, age 41, is a resident of Clarks 
Summit, Pennsylvania and is the president of Milan. On February 8,2007, Pavlico pled guilty to 
felony conspiracy to conduct financial transactions involving the proceeds of drug trafficking. 
On January 16,2008, he was sentenced to ten months in prison, supervised release ofthree years, 
and fined 
$15,000. See USA v. Pavlico, No. 3:07-cr-00052-JMM-l, (M.D. Pa. Jan. 16,2008). 
While on supervised release he was prohibited from engaging in criminal conduct and 
associating with persons engaged in criminal activity. His supervised release ended on 
November 5, 2011. 
12. Brynee K. Baylor, age 37, is an attorney licensed in the District of Columbia, 
Maryland, and 
New Jersey. She is a resident of Silver Spring, Maryland and the co-founder and 
managing partner 
ofB&J in Washington, D.C. 
13. 
The Milan Group, Inc., a!kIa The Milan Trading Group, Inc., is a Pennsylvania 
corporation with its principal place 
of business at Pavlico's home address. 
5 

14. Baylor & Jackson, P.L.L.C. is a Washington, DC law finn with its principal 
place 
of business in Washington, D.C. 
RELIEF DEFENDANTS 
15. 
GPH Holding, LLC ("GPH") is an Idaho limited liability company with its 
principal place 
of business in Lewiston, Utah. GPH received at least $375,000 from the B&J 
IOLTA account. 
16. Global 
Funding Systems, LLC ("Global Funding") is a Wyoming limited 
liability company with its principal place 
of business in New York, New York. Global Funding 
received at least 
$225,000 from Milan. 
17. 
The Law Office of Susan C. Kevra is located in Avoca, Pennsylvania. The 
Law Office of Susan C. Kevra received at least $409,482 from Milan. 
18. 
Susan C. Kevra, a/k/a Susan C. Shiner ("Kevra"), age 43, is a resident of 
Avoca, Pennsylvania. Kevra received at least $10,000 from Milan. 
19. 
Dawn R. Jackson ("Jackson"), age41, is an attorney licensed· in the District of 
Columbia and New Jersey. She is a resident of Bowie, Maryland and a co-founder and partner 
ofB&J. Jackson received at least $153,000 from B&1's IOLTA and operating accounts. 
20. Mia C. Baldassari ("Baldassari"), age 46, is a resident of Dunmore, 
Pennsylvania. Baldassari is the vice president 
of Milan. Baldassari received at least $24,500 
from Milan. 
21. Elmo 
Baldassari is a resident of Scranton, Pennsylvania. Elmo Baldassari 
received at least 
$20,000 through a loan to Mia Baldassari. 
6 

22. Patrick T. Lewis ("Lewis"), age 41, is a resident of Lewiston, Utah. Lewis is 
the managing member 
of GPH. Investor funds received by GPH were transferred to other 
accounts believed to be owned 
or controlled by Lewis. 
23. Brett A. Cooper ("Cooper"), age 35, is a resident of Moorestown, New Jersey. 
Cooper is a managing member 
of Global Funding. Investor funds received by Global Funding 
were transferred to other accounts, including Cooper's personal accounts. 
FACTS 
A. 
The Defendants' Scheme to Defraud Investors 
24. Beginning in at least August 
2010 and continuing to the present, Pavlico and 
Baylor used the mail andwiresto·defraudatleast 
13 investorsoutof$2.1 million by offering 
them a fictitious investment that supposedly involved "leasing," "leveraging," and "trading" 
bank instruments. Several government agencies, including the Commission, the u.S. 
Department of the Treasury, and the Federal Bureau of Investigation, have posted investor alerts 
and warnings about 
fictitious "prime bank" investments on their publicly available websites. 
25. The investors are located in several states, including Califomia, Florida, New 
York, and Colorado. They generally have limited investment experience. 
26. The defendants promised investors extraordinary returns 
of up to twenty times the 
principal amount invested with little or no risk. To deceive them into believing the purported 
investment was legitimate, the defendants provided investors with documents containing 
meaningless legal-sounding terms and references to non-existent financial instruments and 
institutions. To fend 
off further inquiries, which might have provided information investors 
could have checked for themselves and found out about the fraud, investors were told that 
7 

confidentiality and secrecy requirements prevented the defendants from providing details of the 
investments. 
27. 
In furtherance of the scheme, Baylor used her position as an attorney and a 
partner in Washington, D.C. law firm B&J to deceive investors into believing that 
the Milan 
investment was legitimate and that investors' funds would 
be safe. She identified herself and her 
law firm as '"counsel" for Milan and, acting through B&J, she provided '"Attorney Attestation" 
letters to certain investors. B&J acted as escrow agent in connection with the scheme pursuant to 
written agreements between B&J and investors which Baylor executed as 
B&J's managing 
partner. She told investors that she had personally witnessed millions 
of dollars paid to investors 
through 
B&J's trust account, consistent with Pavlico's representations. In addition, Pavlico and 
Baylor directed at least seven investors to deposit approximately $1.65 million into B&J's 
IOL T A account. 
28. 
Pavlico deceived investors by using the name '"Frank Lorenzo" and by failing to 
disclose that he pled guilty to a felony, served 
10 months in prison, and was on supervised 
release at the time he was soliciting their investments. 
29. 
Pavlico and Baylor communicated frequently with investors by telephone, text 
message and email to provide them with updates about 
the. status of the purported investment. 
Baylor used her B&J e-mail address for nearly all 
of her written communications with investors, 
and forwarded investors dozens 
of emails from Pavlico through her B&J email account. Pavlico 
and Baylor used vague and complex terms in these communications to confuse investors, and 
claimed that confidentiality concerns prevented them from providing more fulsome details 
regarding the status 
of the investment. Pavlico and Baylor also provided investors with bogus 
excuses attempting to explain the delay in providing the promised returns including, among other 
8 

things, feigned illnesses, false representations that the European bankers supposedly involved in 
the transaction were on extended vacation, or that there were unspecified problems with 
processing 
the transactions through "Euroclear," a supposed necessary step in the transaction. 
As 
of the date of the filing of this Complaint, Pavlico and Baylor are continuing to mislead 
investors regarding the status 
of their supposed investment. 
30. In furtherance of the scheme, Pavlico and Baylor on several occasions provided 
investors with digitally created computer 
"screen shots" and copies of fictitious foreign bank 
instruments, which they tried to pass 
off as proof of th~ ongoing success of the transactions. 
Baylor sent these fictitious documents 
to investors using her B&J e-mail address. 
31. 
In reality, Pavlico, Baylor, Milan, and B&J never invested any of the money they 
received from investors, and instead misappropriated it for their own use and 
to make payments 
to the relief defendants. 
B. Pavlico's and Baylor's Material Misstatements and Omissions 
32. The defendants made numerous material omissions and omitted to state material 
facts 
in furtherance of the scheme. They solicited unsophisticated investors and promised them 
returns 
of up to twenty times the principal amount invested within as little as 45-60 days with no 
risk of loss. After receiving investors' funds, they continued to make material misstatements and 
omissions to investors about the status 
of their supposed investments to lull them into accepting 
long delays in realizing the promised returns. 
33. Pavlico represented to potential investors, both orally and in writing, that Milan 
. 
would use investor funds to "lease" bank instruments, including standby letters of credit, bank 
guarantees, and medium term notes. These instruments would then 
be "leveraged" to acquire 
9 

