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Thomas C. Newkirk Attorneys for Plaintiff UNITED STATES DISTRICT COURT FOR THE
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SECURITIES AND EXCHANGE COMMISSION,
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COMPLAINT 03 Civ.___ |
Plaintiff Securities and Exchange Commission (the "SEC") alleges as follows:
1. This is an accounting and disclosure fraud action against Medi-Hut Co., Inc.("Medi-Hut"), its former Chief Executive Officer, Joseph A. Sanpietro, Chief Financial Officer, Laurence M. Simon, and Vice President of Sales, Lawrence P. Marasco. These three corporate officers inflated Medi-Hut's revenues and earnings through fictitious period-end invoices and other accounting irregularities. Sanpietro and Simon also concealed from the investing public the fact that Marasco secretly owned and controlled one of Medi-Hut's largest customers.
2. These accounting and disclosure violations enabled Medi-Hut to tout "blockbuster" revenue growth and created the appearance of profitability, when in fact the company was operating at a loss. As a result, Medi-Hut's Form 10-K for the fiscal year ended October 31, 2001, and three Forms 10-Q for fiscal year ended October 31, 2002, were materially false and misleading.
3. The market for Medi-Hut common stock responded to this misinformation, remaining at an artificially high level. The stock traded between approximately $7 and $13 in January 2002. After Medi-Hut's fraud was partially disclosed to the market through news articles and press releases, the stock price spiraled downward.
4. Sanpietro also was unjustly enriched by his sale of Medi-Hut common stock during the relevant period.
5. By engaging in such conduct, Medi-Hut violated, and unless enjoined will continue to violate, Sections 10(b), 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934 ("Exchange Act") [15 U.S.C. §§ 78j(b), 78m(a), 78m(b)(2)(A) and 78m(b)(2)(B)] and Rules 10b-5, 12b-20, 13a-1 and 13a-13 [17 C.F.R. §§ 240.10b-5, 240.12b-20, 240.13a-1 and 240.13a-13], promulgated thereunder.
6. By engaging in such conduct, Sanpietro, Simon and Marasco violated, and unless enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rules 10b-5, 13b2-1 and 13b2-2 [17 C.F.R. §§ 240.10b-5, 240.13b2-1 and 13b2-2], promulgated thereunder, and aided and abetted Medi-Hut's violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act [15 U.S.C. §§ 78m(a), 78m(b)(2)(A) and 78m(b)(2)(B)] and Rules 12b-20, 13a-1 and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1 and 240.13a-13], promulgated thereunder.
7. By engaging in such conduct, Sanpietro, Simon and Marasco demonstrated their substantial unfitness to serve as officers or directors of a publicly-traded company pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)].
8. This Court has jurisdiction over this action pursuant to Sections 20(b) and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b) and 77v(a)] and Sections 21(e) and 27 of the Exchange Act [15 U.S.C. §§ 78u(e) and 78aa].
9. Defendants have, directly or indirectly, made use of the means or instrumentalities of interstate commerce and/or of the mails in connection with the transactions described in this Complaint.
10. Medi-Hut Co. Inc. ("Medi-Hut" or the "company") was, at all relevant times, a Nevada corporation headquartered in New Jersey. Medi-Hut went public in 1998 through a reverse merger with an inactive public shell corporation. During most of the relevant period, Medi-Hut's primary business was wholesaling pharmaceutical drugs. Medi-Hut is now out of the pharmaceutical drug business and is engaged primarily in wholesaling medical products such as syringes, adhesive bandages and hot and cold packs. The company's fiscal year ends October 31.
11. Medi-Hut's common stock is registered with the Commission pursuant to Section 12(g) of the Exchange Act and traded on the NASDAQ small cap market until March 28, 2003, when it was delisted. As of January 2002, Medi-Hut had approximately 300 shareholders of record and 14.5 million shares of common stock outstanding. The stock now trades under $0.25 per share.
12. Joseph A. Sanpietro ("Sanpietro"), age 53, was President, CEO and a director of Medi-Hut at all relevant times through March 21, 2003, when he was terminated. He owned over 3 million shares of Medi-Hut common stock during the relevant period. He resides in Freehold, New Jersey.
13. Laurence M. Simon ("Simon"), age 37, was the CFO of Medi-Hut at all relevant times through March 21, 2003, when he was terminated. He owned approximately 30,000 shares of Medi-Hut common stock during the relevant period. He resides in Englishtown, New Jersey.
14. During the relevant period Simon was a certified public accountant licensed to practice in New Jersey. Prior to joining Medi-Hut, Simon worked as an accountant for Rosenberg, Rich, Baker and Berman LLP ("The Rosenberg Firm"), Medi-Hut's former independent auditor.
15. Lawrence P. Marasco ("Marasco"), age 51, was the Vice President of Sales for Medi-Hut at all relevant times through March 2003, when he was terminated. He owned approximately 350,000 shares of Medi-Hut common stock during the relevant period. He resides in Seaford, New York.
16. Marasco was also the sole officer, director and shareholder of Larval Corporation ("Larval"), a privately owned wholesaler of pharmaceutical products, until February 12, 2002, when he transferred ownership to his sister-in-law.
17. From 1982 to 1998, Medi-Hut was a private company owned and operated by Joseph A. Sanpietro and his brother that bought and sold disposable medical products such as syringes, gowns and condoms.
