INDEPENDENT VERDICT
Avellum Group SPV LLC is an unusually fast-moving new private equity vehicle. Florida records show that the company was formed on August 18, 2026, while its SEC Form D reports a first sale on September 12 and was filed on September 18. In roughly one month from legal formation, the vehicle reported $6.3 million sold toward a fixed $10 million offering to 36 investors, with a $50,000 minimum investment. The issuer selected Rule 506(b), Section 3(c)(1), equity and pooled investment fund interests, and classified itself specifically as a private equity fund. It reported no revenues, no sales commissions, no finder fees and no payments to related persons from proceeds. On the face of the federal filing, this is therefore an active private capital raise that had already reached 63% of its stated target only days after first sale.
The more important research issue is not fundraising speed but the difference between the federal and state control records. The Form D names Vincent Pappalardo, William Enoch Hawkins and Joseph Markiewicz as executive officers and managing members. Florida Division of Corporations records for the same legal entity, document number L26000435315, instead list Anthony Pappalardo, David Dussault and Matthew Sanjari as authorized members, with Anthony Pappalardo also acting as registered agent. The address is identical: 4736 Pebble Bay Circle in Vero Beach. Different state and federal filings can identify different categories of people and do not automatically contradict one another, but the difference is material enough that investors should obtain the operating agreement and capitalization records to understand which individuals have voting authority, economic ownership, investment discretion and authority over investor capital.
The address-level entity trail produces a second distinctive finding. Florida records show Avellum Health Group LLC was formed on June 25, 2026 at the same 4736 Pebble Bay Circle address and names David Dussault, Anthony Pappalardo and Matthew Sanjari as authorized members. Other newly registered Florida entities involving Matthew Sanjari include Avellum Health LLC, Avellum Health Co LLC, Valdura Health LLC and Luvera Labs LLC. This cluster creates a credible healthcare-business connection around the Avellum name and the individuals appearing in state records. It does not prove that Avellum Group SPV invested in Avellum Health Group or any of those companies. The SEC Form D does not identify a portfolio company, acquisition target, sector specialization or use of proceeds beyond stating that none of the offering proceeds are expected to be paid to the persons named in Item 3. The correct conclusion is therefore that healthcare-platform evidence exists around the state entity network, while the SPV-level asset remains undisclosed.
That distinction matters because a $6.3 million private equity SPV can be economically dominated by one transaction. Without an investment memorandum or operating agreement, investors cannot determine whether Avellum Group SPV owns operating-company equity, acquisition-company interests, preferred securities, convertible instruments or another fund interest. There is also no public disclosure of entry valuation, leverage, preferred return, carried interest, management fees, distribution waterfall, exit rights or additional capital-call obligations. The reported average capital sold per investor is approximately $175,000, but that figure is only a mathematical average and does not indicate the actual allocation of the 36 subscriptions. The $50,000 minimum makes the vehicle structurally different from large institutional funds with multimillion-dollar minimums, while Rule 506(b) still means it is a private offering rather than a public retail investment.
The people identified in the SEC filing also require careful identity resolution. A Vincent J. Pappalardo with a long investment-banking history is publicly registered through Brown Gibbons Lang & Company Securities, but public records reviewed do not establish that the Vincent Pappalardo named by Avellum Group SPV is necessarily the same person. The addresses are different, and name matching alone is insufficient for FilingDossier to merge identities. The same caution applies to William Enoch Hawkins and Joseph Markiewicz: unless employment history, biographies or additional issuer documentation provide a direct match, unrelated search results should not be imported into the fund review simply because names coincide. In this case, restraint is more valuable than filling gaps with potentially incorrect biographies.
FINAL ASSESSMENT
Avellum Group SPV can be verified as a real Florida entity and a real SEC Form D issuer, and its initial fundraising is substantial relative to its short existence. A $6.3 million raise from 36 investors within days of first sale is the strongest objective operating signal currently available. The state filing also provides a useful corporate footprint and reveals an Avellum-branded healthcare entity network at the same Vero Beach address.
