Gary is a litigator and trial attorney who has represented clients in federal and state courts across the country, and he is a former senior officer of the Securities and Exchange Commission (SEC) with rare cradle-to-grave experience leading both pre-filing investigations by the SEC as well as the litigation of the SEC’s contested, and most difficult, cases to summary judgment or jury verdict in federal court. He brings deep enforcement experience, complex civil litigation, and trial skills to clients navigating government investigations and regulatory inquiries, capital markets compliance issues, enforcement actions by the government, and high-stakes commercial litigation.
Securities Enforcement and Regulatory Counseling
In his last government role, Gary served as an Associate Director of the SEC’s Division of Enforcement and Regional Director of the SEC’s Los Angeles Regional Office. As co-chief of the Los Angeles office’s enforcement program and the regional director for operations at the SEC’s third-largest regional office, he supervised more than 70 investigative attorneys, litigators, and enforcement accountants responsible for investigating and litigating federal securities law violations across Southern California, Arizona, Nevada, Hawaii, and Guam. He collaborated with SEC staff across the agency’s regulatory divisions, its regional offices, and at the SEC’s home office in Washington, D.C. Gary’s investigative docket included matters concerning public company financial reporting and disclosure, securities registration and offering fraud, insider trading, market manipulation, private funds, investment advisers and broker-dealers, anti-money laundering enforcement, and the Foreign Corrupt Practices Act. Gary also has significant experience conducting parallel investigations with the Department of Justice, FBI, Commodity Futures Trading Commission, FinCEN, and state and foreign regulators.
Asset Management Enforcement and Regulation
Earlier in his government service, Gary’s enforcement docket focused on the asset management industry. He was previously an Assistant Director in the SEC Enforcement Division’s specialized Asset Management Unit, and in that role, he supervised teams of investigative attorneys, industry experts, and enforcement accountants focused on investment adviser misconduct and other regulatory violations involving registered investment companies (mutual funds, closed-end funds/BDCs, and ETFs), private funds (private equity, venture capital, real estate, and hedge funds), and separately managed accounts. When working matters for that specialized unit, Gary closely collaborated with the SEC’s Division of Investment Management and Division of Examinations.
Government and Private Securities Litigation
Gary’s SEC tenure also included a leadership role in the SEC’s trial unit. As the Los Angeles office’s Regional Trial Counsel, he supervised all litigated enforcement actions brought by that regional office from filing to jury verdict and led its emergency action practice, securing temporary restraining orders and preliminary injunctions to halt fraudulent securities offerings, freeze assets, and appoint equity receivers for the benefit of defrauded investors.
Gary began his SEC career as a trial attorney and he litigated dozens of cases in California, Hawaii, Nevada, Arizona, and New York federal courts involving financial accounting and non-accounting issuer disclosure fraud, insider trading, investment adviser breaches of fiduciary duty, securities registration violations, and securities offering frauds. In his time with the SEC’s trial unit, he tried SEC enforcement actions to jury verdict and bench decision, he deposed or defended at deposition 100+ defendants, relief defendants, fact witnesses, and expert witnesses, and he briefed and argued scores of motions on the pleadings, discovery motions, summary judgment motions, motions in limine, Daubert motions, remedies motions, and ex parte applications for emergency injunctive relief.
Prior to joining the SEC, Gary was a member of the McGuireWoods team who defended a multi-district litigation that consolidated putative class actions for securities fraud, breach of fiduciary duty under ERISA, and shareholder derivative claims arising from an alleged fraudulent financial reporting and executive looting scheme by management of an international conglomerate.
Complex Commercial Litigation
Before his government service, Gary was a partner at McGuireWoods, where he litigated complex commercial matters in jurisdictions across the nation. His commercial litigation matters included class action defense of FCRA and FACTA claims, patent infringement matters involving foundry, lamination, and mechanical support technologies, defense of false patent marking claims, trademark counterfeiting and unfair competition, commercial litigation over breaches of drug development agreements, patent licenses, natural resources royalty contracts, and intellectual property transfer agreements, and labor and employment disputes involving non-competition covenants.
Gary began his legal career as a business litigation and appellate attorney in Chicago.
Gary’s Experience in Government includes:
Enforcement Litigation
- Supervised trial unit that defeated every Rule 12(b)(6) motion to dismiss filed in a Los Angeles Regional Office matter during tenure as Regional Trial Counsel.
- As lead trial counsel, litigated SEC v. Liu, the enforcement action that resulted in a seminal Supreme Court decision on SEC disgorgement, in the original district court proceeding and on remand from the Supreme Court, eventually obtaining securities fraud findings and monetary remedies in excess of $26 million.
- As lead trial counsel, charged foreign national with realizing $35 million in profits through insider trading in advance of two market-moving acquisition events, secured emergency freeze of brokerage accounts at filing and defeated serial defense efforts to modify freeze during pendency of the seven-year litigation, defeated defense motions for summary judgment, obtained default judgment as sanction for trader’s persistent discovery misconduct, and secured a $39.5 million civil monetary penalty, the largest funded insider trading settlement against an individual trader obtained by the SEC in decades.
- As lead trial counsel, litigated enforcement action involving fraudulent options cherry-picking scheme by investment adviser with $10 billion in assets under management.
- As lead trial counsel, litigated financial accounting fraud action arising from mandate by c-level executives to falsify books and records for purpose of prematurely recognizing revenue in violation of GAAP for multi-element arrangements.
