SEC v. Peter R. Quartararo; Private Equity Solutions, Inc.; Leonard Quartararo; Paul Casella; and Lisa Eckert, No. 1:21-cv-02305, Eastern District of New York (Apr. 15, 2026) — Complaint
raw: SEC v. PETER R. QUARTARARO
SEC v. PETER R. QUARTARARO, No. 1:21-cv-02305 (Apr. 15, 2026)
Classified pre-ipo-fraud(confidence 97%). EDGAR detection: forms S-1/Form D/1-A· recall 72% / precision 8%. detection rule →
Statutes
15 U.S.C. § 77q(a)15 U.S.C. § 78j(b)15 U.S.C. § 78u(d)15 U.S.C. § 77t(d)15 U.S.C. § 77v(a)15 U.S.C. § 78aa17 C.F.R. § 240.10b-5Section 17(a) of the Securities ActRule 10b-5
Parties
Securities and Exchange CommissionPeter R. QuartararoPrivate Equity Solutions, Inc.Leonard QuartararoPaul CasellaLisa Eckert
Keywords
quartararoprivate equityequity solutionsleonard quartararoinvestorinvestorsprivatesharespre-ipo sharessecuritiesleonarddocument pagepage pageidequitysolutions
Extracted insights
Dollar amounts 17
- $436K $436,000 $100K–$1M
- $436K $436,000 $100K–$1M
- $268K $268,000 $100K–$1M
- $168K $168,000 $100K–$1M
- $156K $156,000 $100K–$1M
- $96K $96,000 $10K–$100K
- $81K $81,000 $10K–$100K
- $72K $72,000 $10K–$100K
- $71K $71,000 $10K–$100K
- $35K $35,000 $10K–$100K
- $28K $28,300 $10K–$100K
- $28K $28,000 $10K–$100K
Entities 10
- person federal racketeering charges
- agency Finra
- company investments in pre-ipo shares of peloton interactive, inc. and airbnb, inc.
- person investor funds
- company investors to make checks to leonard quartararo or private equity solutions
- person leonard quartararo
- person paul casella
- person peter r. quartararo
- company private equity solutions
- agency Securities and Exchange Commission
Triples 14
- Peter R. Quartararo defrauded investors
- Peter R. Quartararo solicited investments in pre-IPO shares of Peloton Interactive, Inc. and Airbnb, Inc.
- Peter R. Quartararo convinced at least four individuals to invest approximately $436,000
- Peter R. Quartararo stole investor funds
- Peter R. Quartararo instructed investors to make checks to Leonard Quartararo or Private Equity Solutions
- Leonard Quartararo made payments that benefitted Peter R. Quartararo, Lisa Eckert, and other family members
- Private Equity Solutions made payments that benefitted Peter R. Quartararo, Lisa Eckert, and other family members
- subject violated Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Exchange Act of 1934
- Securities and Exchange Commission brings action against Peter R. Quartararo and Relief Defendants
- FINRA barred Peter R. Quartararo
- FINRA barred object
- subject convicted of federal racketeering charges
- Paul Casella established Private Equity Solutions
- Paul Casella owns Private Equity Solutions
Text layers
Extracted body text (28,826c)
RICHARD R. BEST
REGIONAL DIRECTOR
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
-against-
PETER R. QUARTARARO,
Defendant,
-and-
PRIVATE EQUITY SOLUTIONS, INC.,
LEONARD QUARTARARO, PAUL CASELLA,
and LISA ECKERT,
Relief Defendants.
COMPLAINT
21 Civ. _____ ( )
JURY TRIAL DEMANDED
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against
Defendant Peter R. Quartararo (“Quartararo”) and Relief Defendants Private Equity Solutions, Inc.
(“Private Equity Solutions”), Leonard Quartararo (“Leonard Quartararo”), Paul Casella (“Casella”),
and Lisa Eckert (“Eckert”) (together, “Relief Defendants”), alleges as follows:
2
SUMMARY OF ALLEGATIONS
1. This matter involves a scheme by Quartararo to defraud investors by claiming that
he could sell them shares in well-known privately-held companies, which were expected to increase
in value when those companies completed their initial public offerings (“IPOs”). These
representations were false.
2. In the summer of 2019, Quartararo began soliciting an acquaintance and others to
invest through him in “pre-IPO” shares of several “unicorn” companies, including Peloton
Interactive, Inc. (“Peloton”) and Airbnb, Inc. (“Airbnb”). Over the next several months, Quartararo
convinced at least four individuals to invest at least approximately $436,000 in the purported pre-
IPO shares.
3. In truth, Quartararo – a former securities broker who had been previously barred by
the Financial Industry Regulatory Authority (“FINRA”) from working at any registered securities
brokerage firm – never purchased or held pre-IPO shares in these companies on behalf of the
investors. Instead, Quartararo stole the funds and used them for his personal benefit.
4. Quartararo instructed the investors to make out their checks to Leonard Quartararo,
Quartararo’s father, or to Private Equity Solutions, a private company owned by Casella. Casella,
who formerly worked in the securities industry, was barred by FINRA from associating with any
registered securities brokerage firm in 2008, and was convicted of federal racketeering charges in
2011.
5. Leonard Quartararo and Private Equity Solutions, in turn, made numerous payments
that benefitted Quartararo, Quartararo’s girlfriend, Eckert, and other family members, including
payments on a Maserati for Quartararo and Eckert.
3
VIOLATIONS
6. By virtue of the foregoing conduct and as alleged further herein, Defendant
Quartararo has violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §
77q(a)]; Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule
10b-5 thereunder [17 C.F.R. § 240.10b-5].
7. Unless Quartararo is restrained and enjoined, he will engage in the acts, practices,
transactions, and courses of business set forth in this Complaint or in acts, practices, transactions,
and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
8. The Commission brings this action pursuant to the authority conferred upon it by
Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)], and Exchange Act Section
21(d) [15 U.S.C. § 78u(d)].
