Litigation Release No. 17176 / October 10, 2001

SECURITIES AND EXCHANGE COMMISSION v. BRETT S. HENDERSON AND RICHARD F.
RANDALL, United States District Court for the Northern District of
California, Civil Action No. 99-3677 PJH

   The Securities and Exchange Commission today announced that Final
   Judgments of Permanent Injunctions and Other Equitable Relief were
   entered in November 2000 against defendant Brett S. Henderson and
   Richard F. Randall by Judge Hamilton of the United States District
   Court of the Northern District of California pursuant to Consents
   executed by Henderson and Randall. Mr. Henderson is a resident of San
   Francisco and a former analyst in the Investment Banking/Corporate
   Finance Division of the Menlo Park office of Morgan Stanley Dean
   Witter (MSDW), while Mr. Randall is a school teacher who lives in
   Urbana, Ohio.

   According to the Final Judgments, Henderson and Randall are each
   permanently enjoined from directly or indirectly violating Section
   17(a) of the Securities Act of 1933, Section 10(b) of the Securities
   Exchange Act of 1934 and Rule 10b-5 promulgated thereunder. Henderson
   and Randall were each ordered to disgorge the amount of $54,109.45,
   plus prejudgment interest, as representing their ill-gotten gains by
   trading on material, non-public information regarding MSDW clients. In
   the case of Mr. Henderson, the disgorgement and prejudgment interest
   amounts were waived in their entirety based upon his demonstrated
   inability to pay. In the case of Mr. Randall, the disgorgement amount
   in excess of $37,000 and all of the prejudgment interest amount were
   waived in light of his demonstrated inability to pay.

   The Commission's complaint alleged that, beginning in September 1998
   and ending in July 1999, Henderson repeatedly tipped Randall with
   material, non-public information regarding MSDW clients so that he and
   Randall could trade on that information through Randall's brokerage
   account. Henderson and Randall generated profits of approximately
   $54,000 by their illegal trading.

   The complaint further alleged that prior to Henderson's starting work
   at MSDW in September 1998, he and Randall agreed that Henderson would
   provide Randall with information he learned from his position at MSDW,
   and Randall would trade on that information in his online brokerage
   account. Henderson and Randall also agreed to split the profits from
   their illegal trading -- 60% to Randall, who provided the capital, and
   40% to Henderson, who provided the information. Within days of
   Henderson's starting work at MSDW, he began to provide Randall with
   inside information relating to MSDW clients and to instruct Randall on
   how to trade in the stock of those companies. Henderson typically used
   pay phones when he called Randall in order to avoid detection. In some