even larger instruments, which would be "monetized." The proceeds from this "monetization" 
would then be put into a foreign "private trading platform." 
34. Certain investors executed investment contracts with Pavlico on behalf of Milan. 
These contracts state that investor funds would 
be used to facilitate the leasing of bank 
instruments (standby letters 
of credit and bank guarantees) in connection with a "private 
placement investment." Certain contracts guaranteed that investors' principal would be returned 
in the event an instrument was 
not procured. 
35. 
Some investors also received "Irrevocable Profit Participation Agreements," 
which purported to apportion th.e profits from the non-existent bank instrument investment 
between and among Milan, B&J, and investors. 
36. Pavlico and Baylor promised investors exceptional returns, typically many 
multiples 
of the initial investment over a timeframe of just a few months. In at least one 
instance, Pavlico offered to lease a $10 million instrument 
in exchange for a $75,000 investment. 
Pavlico told the investor that the 
$10 million instrument would be leveraged into a $100 million 
instrument and that the proceeds from the larger instrument would 
be traded on a "private trading 
platform." He told the investor that this investment would return $1.5 million within 45-60 days. 
37. Pavlico promised another investor that the Milan investment would generate 
a· 
return of $250,000 every two weeks for forty weeks in exchange for an investment of$325,000. 
This represents a 1438% investment return purporting to produce total profits of $4,675,000. 
38. Pavlico promised another investor that the Milan investment would generate a 
return 
of $130,000 every week for forty weeks in exchange for an investment of $130,000. This 
represents a 
4000% investment return purporting to produce total profits of $5,070,000. 
10 

39. Baylor identified herself and her Washington, D.C. law finn as "counsel" for 
Milan. 
In her capacities as a licensed attorney and managing partner in B&J, Baylor assured 
investors that the Milan investment was legitimate and that their funds would 
be safe. For 
example, in an email to investors dated 
October 11,2010 sent from B&J's email account, Baylor 
stated falsely: 
I am writing to confinn the validity 
of the transaction that your client, [REDACTED] is 
involved in. First, I have observed this company successfully complete transactions 
of 
this nature whereby participants received their funds as agreed. Second, I have 
personally been involved in this transaction and can validate 
it as well as confinn the fact 
that the transaction is moving along very well. Although there was a delay 
in the initial 
upstart, this process is moving full speed again and I am most confident that you as well 
as your client will be pleased with the result. 
40. Certain investors executed escrow agreements with B&J, which Baylor executed 
on behalf 
ofB&J as its managing partner. Baylor also provided notarized "Attorney Attestation" 
letters on B&J letterhead verifying the legitimacy of the transaction. Baylor also represented that 
she had conducted a thorough background check on Pavlico, including consultation with the 
Chief of Police of Washington, D.C., and that she had found nothing of concern. 
41. Pavlico, who identified himself to investors as 
"Frank Lorenzo," never disclosed 
his real name to investors, or that 
he pled guilty in 2007 to felony conspiracy to conduct 
tranSactions involving the proceeds 
of drug trafficking, served ten months in prison, and was on 
supervised release when he was soliciting their investments. 
42. Contrary to their representations to investors, the defendants never used investor 
funds to lease any purported bank instruments or participate in any 
"private trading platfonn." 
The defendants never paid or intended to pay investors any money back or provide any returns 
on their investments. 
11 

43. Pavlico and Baylor, and through them, Milan and B&J, each knew or was reckless 
in not knowing that the investment offered was fictitious, and that each 
of the statements made in 
paragraphs 32 to 42 was materially false or misleading or omitted to state material facts which 
would make the statements they made not materially misleading. 
c. Pavlico's and Baylor's Misappropriation Of Investor Funds 
44. Contrary to their representations to investors that their funds would beused to 
lease purported bank instruments and to facilitate their participation in a foreign "private trading 
platform," Pavlico and Baylor misappropriated investors' funds to pay personal expenses. For 
example, 
Pavlico used investor funds to pay for lUxury cars such asa Range Rover and a Jaguar, 
and Baylor used investor funds to 
make purchases at  expensive restaurants and retailers 
including Jimmy Choo, and 
to pay for a trip to the Bahamas in September 2010. Pavlicoand 
Baylor also used investor funds to make payments 
to relief defendants. 
45. Between August 
31,2010 and January 19, 2011, at least seven investors deposited 
$1.73 million into 
B&J's bank accounts, $1.65 million of which was deposited into the law 
firm's 
IOLTA account. At least $1.1 million of those funds was used to pay Baylor's personal 
expenses, B&J business expenses, withdrawn as cash or transferred to Baylor's personal account, 
and transferred to relief defendants and other third parties. The remaining 
$631,000 paid by 
investors was transferred to Milan, predominantly from banking centers located in Washington, 
D.C. 
46. Milan received at least $991,000 of investor funds, either directly from investors 
or from 
B&J's IOLTA account. That money was used to pay Pavlico's personal expenses and 
transferred to the relief defendants. 
12 

47. None of the investors' money was used to "lease," "leverage," or trade any 
purported bank instruments. 
D. Pavlico and Baylor Continue to Deceive Investors about the Status of Their 
Purported Investments 
48. Since at least November 2010 and continuing through the date that this Complaint 
was filed, 
Pavlico and Baylor have deceived investors about the status of their purported 
investments. 
49. 
Pavlico and Baylor have each sent dozens of emails to investors that purported to 
describe the progress 
of the supposed investment. Many of Pavlico' s email updates were sent to 
Baylor, who then disseminated them to investors using B&J's email account. These emails 
typically offered bogus reasons for the delay in providing the promised returns andlor the 
inability to return the principal amount invested. 
50. For example, in an email to investors dated January 10, 2011, Pavlico stated 
[punctuation as 
per original]: 
I will have a full update later on today. I have spoken to 
Platform and the 
Director handling this file is flying into Heathrow today at 3pm, when the Bond 
issuance was signed the 
Platform in return needs to have HSBC sign the 
Undertaking letter witch in turns guarantees the 26Million in return 
Platform 
would not sign until all paperwork is done, it is and we need the undertaking letter 
signed today, hopefully 
by banker, this is why the Platform Director is flying in to 
London to give permission on next steps, I have told everyone that the Platform 
and Bankers do not return from Holiday until the 15th but the Platform asked for 
thereBanker to come back this week, he also has agreed to. 
So bottom line we 
need undertaking contract back and then they will swift over MT -760 and then 
in 
a 24 hour period we receive the instrument, I will confirm once Platform has done 
a call with the Lessor and myself at some point today. This is great news and I 
will update soon. 
51. In another email to investors, dated February 3, 2011, 
Pavlico stated [punctuation 
as per original]: 
13 

Please be advised that because the two sides are not agreeing on procedures to 
send and receive the 
200M instrument, both sides have agreed to do a test run on 
a smaller instrument of 10M usn Letter of Credit. This was given to us last 
evening from the owner, we are in receipt 
of the original copy signed by two bank 
officers and we all agreed on how this instiument will 
be authenticated and 
moved from National Australian Bank to Santander Bank. This procedure will 
be 
replicated in getting our instrument into the Platforms bank. I was also advised 
because 
of the time difference that both are ready and willing to send and receive 
the RWA from this point on. I will be notified when the instrument 
is received by 
Platform. When this happens, all will be identified to move forward in duplicating 
the procedures to send the 
200M Instrument over to Platform. This is the quickest 
mode 
of operation because both sides are willing to compromise through this 
method. 
[] I will update you as soon as I receive confirmation that the instrument 
has been received 
by the platform. Things are now ready to move forward and 
close this transaction out. 
52. Pavlico knew, 
or was reckless in not knowing, that the ''updates'' he provided 
investors materially misrepresented the status 
of the investment activities and omitted the 
material fact that none 
of the investor's monies were used in connection with leasing, leveraging, 
or trading bank instruments as represented. 
53. Baylor also sent numerous emails to investors from 
her B&J email account. 
purporting to report the status 
ofthe transactions. For example, in an email to investors August 
30,2011, Baylor stated: 
Please find attached the documents that relate to the bonds in this transaction. 
The bonds are listed with the National bank in Brazil and have been verified 
through the Brazilian government. Because the bonds have not matured yet, the 
valuation has to 
be determined by the attorneys through due diligence. Weare 
waiting for this information. David is flying to Paris and we are scheduled for 
a conference call this evening at 7pm 
EST. Please be judicious in who you send 
this to. As attorneys, I ask that you keep it confidential in order to protect the 
owners while this transaction is being completed. These documents can confirm 
the validity 
of this transaction that is set to close upon ascertainment of the value 
of the remaining instruments. 
54. Baylor executed numerous 
"Attorney Attestation Letters" to certain investors on 
B&J letterhead assuring them 
of the legitimacy of their investments and to provide them with an 
update regarding the status 
ofthe investments. For example, in a letter to an investor dated 
14 

