UNITED DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

In re: 

UNITED STATES SECURITIES AND 

EXCHANGE COMMISSION, 

 Plaintiff, 

v. 

JOHN J. BRAVATA, RICHARD J. 

TRABULSY, ANTONIO M. BRAVATA, 

BBC EQUITIES, LLC, BRAVATA 

FINANCIAL GROUP, LLC and SHARI A. 

BRAVATA, 

 Defendants. 

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Case No. 2:09-cv-12950-DML-VMM 

Honorable David M. Lawson 

RECEIVER’S MOTION FOR AUTHORITY UNDER HUNTINGTON ORDERS

 

Earle I. Erman, Receiver of BBC Equities, Inc. and Bravata Financial Group, files this 

Motion For Authority Under Huntington Orders (“Receiver’s Motion”) and states as follows: 

1. On July 26, 2009, the United States Securities and Exchange Commission (the 

“SEC”) commenced a lawsuit in this Court against John J. Bravata, Richard J. Trabulsy, Antonio 

M. Bravata, BBC Equities, LLC (“BBC”), Bravata Financial Group, LLC (“Bravata”) and Shari 

A. Bravata. In its Complaint the SEC alleges that the BBC/Bravata Defendants engineered and 

executed a scheme to defraud investors in violation of the Securities Act of 1933, the Securities 

Exchange Act of 1934, and various regulations promulgated under that legislation. 

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Case 2:09-cv-12950-DML-VMM Document 213 Filed 01/22/2010 Page 1 of 6
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2. On September 2, 2009, this Court entered the Receivership Order appointing 

Earle I. Erman (“Receiver”) as the Receiver of BBC Equities, Inc. and Bravata Financial Group 

LLC (“Receivership Entities”). The Receivership Order is preliminary and granted the Receiver 

the powers, authorities, rights, and privileges described within the order necessary to marshal and 

preserve the assets of the Receivership Entities and to prepare a report reflecting the existence, 

value, and location of all assets and liabilities of the Receivership Entities (the “Interim Report”). 

3. On December 4, 2009, Receiver filed his Motion to Abandon Huntington Real 

Property and Request to Expedite the Date By Which Any Party Must Object to the Request for 

Relief to December 11, 2009 (the “Huntington Motion”). 

4. No party objected to the Huntington Motion. 

5. On January 13, 2010, this Court entered: 1) Order Granting the Receiver’s Motion 

to Abandon the Huntington Property in Ashland, Ohio and Amending the Temporary Restraining 

order, the Preliminary Injunction Order and the Order Appointing Receiver to Exclude the 

Huntington Property In Ashland, Ohio (the “Huntington Amberwood Order”); 2) Order 

Amending Temporary Restraining Order, Preliminary Injunction and Order Appointing Receiver 

in Regard to Certain Properties Located in Ohio and Florida Subject to Mortgages Held by 

Huntington National Bank (the “Huntington Timberstone Order”); and 3) the Order Granting the 

Receiver’s Motion to Abandon Huntington P&R and Rockland Property and Amending the 

Temporary Restraining Order, the Preliminary Injunction Order and the Order Appointing 

Receiver to Exclude the P& R and Rockland Properties Mortgaged to the Huntington National 

Bank (the “Huntington P&R and Rockland Properties”). 

Case 2:09-cv-12950-DML-VMM Document 213 Filed 01/22/2010 Page 2 of 6
6. Pursuant to the Huntington Timberstone Order, the Huntington P&R Rockland 

Order and the Huntington Amberwood Order, the Receiver is authorized to provide an 

accounting to Huntington for the rents and other proceeds of the Huntington Abandoned 

Properties that are now, or hereafter come into, his possession or control (the “Accounting”)(Tab 

1). Huntington Timberstone Order, ¶ 4, the Huntington P&R Rockland Order ¶ 4 and the 

Huntington Amberwood Order ¶ 4. 

7. The Receiver is also authorized to turnover to Huntington rents that come into the 

possession of the Receiver after January 13, 2010. Huntington Timberstone Order, ¶ 2, the 

Huntington P&R Rockland Order ¶ 2 and the Huntington Amberwood Order ¶ 2. 

8. The Receiver has provided the Accounting to Huntington through January 13, 

2010. Accordingly, the Receiver requests authority to turnover to Huntington the rents identified 

in the Accounting. 

