The allegations read: Client alleges unsuitability, over-concentration, breach of contract and warranties, promissory estoppel, violations of securities laws and rules, fault, negligence, breach of duties of good faith, fair dealing and care, breach of fiduciary duty and duty of officious manager, fraud, misrepresentation, omission and violations of common law (puerto rico closed-end funds and bonds). Includes request for punitive damages, interest, costs and fees, rescission and disgorgement.