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U.S. Securities and Exchange Commission

Initial Decision of an SEC Administrative Law Judge

In the Matter of
John Christopher McCamey and Sierra Equity Partners, LP

INITIAL DECISION RELEASE NO. 230
ADMINISTRATIVE PROCEEDING
FILE NO. 3-10911

UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


In the Matter of

JOHN CHRISTOPHER McCAMEY
and SIERRA EQUITY PARTNERS, LP


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INITIAL DECISION

June 17, 2003

APPEARANCES:

Kent W. McAllister, for the Division of Enforcement,
Securities and Exchange Commission

John Christopher McCamey, pro se, and for Sierra Equity Partners, LP

BEFORE: Robert G. Mahony, Administrative Law Judge

INTRODUCTION

The Securities and Exchange Commission (Commission) issued an Order Instituting Proceedings (OIP) on October 8, 2002, against Respondents John Christopher McCamey (McCamey) and Sierra Equity Partners, LP, (Sierra Equity) pursuant to Section 8A of the Securities Act of 1933 (Securities Act) and Sections 15(b) and 21C of the Securities Exchange Act of 1934 (Exchange Act).

The OIP alleges that McCamey and Sierra Equity willfully violated Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act, and Rule 10b-5 thereunder. The OIP further alleges that McCamey and Sierra Equity willfully violated and committed violations of Sections 5(a) and 5(c) of the Securities Act by failing to register with the Commission the offering of limited partnership interests in Sierra Equity when no exemption to registration applied. The OIP further alleges that McCamey willfully aided and abetted and caused Sierra Brokerage Services, Inc.'s (Sierra Brokerage), violations of Section 15(c) of the Exchange Act and Rule 15c1-2 thereunder. The OIP also alleges that Sierra Equity caused Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2.

The Respondents filed their Answers on October 23, 2002. On March 17, 2003, the parties filed Stipulations of Fact, pursuant to Rule 324 of the Commission's Rules of Practice, 17 C.F.R. § 201.324.1 On May 30, 2003, the Division filed a Motion to Strike Respondents' Answers based on the Respondents' representation that they would withdraw their Answers. The Respondents have not withdrawn their Answers and the Division's Motion to Strike Respondents' Answers is DENIED.

FINDINGS OF FACT

My findings and conclusions are based on Stips. 1-10, 12, which are accepted. I have applied "preponderance of the evidence" as the applicable standard of proof. See Steadman v. SEC, 450 U.S. 91, 97-104 (1981). The Division has filed a brief in support of the sanctions it seeks. Respondents have not filed a brief. I have considered and rejected all arguments and proposed conclusions that are inconsistent with this decision.

McCamey was at all relevant times the Chairman and CEO, a general securities principal, a registered options principal, and a registered representative of Sierra Brokerage. (Stip. 1)

Sierra Equity is a Delaware limited partnership that was formed by McCamey in May 2000. According to its prospectus, it was formed to invest in and trade equities, options, and other securities. It is headquartered in Columbus, Ohio. (Stip. 2)

Sierra Brokerage is an Ohio corporation with its principal place of business in Columbus, Ohio. Sierra Brokerage is a broker-dealer that has been registered with the Commission since 1994, pursuant to Section 15(b) of the Exchange Act. (Stip. 3)

Sierra Asset Management LLC (Sierra Asset) is a Delaware limited liability corporation formed by McCamey in May 2000. It is headquartered in Columbus, Ohio. Sierra Asset is the general managing partner of Sierra Equity. (Stip. 4.)

McCamey maintained complete control over Sierra Asset, through which he had exclusive control of the management, operations, and policies of Sierra Equity, including the responsibility for making all investment decisions. McCamey developed a prospectus and subscription agreement to offer limited partnerships interests in Sierra Equity with no limits on the amount of funds that could be raised. Investors in Sierra Equity were to be limited partners with no voice in its operations, management, or investment decisions. Investors would rely solely on McCamey, through Sierra Asset, to generate a return on their investment. Sierra Equity was to pool investor funds and they would share in the profits or losses from Sierra Equity investing activity on a pro rata basis. (Stips. 6-7.)

