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. 

 / 

Case No. 09-12950 

Honorable David M. Lawson 

RECEIVER’S MOTION FOR TURNOVER 

OF FERRARI TITLE AND TO COMPEL JOHN BRAVATA TO APPEAR 

FOR EXAMINATION TO ENABLE RECEIVER TO LOCATE AND SECURE ASSETS

 

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

Motion for Turnover of Ferrari Title and to Compel John Bravata to Appear for Examination to 

Enable Receiver to Locate and Secure Assets 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 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 1 of 8
Exchange Act of 1934, and various regulations promulgated under that legislation. A preliminary 

injunction hearing in the SEC enforcement action is now scheduled for October 21, 2009. 

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 (collectively, the “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”). The issue of the ongoing scope of the Receivership will also be 

addressed at the hearing on October 21, 2009. 

3. On September 11, 1009, the SEC filed its Motion for An Order to Show Cause 

Why Defendant John Bravata Should Not Be Adjudicated in Civil Contempt for Violating the 

Court’s Asset Freeze Orders (the “Contempt Motion”). The SEC alleged that John Bravata drew 

down loans against life insurance policies in violation of the Asset Freeze Order. 

4. This Court scheduled a show cause hearing on October 1, 2009. 

5. In his response to the Contempt Motion, John Bravata admitted that, on August 

10, 2009, he drew loans on the life insurance policies in violation of the Asset Freeze Order. 

6. Under the Receivership Order, the Receiver is obligated to marshal assets and to 

take such actions as necessary and appropriate for the preservation of Receivership Property (as 

defined in paragraph 6(A) of the Receivership Order) or to prevent the dissipation or 

concealment of Receivership Property. 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 2 of 8
7. The Receiver filed a Statement with respect to the Contempt Motion (the 

“Receiver’s Statement”) noting that violation of the Asset Freeze Order potentially dissipates 

Receivership Property. 

8. The Receiver requested that this Court order John J. Bravata to immediately 

transfer the Ferrari, the Storage Locker Property and the Motor City Property ( each as defined in 

the Receiver’s Statement and collectively referred to as “Bravata’s Property”) to the Receiver 

pending the hearing on October 21, 2009. 

9. At the hearing, although the Court indicated that it would not order Mr. Bravata to 

turnover possession of Bravata’s Property to the Receiver, the Court did order that Mr. Bravata 

allow the Receiver to locate and review the property. 

10. The Receiver noted that the whereabouts of the Ferrari were unknown and the 

Court questioned Mr. Bravata regarding this issue. Mr. Bravata testified that the Ferrari had been 

located at his residence in Brighton, Michigan, but, approximately one month ago, his friend Les 

Lucas picked up the Ferrari. See Transcript, Tab 1. 

11. The Court ordered Mr. Bravata to provide the Receiver with contact information 

for Mr. Lucas before he left the Court that day. 

12. On October 5, 2009, the Court entered an Order (the “Court Order”) compelling 

the Receiver to locate and secure Bravata’s Property and compelling Defendants to assist the 

Receiver in locating and securing the property. Tab 2. 

13. Although Mr. Lucas eventually (he cancelled the first appointment) met with an 

attorney from the Receiver’s office, David, Miller, Mr. Lucas refused to disclose where the 

Ferrari was stored or allow Mr. Miller to view the Ferrari at its storage location. Affidavit of 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 3 of 8
David Miller, Tab 3. Instead Mr. Miller and Mr. Lucas met at a Wendy’s Restaurant in Monroe, 

Michigan. 

14. Contrary to Mr. Bravata’s testimony, Mr. Lucas stated that he been in possession 

of the Ferrari since February, 2009. Mr. Lucas stated that he had done work on the car, was owed 

money and was asserting a lien on the property. Id. 

15. Mr. Lucas also stated that he was in possession of the title to the Ferrari but would 

not show it to the Receiver unless John Bravata instructed him to do so. Mr. Miller told Mr. 

Lucas that the Receiver wanted to review the front and back of original Ferrari title. Id.

16. Subsequently, John Bravata’s counsel, Mr. Bartko, informed the Receiver that the 

Ferrari had been moved from Les Lucas’ Monroe storage facility back to John Bravata’s 

Brighton home. After much effort, Joe Bravata (John Bravata’s brother) agreed to meet Mr. 

Miller there to allow Mr. Miller to ensure that the Ferrari was “secure” as required by the Court 

Order. Joe Bravata did not bring a copy of the title to the Ferrari for Mr. Miller to review. The 

Ferrari is being stored outside in John Bravata’s driveway covered only by a tarp. Tab 3. 

17. The Receiver is concerned that transfer of physical possession of the Ferrari to 

Les Lucas, Mr. Lucas’ possession of the title and the refusal to allow the Receiver to view the 

original title indicates that the Ferrari has been sold. The Ferrari is also now being stored in an 

open driveway covered only by a tarp. 

18. In addition to issues relating to the Ferrari, the Storage Locker Property was 

moved from the Whitmore Lake storage facility. The boat, two vehicles, jetskis and trophy 

animals have been moved. John Bravata also now claims that the boat stored there is the 

property of his brother Joe Bravata. This is in conflict with a statement by Joe Bravata’s counsel 

that Joe Bravata does not own any watercraft. Tab 4. John Bravata has not produced insurance 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 4 of 8
for the boat which might indicate ownership. Additionally, John Bravata’s inventory of the items 

that were allegedly moved still does not identify the two jetskis. 

19. The Receiver has expended a great deal of effort, time and money attempting to 

locate and secure Bravata’s Property as required by this Court’s order. Because Mr. Bravata has 

refused to produce the title to the Ferrari, because property has been removed from the storage 

facility, because Bravata only responds partially to inquiries necessitating a great deal of time 

and effort, this Court should order John Bravata to turnover the title to the Ferrari, turnover 

possession of the Ferrari and to personally appear for an examination in a room at the courthouse 

with respect to property subject to the Asset Freeze Order. The examination should be scheduled 

at a time when the parties can contact this Court to resolve disputes regarding the scope of the 

examination. 

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 

October 9, 2009 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 5 of 8
Detroit_959078_4 

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. 

 / 

Case No. 09-12950 

Honorable David M. Lawson 

BRIEF IN SUPPORT OF RECEIVER’S MOTION FOR TURNOVER 

OF FERRARI TITLE AND TO COMPEL JOHN BRAVATA TO APPEAR 

FOR EXAMINATION TO ENABLE RECEIVER TO LOCATE AND SECURE ASSETS 

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

Brief in Support of his Motion for Turnover of Ferrari Title and to Compel John Bravata to 

Appear for Examination to Enable Receiver to Locate and Secure Assets and relies on the 

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

and applicable law. 

 

Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 6 of 8
 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 

October 9, 2009 

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Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 7 of 8
Detroit_959078_4 

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. 

 / 

Case No. 09-12950 

Honorable David M. Lawson 

CERTIFICATE OF SERVICE 

The undersigned certifies that on October 9, 2009 Receiver’s Motion for Turnover of 

Ferrari Title and to Compel John Bravata to Appear for Examination to Enable Receiver to 

Locate and Secure Assets 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 

Case 2:09-cv-12950-DML-VMM Document 89 Filed 10/09/2009 Page 8 of 8