 |
 |
|
|
|
|
|
|
|
| | | |
|
|
|
|
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
1
.
MEMO AND ORDER
|
EXTRACTED KEY WORDS
ACCOUNT PGT PINEZ CONTEMPT PERETZ FUNDS CIVIL CONTEMPT CENTENNIAL/PINEZ CIR ASSETS AMOUNT EXCHANGE SECURITIES FREEZE ORDER OBSTRUCTION MISLEADING TESTIMONY SALES MICHAEL UNITED STATES POWER BAYBANK INVESTMENT ACT JUDGEMENT RESPONDENTS COUNSEL CONTROL EVIDENCE EXCHANGE COMMISSION |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
1
SECURITIES AND EXCHANGE COMMISSION,)
Plaintiff, ) )
V. ) )
EMANUTEL PINEZ, 1
Defendant, ) ) CIVIL ACTION NO.
FELIX, INC., and ) 97- 10353- PBS
LEHMAN BROTHERS, INC., 1
Relief Defendants, 1 1
GILBOA PERETZ, and 1
P . G , TECHNOLOGIES, )
Respondents. )
MEMORANDUM AND ORDER
May 25, 1999
SARIS, U.S.D.J.
I. Introduction
Plaintiff, Securities and Exchange Commission ( " S E C " ) , has
moved for an order holding respondents, Gilboa Pe.retz ("Peretz")
and PG Technologies, Inc. (IIPGTrl),
in civil contempt, f o r making
intentionally false and misleading statements during a February
SNIPPETS:
|
|
2
.
PLFS REPLY TO RESP MEM
|
EXTRACTED KEY WORDS
COURT RESPONDENTS COMMISSION ASSET FREEZE ORDER JUDGEMENT LAW PERETZ LAW ENFORCEMENT CONTEMPT PARTIES AMOUNT DEFENDANTS EXCHANGE REASONS CONTRAVENE SETTLEMENT TECH MEMORANDUM SECURITIES ABSENCE INJUSTICE MATTER COUNSEL TECHNOLOGIES PLAINTIFF DISTRICT DIMENTO CERTIFICATE COMMISSION RESPECTHLLY REQUESTS |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SECURITIES AND EXCHANGE COMMISSION, :
Plaintiff,
V.
EMANLTEL PINEZ,
Defendant,
FELIX INC., and
L E w
BROTHERS INC.,
Relief Defendants.
GlLBOA PERETZ and
P.G. TECHNOLOGIES,
Respondents.
SECURITIES AND EXCHANGE COMMISSION'S
REPLY TO RESPONDENTS' MEMORANDUM OF LAW
Plaintiff Securities and Exchange Commission ("Commission"), by counsel,
respectfully submits this Reply to Respondents Gilboa Peretz ("Peretz") and PG
SNIPPETS:
|
|
3
.
RESPONDENTS MEMO OF LAW
|
EXTRACTED KEY WORDS
RESPONDENTS FINDINGS TRANSCRIPT DIMENTO AMOUNT MONEY TESTIMONY PINEZ ACCOUNT FUNDS FREEZE ORDER JUDGEMENT PLAINTIFF WITNESS PERETZ CONTROL PARTIES KOBRICK REQUIRING SIGNATURE SALES DISSOLUTION GOVERNMENT COUNSEL LAW REQUEST PROCEEDING RULINGS SETTLE |
UNITED STATES DISTRICT COupT : #
DISTRICT OF MASSACHUSETTS =' ,
?\,J '' ' ,,. .. .
SECURITIES AND EXCHANGE COMMISSlON, )
Plaintiff, 1 .
1
V. 1 CrVE ACTION
1 NO. 97-10353-PBS
EMANUEL PWEZ, )
Defendant, )
1
FELIX INC., and LEHMAN BROTHERS INC., 1
Relief Defendants. 1 1
GEBOA PERETZ and P.G. TECHNOLOGIES, 1
Respondents. 1
RESPONDENTS' MEMORANDUM OF LAW
The parties have agreed that judgment may enter against the respondents in the amount
of $15,000.00. This figure represents a compromise of the amount claimed by the govemment
and the "worst case" figure advanced by counsel for the respondents during oral argument. The
respondents, however, do not agree to the proposed findings submitted by the government or that
SNIPPETS:
|
|
4
.