At all relevant times, there was no registration statement filed with the Commission or in effect for the securities offered by Sierra Equity and no exemption applied to the offering. In or about October 2001, McCamey obtained information regarding the purchase of real estate tax lien certificates. Based on this information, McCamey developed an investment strategy for Sierra Equity that involved purchasing tax lien certificates that remained available after a public auction. (Stips. 8-9.)

Thereafter, in November and December 2001, McCamey and Sierra Equity made false and misleading statements to potential investors in the following ways:

a. McCamey and Sierra Equity sent a letter to clients of Sierra Brokerage, in or about November 2001, which referred to Sierra Equity as an "unusual opportunity that provides the safety of CDs yet offers . . . returns of 5 to 20 times that of current 1 year CDs." (Emphasis in original).

b. McCamey drafted and sent a spam e-mail on or about November 28, 2001, to 90,000 e-mail addresses which stated: "How would you like to make 15% to 50% a year in a secured, government-sponsored investment vehicle that can give you the safety of CDs yet deliver stock market-type returns, and best of all, no losses?" The spam e-mail included a link that directed investors to the website of Sierra Brokerage.

c. Sierra Brokerage's website, in turn, identified Sierra Equity. According to Sierra Brokerage's website, Sierra Equity's area of investment "has historically provided returns between 15% to 50% annualized, yet remains 100% government secured." (Emphasis in original). McCamey did not inform potential investors that Sierra Equity was to invest in tax lien certificates.

(Stip. 10.)

On November 28, 2001, one brokerage client of McCamey's invested $10,000 in Sierra Equity. In response to an inquiry by the staff of the Commission, in mid-December 2001, McCamey agreed to stop soliciting investments and return the $10,000 to the lone investor, thereby terminating Sierra Equity's offering. McCamey also removed the web page relating to Sierra Equity from Sierra Brokerage's website. (Stip. 12.)

CONCLUSIONS OF LAW

UNREGISTERED OFFERING

The OIP alleges that McCamey and Sierra Equity willfully violated and committed violations of Sections 5(a) and 5(c) of the Securities Act by failing to register with the Commission the offering of limited partnership interests in Sierra Equity when no exemption to registration applied.

Section 2 of the Securities Act and Section 3(a)(10) of the Exchange Act define the term "security" to include an "investment contract." The Supreme Court in SEC v. W.J. Howey Co. defined the term "investment contract" under Section 2 of the Securities Act as "a contract, transaction or scheme whereby a person invests his money in a common enterprise and is led to expect profits solely from the efforts of the promoter or a third party . . . ." 328 U.S. 293, 298-299 (1946); see also Tcherepnin v. Knight, 389 U.S. 332, 338 (1967) (utilizing the Howey test for determining whether a security is an investment contract under Section 3(a)(10) of the Exchange Act).

In this case, McCamey and Sierra Equity stipulated that investors in Sierra Equity were to be limited partners with no voice in its operations, management, or investment decisions. Investors would rely solely on McCamey, through Sierra Asset, to generate a return on their investment. Sierra Equity was to pool investor funds and investors would share in the profits or losses from Sierra Equity investing activity on a pro rata basis. I conclude based on the criteria set out in Howey that the limited partnership interests offered for sale by McCamey and Sierra Equity were investment contracts within the meaning of Section 2 of the Securities Act and Section 3(a)(10) of the Exchange Act.

Sections 5(a) and 5(c) of the Securities Act provide generally that it is unlawful for a person, directly or indirectly, to sell, deliver a security, offer to sell or offer to buy, a security through any means of interstate commerce unless a registration statement is in effect as to a security. In this case, McCamey and Sierra Equity used the mails to offer and sell securities to investors and no exemption to registration applied. Therefore, I conclude that McCamey and Sierra Equity willfully violated Sections 5(a) and 5(c) of the Securities Act.

ANTIFRAUD PROVISIONS

Section 17(a) of the Securities Act prohibits any person from using, directly or indirectly, the mails or instruments of interstate commerce in the offer or sale of securities to employ any device, scheme, or artifice to defraud; use false statements or omissions of material fact to obtain money or property; or engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon a purchaser.