January 20, 2011, Baylor stated: "This letter is to confinn that I am in receipt of a bank 
undertaking letter for funding. 
Our finn is expected to receive said funds by early to middle of 
next week. Upon receipt of the funds, all money will be placed in an escrow account and then 
dispersed to [the investor] as quickly as 
possible." 
55. Baylor also emailed investors copies of documents, certificates, and computer 
generated 
"screen shots" purporting to evidence instruments available for the investors. Baylor 
sent these emails using her B&J email address. 
56. 
At the time of writing such emails, forwarding Pavlico's updates, and transmitting 
documents purporting to evidence bank instruments and 
non-U.S. bonds, Baylor knew, or was 
reckless in not knowing, that the 
"updates" she provided materially misrepresented the status of 
the investment activities and omitted the material·fact that none of the investor's deposits were 
being used 
to secure the investments or the returns which had been represented to them by the 
defendants. 
E. Pavlico and Baylor Continue to Solicit New Investors. 
57. Pavlico and Baylor continue to actively solicit new investors and continue to 
communicate with existing investors with the intent 
of lulling them into believing their 
investments are proceeding as represented to them. As recently 
as September 2011, an 
individual wired 
$250,000 into the B&J escrow account which was forwarded, in part, to Milan. 
Also, in late 
September 2011 Milan paid $10,000 to "Susan Kevra Shiner Trust Account" by a 
check which appears to have been signed 
by Pavlico and states in the memo line, 
"Churchillll OM Euro SBLC." "SBLC" is an abbreviation for "standby letter of credit," a type of 
fictitious bank instrument similar to those offered to the investors alleged in this Complaint. 
F. Allegations Relating to Relief Defendants 
15 

58. From at least August 2010 through January 2011, the. defendants transferred over 
$1.2 million 
of investors' funds to the relief defendants. 
59. 
The defendants transferred at least $375,000 of investor funds to reliefdefendant 
GPH. GPH subsequently transferred these funds to accounts that are believed to be owned or 
controlled by relief defendant Lewis. Neither GPH nor Lewis provided any lawful services or 
products to any defendant or for the benefit of investors in the defendants' fraudulent scheme in 
return for these funds. 
60. The defendarits transferred at least $225,000 of investor funds to relief defendant 
Global Funding. Global Funding subsequently transferred the investor funds to accounts that are 
believed to 
be owned or controlled by relief defendant Cooper and/or his wife. Neither Global 
Funding 
nor Cooper provided any lawful services or products to any defendant or for the benefit 
of investors in the defendants' fraudulent scheme in return for these funds. 
61. The defendants transferred at least $409,482 to relief defendant 
The Law Office 
of Susan C. Kevra and at least $10,000 to the principal of that office, relief defendant Kevra,as a 
"loan." Neither Kevra nor her law offices provided any lawful services or products to any 
defendant or for the benefit of investors in the defendants' fraudulent scheme in return for these 
funds. 
62. 
The defendants transferred at least $153,000 to relief defendant Dawn Jackson. 
Jackson did not provide any lawful services 
or products to any defendant or for the benefit of 
investors in the defendants' fraudulent scheme in return for these funds. 
63. 
The defendants transferred at least $24,500 t6 relief defendant Mia Baldassari. 
Baldissari did not provide any lawful services 
or products to any defendant or for the benefit of 
investors in the defendants' fraudulent scheme in return for these funds. 
16 

64. The defendants transferred at least $20,000 to relief defendant Elmo Baldassari. 
Elmo Baldassari did not provide any lawful services 
or products to any defendant or for the 
benefit 
of investors in the defendants' fraudulent scheme in return for this income 
FIRST CLAIM 
Each Defendant Violated Exchange Act Section lO(b) and Rule lOb-5 
65. The Commission reallegesparagraphs 1 through 64 above. 
66. Each defendant, directly and indirectly, with scienter, 
by use of the means or 
instrumentalities of interstate commerce, or of the mails, employed devices, schemes or artifices 
to defraud; made untrue statements 
of material fact or omitted to state material facts necessary in 
order to make the statements made, in light of the circumstances under which they were made, 
not misleading; and engaged in acts, practices or courses of business which have been and are 
operating as a fraud 
or deceit upon the purchasers or sellers of securities. 
67. As a part of and in furtherance of their scheme, defendants directly and indirectly, 
prepared, disseminated, 
or used contracts, written offering documents, promotional materials, 
investor and other correspondence, and oral presentations, which contained untrue statements 
of 
material facts and misrepresentations of material facts, and which omitted to state material facts 
necessary in order to make the statements made, 
in light of the circumstances under which they 
were made, not misleading, including, but not limited to, those set forth in Paragraphs 
1 through 
64 above. 
68. By reason of the foregoing, each defendant has violated and, unless restrained and 
enjoined, will continue to violate Exchange Act Section lOeb) [15 U.S.C. § 78j(b)] and Rule lOb-
5 [17 C.F.R. § 240.lOb-5]. 
17 

SECOND CLAIM 
Pavlico, Baylor and 
B&J Aided and Abetted Milan's 
Violations 
of Exchange Act Section 10(b) and Rule 10b-5 
69. The Commission realleges paragraphs 1 through 68 above. 
70. Pursuant to Exchange Act Section 20(e) [15 U.S.C. § 78t(e)], Pavlico, Baylor and 
B&J knowingly provided substantial assistance to Milan, and, unless restrained and enjoined, 
will continue to aid and abet Milan's violations 
of Exchange Act Section lOeb) [15 U.S.C. § 
78j(b)] and Rule 
IOb-5 [17 C~F.R. § 240.lOb-5]. 
THIRD CLAIM 
Each Defendant Violated Securities Act Section 17(a) 
71. The Commission realleges paragraphs 1 through 68 above. 
72. Each defendant, directly or indirectly, in the offer or sale 
of securities, by the use 
of the means or instruments of transportation or communication in interstate commerce or by the 
use ofthe mails: (a) has employed, is employing, or is about to employ devices, schemes or 
artifices to defraud; (b) has obtained, is obtaining or is about to obtain money or property by 
means 
of untrue statements of material fact and omissions to state material facts necessary in 
order to make the statements made, in light 
of the circumstances under which they were made, 
not misleading; and ( c) has engaged, is engaged, or is about to engage in transactions, acts, 
practices and courses 
of business that operated or would operate as a fraud upon purchasers of 
securities. 
73. By reason 
ofthe foregoing, each defendant has violated and, unless restrained and 
enjoined, will continue to violate Securities 
Act Section 17(a) [15 U.S.C. § 77q(a)]. 
18 