DEFS POST HEARING MEMO
|
EXTRACTED KEY WORDS
PINEZ TECH COURT ACCOUNT FUNDS SALES AMOUNT TESTIMONY EXHIBIT INVESTMENT COMMISSION ASSET FREEZE ORDER JUDGEMENT ASSET FREEZE SUPPORT ASSERTION MATTER DEFENDANT STOCK DEPOSIT FINANCIAL TRANSACTIONS REGISTER MOTION CONTEMPT RESPONDENTS TECHNOLOGIES EXCHANGE AGREEMENT PROPER AMOUNT |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SECURITIES AND EXCHANGE COMh4ISSION, :
Plaintiff,
V.
EMANUEL PINEZ,
Defendant,
FELIX INC., and
LEHMAN BROTHERS INC.,
Relief Defendants
GILBOA PERETZ and
P.G. TECHNOLOGIES,
Respondents.
SECURITIES AND EXCHANGE COMMISSION'S
POST -HEARING MEMORANDUM
On January 8, 1999, the Court conducted a Contempt Hearing in this matter
against Respondents Glboa Peretz ("Peretz") and PG Technologies, Inc. ("PG Tech").
The Securities and Exchange Commission (the "Commission") respectfully submits this
SNIPPETS:
|
|
5
.
HEARING 7
|
EXTRACTED KEY WORDS
BOSTON COURTHOUSE MCLAUGHLIN JAMES PINEZ HONOR MASSACHUSETTS MONEY PAY TECHNOLOGY FINANCIAL STATEMENT TECH ACCOUNT LIABILITIES EVIDENCE EXHIBIT FLORIDA MORTGAGE COURTROOM FREEZE ORDER PAYMENT CONTEMPT EXPENSES ATTORNEYS ADMISSIBILITY STIPULATE CIVIL ACTION TREMONT STREET SECURITIES |
m 1 2
SARIS, D.J.
SECURITIES and EXCHANGE COMMISSION
V.
8 E"?iNUEL PINEZ
9 . ,- ...- . -
.. , ,. .-.
I
10 . . . ... ,-
~.
. .
Motion for Contempt Re: Gilboa ,
P e r e t z 'Y
11 . , -
12 -.
m .....
13 . -
14 APPEARANCES:
15 For the Government:
SNIPPETS:
|
|
6
.
HEARING 1
|
EXTRACTED KEY WORDS
BOSTON COURTHOUSE MCLAUGHLIN JAMES PINEZ PERETZ HONOR CONTEMPT MASSACHUSETTS MONEY PAY TECHNOLOGY FINANCIAL STATEMENT EVIDENCE DIMENTO ACCOUNT LIABILITIES EXHIBIT FLORIDA MORTGAGE COURTROOM PAYMENT FREEZE ORDER EXPENSES JUDGEMENT EMPLOYEE ADMISSIBILITY STIPULATE CIVIL ACTION |
1
1 UNITED STATES DISTRICT COURT
2 DISTRICT OF MASSACHUSETTS
3 CA 97-10353-PBS SARIS, D.J.
4
5
6 SECURITIES and EXCHANGE COMMISSION
7
V.
8 EMIGINUEL PINEZ
9
10
Motion for Contempt Re: Gilboa Peretz
11
12
13
14 APPEARANCES:
15 For the Government:
16 Kimberly Zimmer, E s q . , and Carlos Costa-Rodriguez, Esq=,
Securities and Exchange Commission, 73 Tremont Street,
SNIPPETS:
|
|
7
.
RESPNCE PERETZ TO PLFS MT
|
EXTRACTED KEY WORDS
RESPONDENT FREEZE ACCOUNT PLAINTIFFS MOTION PINEZ DEPOSIT BALANCE TECHNOLOGIES RESPONDENT DENIES PARAGRAPH AMOUNT PRIVILEGE AGREEMENT PAID PURPOSES EMANUEL PINEZ RESPONDENT ADMITS FACTUAL ALLEGATIONS GOVERNMENT INTERVENING ACCOUNT BALANCE PRIOR PLAINTIFF ALLEGES INSOFAR COURT EQUITY WHIPSAW ASSERTION FINANCIAL AFFAIRS GRAND JURY |
. .
