99.C&A violated Section 13(a) of the Exchange Act and Exchange Act Rules 12b-20, 13a-1, 13a-11, and 13a-13 by failing to file accurate quarterly, annual, and current reports as alleged in the Fourth Claim For Relief.
100.Pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)] whoever “knowingly provides substantial assistance” to another person in connection with a violation of the Exchange Act, or any regulation thereunder, is "deemed to be in violation of such provision to the same extent as the person to whom such assistance is provided.”
101.Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams each knowingly provided substantial assistance to C&A in connection with one or more inaccurate quarterly, annual, or current reports filed by C&A between April 2002 and April 2005, as described in Paragraphs 1-6 and 20-72, and thereby violated Section 13(a) and Rule 12b-20, as well as Rule 13a-1 (for annual reports), Rule 13a-11 (for current reports), or Rule 13a-13 (for quarterly reports).
102.Unless restrained, Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams will continue to aid and abet violations of these reporting provisions.
Violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act
103.Paragraphs 1-72 are incorporated herein with the same force and
effect as if set out in full.