FOURTH CLAIM 
Pavlico, Baylor and B&J Aided and Abetted 
Milan's Violations 
of Securities Act Section 17(a) 
74. The Commission realleges paragraphs 1 through 73 above. 
75. Pursuant to Securities Act Section 15(b) [15 U.S.c. § 770(b)], Pavlico, Baylor 
and B&J knowingly or recklessly provided substantial assistance 
to the fraudulent conduct of 
Milan and, unless restrained and enjoined, will continue to aid and abet Milan's violations of . 
Securities Act Sections 17(a) [15 U.S.C. § 77q(a)]. 
FIFTH CLAIM 
Each Defendant Violated Securities Act Sections 5(a) and S(c) 
76. The Commission realleges paragraphs 1 through 64' above. 
77. The purported instruments, interests in trading platfonn proceeds, and investment 
letters and agreements are securities. 
78. Each defendant, directly or indirectly, made use 
of the means or instruments of 
transportation or communication in interstate commerce or of the mails to offer and sell 
securities in the form 
of oral agreements, purchase agreements and promissory notes through the 
use or medium of a prospectus or otherwise, and carried or caused to be carried through the 
mails, 
or in interstate commerce, by means or instruments of transportation, such securities for 
the purpose 
of sale or for delivery after sale, when no registration statement had been filed or 
was in effect as to such securities and no legally recognized exemption from registration applied. 
79. 
By reason of the foregoing, each defendant violated and unless restrained and 
enjoined, will continue to violate Securities Act Sections 5(a) and 5(c) [15 U.S.C. §§ 77e(a) and 
77e(c)]. 
19 

SIXTH CLAIM 
Baylor and B&J 
Aided and Abetted Violations 
of Securities Act 5(a) and (c) 
80. The Commission realleges paragraphs 1 through 79 above. 
81.· Pursuant to Securities Act Section 15(b) [15 U.S.C. § 770(b)], Baylor.and B&J 
knowingly or recklessly provided substantial assistance to the fraudulent conduct 
of Pavlico and 
Milan and, unless restrained and enjoined, will continue to aid 
and abet Pavlico's and Milan's 
violations 
of Securities Act Sections 5(a) and (c) [15 U.S.C. §§ 77e(a) and 77e(c)]. 
SEVENTH CLAIM 
Pavlico and Baylor Violated Exchange Act Section 15(a) 
82. The Commission realleges paragraphs 1 through 64 above. 
83. Defendants Pavlico and Baylor, while acting as a broker or dealer, made use 
of 
the mails or any means or instrumentality of interstate commerce to effect any transactions in, or 
. to induce or attempt to induce the purchase or sale of, any securities in the form of purchase 
agreements and promissory notes without being registered with the Commission as a broker 
or 
dealer or an associated person of a registered broker-dealer. 
84. 
By reason of the foregoing, defendants Pavlico and Baylor have each violated 
and, unless restrained and enjoined, will continue to violate Exchange Act 
Section 15(a) [15 
U.S.C. § 780(a)]. 
CLAIM AGAINST RELIEF DEFENDANTS 
85. The Commission realleges paragraphs 1 through 84 above. 
86. Relief defendants Global Funding, Lewis, GPH, Cooper, Jackson, The Law 
Office of Susan C. Kevra, Kevra, Baldassari, and Elmo Baldassari received, directly or 
20 

indirectly, funds and/or other benefits from the defendants which are the proceeds of unlawful 
activities alleged 
in this Complaint and to which these relief defendants have no legitimate claim. 
PRAYER FOR RELiEF 
WHEREFORE, the Commission respectfully requests that the Court: 
I. 
Enter judgment in favor of the Commission finding that the defendants violated the 
federal securities laws and Commission rules as alleged 
in this Complaint; 
II. 
Permanently enjoin the defendants from further violations of the federal securities laws 
and Commission rules alleged against them 
in this Complaint; 
III~ 
Order all defendants and relief defendants to disgorge, as the Court may direct, all ill-
gotten gains received 
or benefits in any form derived from the illegal conduct alleged in this 
Complaint, together with pre-judgment interest thereon; 
IV. 
Order all defendants to pay civil monetary penalties pursuant to Securities Act Section 
20(d) [15 
U.S.C. § 77t(d)] and Exchange Act Section 21 (d)(3) [15 U.S.C. § 78u(d)(3)]; 
V. 
Bar Pavlico and Baylor from serving as an officer or director of any public company 
pursuant to Securities Act Section 
20 (e) [15 U.S.C. § 77t(e)] and Exchange Act Section 21 (d)(2) 
[15 
U.S.c. § 78u(d)(2)]; and 
21 

VIII. 
~uch other equitable and legal relief as may be appropriate or necessary for the 
benefit ofinvestors pursuant to Exchange 
Act Section 21 (d)(5) [15 U.S.C. § 78u(d)(5)]. 
The Commission demands a trial 
by jury on all issues so triable. 
22 
J es . 
·dney D.C. Bar 
St 
hen L. Cohen 
Timothy N. England 
Christopher McLean 
-Carolyn Morris 
Counsel for Plaintiff 
Securities and Exchange 
Commission 
100 
F  Street N.E. 
Washington, D.C. 
20549 
Tel: (202) 551-4441 (Kidney) 
Email: 
kidne)[email protected] 

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 

SECURITIES AND EXCHANGE COMMISSION, 
100 F Street, N.E. 
Washington, DC 20549, 

Plaintiff, 

v. 

THE MILAN GROUP, INC., alkla THE MILAN 
TRADING GROUP, INC. 
113 Upland Terrace, Clarks Summit, P A 18411, 

FRANK L. PA VLICO III, a/k/a FRANK LORENZO 
113 Upland Terrace, Clarks Summit, P A 18411, 

BRYNEE K. BAYLOR 
13121 Riviera Terrace, Silver Spring, MD 20904, and 

BAYLOR & JACKSON, P.L.L.C. 
2607 24th Street, Suite 1, N.W., Washington, DC 20008 

Defendants, 

and 

MIA C .. BALDASSARI 
522 Shirley Lane, Dunmore P A 18512, 

ELMO BALDASSARI 
1360 Wyoming Avenue, Scranton, PA 18509, 

BRETT A. COOPER 
229 Carriage Hill Drive, Moorestown, New Jersey 08057, 

GLOBAL FUNDING SYSTEMS LLC 
12 Debrosses Street, New York, NY 10013, 

GPH HOLDINGS, LLC 

Case: 1: 11-cv-02132 
Assigned To: Collyer, Rosemary M. 
Assign. Date: 11/30/2011 
Description: TRO/PI 

COMPLAINT 

SECURITIES· 
FRAUD 

JURY TRIAL DEMANDED 



211 North Main Street, Lewiston, Utah 84320, 

DAWN R. JACKSON 
5705 Hillmeade Road, Bowie, MD 20720, 

PATRICK T. LEWIS 
570 South 250 East, Richmond, Utah 84333, 

SUSAN C. KEVRA-SHINER, a/k/a SUSAN C. KEVRA : 
748 Grove Street, AvocaPA 18641, 

THE LAW OFFICE OF SUSAN C. KEVRA 
748 Grove Street, Avoca PA 18641 

1 . Defendants. 

COMPLAINT 

Plaintiff Securities and Exchange Commission ("CommIssion") alleges as follows: 

SUMMARY 

1. From at least August 2010 and continuing to the date of the filing of this Complaint, 

defendants Frank L. Pavlico, III, a/kIa Frank Lorenzo, ("Pavlico") and Brynee K. Baylor 

("Baylor") _and entities they control, including defendants The Milan Group, Inc., a/k/a The 

Milan Trading Group, Inc., ("Milan") and Baylor & Jackson, P.L.L.C. ("B&J"), conducted a 

"Prime Bank" scheme that defrauded at least thirteen investors out of approximately $2.1 

million. 

2. Pavlico and Baylor lured investors into the scheme by offering them extraordinary 

returns. In at least one instance, Pavlico offered returns of up to twenty times the original 

investment within forty-five days. Investors were told that the investment involved no risk and 

that their principal would be returned if a successful bank instrument transaction was not 

completed. Baylor cloaked these offers in legitimacy by acting through her capacity as a 

2 



licensed attorney and by identifying herself and her Washingt;on, D.C. law finn, B&J, as counsel 

for Milan and engaging in the scheme through B&J. 

