They Took Everything.Then Made Sure He Couldn't Fight Back.

The entire prosecution was built on the exact conduct the United States Supreme Court held lawful in its binding decision in Sprint Communications Co. v. APCC Services, Inc., 554 U.S. 269 (2008) — the assignment of securities class-action settlement claims to an assignee who then files as beneficial owner. That holding, together with Pennsylvania's law of assignments, settled for more than a century, made the charged offense a legal impossibility.

Paragraph 11 of the indictment told the grand jury that only claimants who personally traded and personally lost money were eligible to recover. That was a material misrepresentation of the governing law. Once it was proven at trial that the trades were real, that Mr. Cammarata owned them, and that they were lawfully assigned and filed by a fully disclosed beneficial owner, no crime remained. The government did not disclose Sprint. It never cited it — not once in thirty-five pages of post-trial briefing.

The same judge presided over the criminal fraud prosecution and the parallel SEC civil action. 28 U.S.C. § 455 is mandatory and self-executing. At least six independent grounds required his disqualification. He disqualified himself on none of them. The remedy is vacatur. Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 862–64 (1988).

Any one of these grounds required disqualification. Their convergence in a single judge — who then imposed a 120-month sentence on conduct he conceded involved “real trades” — is the grave § 455 violation for which Liljeberg prescribes vacatur.

The Due Process Clause guarantees not only an impartial trial judge but impartial review. Every panel of the Third Circuit to consider these four related cases was operationally supported by the Executive Office of that court — where Jeanne Donnelly, spouse of John V. Donnelly III, the SEC prosecutor formally accused of the misconduct at issue, serves as an attorney providing administrative and legal support to those judges.

That relationship was never disclosed, in any of four appeals. A court whose own executive office employs the spouse of the prosecutor charged with misconduct cannot sit in impartial judgment of that misconduct. That is the precise circumstance 28 U.S.C. § 455(a) exists to prevent. The conflict was raised on the record repeatedly — motions to recuse, to transfer to an unconflicted venue, for reconsideration, to disqualify the entire Circuit, in Nos. 24-1381 and 25-1188 — and has gone undisclosed, uncontested, and unaddressed for two years.

The government's silence confirms it from the other direction. These allegations have gone unanswered in every forum: the mandamus was unopposed; the SEC has filed no merits brief in more than 31 months; and in this Court, the Solicitor General did not respond to the petition in No. 25-6128. An adversary does not decline, across three proceedings and two levels of the federal judiciary, to contest specific documented allegations of judicial and prosecutorial conflict — unless those allegations cannot safely be contested.

And the Third Circuit refused to follow its own binding precedent. In SEC v. Antar, 71 F.3d 97 (3d Cir. 1995), and United States v. Antar, 53 F.3d 568 (3d Cir. 1995), that court disqualified a district judge who presided over parallel SEC civil and criminal proceedings and revealed an objective of returning money to victims. Here the facts are worse in every dimension: no crime occurred, the judge declared his own financial interest from the bench, and the only person ever to identify a “victim” was the judge himself — naming administrators the appellate panel then confirmed were not victims at all. A court that will not follow its own controlling law when the conflict implicates the court itself is not providing review.

The conduct at issue — assigning securities class action settlement claims to business entities — was established as entirely lawful by the United States Supreme Court in Sprint Communications Co. v. APCC Services, 554 U.S. 269 (2008), binding Supreme Court precedent decided thirteen years before the first charge was filed. Sprint was not discovered after conviction. It was the defense raised at trial, presented to the jury, briefed on appeal, and submitted to the Supreme Court. Not one court has ever explained why Sprint does not make this conduct legal. Not once in nearly five years.

The SEC filed its complaint the same day as the arrest. On November 9, 2021 — at a hearing held without notice while Mr. Cammarata sat in custody in Miami, 1,200 miles away and unable to attend — that same judge declared "I consider this a crime against the courts" before seeing a single piece of evidence. He had already a 900-page ex parte order freezing over $78 million without the irreparable harm finding that Rule 65(b) requires as a mandatory prerequisite. No jurisdiction. Simultaneous hearings 1,200 miles apart while the defendant sat in custody. A forged service document. A summary judgment granted without satisfying a single required legal element. Every step designed to freeze the money, strip any ability to fight back, and protect the cover-up.

The lead SEC prosecutor, John V. Donnelly III, is married to an active attorney in the Executive Office of the Third Circuit Court of Appeals — the exact court where every appeal ended up. This was never disclosed. Four appeals went to that court. Three were decided without the court addressing the core issues. The fourth, the SEC appeal, has sat more than 31 months without a merits brief from the SEC. When judicial misconduct complaints were filed to that court, they were denied with no explanation and no review of a single documented violation. Perhaps that is why.

Federal Rule of Criminal Procedure 5(f) requires courts to issue specific discovery directives ensuring Brady compliance. Brady v. Maryland requires the government to produce exculpatory evidence — including controlling Supreme Court precedent that proves the conduct was legal. Had either been followed, Sprint would have been produced, and there would never have been a case. Perhaps that is why neither was followed.

When the controlling Supreme Court precedent was raised, the government should have dismissed the case. Instead it never cited Sprint at all, not once in thirty-five pages of post-trial briefing, and the courts that followed never adjudicated it. By then six agencies had committed years of resources and 5.5 million pages of documents, and more than $78 million had been frozen. The documented record of what followed, including the November 9, 2021 transcript and the simultaneous hearings, is set out in the 93 documented violations.

On September 22, 2022, twenty-five days before the fraud trial began, a grand jury in the District of New Jersey indicted Mr. Cammarata on five counts of tax evasion for 2015 through 2019, alleging about $16 million in unreported income. The only witness was an IRS special agent, examined by a prosecutor who used the word “fraud” twenty-seven times in a fifty-page presentation, before any jury had found fraud. No Rule 5(f) order was ever entered. The government withheld the business records showing expenses exceeding the income charged, the Forms 1042-S showing the income had been reported and tax withheld, and the claims administrator letters stating the payments were not taxable. A month before trial he was moved to a county jail without his discovery laptop. The jury convicted on all five counts, and the court imposed 72 months. His sworn, line-by-line accounting puts documented business expenses at $16,982,751.81, and above $20 million with credit card and additional bank records. The government has never contested a single line item. The Third Circuit affirmed on April 7, 2026 and denied rehearing en banc on May 7, 2026. The certiorari petition is posted above.

Those are six. There are 87 more — every one documented, every one on the public record, every one unanswered.