Section 10(b) of the Exchange Act and Rule 10b-5 prohibit any person from using, directly or indirectly, the mails or instruments of interstate commerce in connection with the purchase or sale of any security to employ any device, scheme, or artifice to defraud; make any untrue statement or omission of material fact; or engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.

The test for materiality is whether there is a substantial likelihood that a reasonable investor would consider the information important to the investment decision, and would view it as having significantly altered the total mix of available information. See Basic Inc. v. Levinson, 485 U.S. 224, 231-32 (1988); see also TSC Indus., Inc. v. Northway, Inc., 426 U.S. 438, 449 (1976). Materiality is a mixed question of law and fact. See Ganino v. Citizens Utils. Co., 228 F.3d 154, 162 (2d Cir. 2000).

Scienter is a required element under Section 17(a)(1) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5, but not Sections 17(a)(2) and 17(a)(3) of the Securities Act.2 See Aaron v. SEC, 446 U.S. 680, 701-02 (1980). The Supreme Court has defined scienter as "a mental state embracing intent to deceive, manipulate, or defraud." Ernst & Ernst v. Hochfelder, 425 U.S. 185, 193 n.12 (1976). The scienter requirement is also satisfied by showing that a respondent acted recklessly, defined as "an extreme departure from the standards of ordinary care, and which presents a danger of misleading buyers or sellers that is either known to the [respondent] or is so obvious that the actor must have been aware of it." See Sundstrand Corp. v. Sun Chem. Corp., 553 F.2d 1033, 1045 (7th Cir. 1977); see also Hollinger v. Tital Capital Corp., 914 F.2d 1564, 1569 (9th Cir. 1990); Meyer Blinder, 50 S.E.C. 1215, 1229-30 (1992).

The "in connection with" requirement has been broadly construed by the Supreme Court. See SEC v. Hasho, 784 F. Supp. 1059, 1106 (S.D.N.Y. 1992) (citing Superintendent of Ins. v. Bankers Life and Cas. Co., 404 U.S. 6, 12 (1971)). "Any statement that is reasonably calculated to influence the average investor satisfies the `in connection with' requirement of Rule 10b-5." Hasho, 784 F. Supp. at 1106; see also SEC v. Zandford, 122 S.Ct. 1899, 1904 (2002).

The jurisdictional clauses under the antifraud provisions are given broad interpretation and are satisfied by intrastate telephone calls and by incidental use of the mails. See McDaniel v. United States, 343 F.2d 785, 787-88 (5th Cir. 1965); see also Ruebe v. Pharmacodynamics, Inc., 348 F. Supp. 900, 912 (D.C. Pa. 1972); Ingraffia v. Belle Meade Hosp., Inc., 319 F. Supp. 537, 538 (D.C. La. 1970).

The OIP alleges that McCamey and Sierra Equity willfully violated Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act, and Rule 10b-5. In this case, McCamey and Sierra Equity offered and sold limited partnership interests in Sierra Equity to investors. During the sale of those securities, McCamey and Sierra Equity made false and misleading statements to investors about the safety and return that they could expect from an investment in the hedge fund. McCamey and Sierra Equity also made material omissions by failing to disclose that the investors' monies would be invested in tax lien certificates. These false statements and omissions are material since a reasonable investor would consider them important in deciding whether or not to purchase the limited partnership interests.

In addition, McCamey and Sierra Equity acted with scienter. I conclude that Respondents knew or were reckless in not knowing that their statements were false and misleading at the time they were made. I further conclude that the offer and sale of the limited partnership interests were "in connection with the purchase or sale of a security" since the Respondents' sale of securities and an investor's purchase of a limited partnership interest on November 28, 2001, coincided with the false statements and material omissions made by the Respondents in November and December 2001. The jurisdictional requirement has been met since McCamey and Sierra Equity mailed a letter to clients of Sierra Brokerage, which contained false and misleading statements.

SECTION 15(c) OF THE EXCHANGE ACT AND RULE 15c1-2

The OIP further alleges that McCamey willfully aided and abetted Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2.