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS _,
_,
I .
I
.
-
..
,
. ,".
? . .:
SNIPPETS:
|
|
8
.
DEFS MEM SUP OF MTN
|
EXTRACTED KEY WORDS
FREEZE ORDER PERETZ ASSET FREEZE BAYBANK CONTEMPT ACCOUNT COURT PINEZ FUNDS MOTION TESTIMONY COMMISSION REGISTER MODIFY CIVIL CONTEMPT CIR RESPONDENTS OBSTRUCT INVESTMENT DISSOLVE CENTENNIAI BAYBANK FROZE VIOLATION TECHNOLOGIES TRANSFERS BAYBANK PURSUANT REQUESTS AUTHORITY SUPPORT |
r
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SECURITIES AND EXCHANGE COMMISSION,
- Plaintiff,
V .
E m E L P I N U ,
-
D e f endarit, . -
-
- FELIX INC., and. - ..
' . L E V "
BROTHERS INC . , - .
- -
Relief Defendants.
- :
-
-
SNIPPETS:
|
|
9
.
DECLARATION OF FELDMAN
|
EXTRACTED KEY WORDS
CENTENNIAL-INTEROFFICE EXHIBIT HERETO COMMISSION STAFF SUBPOENA PURSUANT INTEROFFICE MEMORANDUM COUNSEL AMOUNT TECH TESTIMONY BAYBANK ACCOUNT TESTIFICANDUM REGISTER PERJURY PENALTYAF DECLARE EMANUEL INTEROFFICE MEMORANDUM APPENDS AUDLTORS LYBRAND LLP COOPERS K-LRUE-AND CORRECT DATED JANUA-T TEC3NOLOGIES ACCOUNT STATEZNT COFRECT IRUE |
--
UNITED STATES DISTRICT COURT
DISTRICT OF mSSACHTJSETTS
-
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v. CIVIL ACTION
'NO.
EMANCTEL P I N E Z ,
Defendant,
FELIX INC-. , and -
I
- ' LE- BROTHERS INC., - -
,Relief
-Defendant.& . '
- - -
DECLARATIQN OF STUART P. F E L D W
SNIPPETS:
|
|
10
.
MEMO AND ORDER
|
EXTRACTED KEY WORDS
SECURITIES STOCK VIOLATION ASSETS TRADING LEHMAN ACT DEFENDANT ACCOUNT EXCHANGE ACT COURT INSIDER TRADING RELIEF MARGIN ACCOUNT COMMISSION THEREUNDER NONPUBLIC INFORMATION PRACTICES FEDERAL SECURITIES LAW RESTRAINING ORDER BONA FIDE PURCHASER TRANSACTIONS PRELIMINARY INJUNCTION AGREEMENT CONSTRUCTIVE TRUST COMMON STOCK COMPLAINT LIKELIHOOD POSSESSION |
)
SECURITIES AND EXCHANGE )
I
COMMISSION, )
Plaintiff, 1 1
v . ) CIVIL ACTION NO. 97-10353-PBS
)
EMANUEL PINEZ, Defendant , )
AND )
LEHMAN BROTHERS, INC., )
Relief Defendant. ) 1
MEMORANDUM AND ORDER
December 1 6 , 1997
Saris, U.S.D.J.
I. INTRODUCTION
This action arises out of the alleged illegal insider
trading practices of the former Chairman and Chief Executive
Officer of Centennial Technologies, Inc . ( llCentennialll)
, Emanuel
Pinez (I1Pinezl1).
On February 14, 1997, the Securities and
Exchange Commission ( l l S E C 1 l ) filed a complaint against Pinez
alleging that he traded in options on the common stock of
Centennial while in possession of material, nonpublic information
regarding Centennial's true financial condition in violation of
section l O ( b ) of the Securities Exchange Act of 1934 (IlExchange
SNIPPETS:
|
|
11
.