3. Pavlico and Baylor told investors both orally and in writing that Milan would use 

investor funds to "lease," "leverage," and "trade" foreign bank instruments, including "standby 

letters of credit" and "bank guarantees." The Milan investment, however, was entirely fictitious. 

Pavlico and Baylor provided investors with investment contracts and other documents that 

described the investment in vague and complex tenus. These documents were only legal­

sounding gibberish dotted with meaningless legal and financial tenns that were designed to 

deceive investors into believing they were participants in a legitimate investment. Contrary to 

their representations, Pavlico and Baylor never used investor funds to lease, leverage, or trade 

any purported foreign bank instruments. Instead, Pavlico and Baylor used investor money to 

purchase luxury cars such as a Range Rover and a Jaguar, make purchases at expensive 

restaurants and retailers including Jimmy Choo, pay for a trip to the Bahamas, pay other personal 

expenses, pay B&J business expenses, and make payments to the relief defendants. 

4. Pavlico and Baylor made numerous material misrepresentations to investors in 

furtherance of the scheme. Most importantly, Pavlico and Baylor lied to investors about the 

existence of the supposed investment and the use of investor funds. Baylor falsely claimed that 

she had been involved in prior successful transactions with Milan and that she had personally 

witnessed prior investors receive large 'returns through B&J's attorney trust ("IOLTA") account 

consistent with Pavlico;s representations. B&J participated in and aided and abetted the scheme 

by acting as escrow agent for Milan pursuant to written agreements between B&J and investors 

that Baylor executed as B&J's managing partner. At least seven investors deposited at least 

3 



$1.65 million into B&J's IOLTA account. In addition, agreements with investors provided that 

investment profits would be shared among investors, Milan, and B&J. 

5. Pavlico and Baylor are continuing to deceive investors about the status of their 

purported investments. Pavlico and Baylor have sent investors dozens of emails describing the 

progress of the supposed transaction, and Baylor has sent investors notarized "Attorney 

Attestation" letters on B&J letterhead assuring them that the investment is legitimate and will be 

consummated soon. Pavlico and Baylor have also sent investors fictitious computer generated 

"screen shots" and copies of purported foreign bank instruments to deceive them into believing 

that Milan has acquired bank instruments. 

6. No transactions in securities offered or sold by or for the defendants have been 

registered with the Commission, or are eligible for an exemption from registration. 

7. None of the defendants were registered as broker-dealers, as is required for offering 

securities to investors in these circumstances. 

8. By virtue of their conduct, the defendants have engaged, and unless enjoined will 

continue to engage, in violations of, or aid and abet violations of Sections 5(a), 5(c) and 17(a) of 

the Securities Actof 1933 (the "Securities Act") [15 U.S.C. §§ 77e(a), 77e(c) and 77q(a)], 

Sections 10(b) and 15(a) of the Securities Exchange Act of 1934 (the "Exchange Act") [15 

U.S.C. §§ 78j(b) and 780(a)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereund.er. 

JURISDICTION AND VENUE 

9. The Commission brings this action, and this Court has jurisdiction over 

this action, pursuant to authority conferred by Sections 20(b) and 22(a) of the 

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

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

4 



10. This Court has personal jurisdiction over the defendants and venue is 

proper in the District of Columbia pursuant to Section 20(b) of the Securities Act [15 U.S.C. § 

77t(b)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa] because each defendant engaged 

in transactions, acts, practices, and courses of business constituting the violations alleged herein 

within this District and two of the defendants can be found and do business in this District. 

11. The defendants, directly and indirectly, have made use of the means and 

instrumentalities of interstate commerce, and the means and instruments of transportation and 

communication in interstate commerce, in connection with the transactions, acts, practices, and 

courses of business alleged in this Complaint. 

DEFENDANTS 

11. Frank L. Pavlico, III, a!kIaFrank Lorenzo, age 41, is a resident of Clarks 

Summit, Pennsylvania and is the president of Milan. On February 8,2007, Pavlico pled guilty to 

felony conspiracy to conduct financial transactions involving the proceeds of drug trafficking. 

On January 16,2008, he was sentenced to ten months in prison, supervised release ofthree years, 

and fined $15,000. See USA v. Pavlico, No. 3:07-cr-00052-JMM-l, (M.D. Pa. Jan. 16,2008). 

While on supervised release he was prohibited from engaging in criminal conduct and 

associating with persons engaged in criminal activity. His supervised release ended on 

November 5, 2011. 

12. Brynee K. Baylor, age 37, is an attorney licensed in the District of Columbia, 

Maryland, and New Jersey. She is a resident of Silver Spring, Maryland and the co-founder and 

managing partner ofB&J in Washington, D.C. 

13. The Milan Group, Inc., a!kIa The Milan Trading Group, Inc., is a Pennsylvania 

corporation with its principal place of business at Pavlico's home address. 

5 



14. Baylor & Jackson, P.L.L.C. is a Washington, DC law finn with its principal 

place of business in Washington, D.C. 

RELIEF DEFENDANTS 

15. GPH Holding, LLC ("GPH") is an Idaho limited liability company with its 

principal place of business in Lewiston, Utah. GPH received at least $375,000 from the B&J 

IOLTA account. 

16. Global Funding Systems, LLC ("Global Funding") is a Wyoming limited 

liability company with its principal place of business in New York, New York. Global Funding 

received at least $225,000 from Milan. 

17. The Law Office of Susan C. Kevra is located in Avoca, Pennsylvania. The 

Law Office of Susan C. Kevra received at least $409,482 from Milan. 

18. Susan C. Kevra, a/k/a Susan C. Shiner ("Kevra"), age 43, is a resident of 

Avoca, Pennsylvania. Kevra received at least $10,000 from Milan. 

19. Dawn R. Jackson ("Jackson"), age41, is an attorney licensed· in the District of 

Columbia and New Jersey. She is a resident of Bowie, Maryland and a co-founder and partner 

ofB&J. Jackson received at least $153,000 from B&1's IOLTA and operating accounts. 

20. Mia C. Baldassari ("Baldassari"), age 46, is a resident of Dunmore, 

Pennsylvania. Baldassari is the vice president of Milan. Baldassari received at least $24,500 

from Milan. 

21. Elmo Baldassari is a resident of Scranton, Pennsylvania. Elmo Baldassari 

received at least $20,000 through a loan to Mia Baldassari. 

6 



22. Patrick T. Lewis ("Lewis"), age 41, is a resident of Lewiston, Utah. Lewis is 

the managing member of GPH. Investor funds received by GPH were transferred to other 

accounts believed to be owned or controlled by Lewis. 

23. Brett A. Cooper ("Cooper"), age 35, is a resident of Moorestown, New Jersey. 

Cooper is a managing member of Global Funding. Investor funds received by Global Funding 

were transferred to other accounts, including Cooper's personal accounts. 

FACTS 

A. The Defendants' Scheme to Defraud Investors 

24. Beginning in at least August 2010 and continuing to the present, Pavlico and 

Baylor used the mail andwiresto·defraudatleast 13 investorsoutof$2.1 million by offering 

them a fictitious investment that supposedly involved "leasing," "leveraging," and "trading" 

bank instruments. Several government agencies, including the Commission, the u.S. 

Department of the Treasury, and the Federal Bureau of Investigation, have posted investor alerts 

and warnings about fictitious "prime bank" investments on their publicly available websites. 

25. The investors are located in several states, including Califomia, Florida, New 

York, and Colorado. They generally have limited investment experience. 