9. The Commission seeks a final judgment: (a) permanently enjoining Quartararo from
violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering
Quartararo to disgorge all ill-gotten gains he received as a result of the violations alleged here and to
pay prejudgment interest thereon pursuant to Exchange Act Section 21(d)(5) [15 U.S.C. § 78u(d)(5)]
and Sections 6501(a)(1) and (a)(3) of the National Defense Authorization Act for Fiscal Year 2021,
Pub. L. No. 116-283, to be codified at 15 U.S.C. §§ 78u(d)(3) and 78u(d)(7); (c) ordering Quartararo
to pay civil money 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)]; (d) ordering each of the Relief Defendants to
pay, with prejudgment interest, all ill-gotten gains by which they were unjustly enriched, under
Exchange Act Section 21(d)(5) [15 U.S.C. § 78u(d)(5)]; and (d) ordering any other and further relief
the Court may deem just and proper.
4
JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a)
[15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa].
11. Quartararo, directly and indirectly, has made use of the means or instrumentalities of
interstate commerce or of the mails in connection with the transactions, acts, practices, and courses
of business alleged herein.
12. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and
Exchange Act Section 27 [15 U.S.C. § 78aa]. Quartararo resides in the Eastern District of New
York, and certain of the acts, transactions, practices and courses of business alleged herein took
place in the Eastern District of New York. Quartararo solicited investments from investors who
reside in the Eastern District of New York. Eckert and Casella’s residences, and Private Equity
Solutions’ principal place of business, are in the Eastern District of New York.
DEFENDANT
13. Quartararo, age 56, resides in Glen Cove, New York. From April 2000 until
September 2011, Quartararo worked as a registered representative for various brokerage firms. In
2013, FINRA found that Quartararo willfully violated Section 10(b) of the Exchange Act and Rule
10b-5 thereunder, along with several FINRA rules, when he solicited acquaintances with a penny
stock tip, but failed to invest the funds and provided false documents to the investors. That year,
Quartararo was permanently barred by FINRA from association with any FINRA-registered
brokerage firm.
RELIEF DEFENDANTS
14. Private Equity Solutions is a New York corporation located in Jericho, New York
and purports to offer debt restructuring services. Private Equity Solutions was established by
Casella in approximately September 2017.
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15. Leonard Quartararo, age 78, is Quartararo’s father and resides in Staten Island,
New York.
16. Casella, age 54, resides in Woodbury, New York and is the owner of Private Equity
Solutions. In 2011, he was convicted on federal racketeering charges in connection with the
trafficking of women from Eastern Europe to work as exotic dancers. In 2008, Casella was barred
by FINRA from associating with any FINRA-registered brokerage firm after failing to pay sanctions
imposed by FINRA in connection with a customer complaint. Casella and Quartararo previously
worked together at Milestone Group Management LLC, a Lake Success, New York brokerage firm.
17. Eckert (formerly, Lisa Brownstein), age 45, is Quartararo’s girlfriend and resides in
Glen Cove, New York.
FACTS
I. QUARTARARO SOLICITED SHAM INVESTMENTS IN “PRE-IPO”
SHARES OF WELL KNOWN PRIVATE COMPANIES
18. In approximately July 2019, Quartararo commenced his scheme to defraud investors
when he approached an acquaintance, Investor A, with an alleged investment opportunity.
19. Quartararo told Investor A that he had previously acquired shares in the then-private
companies Airbnb and WeWork (formally known as The We Company, Inc.) (“WeWork”), both of
which were widely expected to be taken public through IPOs. (In fact, Quatararo had never
obtained shares of those prominent private companies.) Quartararo claimed that, to show his
appreciation for a favor that Investor A had done for Quartararo, Quartararo would sell some of the
pre-IPO shares to Investor A for $2 per share. Quartararo further claimed that, once the companies
went public, he would sell the shares and Investor A could keep all of the profits, less any capital
gains taxes.
20. Based on these representations, Investor A agreed to purchase the pre-IPO shares
and, on approximately August 5, 2019, gave Quartararo an initial payment of $96,000. At
6
Quartararo’s direction, Investor A wrote the check out to Private Equity Solutions, with the notation
“Stock Purchase IPO.”
21. In late August 2019, Quartararo told Investor A that he had access to pre-IPO shares
in a third company, Peloton, at prices between $1.80 and $2 per share. Based on Quartararo’s
representations, Investor A agreed to purchase the shares, and gave Quartararo a second check for
$71,000 on approximately August 29, 2019. In this case, Quartararo instructed Investor A to make
the check out to Leonard Quartararo. In the memo section of the check, Investor A wrote “Stock
Purchase.”
22. Several weeks later, in September 2019, Quartararo solicited a third investment of
$35,000 from Investor A, ostensibly for additional Peloton pre-IPO shares. In the memo section of
the check, Investor A wrote “Stock Purchase.” Once again, Quartararo instructed Investor A to
make the check out to Leonard Quartararo.
23. Investor A introduced several other acquaintances to Quartararo. First, Investor A
told his girlfriend, Investor B, about the opportunity, and Investor B invested $72,000 with
Quartararo in early September 2019. At Quartararo’s request, Investor B made the check out to
Private Equity Solutions.
24. Second, Investor A introduced Quartararo to his friends, Investor C and Investor D,
who are brothers. In approximately August or September 2019, Investors C and D met Quartararo
at a Starbucks in Jericho, New York and Quartararo repeated his claims about the pre-IPO shares.
Specifically, Quartararo claimed that he could sell Investors C and D pre-IPO shares in Airbnb,
Peloton and WeWork; that he would liquidate the shares once the companies completed their IPOs;
and that, after completing the necessary tax paperwork, he would pay out the profits and principal to
Investors C and D in approximately five to six months.
