X hits on this document

128 views

0 shares

0 downloads

0 comments

34 / 40

109.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.”

110.As described in paragraphs 1-6, 20-48, and 70-71, Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams knowingly provided substantial assistance to C&A in connection with C&A’s failure to maintain accurate books and records and C&A's failure to establish an adequate system of internal  controls, and thereby violated Sections 13(b)(2)(A) and 13(b)(2)(B) to the same extent as C&A.

111.Unless restrained, defendants Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams will continue to aid and abet C&A's violations of these record-keeping and internal control provisions.

      EIGHTH CLAIM FOR RELIEF

Violations of Section 13(b)(5) of the Exchange Act

(Stockman, Stepp, Jones, Cosgrove, McCallum,

Barnaba, Gougherty, Galante, and Williams)

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

effect as if set out in full.

113.Pursuant to Section 13(b)(5) of the Exchange Act, no person may knowingly circumvent or fail to implement a system of internal accounting controls or knowingly falsify any book, record, or account maintained pursuant to Section 13(b)(2) of the Exchange Act.

Document info
Document views128
Page views128
Page last viewedTue Jan 17 02:09:57 UTC 2017
Pages40
Paragraphs377
Words10045

Comments