The complaint alleges that during all times material to this action, the Defendants solicited investments from Plaintiffs and others both individually and through Concept$, Consortium, and various "investment clubs" to promote and perpetuate the Ponzi scheme.
In violation of federal securities laws and the common law, Defendants all knowingly, or with reckless disregard, made material misrepresentations and, more significantly, failed to disclose material information to Plaintiffs, including the primary omissions that form the heart of the claims herein, namely the Defendants' failure to inform Plaintiffs that: (a) any and all investment returns depended on the contribution of moneys from new investors; and (b) that Defendants intended simply to steal Plaintiffs' moneys pursuant to an illegal Ponzi scheme.
On July 22, 2009, an order granting plaintiffs’ motion to stay and order of administrative close-out was entered into the Court’s record. This proceeding shall be stayed pending resolution of the parallel civil proceeding. This order was entered without prejudice for the plaintiffs to seek dissolution of the stay and re-opening of this case upon notice to all parties and good cause shown.