26. The defendants promised investors extraordinary returns of up to twenty times the 

principal amount invested with little or no risk. To deceive them into believing the purported 

investment was legitimate, the defendants provided investors with documents containing 

meaningless legal-sounding terms and references to non-existent financial instruments and 

institutions. To fend off further inquiries, which might have provided information investors 

could have checked for themselves and found out about the fraud, investors were told that 

7 



confidentiality and secrecy requirements prevented the defendants from providing details of the 

investments. 

27. In furtherance of the scheme, Baylor used her position as an attorney and a 

partner in Washington, D.C. law firm B&J to deceive investors into believing that the Milan 

investment was legitimate and that investors' funds would be safe. She identified herself and her 

law firm as '"counsel" for Milan and, acting through B&J, she provided '"Attorney Attestation" 

letters to certain investors. B&J acted as escrow agent in connection with the scheme pursuant to 

written agreements between B&J and investors which Baylor executed as B&J's managing 

partner. She told investors that she had personally witnessed millions of dollars paid to investors 

through B&J's trust account, consistent with Pavlico's representations. In addition, Pavlico and 

Baylor directed at least seven investors to deposit approximately $1.65 million into B&J's 

IOL T A account. 

28. Pavlico deceived investors by using the name '"Frank Lorenzo" and by failing to 

disclose that he pled guilty to a felony, served 10 months in prison, and was on supervised 

release at the time he was soliciting their investments. 

29. Pavlico and Baylor communicated frequently with investors by telephone, text 

message and email to provide them with updates about the. status of the purported investment. 

Baylor used her B&J e-mail address for nearly all of her written communications with investors, 

and forwarded investors dozens of emails from Pavlico through her B&J email account. Pavlico 

and Baylor used vague and complex terms in these communications to confuse investors, and 

claimed that confidentiality concerns prevented them from providing more fulsome details 

regarding the status of the investment. Pavlico and Baylor also provided investors with bogus 

excuses attempting to explain the delay in providing the promised returns including, among other 

8 



things, feigned illnesses, false representations that the European bankers supposedly involved in 

the transaction were on extended vacation, or that there were unspecified problems with 

processing the transactions through "Euroclear," a supposed necessary step in the transaction. 

As of the date of the filing of this Complaint, Pavlico and Baylor are continuing to mislead 

investors regarding the status of their supposed investment. 

30. In furtherance of the scheme, Pavlico and Baylor on several occasions provided 

investors with digitally created computer "screen shots" and copies of fictitious foreign bank 

instruments, which they tried to pass off as proof of th~ ongoing success of the transactions. 

Baylor sent these fictitious documents to investors using her B&J e-mail address. 

31. In reality, Pavlico, Baylor, Milan, and B&J never invested any of the money they 

received from investors, and instead misappropriated it for their own use and to make payments 

to the relief defendants. 

B. Pavlico's and Baylor's Material Misstatements and Omissions 

32. The defendants made numerous material omissions and omitted to state material 

facts in furtherance of the scheme. They solicited unsophisticated investors and promised them 

returns of up to twenty times the principal amount invested within as little as 45-60 days with no 

risk of loss. After receiving investors' funds, they continued to make material misstatements and 

omissions to investors about the status of their supposed investments to lull them into accepting 

long delays in realizing the promised returns. 

33. Pavlico represented to potential investors, both orally and in writing, that Milan . 

would use investor funds to "lease" bank instruments, including standby letters of credit, bank 

guarantees, and medium term notes. These instruments would then be "leveraged" to acquire 

9 



even larger instruments, which would be "monetized." The proceeds from this "monetization" 

would then be put into a foreign "private trading platform." 

34. Certain investors executed investment contracts with Pavlico on behalf of Milan. 

These contracts state that investor funds would be used to facilitate the leasing of bank 

instruments (standby letters of credit and bank guarantees) in connection with a "private 

placement investment." Certain contracts guaranteed that investors' principal would be returned 

in the event an instrument was not procured. 

35. Some investors also received "Irrevocable Profit Participation Agreements," 

which purported to apportion th.e profits from the non-existent bank instrument investment 

between and among Milan, B&J, and investors. 

36. Pavlico and Baylor promised investors exceptional returns, typically many 

multiples of the initial investment over a timeframe of just a few months. In at least one 

instance, Pavlico offered to lease a $10 million instrument in exchange for a $75,000 investment. 

Pavlico told the investor that the $10 million instrument would be leveraged into a $100 million 

instrument and that the proceeds from the larger instrument would be traded on a "private trading 

platform." He told the investor that this investment would return $1.5 million within 45-60 days. 

37. Pavlico promised another investor that the Milan investment would generate a· 

return of $250,000 every two weeks for forty weeks in exchange for an investment of$325,000. 

This represents a 1438% investment return purporting to produce total profits of $4,675,000. 

38. Pavlico promised another investor that the Milan investment would generate a 

return of $130,000 every week for forty weeks in exchange for an investment of $130,000. This 

represents a 4000% investment return purporting to produce total profits of $5,070,000. 

10 



39. Baylor identified herself and her Washington, D.C. law finn as "counsel" for 

Milan. In her capacities as a licensed attorney and managing partner in B&J, Baylor assured 

investors that the Milan investment was legitimate and that their funds would be safe. For 

example, in an email to investors dated October 11,2010 sent from B&J's email account, Baylor 

stated falsely: 

I am writing to confinn the validity of the transaction that your client, [REDACTED] is 
involved in. First, I have observed this company successfully complete transactions of 
this nature whereby participants received their funds as agreed. Second, I have 
personally been involved in this transaction and can validate it as well as confinn the fact 
that the transaction is moving along very well. Although there was a delay in the initial 
upstart, this process is moving full speed again and I am most confident that you as well 
as your client will be pleased with the result. 

40. Certain investors executed escrow agreements with B&J, which Baylor executed 

on behalf ofB&J as its managing partner. Baylor also provided notarized "Attorney Attestation" 

letters on B&J letterhead verifying the legitimacy of the transaction. Baylor also represented that 

she had conducted a thorough background check on Pavlico, including consultation with the 

Chief of Police of Washington, D.C., and that she had found nothing of concern. 

41. Pavlico, who identified himself to investors as "Frank Lorenzo," never disclosed 

his real name to investors, or that he pled guilty in 2007 to felony conspiracy to conduct 

tranSactions involving the proceeds of drug trafficking, served ten months in prison, and was on 

supervised release when he was soliciting their investments. 

42. Contrary to their representations to investors, the defendants never used investor 

funds to lease any purported bank instruments or participate in any "private trading platfonn." 

The defendants never paid or intended to pay investors any money back or provide any returns 

on their investments. 

11 



43. Pavlico and Baylor, and through them, Milan and B&J, each knew or was reckless 

in not knowing that the investment offered was fictitious, and that each of the statements made in 

paragraphs 32 to 42 was materially false or misleading or omitted to state material facts which 

would make the statements they made not materially misleading. 

c. Pavlico's and Baylor's Misappropriation Of Investor Funds 

44. Contrary to their representations to investors that their funds would beused to 

lease purported bank instruments and to facilitate their participation in a foreign "private trading 

platform," Pavlico and Baylor misappropriated investors' funds to pay personal expenses. For 

example, Pavlico used investor funds to pay for lUxury cars such asa Range Rover and a Jaguar, 

and Baylor used investor funds to make purchases at expensive restaurants and retailers 

including Jimmy Choo, and to pay for a trip to the Bahamas in September 2010. Pavlicoand 

Baylor also used investor funds to make payments to relief defendants. 

45. Between August 31,2010 and January 19, 2011, at least seven investors deposited 

$1.73 million into B&J's bank accounts, $1.65 million of which was deposited into the law 

firm's IOLTA account. At least $1.1 million of those funds was used to pay Baylor's personal 

expenses, B&J business expenses, withdrawn as cash or transferred to Baylor's personal account, 

and transferred to relief defendants and other third parties. The remaining $631,000 paid by 

investors was transferred to Milan, predominantly from banking centers located in Washington, 

D.C. 