7
25. Based on Quartararo’s representations, Investors C and D invested in the purported
pre-IPO shares. Investor C and Investor D each provided a check to Quartararo in the amount of
$81,000 on approximately September 29, 2019. Once again, Quartararo instructed Investors C and
D to make these checks out to Leonard Quartararo. Quartararo initially claimed that “Leonard” was
his legal name, but, when pressed by Investors C and D, admitted that Leonard was his father,
whom he said was involved in the investments.
26. In the memo line of his check, Investor C wrote the names of the companies in
which Investor C believed he was investing, and the amount of funds allocated to each company:
“43,500 Airbnb, 18,000 WeWorks [sic], 19,500 Pelaton [sic]”. Investor D wrote the same
information on his check.
27. Quartararo hand wrote and signed a “bill of sale” to Investors C and D, which
indicated the amount of shares they allegedly purchased and the amount of money they paid him:
[Investors C and D]
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II. QUARTARARO’S CLAIMS ABOUT THE INVESTMENTS WERE FALSE:
THE INVESTOR FUNDS WERE MISAPPROPRIATED FOR
QUARTARARO’S BENEFIT
28. As Quartararo knew, or recklessly disregarded, his claims about the purported pre-
IPO investments were false. Quartararo had no access to pre-IPO shares in these prominent private
companies and had never obtained such shares in prominent private companies prior to their IPOs.
Quartararo had no reasonable basis to tell investors he owned or could obtain such pre-IPO shares.
Quartararo did not use the investors’ funds to purchase pre-IPO shares of Airbnb, Peloton or
WeWork, nor did Quartararo ever hold any pre-IPO shares in these companies. Instead, Quartararo
misappropriated the investor funds for his benefit and the benefit of Relief Defendants, among
others.
A. Transfers from Private Equity Solutions to the Relief Defendants
29. As described above, the four investors gave Quartararo six personal checks for a
total of $436,000.00. Two of the checks, totaling $168,000, were made out to and deposited into a
Private Equity Solutions checking account, for which Casella is the only authorized signatory.
30. After the investor checks were deposited in the Private Equity Solutions account, a
significant amount of funds were transferred from that account to accounts connected to
Quartararo and the Relief Defendants.
31. For example, between approximately November 2019 and April 2020, $14,500 was
transferred from the Private Equity Solutions account to Eckert, Quartararo’s girlfriend.
32. Additionally, between approximately December 2019 and September 2020,
approximately $28,300 was transferred from the Private Equity Solutions account to Casella’s
personal bank account. In turn, between approximately May 2020 and July 2020, Casella’s personal
bank account transferred approximately $28,000 to Eckert.
9
33. Leonard Quartararo also received funds from the Private Equity Solutions account.
A check from the Private Equity Solutions account dated November 22, 2019 for $12,500 was made
out to Leonard Quartararo and cleared December 16, 2019.
34. Other funds from the Private Equity Solutions account were used to pay for
personal items for Quartararo and Eckert. For example, on approximately October 30, 2019,
Private Equity Solutions paid $8,500 to a Long Island, New York car dealership for a down payment
on a Maserati. Registration documents for the vehicle show that it is registered to Eckert and owned
by Quartararo.
B. Withdrawals from the Leonard Quartararo Account
35. Four of the investors’ checks, totaling $268,000, were made out and deposited into
an account held by Leonard Quartararo.
36. After the investors’ checks were deposited in Leonard Quartararo’s account, the
majority of those funds were withdrawn from the account in cash. In total, at least $156,000 in cash
was withdrawn from the Leonard Quartararo account between the date of the first investor deposit
and January 27, 2021.
37. Many of these cash withdrawals were made almost immediately after the investors’
funds were deposited. For example, on August 30, 2019, Investor A’s $71,000 was deposited into
Leonard Quartararo’s account at 11:53 a.m., and $7,600 in cash was withdrawn from the account
two minutes later.
38. As another example, on October 4, 2019, Investor D’s $81,000 check was deposited
into Leonard Quartararo’s account at 12:07 p.m., and $9,000 in cash was withdrawn four minutes
later.
39. None of Private Equity Solutions, Leonard Quartararo, Casella or Eckert had any
legitimate claim to the investor funds that they received.
10
III. QUARTARARO CONCEALED HIS FRAUD
40. Peloton completed its IPO in September 2019, and Airbnb completed its IPO in
December 2020. WeWork announced that it was cancelling its planned IPO in September 2019.
Despite his prior promises to the investors, Quartararo did not return any investment funds to the
investors after the Peloton or Airbnb IPOs.
41. Instead, Quartararo, knowingly, or with reckless disregard, concealed and
perpetuated his fraud by periodically promising the investors that he would sell the shares in the
investments and give them their profits.
42. For example, in approximately June 2020, Quartararo knowingly, or with reckless
disregard, falsely informed Investor A that he had 56 total investors in different pre-IPO
investments, and further falsely promised Investor A that he had his “finger on the trigger” and was
“close” to selling the shares.
43. Similarly, in December 2020, Investors C and D spoke with Quartararo and
demanded that Quartararo sell their shares. Quartararo then knowingly, or with reckless disregard,
falsely promised that he would “sell at the beginning of the year and you’ll get your money.”
44. Quartararo routinely knowingly, or with reckless disregard, failed to provide the
investors with any evidence of any investment, refusing to show account statements or other proof
of the purported pre-IPO shares when asked by investors to do so.
45. Quartararo has continued to intentionally or with reckless disregard deceive his
investors regarding the true disposition of the funds they entrusted to him. To date, Quartararo has
not returned any of the investment funds to the investors, nor has he transferred any securities or
other assets to the investors.