9. Huntington and the Receiver negotiated payment to the Receiver by Huntington 

to reimburse Erman Teicher and O’Keefe & Associates for certain administrative expenses of the 

investigation, review and analysis related to entry of the Huntington Timberstone Order, the 

Huntington P&R Rockland Order and the Huntington Amberwood Order. Erman Teicher and 

O’Keefe shall deduct the fees compensated by Huntington from future fee applications made in 

this matter by the Receiver and the Financial Advisor. 

10. The fees are as follows: 1) Huntington Timberstone Order $7,287.50 and 

$6,443.00; 2) Huntington P&R Rockland Order $13,245.00 and $10,000; and 3) Huntington 

Amberwood Order $1,917.50 and $2,956.00. Huntington Timberstone Order, ¶ 5, the Huntington 

P&R Rockland Order ¶ 5 and the Huntington Amberwood Order ¶ 10. 

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11. Accordingly, the Receiver requests authority to pay $22,450.00 to Erman Teicher 

and $19,399.00 to O’Keefe and Associates. 

12. The Receiver requests this Court enter an order in the form attached as Tab 2 

13. The Receiver has sought concurrence from counsel for the Bravata Defendant and 

counsel for the SEC. Counsel for the SEC does not oppose the Motion. Receiver’s counsel left a 

message for the Bravata Defendants’ counsel but has not heard back from him. 

Respectfully submitted, 

 BODMAN LLP 

By: s/Jane Derse Quasarano___________________ 

F. Thomas Lewand (P16619) 

tlewand@bodmanllp.com 

Robert J. Diehl (P31264) 

rdiehl@bodmanllp.com 

Jane Derse Quasarano (P45514) 

jquasarano@bodmanllp.com 

Alan N. Harris (P56324) 

aharris@bodmanllp.com 

6th Floor at Ford Field 

1901 St. Antoine Street 

Detroit, Michigan 48226 

(313) 259-7777 

Attorneys for Receiver 

January 22, 2010. 

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UNITED DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

In re: 

UNITED STATES SECURITIES AND 

EXCHANGE COMMISSION, 

 Plaintiff, 

v. 

JOHN J. BRAVATA, RICHARD J. 

TRABULSY, ANTONIO M. BRAVATA, 

BBC EQUITIES, LLC, BRAVATA 

FINANCIAL GROUP, LLC and SHARI A. 

BRAVATA, 

 Defendants. 

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Case No. 2:09-cv-12950-DML-VMM

Honorable David M. Lawson 

BRIEF IN SUPPORT OF RECEIVER’S MOTION 

FOR AUTHORITY UNDER HUNTINGTON ORDERS

Earle I. Erman, Receiver of BBC Equities, Inc. and Bravata Financial Group, files this 

Brief in Support of his Motion authority Under the Huntington Orders and relies on the Federal 

Rules of Civil Procedures, the terms of the Receivership Order, this Court’s prior orders and 

applicable law. 

 Respectfully submitted, 

 BODMAN LLP 

By: s/Jane Derse Quasarano___________________ 

F. Thomas Lewand (P16619) 

tlewand@bodmanllp.com 

Robert J. Diehl (P31264) 

rdiehl@bodmanllp.com 

Jane Derse Quasarano (P45514) 

jquasarano@bodmanllp.com 

Alan N. Harris (P56324) 

aharris@bodmanllp.com 

6th Floor at Ford Field, 1901 St. Antoine Street 

Detroit, Michigan 48226 

(313) 259-7777 

Attorneys for Receiver 

January 22, 2010 

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UNITED DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

In re: 

UNITED STATES SECURITIES AND 

EXCHANGE COMMISSION, 

 Plaintiff, 

v. 

JOHN J. BRAVATA, RICHARD J. 

TRABULSY, ANTONIO M. BRAVATA, 

BBC EQUITIES, LLC, BRAVATA 

FINANCIAL GROUP, LLC and SHARI A. 

BRAVATA, 

 Defendants. 

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Case No. 2:09-cv-12950-DML-VMM 

Honorable David M. Lawson 

CERTIFICATE OF SERVICE 

The undersigned certifies that on January 22, 2010 Receiver’s Motion for Authority 

Under Huntington Orders, Brief in Support and this Certificate of Service was electronically 

filed with the Clerk of the Court for the United States District Court, Eastern District of 

Michigan, Southern Division using the CM/ECF System, which will send notification of such 

filing to all attorneys and parties of record registered electronically. 

/s/ Jane Derse Quasarano 

Bodman LLP 

6th Floor at Ford Field 

1901 St. Antoine Street 

Detroit, Michigan 48226 

Phone: (313) 259-7777 

Fax: (313) 393-7579 

Email: jquasarano@bodmanllp.com 

Attorney for Receiver, Earle I. Erman 

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