The allegations read: Claimants began investing with respondent pellegrino in or around 2012. In or around june 2017, pellegrino recommended that claimants consider investing in 1st global capital short-term notes which was an unsuitable recommendation and investment for the claimants. Pellegrino pursued an unsuitable investment strategy in claimants' accounts through material misrepresentations and omissions in disregard of claimants' rights, interests and investment objectives.