SEC SUPP MEMO RE INJUNCTI
|
EXTRACTED KEY WORDS
ACCOUNTS COURT SECURITIES COMMISSION PRELIMINARY INJUNCTION TAB HERETO CONTROL NONPUBLIC INFORMATION ASSETS BROKERAGE ACCOUNTS FELIX TRADING RESTRAINING ORDER TEMPORARY RESTRAINING ORDER FINANCES VIOLATING EXCHANGE WEBSECURE OFFSHORE POSSESSION TRADE SECURITIES LAWS LEHMAN REQUESTS NOMINEE MATERIAL NONPUBLIC INFORMATION EXCHANGE ACT EXTENSION |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS . "
SECURITIES AND EXCHANGE COMMISSION,
0
.
Plaintiff,
0
V. :
. CIVIL ACTION
NO. 97-10353-PBS
-EL PINEZ, :
.
Defendant,
FELIX INC., and :
LE- BROTHERS INCm, 0
Relief Defendants. :
On September 23, 1997, the Court invited the Securities and
Exchange Commission (the llCommission*l)
SNIPPETS:
|
|
12
.
HEARING 2
|
EXTRACTED KEY WORDS
PINEZ SECURITIES TRANSCRIPT LEHMAN BROTHERS COURT JUDGE PIERCE UNITED STATES HONOR FELIX ATTORNEY GAD INSIDER TRADING VIOLATION TRANSACTION UNITED STATES DISTRICT STANDARD EVIDENCE PRELIMINARY INJUNCTION EXCHANGE COMMISSION SECURITIES ACT ACCOUNT OPTIONS CONTRACT UCC DISTRICT TRIAL COUNSEL GOODMAN FELDMAN EMANUEL PINEZ NONPUBLIC INFORMATION |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
---_---_---_---_----____I_______
SECURITIES AND EXCHANGE .
COMMISSION Civil Action
V. NO. 97-10353-PBS
EMANUEL PINEZ
_--__---_---_----_--______I_____
Hearing
Before : THE HONORABLE PATTI B. SARIS
UNITED STATES DISTRICT COURT JUDGE
APPEARANCES :
Securities and Exchange Commission (by Linda B. Bridgman,
Esq. and Stuart P. Feldman, Esq.),
73 Tremont Street, Boston, MA 02108,
on behalf of the Plaintiff.
Ropes & Gray (by Robert K. Gad, 111, Esq., Mark Szpak, Esq.
and Ana Francisco, E s q . ) ,
One International Place, Boston, MA 02110;
on behalf of Lehman Brothers.
3ernkopf, Goodman & Baseman, (by Valerie S = Carter, E s q = ) ,
125 Summer Street, Boston, MA 02110,
on behalf of PaineWebber.
Ylarilyn Stempler, Esquire,
on behalf of Felix, Inc. Courtrdom No. 6
1O:OO a.m., Tuesday
September 23, 1997
SNIPPETS:
|
|
13
.
PINEZ MOT TO STRIKE
|
EXTRACTED KEY WORDS
MOTION COURT REQUEST RECONSIDERATION OPPOSE BOSTON SANCTIONS OPPOSITION IMPOSE LITIGATION CIVIL PROCEDURE FLAGRANT VIOLATION ESQ FELIX COUNSEL REASON AGENDA PUZZLING EXCHANGE STRIKE NUMEROUS INACCURACIES INFLAMMATORY WORDS DEROGATOV BIASED AGENDA DOEST PROTEST FAMOUS WORDS RECONSIDERATION EVINCES LAW DISPUTING CIVILITY |
I: d' - ..,
, .-..' SECURITIES AND EXCHAl'JGq,@mISSION,
'4 "
Plaintiff, . .
. -
I . V.
. . . ...-!
5
EMANUELPINEZ7 Defendant,
FELIX, INC., and
LEHMAN BROTHERS INC.,
Relief Defendants.
PINEZ'S MOTION TO STRIKE
FOR SANCTIONS AGAINST THE SEC
The defendant, Emanuel Pinez ("Pinez"), hereby
to Pinez's Opposition to Motion For Reconsideration of
6 `Reply Brief,) filed with this Court at 7:24 p.m. on Friday September 12, 1997 and
r\ served by mail on the undersigned counsel. Pinez hrther
* SEC for its knowing, repeated and flagrant violation of this Court's rules.