At the same time, the investment itself remains unusually opaque. There is no dedicated official investment website identified, no SEC-registered investment adviser attached to the Form D, no portfolio company disclosed and no publicly confirmed service-provider structure. Most importantly, the federal managing-member list and Florida authorized-member list are materially different. That is not evidence of wrongdoing, but it makes the operating agreement, ownership ledger, investment-management authority and exact relationship to Avellum Health Group essential documents for any serious diligence process.
SEC SNAPSHOT
Issuer: Avellum Group SPV LLC CIK: 0002155735 Entity Type: Florida Limited Liability Company Florida Document Number: L26000435315 Florida Status: Active Florida Formation Date: August 18, 2026 SEC Form D Filing Date: September 18, 2026 Date of First Sale: September 12, 2026 Principal Address: 4736 Pebble Bay Circle, Vero Beach, Florida 32963 Phone: 614-221-5474 Industry: Pooled Investment Fund / Private Equity Fund Federal Exemption: Regulation D Rule 506(b) Investment Company Act Exclusion: Section 3(c)(1) Security Types: Equity / Pooled Investment Fund Interests Offering Duration: One year or less Total Offering Amount: $10,000,000 Amount Sold: $6,300,000 Amount Remaining: $3,700,000 Percentage Sold: 63% Investors: 36 Minimum Investment: $50,000 Average Reported Capital Per Investor: Approximately $175,000 Non-Accredited Investors Reported: None Revenue: No Revenues Sales Commissions: $0 Finder Fees: $0 Payments to Related Persons From Proceeds: $0 Current NAV: Not publicly disclosed Portfolio Assets: Not publicly disclosed Investment Adviser: Not identified in Form D Broker / Placement Agent: None identified Auditor: Not publicly identified Administrator: Not publicly identified Custodian: Not publicly identified
SEC MANAGEMENT DISCLOSURE
Vincent Pappalardo Role: Executive Officer / Managing Member Address: Bay Shore, New York
William Enoch Hawkins Role: Executive Officer / Managing Member Address: Crosslake, Minnesota
Joseph Markiewicz Role: Executive Officer / Managing Member Address: Raleigh, North Carolina
Form D Signatory: Mahir Becirovic Role: Attorney
FLORIDA CORPORATE DISCLOSURE
Registered Agent: Anthony Pappalardo
Authorized Member: Anthony Pappalardo
Authorized Member: David Dussault
Authorized Member: Matthew Sanjari
Principal Address: 4736 Pebble Bay Circle Vero Beach, Florida 32963
Important: These individuals differ from the managing members named in the Form D.
This difference should be reconciled through current operating documents rather than treated automatically as an error.
RELATED AVELLUM ENTITY PENETRATION
Avellum Health Group LLC
Florida Document Number: L26000346930
Formation Date: June 25, 2026
Status: Active
Principal Address: 4736 Pebble Bay Circle Indian River Shores / Vero Beach area, Florida 32963
Authorized Members: David Dussault Anthony Pappalardo Matthew Sanjari
Registered Agent: Anthony Pappalardo
The exact address and member overlap create a strong entity-network connection between Avellum Group SPV and Avellum Health Group.
Additional Florida records associated with Matthew Sanjari include:
Avellum Health LLC Avellum Health Co LLC Valdura Health LLC Luvera Labs LLC LI Solutions LLC
This supports a broader healthcare/business network around the same individuals.
It does NOT establish that Avellum Group SPV owns those entities.
ENTITY-CONTROL DISCREPANCY
SEC Form D: Vincent Pappalardo William Enoch Hawkins Joseph Markiewicz
Florida State Record: Anthony Pappalardo David Dussault Matthew Sanjari
Possible explanations can include: Different legal roles Operating members versus authorized members Subsequent ownership or governance changes State filing categories differing from federal Form D categories Incomplete public reporting of all beneficial owners
Public evidence reviewed does not establish which explanation applies.
