Is this the same Joe Cillo as
the CEO of this company? Thanks...
COMPLAINT
Plaintiff, United States Telecommunications, Inc., sues defendants,
Joseph P. Cillo, Richard Inzer, Joseph Thacker, Prime Equities Group, Inc., GIRI
Holdings, Raymond Beam, and Captive Administrators, Inc., and alleges:
I. INTRODUCTION:
Beginning in 1996, defendants devised and implemented a fraudulent
scheme to enrich themselves and their associates by illegally selling, at
grossly inflated prices using boiler-room tactics, securities in plaintiff,
United States Telecommunications, Inc. and its predecessor entities (the
"COMPANY"). Directly and indirectly through the defendant entities, the
individual defendants defrauded the Company and its shareholders out of millions
of dollars and millions of
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shares of the Company's stock. Pursuant to the defendants' scheme, public
investors paid an aggregate purchase price of approximately $31,000,000 for
securities in the Company, of which only approximately $6,450,000 was ever
received by the Company. The remaining $24,500,000 paid by investors was
retained by the defendants and other unlicensed brokers and facilitators the
defendants involved in their fraudulent scheme. In addition to the proceeds they
siphoned off of the securities sales, the Company also believes that defendants
Joseph Cillo and Richard Inzer, through a series of shell entities and off-shore
corporations, granted themselves approximately 10 million shares of the
Company's stock without consideration. Those shares equate to nearly 22% of the
Company shares currently outstanding.
To further their scheme, the individual defendants served at various
times as incorporators, promoters, officers and/or directors of the Company.
Defendant Cillo also served as compliance officer and de facto legal counsel for
the Company and was charged with overseeing the offer and sale of securities in
the Company. In those capacities, the defendants owed fiduciary duties of care
and loyalty to the Company and its investors. In breach of those duties, the
individual defendants, among other wrongful and illegal acts, used their
positions and engaged in a pattern of deceit and illegal activity to conceal and
perpetuate their scheme from the Company and its investors, aided and abetted
the illegal offer and sale of securities in the Company, and engaged in
self-dealing to enrich themselves and their associates at the expense of the
Company and its investors. Despite serving as compliance officer and de facto
legal counsel for the Company, defendant Cillo failed to disclose that he had
voluntarily surrendered his license to practice law in Florida and was the
subject of at least four separate permanent injunctions entered respectively by
California, Utah and three by the United States Securities and Exchange
Commission (the