11
FIRST CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)
(Quartararo)
46. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
47. Quartararo, directly or indirectly, singly or in concert, in the offer or sale of securities
and by the use of the means or instruments of transportation or communication in interstate
commerce or the mails, (1) knowingly or recklessly has employed one or more devices, schemes or
artifices to defraud, (2) knowingly, recklessly, or negligently has obtained money or property by
means of one or more untrue statements of a material fact or omissions of a material fact necessary
in order to make the statements made, in light of the circumstances under which they were made,
not misleading, and/or (3) knowingly, recklessly, or negligently has engaged in one or more
transactions, practices, or courses of business which operated or would operate as a fraud or deceit
upon the purchaser.
48. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has
violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].
SECOND CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(Quartararo)
49. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
50. Quartararo, directly or indirectly, singly or in concert, in connection with the
purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or
the mails, or the facilities of a national securities exchange, knowingly or recklessly has (i) employed
one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of a
material fact or omitted to state one or more material facts necessary in order to make the
12
statements made, in light of the circumstances under which they were made, not misleading, and/or
(iii) engaged in one or more acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon other persons.
51. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has
violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Unjust Enrichment
(Relief Defendants)
52. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
53. Investor funds were either directly paid to Relief Defendants or wrongly diverted to
Relief Defendants.
54. Private Equity Solutions and Leonard Quartararo directly obtained funds as alleged
above through investor checks made out to them, as part, and in furtherance, of the securities
violations alleged in paragraphs 13-45, and under circumstances in which it is not just, equitable or
conscionable for Private Equity Solutions and Leonard Quartararo to retain the funds. As a result
of the foregoing, relief defendants Private Equity Solutions and Leonard Quartararo were unjustly
enriched.
55. In addition, Leonard Quartararo, Casella and Eckert obtained funds diverted to them
as alleged above as part, and in furtherance, of the securities violations alleged in paragraphs 13-45,
and under circumstances in which it is not just, equitable or conscionable for Casella or Eckert to
retain the funds. As a result of the foregoing, relief defendants Leonard Quartararo, Casella and
Eckert were unjustly enriched.
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PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Quartararo and his agents, servants, employees and attorneys and all
persons in active concert or participation with any of them from violating, directly or indirectly,
Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Quartararo to disgorge all ill-gotten gains he received, directly or indirectly, with
pre-judgment interest thereon, as a result of the alleged violations;
III.
Ordering Quartararo to pay civil monetary penalties under 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)];
IV.
Ordering Relief Defendants to disgorge all investor funds unlawfully received by them by
which they were unjustly enriched, and to pay prejudgment interest thereon.
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VIII.
Granting any other and further relief this Court may deem just and proper.
Dated: New York, New York
April 27, 2021
RICHARD R. BEST
REGIONAL DIRECTOR
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
[email protected]
Richard R. best
Regional Director
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against Defendant Peter R. Quartararo (“Quartararo”) and Relief Defendants Private Equity Solutions, Inc. (“Private Equity Solutions”), Leonard Quartararo (“Leonard Quartar...
SUMMARY OF ALLEGATIONS
4. Quartararo instructed the investors to make out their checks to Leonard Quartararo, Quartararo’s father, or to Private Equity Solutions, a private company owned by Casella. Casella, who formerly worked in the securities industry, was barred by FIN...
5. Leonard Quartararo and Private Equity Solutions, in turn, made numerous payments that benefitted Quartararo, Quartararo’s girlfriend, Eckert, and other family members, including payments on a Maserati for Quartararo and Eckert.
VIOLATIONS
6. By virtue of the foregoing conduct and as alleged further herein, Defendant Quartararo has violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)]; Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15 ...
7. Unless Quartararo is restrained and enjoined, he will engage in the acts, practices, transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
8. The Commission brings this action pursuant to the authority conferred upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)], and Exchange Act Section 21(d) [15 U.S.C. § 78u(d)].
9. The Commission seeks a final judgment: (a) permanently enjoining Quartararo from violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering Quartararo to disgorge all ill-gotten gains he received as a resul...
JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa].
11. Quartararo, directly and indirectly, has made use of the means or instrumentalities of interstate commerce or of the mails in connection with the transactions, acts, practices, and courses of business alleged herein.
12. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa]. Quartararo resides in the Eastern District of New York, and certain of the acts, transactions, practices and cour...
DEFENDANT
13. Quartararo, age 56, resides in Glen Cove, New York. From April 2000 until September 2011, Quartararo worked as a registered representative for various brokerage firms. In 2013, FINRA found that Quartararo willfully violated Section 10(b) of the ...
40. Peloton completed its IPO in September 2019, and Airbnb completed its IPO in December 2020. WeWork announced that it was cancelling its planned IPO in September 2019. Despite his prior promises to the investors, Quartararo did not return any inv...
41. Instead, Quartararo, knowingly, or with reckless disregard, concealed and perpetuated his fraud by periodically promising the investors that he would sell the shares in the investments and give them their profits.
42. For example, in approximately June 2020, Quartararo knowingly, or with reckless disregard, falsely informed Investor A that he had 56 total investors in different pre-IPO investments, and further falsely promised Investor A that he had his “finger...
43. Similarly, in December 2020, Investors C and D spoke with Quartararo and demanded that Quartararo sell their shares. Quartararo then knowingly, or with reckless disregard, falsely promised that he would “sell at the beginning of the year and you’...
44. Quartararo routinely knowingly, or with reckless disregard, failed to provide the investors with any evidence of any investment, refusing to show account statements or other proof of the purported pre-IPO shares when asked by investors to do so.
45. Quartararo has continued to intentionally or with reckless disregard deceive his investors regarding the true disposition of the funds they entrusted to him. To date, Quartararo has not returned any of the investment funds to the investors, nor h...