CORE INVESTOR QUESTIONS
Investors should obtain the current operating agreement and identify all members and ownership percentages; determine why the SEC managing-member list differs from the Florida authorized-member list; confirm who controls the bank account and investment decisions; identify whether Anthony Pappalardo and Vincent Pappalardo are related and what each person's legal role is; determine the roles of David Dussault, Matthew Sanjari, William Hawkins and Joseph Markiewicz; identify the precise underlying investment or acquisition target; determine whether Avellum Group SPV is financing Avellum Health Group or another healthcare company; obtain the purchase price and valuation of the underlying asset; identify management fees, carried interest and transaction fees; determine whether leverage or acquisition debt is used; identify the auditor, administrator, bank and custodian; obtain investor reporting procedures; confirm whether additional capital calls are permitted; and establish the expected liquidity or exit path.
CORE RISKS
Management-Control Transparency Risk: Federal and state records identify different sets of management or authorized persons.
Underlying-Asset Risk: The exact portfolio company or transaction is not publicly disclosed.
New-Entity Risk: The LLC was formed only one month before the SEC filing.
Concentration Risk: An SPV may hold a single or highly concentrated private equity position.
Valuation Risk: No public current NAV, entry valuation or independent appraisal is available.
Liquidity Risk: Private SPV interests may remain illiquid until an underlying transaction exits.
Healthcare-Link Interpretation Risk: Shared addresses and members connect the SPV to Avellum Health Group, but ownership or investment linkage is not yet proven.
Management Biography Risk: Name matches found elsewhere should not be attributed to the SEC-listed persons without direct identity confirmation.
Fee Transparency Risk: Management fees, carry, transaction fees and administrative expenses are not disclosed in Form D.
Leverage Risk: The filing does not disclose whether debt is used at the SPV or operating-company level.
Service-Provider Transparency Risk: No auditor, administrator, custodian or independent valuation provider was identified in reviewed public records.
Short Track-Record Risk: The entity has essentially no standalone operating history before the September 2026 offering.
Investor Concentration Risk: 36 investors fund $6.3 million of the offering, potentially creating dependence on a relatively small investor base.
WEBSITE / ENTITY PENETRATION
SEC Form D Located: Yes Florida Entity Registration Located: Yes Florida Active Status: Yes Principal Address Matched: Yes Formation Date Confirmed: Yes Federal Related Persons Identified: Yes Florida Authorized Members Identified: Yes Management Lists Fully Consistent: No Avellum Health Group Identified: Yes Avellum Health Group Address Matched: Yes Authorized-Member Overlap With State SPV Record: Yes Dedicated Investment Website Verified: No Investment Adviser Identified: No CRD Identified: No SEC Form ADV Identified: No Exact Underlying Asset Identified: No Current NAV Identified: No Current Fund-Level Audited Performance Identified: No Independent Auditor Identified: No Administrator Identified: No Custodian Identified: No
PRIMARY EVIDENCE REVIEWED
SEC EDGAR — Avellum Group SPV LLC Form D filed September 18, 2026 Florida Division of Corporations — Avellum Group SPV LLC, document L26000435315 Florida Division of Corporations — Avellum Health Group LLC Florida Division of Corporations — related Avellum Health entities Florida officer / registered-agent search for Matthew Sanjari Public securities-registration databases used only for identity cross-checking where direct linkage could be established
IMPORTANT FORM D NOTICE
Form D is a notice filing for an offering relying on an exemption from Securities Act registration. It is not SEC approval, certification, endorsement or verification that the issuer's investment is profitable or suitable. The SEC expressly states that it has not necessarily reviewed information contained in Form D filings and has not determined whether the information is accurate or complete. Avellum Group SPV's $6.3 million amount sold therefore reflects reported securities sales, not current NAV, audited investment value or investor profit.