==========================================START OF PAGE 1====== UNITED STATES SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 14908 / May 13, 1996 SECURITIES AND EXCHANGE COMMISSION v. RANDALL E. BRADBURY, THE BRADBURY FINANCIAL GROUP, INC., and TBFG INTERNATIONAL, LTD., 96 CIV. 758 (RSP) (N.D.N.Y.) The Securities and Exchange Commission announced the filing of a Complaint on May 13, 1996 in the United States District Court for the Northern District of New York, alleging a series of frauds which netted approximately $414,000 in ill-gotten gains for an investment adviser and companies he controlled. Named as defendants were: ù Randall E. Bradbury ("Bradbury"), age 37, an investment adviser and former resident of Syracuse, New York, who fled the United States in 1994; ù The Bradbury Financial Group Inc. ("BFG"), a New York corporation and registered investment adviser owned by Bradbury, which was located in Whitesboro, New York; and ù TBFG International, Ltd. ("TBFG"), a Wyoming corporation controlled by Bradbury, which was located in Whitesboro, New York, and purportedly sought to engage in trade with, financing for, and consulting to developing businesses in Russia and other newly independent states of the former Soviet Union. The Commission's Complaint alleges as follows: From at least February 1992 through approximately February 1994, Bradbury and his companies defrauded 80 investors by making materially false and misleading statements concerning the issuers of securities that Bradbury recommended and/or sold. Bradbury also failed to disclose material conflicts of interest with respect to certain investments, recommended unsuitable investments, and acted as an unregistered broker-dealer. Many of Bradbury's victims were retirees and other persons of limited means, and many of them met Bradbury through an evangelical church group. The investments are now worthless. Bradbury sold and recommended stock in Carib Med, Inc. ("Carib Med"), a now defunct developmental pharmaceutical company also known as H. E. Stanley Pharmaceuticals, Inc., to advisory clients and other investors. Among other things, Bradbury made false and misleading statements concerning the anticipated appreciation of the stock price and omitted material information concerning Carib Med's poor financial condition. Bradbury failed to disclose to investors that he was selling them his own shares ==========================================START OF PAGE 2====== of Carib Med stock and failed to disclose his receipt of commissions from the sale of securities of two other now defunct start-up companies, Advanced Financial Group, Inc. ("AFG") and International Consumers Bureau, as well as the fact that AFG was Bradbury's brother's company. In addition, Bradbury and TBFG fraudulently induced investors to purchase TBFG stock, bonds, and notes by making false and misleading statements concerning TBFG's purported plans to make a public offering, TBFG's financial condition, and the status of TBFG's purported projects -- which supposedly included, among other things, gold mining, development and upgrading of telecommunications systems, and the export - 2 - of caviar. Bradbury and TBFG also defrauded investors by disseminating financial projections which predicted millions of dollars in profits without any reasonable basis, and by failing to disclose the numerous hurdles that would have to be overcome before any of TBFG's purported projects could result in actual revenues for TBFG. TBFG never completed arrangements for financing any of its supposed major projects, and never earned more than several hundred dollars in revenue, all from importation and sale of Russian craft items. The Complaint charges all three defendants with violating Section 17(a) of the Securities Act of 1933 ("Securities Act"), and Section 10(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Rule 10b-5 thereunder, and charges Bradbury and BFG with also violating Sections 15(a) and (c) of the Exchange Act and Rules 10b-3, 10b-10 and 15c1-2 thereunder, and Sections 206(1), (2), and (3) of the Investment Advisers Act of 1940, and seeks permanent injunctive relief, disgorgement, and civil penalties.