Violations of Securities Act Section 17(a)
(Quartararo)
46. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
47. Quartararo, directly or indirectly, singly or in concert, in the offer or sale of securities and by the use of the means or instruments of transportation or communication in interstate commerce or the mails, (1) knowingly or recklessly has employe...
48. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(Quartararo)
49. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
50. Quartararo, directly or indirectly, singly or in concert, in connection with the purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or the mails, or the facilities of a national securities exchange,...
51. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Unjust Enrichment
(Relief Defendants)
52. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
53. Investor funds were either directly paid to Relief Defendants or wrongly diverted to Relief Defendants.
54. Private Equity Solutions and Leonard Quartararo directly obtained funds as alleged above through investor checks made out to them, as part, and in furtherance, of the securities violations alleged in paragraphs 13-45, and under circumstances in wh...
55. In addition, Leonard Quartararo, Casella and Eckert obtained funds diverted to them as alleged above as part, and in furtherance, of the securities violations alleged in paragraphs 13-45, and under circumstances in which it is not just, equitable ...
PRAYER FOR RELIEF
Dated: New York, New York
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
[email protected]OCR text (30,568c · textlayer · 95% conf)
RICHARD R. BEST
REGIONAL DIRECTOR
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
-against-
PETER R. QUARTARARO,
Defendant,
-and-
PRIVATE EQUITY SOLUTIONS, INC.,
LEONARD QUARTARARO, PAUL CASELLA,
and LISA ECKERT,
Relief Defendants.
COMPLAINT
21 Civ. _____ ( )
JURY TRIAL DEMANDED
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against
Defendant Peter R. Quartararo (“Quartararo”) and Relief Defendants Private Equity Solutions, Inc.
(“Private Equity Solutions”), Leonard Quartararo (“Leonard Quartararo”), Paul Casella (“Casella”),
and Lisa Eckert (“Eckert”) (together, “Relief Defendants”), alleges as follows:
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SUMMARY OF ALLEGATIONS
1. This matter involves a scheme by Quartararo to defraud investors by claiming that
he could sell them shares in well-known privately-held companies, which were expected to increase
in value when those companies completed their initial public offerings (“IPOs”). These
representations were false.
2. In the summer of 2019, Quartararo began soliciting an acquaintance and others to
invest through him in “pre-IPO” shares of several “unicorn” companies, including Peloton
Interactive, Inc. (“Peloton”) and Airbnb, Inc. (“Airbnb”). Over the next several months, Quartararo
convinced at least four individuals to invest at least approximately $436,000 in the purported pre-
IPO shares.
3. In truth, Quartararo – a former securities broker who had been previously barred by
the Financial Industry Regulatory Authority (“FINRA”) from working at any registered securities
brokerage firm – never purchased or held pre-IPO shares in these companies on behalf of the
investors. Instead, Quartararo stole the funds and used them for his personal benefit.
4. Quartararo instructed the investors to make out their checks to Leonard Quartararo,
Quartararo’s father, or to Private Equity Solutions, a private company owned by Casella. Casella,
who formerly worked in the securities industry, was barred by FINRA from associating with any
registered securities brokerage firm in 2008, and was convicted of federal racketeering charges in
2011.
5. Leonard Quartararo and Private Equity Solutions, in turn, made numerous payments
that benefitted Quartararo, Quartararo’s girlfriend, Eckert, and other family members, including
payments on a Maserati for Quartararo and Eckert.
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VIOLATIONS
6. By virtue of the foregoing conduct and as alleged further herein, Defendant
Quartararo has violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §
77q(a)]; Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule
10b-5 thereunder [17 C.F.R. § 240.10b-5].
7. Unless Quartararo is restrained and enjoined, he will engage in the acts, practices,
transactions, and courses of business set forth in this Complaint or in acts, practices, transactions,
and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
8. The Commission brings this action pursuant to the authority conferred upon it by
Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)], and Exchange Act Section
21(d) [15 U.S.C. § 78u(d)].
9. The Commission seeks a final judgment: (a) permanently enjoining Quartararo from
violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering
Quartararo to disgorge all ill-gotten gains he received as a result of the violations alleged here and to
pay prejudgment interest thereon pursuant to Exchange Act Section 21(d)(5) [15 U.S.C. § 78u(d)(5)]
and Sections 6501(a)(1) and (a)(3) of the National Defense Authorization Act for Fiscal Year 2021,
Pub. L. No. 116-283, to be codified at 15 U.S.C. §§ 78u(d)(3) and 78u(d)(7); (c) ordering Quartararo
to pay civil money 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)]; (d) ordering each of the Relief Defendants to
pay, with prejudgment interest, all ill-gotten gains by which they were unjustly enriched, under
Exchange Act Section 21(d)(5) [15 U.S.C. § 78u(d)(5)]; and (d) ordering any other and further relief
the Court may deem just and proper.
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JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a)
[15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa].
11. Quartararo, directly and indirectly, has made use of the means or instrumentalities of
interstate commerce or of the mails in connection with the transactions, acts, practices, and courses
of business alleged herein.
12. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and
Exchange Act Section 27 [15 U.S.C. § 78aa]. Quartararo resides in the Eastern District of New
York, and certain of the acts, transactions, practices and courses of business alleged herein took
place in the Eastern District of New York. Quartararo solicited investments from investors who
reside in the Eastern District of New York. Eckert and Casella’s residences, and Private Equity
Solutions’ principal place of business, are in the Eastern District of New York.
DEFENDANT
13. Quartararo, age 56, resides in Glen Cove, New York. From April 2000 until
September 2011, Quartararo worked as a registered representative for various brokerage firms. In
2013, FINRA found that Quartararo willfully violated Section 10(b) of the Exchange Act and Rule
10b-5 thereunder, along with several FINRA rules, when he solicited acquaintances with a penny
stock tip, but failed to invest the funds and provided false documents to the investors. That year,
Quartararo was permanently barred by FINRA from association with any FINRA-registered
brokerage firm.
