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114.As described in Paragraphs 1-6, 20-48, and 70-71, Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams knowingly circumvented C&A’s internal accounting controls and knowingly falsified books, records, and accounts maintained by C&A pursuant to Section 13(b)(2) of the Exchange Act.

115.By reason of the foregoing, Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams violated Section 13(b)(5), and unless restrained will continue to violate this provision.

NINTH CLAIM FOR RELIEF

Violations of Exchange Act Rule 13b2-1

(Stockman, Stepp, Jones, Cosgrove, McCallum,

Barnaba, Gougherty, Galante, and Williams)

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

effect as if set out in full.

117.Exchange Act Rule 13b2-1 [17 C.F.R. § 240.13b2-1] provides that no person shall directly or indirectly falsify any book, record, or account subject to Section 13(b)(2)(A) of the Exchange Act.

118.As described in paragraphs 1-6, 20-48, and 70-71, Stockman, Stepp, Jones, Cosgrove, McCallum, Barnaba, Gougherty, Galante, and Williams falsified or caused the falsification of books, records, and accounts maintained by C&A and within the scope of  Section 13(b)(2)(A) of the Exchange Act.

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