46. Milan received at least $991,000 of investor funds, either directly from investors 

or from B&J's IOLTA account. That money was used to pay Pavlico's personal expenses and 

transferred to the relief defendants. 

12 



47. None of the investors' money was used to "lease," "leverage," or trade any 

purported bank instruments. 

D. Pavlico and Baylor Continue to Deceive Investors about the Status of Their 
Purported Investments 

48. Since at least November 2010 and continuing through the date that this Complaint 

was filed, Pavlico and Baylor have deceived investors about the status of their purported 

investments. 

49. Pavlico and Baylor have each sent dozens of emails to investors that purported to 

describe the progress of the supposed investment. Many of Pavlico' s email updates were sent to 

Baylor, who then disseminated them to investors using B&J's email account. These emails 

typically offered bogus reasons for the delay in providing the promised returns andlor the 

inability to return the principal amount invested. 

50. For example, in an email to investors dated January 10, 2011, Pavlico stated 

[punctuation as per original]: 

I will have a full update later on today. I have spoken to Platform and the 
Director handling this file is flying into Heathrow today at 3pm, when the Bond 
issuance was signed the Platform in return needs to have HSBC sign the 
Undertaking letter witch in turns guarantees the 26Million in return Platform 
would not sign until all paperwork is done, it is and we need the undertaking letter 
signed today, hopefully by banker, this is why the Platform Director is flying in to 
London to give permission on next steps, I have told everyone that the Platform 
and Bankers do not return from Holiday until the 15th but the Platform asked for 
thereBanker to come back this week, he also has agreed to. So bottom line we 
need undertaking contract back and then they will swift over MT -760 and then in 
a 24 hour period we receive the instrument, I will confirm once Platform has done 
a call with the Lessor and myself at some point today. This is great news and I 
will update soon. 

51. In another email to investors, dated February 3, 2011, Pavlico stated [punctuation 

as per original]: 

13 



Please be advised that because the two sides are not agreeing on procedures to 
send and receive the 200M instrument, both sides have agreed to do a test run on 
a smaller instrument of 10M usn Letter of Credit. This was given to us last 
evening from the owner, we are in receipt of the original copy signed by two bank 
officers and we all agreed on how this instiument will be authenticated and 
moved from National Australian Bank to Santander Bank. This procedure will be 
replicated in getting our instrument into the Platforms bank. I was also advised 
because of the time difference that both are ready and willing to send and receive 
the RWA from this point on. I will be notified when the instrument is received by 
Platform. When this happens, all will be identified to move forward in duplicating 
the procedures to send the 200M Instrument over to Platform. This is the quickest 
mode of operation because both sides are willing to compromise through this 
method. [] I will update you as soon as I receive confirmation that the instrument 
has been received by the platform. Things are now ready to move forward and 
close this transaction out. 

52. Pavlico knew, or was reckless in not knowing, that the ''updates'' he provided 

investors materially misrepresented the status of the investment activities and omitted the 

material fact that none of the investor's monies were used in connection with leasing, leveraging, 

or trading bank instruments as represented. 

53. Baylor also sent numerous emails to investors from her B&J email account. 

purporting to report the status ofthe transactions. For example, in an email to investors August 

30,2011, Baylor stated: 

Please find attached the documents that relate to the bonds in this transaction. 
The bonds are listed with the National bank in Brazil and have been verified 
through the Brazilian government. Because the bonds have not matured yet, the 
valuation has to be determined by the attorneys through due diligence. Weare 
waiting for this information. David is flying to Paris and we are scheduled for 
a conference call this evening at 7pm EST. Please be judicious in who you send 
this to. As attorneys, I ask that you keep it confidential in order to protect the 
owners while this transaction is being completed. These documents can confirm 
the validity of this transaction that is set to close upon ascertainment of the value 
of the remaining instruments. 

54. Baylor executed numerous "Attorney Attestation Letters" to certain investors on 

B&J letterhead assuring them of the legitimacy of their investments and to provide them with an 

update regarding the status ofthe investments. For example, in a letter to an investor dated 

14 



January 20, 2011, Baylor stated: "This letter is to confinn that I am in receipt of a bank 

undertaking letter for funding. Our finn is expected to receive said funds by early to middle of 

next week. Upon receipt of the funds, all money will be placed in an escrow account and then 

dispersed to [the investor] as quickly as possible." 

55. Baylor also emailed investors copies of documents, certificates, and computer 

generated "screen shots" purporting to evidence instruments available for the investors. Baylor 

sent these emails using her B&J email address. 

56. At the time of writing such emails, forwarding Pavlico's updates, and transmitting 

documents purporting to evidence bank instruments and non-U.S. bonds, Baylor knew, or was 

reckless in not knowing, that the "updates" she provided materially misrepresented the status of 

the investment activities and omitted the material·fact that none of the investor's deposits were 

being used to secure the investments or the returns which had been represented to them by the 

defendants. 

E. Pavlico and Baylor Continue to Solicit New Investors. 

57. Pavlico and Baylor continue to actively solicit new investors and continue to 

communicate with existing investors with the intent of lulling them into believing their 

investments are proceeding as represented to them. As recently as September 2011, an 

individual wired $250,000 into the B&J escrow account which was forwarded, in part, to Milan. 

Also, in late September 2011 Milan paid $10,000 to "Susan Kevra Shiner Trust Account" by a 

check which appears to have been signed by Pavlico and states in the memo line, 

"Churchillll OM Euro SBLC." "SBLC" is an abbreviation for "standby letter of credit," a type of 

fictitious bank instrument similar to those offered to the investors alleged in this Complaint. 

F. Allegations Relating to Relief Defendants 

15 



58. From at least August 2010 through January 2011, the. defendants transferred over 

$1.2 million of investors' funds to the relief defendants. 

59. The defendants transferred at least $375,000 of investor funds to reliefdefendant 

GPH. GPH subsequently transferred these funds to accounts that are believed to be owned or 

controlled by relief defendant Lewis. Neither GPH nor Lewis provided any lawful services or 

products to any defendant or for the benefit of investors in the defendants' fraudulent scheme in 

return for these funds. 

60. The defendarits transferred at least $225,000 of investor funds to relief defendant 

Global Funding. Global Funding subsequently transferred the investor funds to accounts that are 

believed to be owned or controlled by relief defendant Cooper and/or his wife. Neither Global 

Funding nor Cooper provided any lawful services or products to any defendant or for the benefit 

of investors in the defendants' fraudulent scheme in return for these funds. 

61. The defendants transferred at least $409,482 to relief defendant The Law Office 

of Susan C. Kevra and at least $10,000 to the principal of that office, relief defendant Kevra,as a 

"loan." Neither Kevra nor her law offices provided any lawful services or products to any 

defendant or for the benefit of investors in the defendants' fraudulent scheme in return for these 

funds. 

62. The defendants transferred at least $153,000 to relief defendant Dawn Jackson. 

Jackson did not provide any lawful services or products to any defendant or for the benefit of 

investors in the defendants' fraudulent scheme in return for these funds. 

63. The defendants transferred at least $24,500 t6 relief defendant Mia Baldassari. 

Baldissari did not provide any lawful services or products to any defendant or for the benefit of 

investors in the defendants' fraudulent scheme in return for these funds. 