RELIEF DEFENDANTS
14. Private Equity Solutions is a New York corporation located in Jericho, New York
and purports to offer debt restructuring services. Private Equity Solutions was established by
Casella in approximately September 2017.
Case 1:21-cv-02305 Document 1 Filed 04/27/21 Page 4 of 14 PageID #: 4
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15. Leonard Quartararo, age 78, is Quartararo’s father and resides in Staten Island,
New York.
16. Casella, age 54, resides in Woodbury, New York and is the owner of Private Equity
Solutions. In 2011, he was convicted on federal racketeering charges in connection with the
trafficking of women from Eastern Europe to work as exotic dancers. In 2008, Casella was barred
by FINRA from associating with any FINRA-registered brokerage firm after failing to pay sanctions
imposed by FINRA in connection with a customer complaint. Casella and Quartararo previously
worked together at Milestone Group Management LLC, a Lake Success, New York brokerage firm.
17. Eckert (formerly, Lisa Brownstein), age 45, is Quartararo’s girlfriend and resides in
Glen Cove, New York.
FACTS
I. QUARTARARO SOLICITED SHAM INVESTMENTS IN “PRE-IPO”
SHARES OF WELL KNOWN PRIVATE COMPANIES
18. In approximately July 2019, Quartararo commenced his scheme to defraud investors
when he approached an acquaintance, Investor A, with an alleged investment opportunity.
19. Quartararo told Investor A that he had previously acquired shares in the then-private
companies Airbnb and WeWork (formally known as The We Company, Inc.) (“WeWork”), both of
which were widely expected to be taken public through IPOs. (In fact, Quatararo had never
obtained shares of those prominent private companies.) Quartararo claimed that, to show his
appreciation for a favor that Investor A had done for Quartararo, Quartararo would sell some of the
pre-IPO shares to Investor A for $2 per share. Quartararo further claimed that, once the companies
went public, he would sell the shares and Investor A could keep all of the profits, less any capital
gains taxes.
20. Based on these representations, Investor A agreed to purchase the pre-IPO shares
and, on approximately August 5, 2019, gave Quartararo an initial payment of $96,000. At
Case 1:21-cv-02305 Document 1 Filed 04/27/21 Page 5 of 14 PageID #: 5
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Quartararo’s direction, Investor A wrote the check out to Private Equity Solutions, with the notation
“Stock Purchase IPO.”
21. In late August 2019, Quartararo told Investor A that he had access to pre-IPO shares
in a third company, Peloton, at prices between $1.80 and $2 per share. Based on Quartararo’s
representations, Investor A agreed to purchase the shares, and gave Quartararo a second check for
$71,000 on approximately August 29, 2019. In this case, Quartararo instructed Investor A to make
the check out to Leonard Quartararo. In the memo section of the check, Investor A wrote “Stock
Purchase.”
22. Several weeks later, in September 2019, Quartararo solicited a third investment of
$35,000 from Investor A, ostensibly for additional Peloton pre-IPO shares. In the memo section of
the check, Investor A wrote “Stock Purchase.” Once again, Quartararo instructed Investor A to
make the check out to Leonard Quartararo.
23. Investor A introduced several other acquaintances to Quartararo. First, Investor A
told his girlfriend, Investor B, about the opportunity, and Investor B invested $72,000 with
Quartararo in early September 2019. At Quartararo’s request, Investor B made the check out to
Private Equity Solutions.
24. Second, Investor A introduced Quartararo to his friends, Investor C and Investor D,
who are brothers. In approximately August or September 2019, Investors C and D met Quartararo
at a Starbucks in Jericho, New York and Quartararo repeated his claims about the pre-IPO shares.
Specifically, Quartararo claimed that he could sell Investors C and D pre-IPO shares in Airbnb,
Peloton and WeWork; that he would liquidate the shares once the companies completed their IPOs;
and that, after completing the necessary tax paperwork, he would pay out the profits and principal to
Investors C and D in approximately five to six months.
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25. Based on Quartararo’s representations, Investors C and D invested in the purported
pre-IPO shares. Investor C and Investor D each provided a check to Quartararo in the amount of
$81,000 on approximately September 29, 2019. Once again, Quartararo instructed Investors C and
D to make these checks out to Leonard Quartararo. Quartararo initially claimed that “Leonard” was
his legal name, but, when pressed by Investors C and D, admitted that Leonard was his father,
whom he said was involved in the investments.
26. In the memo line of his check, Investor C wrote the names of the companies in
which Investor C believed he was investing, and the amount of funds allocated to each company:
“43,500 Airbnb, 18,000 WeWorks [sic], 19,500 Pelaton [sic]”. Investor D wrote the same
information on his check.
27. Quartararo hand wrote and signed a “bill of sale” to Investors C and D, which
indicated the amount of shares they allegedly purchased and the amount of money they paid him:
[Investors C and D]
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II. QUARTARARO’S CLAIMS ABOUT THE INVESTMENTS WERE FALSE:
THE INVESTOR FUNDS WERE MISAPPROPRIATED FOR
QUARTARARO’S BENEFIT
28. As Quartararo knew, or recklessly disregarded, his claims about the purported pre-
IPO investments were false. Quartararo had no access to pre-IPO shares in these prominent private
companies and had never obtained such shares in prominent private companies prior to their IPOs.
Quartararo had no reasonable basis to tell investors he owned or could obtain such pre-IPO shares.
Quartararo did not use the investors’ funds to purchase pre-IPO shares of Airbnb, Peloton or
WeWork, nor did Quartararo ever hold any pre-IPO shares in these companies. Instead, Quartararo
misappropriated the investor funds for his benefit and the benefit of Relief Defendants, among
others.