In support of this Motion, Pinez states as follows:
1. On or about June 26, 1997, the SEC filed a
Asset Freeze to include the accounts of Felix, Inc.,
Financial Corporation (the `Motion for Modificationy').
SNIPPETS:
|
|
14
.
PLF REPLY TO DEFS OPP
|
EXTRACTED KEY WORDS
FELIX ACCOUNTS MOTION DEFENDANT PINEZ FREEZE COURT EVIDENCE COUNSEL ASSET FREEZE CONTROL COMMISSION SECOND AMENDED COMPLAINT DISCOVERY REQUEST MERITS STANBRIDGE TRIXY ACCOUNTS RECONSIDERATION OFF-SHORE VIOLATING INSIDER TRADING INDIRECT CONTROL OPPOSE LEHMAN PENDING EXTENSION EXCHANGE SECURITIES JURISDICTION |
BECURITIES "D EXCHANGE COMMIf38ION, :
.
Plaintiff,
0
V. CIVIL ACTION
: NO. 97-10353-PBS
EMANUBL PINMI :
0
Defendant, 0
FELIX INC., and
LE- BROTHERS INC.,
Relief Defendants. 0 .
BEC REPLY TO PINE2'S OPPOSITION TO MOTION FOR
RECONSIDERATION OF MODIFICATION OF ASSET FREEZE
Plaintiff Securities and Exchange Commission (tlCommission'l
or rlSEC1l), through counsel, respectfully requests leave to file
this reply to defendant Pinez's opposition to the SEC's motion to
Defendant Pinez's entire pleading is nonsensical and
puzzling as he consented on February 20, 1997 to an indefinite
extension of the Court's asset freeze order against all of his
assets. See Consent of Emanuel Pinez to Continuation of the
Temporary Restraining Order and Order For the Freezing of Assets
SNIPPETS:
|
|
15
.
OPP TO DEFS MOT TO STRIKE
|
EXTRACTED KEY WORDS
DEFENDANT EVIDENCE COURT COMMISSION ASSET FREEZE TRADING MOTION COUNSEL SUPPORT SECURITIES SUBMISSIONS MEMORANDUM REQUEST EXCHANGE RELIEF DEFENDANT INSIDER TRADING DEFENDANT PINEZ DISCOVERY CONSTRUCTIVE TRUSTEE CONTINUATION FELIX ACCOUNT TRANSCRIPTS RESPECTFULLY REQUESTS CARLOS COSTA-RODRIGUES DECLARATION LEHMAN BROTHERS BFP BONA FIDE PURCHASER PRELIMINARY INJUNCTION |
UNITED BTATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
v.
.
FELIX INC., and :
LEHMAN BROTHERS INCm, 0
:
Relief Defendants. :
OPPOSITION TO RELIEF DEFENDANT LEffMAN'B MOTION TO STRIKE
AND REPLY TO LEHMAN'S OTHER 8/22/97 SUBMISSIONS
OPPOSING PLAINTIFF'S SECOND SUPPLEMENTAL MEMORANDUM
AND APPENDIX OF EVIDENCE
The Plaintiff Securities and Exchange Commission
(ttCommissiontt
or "SEC") , by the undersigned counsel, hereby
opposes relief defendant Lehman Brothers Inc.'s ("Lehmantt)
motion
to strike the Declaration of Carlos Costa-Rodrigues submitted on
July 22, 1997 in support of the SEC's motion to modify the asset
freeze. The SEC, by counsel, also respectfully requests leave to
file this Reply to Lehman's other submissions filed on August 22,
SNIPPETS:
|
|
16
.
