SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 18329 / September 8, 2003

, No. 03-4206 (JWB) (D.N.J.)

SEC CHARGES THREE FORMER TRADERS AT KNIGHT SECURITIES WITH ENGAGING IN
FRAUDULENT TRADING SCHEME

   On September 8, 2003, the Securities and Exchange Commission filed a
   complaint in the United States District Court for the District of New
   Jersey charging three former traders at Knight Securities, L.P. -
   Brian P. Delaney of New Jersey, Nicole M. Shkedi of New Jersey, and
   Thomas J. Donovan of New York - with engaging in a trading scheme that
   defrauded Knight of approximately $1.4 million. The Commission also
   issued a related administrative order charging a fourth individual -
   Charles C. Campbell of New Jersey - with being a cause of the
   violations by two of the former Knight traders. Delaney, Shkedi, and
   Campbell each settled the proceedings against them without admitting
   or denying the Commission's charges, while Donovan is contesting the
   charges.

   In its complaint in federal court, the Commission alleged that
   Delaney, Shkedi, and Donovan were all formerly employed by Knight as
   equity traders responsible for making markets in specific equity
   securities. The Commission further alleged that, as equity traders,
   the defendants had discretionary trading authority over Knight trading
   accounts maintained for the purpose of carrying out Knight's business
   as a market maker in these specific stocks. According to the
   Commission, from at least March 2001 through February 2002, the three
   former traders abused their positions at Knight by knowingly and
   intentionally executing fraudulent stock trades from the Knight
   proprietary accounts they controlled at prices guaranteed to generate
   profits in private brokerage accounts that they also controlled. The
   Commission alleged that the defendants' trading scheme defrauded
   Knight of approximately $1.4 million, which Knight has since recovered
   from Delaney.

   The complaint charges Delaney, Shkedi, and Donovan with committing
   securities fraud in violation of Section 17(a) of the Securities Act
   of 1933 (the "Securities Act"), Section 10(b) of the Securities
   Exchange Act of 1934 (the "Exchange Act"), and Exchange Act Rule
   10b-5. Without admitting or denying the Commission's allegations,
   Delaney and Shkedi have consented to the court's entry of final
   judgments that would permanently enjoin them from violating the
   foregoing provisions of the securities laws, as well as to the
   Commission's issuance of administrative orders that would bar them
   from associating with any registered broker or dealer based on the