16 



64. The defendants transferred at least $20,000 to relief defendant Elmo Baldassari. 

Elmo Baldassari did not provide any lawful services or products to any defendant or for the 

benefit of investors in the defendants' fraudulent scheme in return for this income 

FIRST CLAIM 

Each Defendant Violated Exchange Act Section lO(b) and Rule lOb-5 

65. The Commission reallegesparagraphs 1 through 64 above. 

66. Each defendant, directly and indirectly, with scienter, by use of the means or 

instrumentalities of interstate commerce, or of the mails, employed devices, schemes or artifices 

to defraud; made untrue statements of material fact or omitted to state material facts necessary in 

order to make the statements made, in light of the circumstances under which they were made, 

not misleading; and engaged in acts, practices or courses of business which have been and are 

operating as a fraud or deceit upon the purchasers or sellers of securities. 

67. As a part of and in furtherance of their scheme, defendants directly and indirectly, 

prepared, disseminated, or used contracts, written offering documents, promotional materials, 

investor and other correspondence, and oral presentations, which contained untrue statements of 

material facts and misrepresentations of material facts, and which omitted to state material facts 

necessary in order to make the statements made, in light of the circumstances under which they 

were made, not misleading, including, but not limited to, those set forth in Paragraphs 1 through 

64 above. 

68. By reason of the foregoing, each defendant has violated and, unless restrained and 

enjoined, will continue to violate Exchange Act Section lOeb) [15 U.S.C. § 78j(b)] and Rule lOb-

5 [17 C.F.R. § 240.lOb-5]. 

17 



SECOND CLAIM 

Pavlico, Baylor and B&J Aided and Abetted Milan's 
Violations of Exchange Act Section 10(b) and Rule 10b-5 

69. The Commission realleges paragraphs 1 through 68 above. 

70. Pursuant to Exchange Act Section 20(e) [15 U.S.C. § 78t(e)], Pavlico, Baylor and 

B&J knowingly provided substantial assistance to Milan, and, unless restrained and enjoined, 

will continue to aid and abet Milan's violations of Exchange Act Section lOeb) [15 U.S.C. § 

78j(b)] and Rule IOb-5 [17 C~F.R. § 240.lOb-5]. 

THIRD CLAIM 

Each Defendant Violated Securities Act Section 17(a) 

71. The Commission realleges paragraphs 1 through 68 above. 

72. Each defendant, directly or indirectly, in the offer or sale of securities, by the use 

of the means or instruments of transportation or communication in interstate commerce or by the 

use ofthe mails: (a) has employed, is employing, or is about to employ devices, schemes or 

artifices to defraud; (b) has obtained, is obtaining or is about to obtain money or property by 

means of untrue statements of material fact and omissions to state material facts necessary in 

order to make the statements made, in light of the circumstances under which they were made, 

not misleading; and ( c) has engaged, is engaged, or is about to engage in transactions, acts, 

practices and courses of business that operated or would operate as a fraud upon purchasers of 

securities. 

73. By reason ofthe foregoing, each defendant has violated and, unless restrained and 

enjoined, will continue to violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)]. 

18 



FOURTH CLAIM 

Pavlico, Baylor and B&J Aided and Abetted 
Milan's Violations of Securities Act Section 17(a) 

74. The Commission realleges paragraphs 1 through 73 above. 

75. Pursuant to Securities Act Section 15(b) [15 U.S.c. § 770(b)], Pavlico, Baylor 

and B&J knowingly or recklessly provided substantial assistance to the fraudulent conduct of 

Milan and, unless restrained and enjoined, will continue to aid and abet Milan's violations of . 

Securities Act Sections 17(a) [15 U.S.C. § 77q(a)]. 

FIFTH CLAIM 

Each Defendant Violated Securities Act Sections 5(a) and S(c) 

76. The Commission realleges paragraphs 1 through 64' above. 

77. The purported instruments, interests in trading platfonn proceeds, and investment 

letters and agreements are securities. 

78. Each defendant, directly or indirectly, made use of the means or instruments of 

transportation or communication in interstate commerce or of the mails to offer and sell 

securities in the form of oral agreements, purchase agreements and promissory notes through the 

use or medium of a prospectus or otherwise, and carried or caused to be carried through the 

mails, or in interstate commerce, by means or instruments of transportation, such securities for 

the purpose of sale or for delivery after sale, when no registration statement had been filed or 

was in effect as to such securities and no legally recognized exemption from registration applied. 

79. By reason of the foregoing, each defendant violated and unless restrained and 

enjoined, will continue to violate Securities Act Sections 5(a) and 5(c) [15 U.S.C. §§ 77e(a) and 

77e(c)]. 

19 



SIXTH CLAIM 

Baylor and B&J 
Aided and Abetted Violations of Securities Act 5(a) and (c) 

80. The Commission realleges paragraphs 1 through 79 above. 

81.· Pursuant to Securities Act Section 15(b) [15 U.S.C. § 770(b)], Baylor.and B&J 

knowingly or recklessly provided substantial assistance to the fraudulent conduct of Pavlico and 

Milan and, unless restrained and enjoined, will continue to aid and abet Pavlico's and Milan's 

violations of Securities Act Sections 5(a) and (c) [15 U.S.C. §§ 77e(a) and 77e(c)]. 

SEVENTH CLAIM 

Pavlico and Baylor Violated Exchange Act Section 15(a) 

82. The Commission realleges paragraphs 1 through 64 above. 

83. Defendants Pavlico and Baylor, while acting as a broker or dealer, made use of 

the mails or any means or instrumentality of interstate commerce to effect any transactions in, or 

. to induce or attempt to induce the purchase or sale of, any securities in the form of purchase 

agreements and promissory notes without being registered with the Commission as a broker or 

dealer or an associated person of a registered broker-dealer. 

84. By reason of the foregoing, defendants Pavlico and Baylor have each violated 

and, unless restrained and enjoined, will continue to violate Exchange Act Section 15(a) [15 

U.S.C. § 780(a)]. 

CLAIM AGAINST RELIEF DEFENDANTS 

85. The Commission realleges paragraphs 1 through 84 above. 

86. Relief defendants Global Funding, Lewis, GPH, Cooper, Jackson, The Law 

Office of Susan C. Kevra, Kevra, Baldassari, and Elmo Baldassari received, directly or 

20indirectly, funds and/or other benefits from the defendants which are the proceeds of unlawful 

activities alleged in this Complaint and to which these relief defendants have no legitimate claim. 

PRAYER FOR RELiEF 

WHEREFORE, the Commission respectfully requests that the Court: 

I. 

Enter judgment in favor of the Commission finding that the defendants violated the 

federal securities laws and Commission rules as alleged in this Complaint; 

II. 

Permanently enjoin the defendants from further violations of the federal securities laws 

and Commission rules alleged against them in this Complaint; 

III~ 

Order all defendants and relief defendants to disgorge, as the Court may direct, all ill­

gotten gains received or benefits in any form derived from the illegal conduct alleged in this 

Complaint, together with pre-judgment interest thereon; 

IV. 

Order all defendants to pay civil monetary penalties pursuant to Securities Act Section 

20(d) [15 U.S.C. § 77t(d)] and Exchange Act Section 21 (d)(3) [15 U.S.C. § 78u(d)(3)]; 

V. 

Bar Pavlico and Baylor from serving as an officer or director of any public company 

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

[15 U.S.c. § 78u(d)(2)]; and 

21 



VIII. 

~uch other equitable and legal relief as may be appropriate or necessary for the 

benefit ofinvestors pursuant to Exchange Act Section 21 (d)(5) [15 U.S.C. § 78u(d)(5)]. 

The Commission demands a trial by jury on all issues so triable. 

22 

J es . ·dney D.C. Bar 
St hen L. Cohen 
Timothy N. England 
Christopher McLean 

-Carolyn Morris 

Counsel for Plaintiff 
Securities and Exchange Commission 
100 F Street N.E. 
Washington, D.C. 20549 
Tel: (202) 551-4441 (Kidney) 
Email: kidne)[email protected]