Aiding and Abetting

For aiding and abetting liability to attach under the federal securities laws, three elements must be established: (1) an independent securities law violation committed by another party; (2) knowledge by the aider and abettor that his or her role was part of an overall activity that was improper; and (3) that the aider and abettor knowingly and substantially assisted the conduct that constitutes the violation. See Woods v. Barnett Bank, 765 F.2d 1004, 1009 (11th Cir. 1985); see also Investors Research Corp. v. SEC, 628 F.2d 168, 178 (D.C. Cir. 1980); IIT v. Cornfeld, 619 F.2d 909, 922 (2d Cir. 1980); Woodward v. Metro Bank, 522 F.2d 84, 97 (5th Cir. 1975).

Primary Violation

Section 15(c)(1)(A) of the Exchange Act prohibits a broker or dealer from using the mails or instruments of interstate commerce to effect transactions in, or to induce or attempt to induce the purchase or sale of any security by means of any manipulative, deceptive, or other fraudulent device or contrivance.

Section 15(c)(2)(A) of the Exchange Act prohibits a broker or dealer from using the mails or instruments of interstate commerce to effect transactions in, or to induce or attempt to induce the purchase or sale of any security, in connection with which such broker or dealer engages in any fraudulent, deceptive, or manipulative act or practice, or makes any fictitious quotation.

Rule 15c1-2 of the Exchange Act defines the term "manipulative, deceptive, or other fraudulent device or contrivance" as (a) "any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person," (b) "as any untrue statement of a material fact and any omission to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, which statement or omission is made with knowledge or reasonable grounds to believe that it is untrue or misleading."

Sierra Brokerage made a false representation on its website that Sierra Equity's area of investment "has historically provided returns between 15% to 50% annualized, yet remains 100% government secured." (Emphasis in original.) McCamey knew or was reckless in not knowing that the statements made on Sierra Brokerage's website were false and misleading. Since McCamey maintained control over Sierra Brokerage, as its Chairman and CEO, his knowledge is imputed to Sierra Brokerage. See SEC v. Manor Nursing Ctrs. Inc., 458 F.2d 1082, 1096-97 nn.16-18 (2d Cir. 1972) (holding that a company's knowledge can be imputed by the individuals that control it.) Based on its conduct, I conclude that Sierra Brokerage violated Sections 15(c)(1)(A) and 15(c)(2)(A) of the Exchange Act and Rule 15c1-2.

Knowledge and Substantial Assistance

At all relevant times, McCamey was the Chairman and CEO of Sierra Brokerage. McCamey mailed letters to Sierra Brokerage's clients, sent spam e-mails, and created a web page on Sierra Brokerage's website, which he knew or was reckless in not knowing contained false misrepresentations. I conclude that McCamey substantially assisted Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2. I further conclude that McCamey willfully aided and abetted Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2.

Causing

The OIP further alleges that McCamey and Sierra Equity caused Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2 thereunder. The Commission recently held that "[a] finding that a respondent willfully aided and abetted violations of the securities laws necessarily makes that respondent a `cause' of those violations." John J. Kenny, 2003 SEC LEXIS 1170, at *49 (citing Sharon M. Graham, 53 S.E.C. 1072, 1085 n.35 (1998), aff'd, 222 F.3d 994 (D.C. Cir. 2000); Dominick & Dominick, Inc., 50 S.E.C. 571, 578 n.11 (1991)). Since McCamey willfully aided and abetted Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2, I conclude that he was also a cause of those violations. In addition, since McCamey maintained complete control over Sierra Equity, through the use of Sierra Asset, I further conclude that Sierra Equity was a cause of Sierra Brokerage's violations of Section 15(c) of the Exchange Act and Rule 15c1-2.

SANCTIONS

I have concluded that McCamey and Sierra Equity committed the violations charged in the OIP. The remaining issue is to determine sanctions that are appropriate in the public interest. The following factors are relevant for determining the public interest:

[T]he egregiousness of the defendant's actions; the isolated or recurrent nature of the infraction; the degree of scienter involved; the sincerity of the defendant's assurances against future violations; the defendant's recognition of the wrongful nature of his conduct; and the likelihood that the defendant's occupation will present opportunities for future violations.