A. Transfers from Private Equity Solutions to the Relief Defendants
29. As described above, the four investors gave Quartararo six personal checks for a
total of $436,000.00. Two of the checks, totaling $168,000, were made out to and deposited into a
Private Equity Solutions checking account, for which Casella is the only authorized signatory.
30. After the investor checks were deposited in the Private Equity Solutions account, a
significant amount of funds were transferred from that account to accounts connected to
Quartararo and the Relief Defendants.
31. For example, between approximately November 2019 and April 2020, $14,500 was
transferred from the Private Equity Solutions account to Eckert, Quartararo’s girlfriend.
32. Additionally, between approximately December 2019 and September 2020,
approximately $28,300 was transferred from the Private Equity Solutions account to Casella’s
personal bank account. In turn, between approximately May 2020 and July 2020, Casella’s personal
bank account transferred approximately $28,000 to Eckert.
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33. Leonard Quartararo also received funds from the Private Equity Solutions account.
A check from the Private Equity Solutions account dated November 22, 2019 for $12,500 was made
out to Leonard Quartararo and cleared December 16, 2019.
34. Other funds from the Private Equity Solutions account were used to pay for
personal items for Quartararo and Eckert. For example, on approximately October 30, 2019,
Private Equity Solutions paid $8,500 to a Long Island, New York car dealership for a down payment
on a Maserati. Registration documents for the vehicle show that it is registered to Eckert and owned
by Quartararo.
B. Withdrawals from the Leonard Quartararo Account
35. Four of the investors’ checks, totaling $268,000, were made out and deposited into
an account held by Leonard Quartararo.
36. After the investors’ checks were deposited in Leonard Quartararo’s account, the
majority of those funds were withdrawn from the account in cash. In total, at least $156,000 in cash
was withdrawn from the Leonard Quartararo account between the date of the first investor deposit
and January 27, 2021.
37. Many of these cash withdrawals were made almost immediately after the investors’
funds were deposited. For example, on August 30, 2019, Investor A’s $71,000 was deposited into
Leonard Quartararo’s account at 11:53 a.m., and $7,600 in cash was withdrawn from the account
two minutes later.
38. As another example, on October 4, 2019, Investor D’s $81,000 check was deposited
into Leonard Quartararo’s account at 12:07 p.m., and $9,000 in cash was withdrawn four minutes
later.
39. None of Private Equity Solutions, Leonard Quartararo, Casella or Eckert had any
legitimate claim to the investor funds that they received.
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III. QUARTARARO CONCEALED HIS FRAUD
40. Peloton completed its IPO in September 2019, and Airbnb completed its IPO in
December 2020. WeWork announced that it was cancelling its planned IPO in September 2019.
Despite his prior promises to the investors, Quartararo did not return any investment funds to the
investors after the Peloton or Airbnb IPOs.
41. Instead, Quartararo, knowingly, or with reckless disregard, concealed and
perpetuated his fraud by periodically promising the investors that he would sell the shares in the
investments and give them their profits.
42. For example, in approximately June 2020, Quartararo knowingly, or with reckless
disregard, falsely informed Investor A that he had 56 total investors in different pre-IPO
investments, and further falsely promised Investor A that he had his “finger on the trigger” and was
“close” to selling the shares.
43. Similarly, in December 2020, Investors C and D spoke with Quartararo and
demanded that Quartararo sell their shares. Quartararo then knowingly, or with reckless disregard,
falsely promised that he would “sell at the beginning of the year and you’ll get your money.”
44. Quartararo routinely knowingly, or with reckless disregard, failed to provide the
investors with any evidence of any investment, refusing to show account statements or other proof
of the purported pre-IPO shares when asked by investors to do so.
45. Quartararo has continued to intentionally or with reckless disregard deceive his
investors regarding the true disposition of the funds they entrusted to him. To date, Quartararo has
not returned any of the investment funds to the investors, nor has he transferred any securities or
other assets to the investors.
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FIRST CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)
(Quartararo)
46. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
47. Quartararo, directly or indirectly, singly or in concert, in the offer or sale of securities
and by the use of the means or instruments of transportation or communication in interstate
commerce or the mails, (1) knowingly or recklessly has employed one or more devices, schemes or
artifices to defraud, (2) knowingly, recklessly, or negligently has obtained money or property by
means of one or more untrue statements of a material fact or omissions of a material fact necessary
in order to make the statements made, in light of the circumstances under which they were made,
not misleading, and/or (3) knowingly, recklessly, or negligently has engaged in one or more
transactions, practices, or courses of business which operated or would operate as a fraud or deceit
upon the purchaser.
48. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has
violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].
SECOND CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(Quartararo)
49. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
50. Quartararo, directly or indirectly, singly or in concert, in connection with the
purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or
the mails, or the facilities of a national securities exchange, knowingly or recklessly has (i) employed
one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of a
material fact or omitted to state one or more material facts necessary in order to make the
Case 1:21-cv-02305 Document 1 Filed 04/27/21 Page 11 of 14 PageID #: 11
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statements made, in light of the circumstances under which they were made, not misleading, and/or
(iii) engaged in one or more acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon other persons.
51. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has
violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Unjust Enrichment
(Relief Defendants)
52. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 5 and 13 through 45.
53. Investor funds were either directly paid to Relief Defendants or wrongly diverted to
Relief Defendants.
54. Private Equity Solutions and Leonard Quartararo directly obtained funds as alleged
above through investor checks made out to them, as part, and in furtherance, of the securities
violations alleged in paragraphs 13-45, and under circumstances in which it is not just, equitable or
conscionable for Private Equity Solutions and Leonard Quartararo to retain the funds. As a result
of the foregoing, relief defendants Private Equity Solutions and Leonard Quartararo were unjustly
enriched.
