The allegations read: Client alleges, among other things, unsuitability; respondeat superior/apparent authority liability for violations of section 10(b) of the securities exchange act of 1934 and rule 10b-5; control person liability for violations of section 10(b) of the securities exchange act of 1934 and rule 10b-5; respondeat superior/control person liability for violations of section 404(a)(1) of the the employee retirement income security act of 1974 and direct liability for its violations of section 404(a)(1); respondeat superior/apparent authority liability for violation of section 890(a)(2) the uniform securities act of puerto rico; control person liability for violation of section 890 (b) the uniform securities act of puerto rico; respondeat superior/apparent authority liability for violations of regulation 6078 and direct liability for its violations of regulation 6078; and breach of contract (puerto rico bonds and closed-end funds). Includes request for disgorgement of profits, interests, fees, and punitive damages.