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75.C&A, Stockman, Stepp, and Cosgrove, acting knowingly, recklessly, or negligently, violated Section 17(a) in August 2004 when C&A sold $415 million in senior subordinated notes, as described in Paragraph 49.  The offering memorandum relating to these notes included financial information from 2001 through June 30, 2004,  that was materially false or misleading due to the fraudulent payment and rebate recognition schemes.  Stockman, Stepp and Cosgrove participated in the road shows and/or prepared the materials for those road shows, knowing that those materials contained false or misleading financial information.    

76.C&A, Stockman, Stepp, and Cosgrove, acting knowingly, recklessly, or negligently, violated Section 17(a) on January 27, 2005 when C&A filed a registration statement containing materially false or misleading financial information for the period from 2001 through September 30, 2004, as described in Paragraph 53.  Stockman, Stepp, and Cosgrove signed this registration statement.

77.Stockman, acting knowingly, recklessly, or negligently, violated Section 17(a) by making materially false or misleading statements to potential bond investors at the March 23, 2005 meeting, as described in Paragraph 67.

78.Unless restrained, C&A, Stockman, Stepp, and Cosgrove will continue to violate Section 17(a).

SECOND CLAIM FOR RELIEF

Violations of Sections 10(b) of the Exchange Act

and Exchange Act Rule 10b-5

(C&A, Stockman, Stepp, Jones, Cosgrove, McCallum,

Barnaba, Gougherty, Galante, and Williams)

79.Paragraphs 1-72 are incorporated herein with the same force and

effect as if set out in full.

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