55. In addition, Leonard Quartararo, Casella and Eckert obtained funds diverted to them
as alleged above as part, and in furtherance, of the securities violations alleged in paragraphs 13-45,
and under circumstances in which it is not just, equitable or conscionable for Casella or Eckert to
retain the funds. As a result of the foregoing, relief defendants Leonard Quartararo, Casella and
Eckert were unjustly enriched.
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PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Quartararo and his agents, servants, employees and attorneys and all
persons in active concert or participation with any of them from violating, directly or indirectly,
Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Quartararo to disgorge all ill-gotten gains he received, directly or indirectly, with
pre-judgment interest thereon, as a result of the alleged violations;
III.
Ordering Quartararo to pay civil monetary penalties under 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)];
IV.
Ordering Relief Defendants to disgorge all investor funds unlawfully received by them by
which they were unjustly enriched, and to pay prejudgment interest thereon.
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VIII.
Granting any other and further relief this Court may deem just and proper.
Dated: New York, New York
April 27, 2021
RICHARD R. BEST
REGIONAL DIRECTOR
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
[email protected]
Case 1:21-cv-02305 Document 1 Filed 04/27/21 Page 14 of 14 PageID #: 14
Richard R. best
Regional Director
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
(212) 336-0062 (Ellenbogen)
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against Defendant Peter R. Quartararo (“Quartararo”) and Relief Defendants Private Equity Solutions, Inc. (“Private Equity Solutions”), Leonard Quartararo (“Leonard Quartar...
SUMMARY OF ALLEGATIONS
4. Quartararo instructed the investors to make out their checks to Leonard Quartararo, Quartararo’s father, or to Private Equity Solutions, a private company owned by Casella. Casella, who formerly worked in the securities industry, was barred by FIN...
5. Leonard Quartararo and Private Equity Solutions, in turn, made numerous payments that benefitted Quartararo, Quartararo’s girlfriend, Eckert, and other family members, including payments on a Maserati for Quartararo and Eckert.
VIOLATIONS
6. By virtue of the foregoing conduct and as alleged further herein, Defendant Quartararo has violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)]; Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15 ...
7. Unless Quartararo is restrained and enjoined, he will engage in the acts, practices, transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
8. The Commission brings this action pursuant to the authority conferred upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)], and Exchange Act Section 21(d) [15 U.S.C. § 78u(d)].
9. The Commission seeks a final judgment: (a) permanently enjoining Quartararo from violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering Quartararo to disgorge all ill-gotten gains he received as a resul...
JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa].
11. Quartararo, directly and indirectly, has made use of the means or instrumentalities of interstate commerce or of the mails in connection with the transactions, acts, practices, and courses of business alleged herein.
12. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)], and Exchange Act Section 27 [15 U.S.C. § 78aa]. Quartararo resides in the Eastern District of New York, and certain of the acts, transactions, practices and cour...
DEFENDANT
13. Quartararo, age 56, resides in Glen Cove, New York. From April 2000 until September 2011, Quartararo worked as a registered representative for various brokerage firms. In 2013, FINRA found that Quartararo willfully violated Section 10(b) of the ...
40. Peloton completed its IPO in September 2019, and Airbnb completed its IPO in December 2020. WeWork announced that it was cancelling its planned IPO in September 2019. Despite his prior promises to the investors, Quartararo did not return any inv...
41. Instead, Quartararo, knowingly, or with reckless disregard, concealed and perpetuated his fraud by periodically promising the investors that he would sell the shares in the investments and give them their profits.
42. For example, in approximately June 2020, Quartararo knowingly, or with reckless disregard, falsely informed Investor A that he had 56 total investors in different pre-IPO investments, and further falsely promised Investor A that he had his “finger...
43. Similarly, in December 2020, Investors C and D spoke with Quartararo and demanded that Quartararo sell their shares. Quartararo then knowingly, or with reckless disregard, falsely promised that he would “sell at the beginning of the year and you’...
44. Quartararo routinely knowingly, or with reckless disregard, failed to provide the investors with any evidence of any investment, refusing to show account statements or other proof of the purported pre-IPO shares when asked by investors to do so.
45. Quartararo has continued to intentionally or with reckless disregard deceive his investors regarding the true disposition of the funds they entrusted to him. To date, Quartararo has not returned any of the investment funds to the investors, nor h...
Violations of Securities Act Section 17(a)
(Quartararo)
46. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
47. Quartararo, directly or indirectly, singly or in concert, in the offer or sale of securities and by the use of the means or instruments of transportation or communication in interstate commerce or the mails, (1) knowingly or recklessly has employe...
48. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(Quartararo)
49. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
50. Quartararo, directly or indirectly, singly or in concert, in connection with the purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or the mails, or the facilities of a national securities exchange,...
51. By reason of the foregoing, Quartararo, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
THIRD CLAIM FOR RELIEF
Unjust Enrichment
(Relief Defendants)
52. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 5 and 13 through 45.
53. Investor funds were either directly paid to Relief Defendants or wrongly diverted to Relief Defendants.
54. Private Equity Solutions and Leonard Quartararo directly obtained funds as alleged above through investor checks made out to them, as part, and in furtherance, of the securities violations alleged in paragraphs 13-45, and under circumstances in wh...
55. In addition, Leonard Quartararo, Casella and Eckert obtained funds diverted to them as alleged above as part, and in furtherance, of the securities violations alleged in paragraphs 13-45, and under circumstances in which it is not just, equitable ...
PRAYER FOR RELIEF
Dated: New York, New York
Lara Shalov Mehraban
Vanessa De Simone
Bennett Ellenbogen
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, New York 10281-1022
[email protected]