Mazer Law Firm P.C. is investigating investment solicitations involving Dr. Raj Bhayani, Prior2IPO, and Late Stage investment funds. We are seeking information from physicians and other investors who were introduced to pre-IPO investment opportunities through physician networks, professional associations, or related presentations.
Documents reviewed by Mazer Law Firm include an August 9, 2023 email sent by Dr. Raj Bhayani to an Alabama physician. The email included promotional material bearing the headline “Attention Indian Physicians” and advertised investment opportunities through Prior2IPO.
The promotional material discussed access to shares of prominent private companies, including SpaceX, Neuralink, Instacart, and Triller, before potential public offerings.
It also referred to a family-and-friends referral program that could reduce investors’ carried-interest charges.
The promotional material contained an earlier June 2023 presentation date. Separate correspondence documents an August 13, 2023 Prior2IPO presentation and subsequent follow-up communications.
These documents establish that Dr. Bhayani transmitted Prior2IPO promotional material to at least one physician. The extent of the distribution, his relationship with the investment promoters, and whether he received compensation for referring investors remain subjects for further investigation.
Late Stage Management’s published Board of Advisors webpage identifies Dr. Raj Bhayani as an advisor.
His biography on that website also describes leadership positions within the American Association of Physicians of Indian Origin (AAPI), including service as a trustee, treasurer, and president of its New York region.
The relationship between professional associations, physician networks, and investment promotions deserves examination when investors may have relied upon the professional reputation or influence of the individuals introducing an investment.
Important questions include:
Neither membership in AAPI nor service on an investment company’s advisory board independently establishes a securities-law violation.
On December 7, 2023, the Securities and Exchange Commission announced charges against individuals and companies associated with a widespread pre-IPO investment operation involving Prior2IPO and Late Stage Asset Management.
According to the SEC, the defendants raised approximately $528 million from more than 4,000 investors through offerings associated with pre-IPO companies.
The SEC alleged that investors were told the offerings involved no upfront fees, while undisclosed markups were actually charged.
On March 3, 2026, the United States Attorney’s Office for the Eastern District of New York announced that Raymond John Pirrello Jr. and Joseph Passalaqua had pleaded guilty to securities-fraud-related charges. Robert Cassino had also pleaded guilty to wire fraud conspiracy.
Federal prosecutors described a scheme involving approximately $88 million in undisclosed upfront markups.
The criminal announcement identified the principal fundraising period as approximately March 2019 through July 2022.
These proceedings do not establish that Dr. Bhayani committed wrongdoing or that all investments promoted after July 2022 involved the same practices. Those questions require separate factual and legal analysis.
The documents reviewed by Mazer Law Firm include August 2023 correspondence from a Prior2IPO representative describing investment opportunities through affiliated private-equity funds.
That correspondence represented that participating funds did not charge upfront commissions or management fees and instead received a 20% carried interest based upon investment profits.
These representations warrant examination in light of the federal allegations concerning undisclosed markups in the earlier Prior2IPO operation.
A central question for investors is whether the amount paid for a fund interest accurately reflected the acquisition cost of the underlying shares and whether all compensation and markups were properly disclosed.
The documentation also raises questions about the actual ownership interests acquired by investors, the fund structures, and the current status of the investments.
Mazer Law Firm is interested in speaking with individuals who:
We are particularly interested in reviewing original investment invitations, promotional materials, subscription agreements, statements, and communications concerning fees or compensation.
Depending on the circumstances, investors may have potential claims involving material misrepresentations, omissions, undisclosed conflicts of interest, or violations of state or federal securities laws.
Whether a viable claim exists depends on the individual transaction, applicable limitations periods, available evidence, and the parties involved.
Did you invest in Prior2IPO or Late Stage Funds after receiving an invitation from Dr. Raj Bhayani or an introduction through a physician network
Your experience may help clarify how the investments were promoted and whether additional investors received similar representations.
Mazer Law Firm P.C. welcomes confidential inquiries from physicians and other investors nationwide.
Attorney Advertising. The discussion of Dr. Bhayani concerns documented communications and questions under investigation; it is not a finding that he committed fraud or other unlawful conduct. The facts described do not establish the validity of any individual claim. Contacting Mazer Law Firm does not create an attorney-client relationship. Representation is subject to conflict review and a written engagement agreement. Representation outside Alabama is subject to applicable jurisdictional and professional requirements.
Sources and Further Reading
Securities and Exchange Commission
SEC Charges Five Unregistered Brokers and Four Companies in Pre-IPO Fraud Scheme — December 7, 2023
United States Department of Justice
Three Sales Executives Plead Guilty to $500 Million Investment Fraud Scheme — March 3, 2026
Late Stage Management
Board of Advisors — Dr. Raj Bhayani