DEFS OPP TO PLFS RECONSID
|
EXTRACTED KEY WORDS
COURT PINEZ RECONSIDERATION LAW REQUEST DISCOVERY CONTROL LITIGATION EVIDENCE SUPPORT ACCOUNTS FELIX ASSET FREEZE LEHMAN STANBRIDGE TRIXY TESTIMONY SUBSTANCE JURISDICTION EXCHANGE SECURITIES PRIVATE INVESTIGATION DEPOSITION TRANSCRIPTS ACTS EXHIBITS DENY SHOWING MATTER ARGUES |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SECURITIES AND EXCHANGE
COMMISSION
Plaintiff,
V. CIVIL ACTION NO. 97-10353-PBS
EMANUEL PINEZ,
Defendant
and
LEHMAN BROTHERS, INC.,
Relief Defendant
PINEZ'S OPPOSITION TO SECURITIES AND EXCHANGE COMMISSION'S
MOTION FOR RECONSIDERATION AND MOTION AGAINST LEHMAN
I. INTRODUCTION
On July 9, 1997 this Court denied the Securities and Exchange Commission's Motion to
Modify Asset Freeze (the "Motion''). Through its Motion, the Securities and Exchange Commission
(the "SECII) sought to modify this Court's February 14, 1997 Asset Freeze to prohibit the defendant
Emanuel Pinez ("Pinez") fiom withdrawing any funds in accounts in the name of Felix, Inc.
SNIPPETS:
|
|
17
.
ANSR TO 2ND AMEN COMPLAIN
|
EXTRACTED KEY WORDS
ALLEGATIONS SET PARAGRAPH TRUTH INFORMATION SUFFICIENT PINEZ LEHMAN BROTHERS FELIX ADMITS EXCHANGE COMMISSION SECURITIES SECOND AMENDED COMPLAINT DEFENDANT HEREBY RELIEF DEFENDANT EMANUEL PINEZ SEKA TRUST CENTENNIAL COMMON STOCK WERTO REALLEGES FELIX REPEATS RESPONSE SUBSEQUENT TRADE ARTICLES SPEAK CEASED TRADING INFOMATION SUFFICIENT LEHMAN WIRED FUNDS CHANNEL ISLANDS JERSEY DISCRETIONARY TRUST INTERNATIONAL BUSINESS COMPANY INFORMATION SUFFCIENT |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
SECURITIES AND EXCHANGE COMMISSION7
Plaintiff,
V. CIVIL ACTION
NO. 97-10353 (PBS)
EMANUEL PINEZ,
Defendant,
and
FELIX INC. and
LEHMAN BROTHERS INC.,
Related Defendants.
4
;
WERTO E
Felix Inc. (''Felix7'), added to this action as a so-called Relief Defendant, hereby
the Second Amended Complaint of the Securities and Exchange Commission ("SEC") as
follows:
SNIPPETS:
|
|
18
.
DEFS MEM IN RESP PLF MEMO
|
EXTRACTED KEY WORDS
PINEZ STANDARD COURT TAB STATUTE EXCHANGE ACT SUPPLEMENTAL MEMORANDUM SECURITIES APP ACCOUNT FRAUD EMPHASIS TRADE SECURITY CONTRACT PRELIMINARY INJUNCTION TESTIMONY TRANSACTION ALLEGED FRAUD LEHMAN BROTHERS SUSPICIOUSNESS VIOLATION PROVISION CONTENDED-AND CONTENTIONS ACCORDING REASONABLENESS SPECULATION COMMERCIAL CODE |
United States District Court:
for the .-
,
District of Massachusetts
'\
SECURITIES AND EXCHANGE COMIVIISSION,
Plaint8
Civil Action No. 97-10353-PBS
V.
MEMORANDUM OF LEHMAN BROTHERS, INC.
IN RESPONSE TO SEC'S
"SECOND SUPPLEMENTAL MEMORANDUM"
More than four months after this Court closed the record on the SEC's pending
motion for a preliminary injunction, the SEC has filed a "Second Supplemental
Memorandum'' that: (i) still fails to allege that Lehman Brothers, Inc. ("Lehman") had
actual knowledge of the alleged fraud by which Emanuel Pinez ('Tinez") acquired the
options contracts to which Lehman's security interest attached; (ii) attempts to avoid the
controlling ''actual knowledge" standard of Exchange Act $29 by arguments that bear no
fidelity to the words of the statute or decisions by the Courts of Appeals; and (iii) attempts
to demonstrate that Lehman had some lesser form of "notice" of "po~~ibly
illegal
by Pinez on the basis of distorted excerpts from a one-sided and partially secret record.'
Lehman responds herein.
SNIPPETS:
|