Steadman v. SEC, 603 F.2d 1126, 1140 (5th Cir. 1979), aff'd on other grounds, 450 U.S. 91 (1981). The severity of a sanction depends on the facts of each case and the value of the sanction in preventing a recurrence. See Berko v. SEC, 316 F.2d 137, 141 (2d Cir. 1963); see also Richard C. Spangler, Inc., 46 S.E.C. 238, 254 n.67 (1976); Leo Glassman, 46 S.E.C. 209, 211-12 (1975). Willfulness does not require intent to violate, but merely intent to do the act, which constitutes a violation. See Arthur Lipper Corp. v. SEC, 547 F.2d 171, 180 (2d Cir. 1976).

Cease and Desist

Section 8A of the Securities Act and Section 21C of the Exchange Act provide that the Commission may enter a cease-and-desist order against any person, who is violating, has violated, or is about to violate any provision of the Securities Act and Exchange Act, or any rule or regulation thereunder, from committing or causing such violation and any future violation of the same provision, rule, or regulation. The Commission has held that in order to issue a cease-and-desist order, there must be "some likelihood of future violations" and "[a]bsent evidence to the contrary, a finding of violation raises a sufficient risk of future violation." KPMG Peat Marwick, LLP, 74 SEC Docket 384, 429-30 (2001), petition denied, 289 F.3d 109 (D.C. Cir. 2002). Based on their violations of the securities laws, there exists a strong likelihood that McCamey and Sierra Equity will violate the same provisions of the Securities Act and Exchange Act in the future. Therefore, cease-and-desist orders, which Respondents do not oppose, are appropriate against McCamey and Sierra Equity.

Bar

Section 15(b)(6) of the Exchange Act authorizes the imposition of sanctions on any person associated with a broker-dealer, if it is in the public interest and the person has willfully violated, or aided and abetted a violation of, any provision of the federal securities laws. Among the sanctions that may be imposed include a censure, limitations on the activities or functions of such person, or suspension for a period not exceeding 12 months, or a bar on such person from being associated with a broker or dealer, or from participating in an offering of penny stock.

McCamey's actions were egregious. He developed an elaborate scheme to defraud investors by sending letters, spam e-mails, and making false representations on Sierra Brokerage's website. He acted with scienter. While McCamey has stipulated to the facts alleged in the OIP, he has not given any assurances that he will not commit the same violations in the future. Given the seriousness of McCamey's violations, there is a strong likelihood that he will again violate the securities laws. I conclude that a permanent bar is the appropriate sanction to be imposed against McCamey.

Civil Monetary Penalty

Section 21B of the Exchange Act authorizes the Commission to impose a civil monetary penalty against any person, if it finds that it is in the public interest and the person has willfully violated, or aided and abetted a violation of, the Securities Act, Exchange Act, or the rules or regulations thereunder. Section 21B(b)(3) of the Exchange Act provides for a maximum third-tier civil monetary penalty of $120,000 against a natural person for violations involving fraud and substantial losses to others and which occur after February 2, 2001. See 17 C.F.R. § 201.1002. In this case, McCamey's actions took place after February 2, 2001. The Division has requested a civil monetary penalty in the amount of $120,000 against McCamey.

The assessment of a civil monetary penalty pursuant to Section 21B of the Exchange Act depends on the finding that such assessment is in the public interest. In determining the public interest, the Commission may consider: (1) whether the act or omission for which such penalty is assessed involved fraud, deceit, manipulation, or deliberate or reckless disregard of a regulatory requirement; (2) the harm to other persons resulting either directly or indirectly from such act or omission; (3) the extent to which any person was unjustly enriched, taking into account any restitution made to persons injured by such behavior; (4) whether such person previously has been found by the Commission, another appropriate regulatory agency, or a self-regulatory organization to have violated the federal securities laws, state securities laws, or the rules of a self-regulatory organization, has been enjoined by a court of competent jurisdiction from violations of such laws or rules, or has been convicted by a court of competent jurisdiction of violations of such laws or of any felony or misdemeanor described in section 15(b)(4)(B); (5) the need to deter such person and other persons from committing such acts or omissions; and (6) such other matters as justice may require. See Section 21B(c) of the Exchange Act.