- As lead trial counsel, litigated insider trading case against broker dealer registered representative who assisted public company executive in creating off-shore nominee brokerage accounts used to insider trade, and then piggybacked that executive’s illegal trades in a nominee account of his own.
- As lead trial counsel, litigated insider trading action charging investment banking analyst with trading on material non-public information concerning 12 different advisory client transactions.
- As lead trial counsel, obtained summary judgment finding that defendant orchestrated fraudulent Twitter-based microcap pump-and-dump scheme.
- As lead trial counsel, secured emergency asset freeze and appointment of equity receiver in $63 million cannabis offering fraud.
- As lead trial counsel, secured ex parte emergency relief freezing assets, appointing equity receiver, and enjoining $123 million fraudulent ATM leaseback securities offering.
- As lead trial counsel, secured preliminary injunction following evidentiary hearing to halt fraudulent securities offering and freeze assets of technology firm that misrepresented value of patent portfolio.
- Litigated 102(e) proceeding before the SEC charging improper professional conduct by Big Four engagement partner.
Enforcement Investigations and Regulatory Matters
- Investigation resulting in settled enforcement action against institutional fixed income asset manager concerning disclosure violations arising from fund manager’s use of paired interest rate swaps strategy for closed-end fund.
- Investigation resulting in settled enforcement action against institutional asset manager in connection with fund-of-fund adviser’s miscalculation of management fee waiver provision.
- Investigation resulting in settled enforcement action against institutional fixed income asset manager arising from adviser’s use of round-lot pricing marks to value ETF’s investments in odd lots of illiquid mortgage-backed securities when calculating fund’s daily NAV.
- Investigations resulting in settled enforcement action sweep against private fund advisers for custody rule and Form ADV violations.
- Investigation resulting in settled enforcement action against independent financial planning arm of institutional asset manager concerning disclosure violations that arose from investment adviser’s mutual fund share class selection practices, advice relating to illiquid alternatives, and cash sweep recommendations.
- Investigation resulting in settled enforcement action against investment adviser finding breaches of fiduciary duty in connection with investment in no-transaction-fee mutual fund share classes for wrap account advisory clients.
- Investigation resulting in settled enforcement action against former public company CEO for disclosure violations arising from deteriorating supply chain issues that the company did not adequately disclose to the market as it was closing a de-SPAC merger transaction to go public.
- Investigation resulting in settled enforcement action against public company and its former CEO and CFO for negligently misrepresenting a key non-accounting operating metric for its online marketplace business.
- Investigation resulting in settled enforcement action against global technology firm for FCPA violations in China.
- Investigation resulting in litigated enforcement action in connection with fraudulent microcap scheme to sell unregistered securities to public investors through bogus debt-for-equity 3(a)(10) exchanges.
Events
- Panelist, "Best Practices for Liaising with Regulators and Auditors During an Internal Investigation," PLI Audit Committees, Special Committees, and Internal Investigations, March 31, 2026
- Panelist, "SEC Year in Review," SoCal Women in Securities Enforcement, February 2026
- Panelist, "Legislative, Regulatory and Legal Developments in Securities Law," Los Angeles County Bar Association, 56th Annual Securities Regulation Seminar, February 2026
- Presenter, "Evolving SEC and State Regulatory Trends," Southern California Compliance Group, May 2025
- Panelist, "Masterclass II: Pre-SEC Litigation – Testimony, Subpoenas, the Wells Process, Cooperation, and Settlements," Securities Enforcement West, May 2025
- Panelist, "Financial Institutions – Exam and Enforcement Challenges and Priorities," Los Angeles County Bar Association, 55th Annual Securities Regulation Seminar, October 2024
- Moderator, "Enforcement: Artificial Intelligence," 36th Annual Joint Regulatory Conference, June 2024
- Presenter, "How To Protect Seniors From Financial Scams," Herald Christian Health Center, June 2024
- Panelist, "Current Issues in Securities Enforcement," 55th Annual Northwest State-Federal-Provincial Securities Conference, May 2024
- Panelist, "Meet the Enforcers," Los Angeles Federal Bar Association, March 2024
- Panelist, "Recent Developments and Trends in Enforcement Actions," 2023 North American Securities Administrators Association Fall Annual Meeting, September 2023
- Panelist, "Masterclass: How to Keep the SEC From Suing Your Client," Securities Enforcement Forum West, May 2023
- Panelist, "Litigating Enforcement Actions," Los Angeles County Bar Association, 54th Annual Securities Regulation Seminar, October 2022
- Panelist, "Financial Disclosure and Accounting Fraud," Securities Enforcement Forum West, May 2022
- Panelist, "Patent Reform: Does the New America Invents Act End the Old “First to Invent” IP Lottery?," Minority Corporate Counsel Association 2011 CLE Expo, March 2012
Insights
- Author, At Sripetch Oral Argument, Supreme Court Weighs the Future of SEC Disgorgement, McGuireWoods Legal Alert, April 24, 2026
- Author, SEC Enforcement Speaks in 2026, McGuireWoods Legal Alert, April 3, 2026
- Recipient, SEC Division of Enforcement, Director’s Award, 2014-2020
- Fellow, Leadership Council on Legal Diversity, 2012
- Named to “Illinois Rising Stars,” Intellectual Property Litigation – Thomson Reuters, 2011
- McGuireWoods LLP Excellence Award, 2008
- McGuireWoods LLP Pro Bono Award, 2006