McCamey's violations of the securities laws were serious. His actions involved fraud and were done knowingly and willfully. McCamey sent out spam e-mails to 90,000 e-mail addresses, which contained false statements. In addition, McCamey used Sierra Brokerage, a registered broker-dealer with the Commission, to help facilitate the fraud by sending letters, which contained false statements, and posting fraudulent statements on Sierra Brokerage's website. However, there are certain mitigating factors against imposing the maximum civil monetary penalty against McCamey. McCamey does not have a history of violating the securities laws. In addition, in response to an inquiry by the staff of the Commission, McCamey agreed to stop soliciting investments and he has returned the $10,000 to the lone investor. McCamey also removed the web page relating to Sierra Equity from Sierra Brokerage's website. Taking these mitigating factors into account, I conclude that a third-tier civil monetary penalty in the amount of $60,000 is appropriate against McCamey.

ORDER

Based upon the findings and conclusions set forth above:

IT IS ORDERED, pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, that John Christopher McCamey and Sierra Equity Partners, LP, CEASE AND DESIST from committing or causing violations, and any future violations, of Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 and Sections 10(b) and 15(c)(1) of the Securities Exchange Act of 1934 and Rules 10b-5 and 15c1-2 thereunder;

IT IS FURTHER ORDERED, pursuant to Section 15(b) of the Securities Exchange Act of 1934, that John Christopher McCamey is hereby BARRED permanently from being associated with any broker or dealer; and

IT IS FURTHER ORDERED, pursuant to Section 21B of the Securities Exchange Act of 1934, that John Christopher McCamey pay a CIVIL MONETARY PENALTY of Sixty Thousand Dollars ($60,000).

Payment of the penalty shall be made by certified check, U.S. postal money order, bank cashier's check, or bank money order payable to the Securities and Exchange Commission on the first day following the day this Initial Decision becomes final. The check and a cover letter identifying Respondents and Administrative Proceeding No. 3-10911, should be delivered by hand or courier to the Comptroller, U.S. Securities and Exchange Commission, Operations Center, 6432 General Green Way, Stop-3, Alexandria, Virginia 22312. A copy of the cover letter should be sent to Kent W. McAllister, Division of Enforcement, Midwest Regional Office, U.S. Securities and Exchange Commission, 175 West Jackson Blvd., Suite 900, Chicago, Illinois 60604.

This order shall become effective in accordance with and subject to the provisions of 17 C.F.R. § 201.360. Pursuant to that rule, a petition for review of this Initial Decision may be filed within twenty-one days after service of the Decision. It shall become the final decision of the Commission as to each party who has not filed a petition for review pursuant to 17 C.F.R. § 201.360(d)(1) within twenty-one days after service of the Initial Decision upon him, unless the Commission, pursuant to 17 C.F.R. § 201.360(b)(1), determines on its own initiative to review this Initial Decision as to any party. If a party timely files a petition for review, or the Commission acts to review as to a party, the Initial Decision shall not become final as to that party.

__________________
Robert G. Mahony
Administrative Law Judge

Endnotes

1 The Stipulations are referred to by number and cited herein as (Stip. ___.).

2 A finding of negligence is adequate to establish a violation of Sections 17(a)(2) and 17(a)(3) of the Securities Act. See SEC v. Steadman, 967 F.2d 636, 643 & n.5 (D.C. Cir. 1992) (citing Aaron, 446 U.S. at 701-02; Newcome v. Esrey, 862 F.2d 1099, 1102 n.7 (4th Cir. 1988)); see also Jay H. Meadows, 52 S.E.C. 778, 785 n.16 (1996), aff'd, 119 F.3d 1219 (5th Cir. 1997).

 

http://www.sec.gov/litigation/aljdec/id230rgm.htm


Modified: 06/17/2003