18. Medi-Hut went public in January 1998 through a reverse merger with a publicly-traded shell. In January 2000, Medi-Hut expanded into the pharmaceutical drug business by acquiring Vallar Consulting Corporation, a private drug wholesaler owned and operated by defendant Lawrence P. Marasco. That year Marasco became Medi-Hut's Vice President of Sales.
19. Utilizing Marasco's extensive and long standing ties to the pharmaceutical drug industry, Medi-Hut experienced unprecedented revenue and earnings growth during fiscal year 2000. The company's apparent prosperity continued in fiscal years 2001 and 2002, as reported revenues and earnings continued to increase dramatically.
20. Medi-Hut's apparent success resulted in part from substantial drug sales to Larval Corporation, a wholesale pharmaceutical drug company owned and operated by Marasco, Medi-Hut's Vice President of Sales. In fiscal year 2000, sales to Larval accounted for approximately $1 million or 13% of Medi-Hut's total revenues of $8.1 million. At the end of fiscal year 2001, sales to Larval reportedly accounted for approximately $8.0 million or 62% of Medi-Hut's total revenues of $12.96 million.
21. Medi-Hut's sales to Larval constituted material, related-party transactions that should have been disclosed by the company under generally accepted accounting principles ("GAAP") (Statement of Financial Accounting Standards No. 57) and the rules and regulations of the SEC (Item 404 of Regulation S-K). Sanpietro and Simon knew, or were reckless in not knowing, that Marasco owned and controlled Larval and that, as a result, Medi-Hut's sales to Larval constituted related party transactions that should have been disclosed to the public.
22. Throughout fiscal years 2000 and 2001, Medi-Hut never disclosed that its Vice President of Sales was also the sole officer, director and shareholder of Larval. The relationship between Marasco and Larval was first revealed to the public in a New York Post article published on February 4, 2002. Immediately thereafter, Medi-Hut's stock price fell from approximately $7 to approximately $3 per share. On February 12, 2002, Marasco transferred ownership of Larval to his sister-in-law.
23. In order to conceal the true nature of the transactions between Medi-Hut and Larval during the fiscal year 2001 audit, Marasco signed a third party confirmation dated November 1, 2001, that he knew was false and misleading in two respects. First, the third party confirmation represented falsely to Medi-Hut's independent auditors that Marasco's sister-in-law was Larval's President and Secretary. Second, it represented falsely that Invoice No. 5454 for $624,308 was a valid receivable, when, as alleged below, it was not.
24. On January 10, 2002, Medi-Hut filed its Form 10-K for fiscal year ended October 31, 2001, and issued a related press release. Sanpietro and Simon each signed the Form 10-K. Medi-Hut reported annual revenues of $12.96 million and earnings of $520 thousand, or $0.04 per share. As reported, revenues were up from $8.1 million the prior year, or 59 percent; earnings were up from $235 thousand the prior year, or 121 percent. The financial results were consistent with revenue projections of $12 to $15 million that Medi-Hut disseminated to stockbrokers, investors and the general public.
25. The financial results were false and misleading, however, because, as alleged below, they overstated revenues by approximately $1.45 million and pre-tax earnings by approximately $1.3 million. Sanpietro and Simon achieved these enviable financial results through the creation of two sham transactions that were backdated to fiscal year 2001 and the premature recognition of revenue on two sales to Larval during the fourth quarter of 2001.
26. Sanpietro and Simon also knew, or were reckless in not knowing, that Medi-Hut's Form 10-K was false and misleading because it failed to disclose the related party transactions with Larval.
27. After the close of fiscal year ended October 31, 2001, Simon and Sanpietro realized that while Medi-Hut's revenues were up, earnings were flat compared to the prior fiscal year. In an effort to remedy this situation, Sanpietro and Simon created two sham transactions, one involving the sale of Acetaminophen to Larval Corporation (Invoice No. 5454) the other involving the sale of cleaning and paper products to Development Specialties, Inc. (Invoice No. 5351). Simon, with Sanpietro's knowledge and approval, then backdated the sales to 2001.
The First Fraudulent Acetaminophen
Transaction (Invoice No. 5454)
28. The first sham transaction related to a fictitious sale of Acetaminophen 500 mg tablets to Larval at inflated prices. The market price for this product at the time was approximately $6 to $7 per unit.
29. In November 2001, Simon created Invoice No. 5454, which was then backdated to October 24, 2001. On its face, Invoice No. 5454 showed that Medi-Hut had sold 20,845 Acetaminophen 500 mg tablets to Larval at the exorbitant price of $29.95 per unit -- a 400 percent markup -- for a total of $624,308.
30. Simon and Sanpietro then paired Invoice No. 5454 with an equally bogus purchase invoice, which they backdated to October 22, 2001. On its face, the purchase invoice showed that Medi-Hut had acquired the Acetaminophen from a company called "Intermax" for $5.99 per unit, or a total of $124,862.
31. Marasco provided Sanpietro and Simon with the bogus Intermax invoice.
32. Neither Medi-Hut's Invoice No. 5454 nor the purchase invoice from Intermax reflected the terms of a true transaction. This sham transaction enabled Medi-Hut to book an additional $500 thousand in gross profit for fiscal year 2001. Sanpietro, Simon and Marasco knew that Invoice No. 5454 and the Intermax invoice were backdated and did not reflect the terms of a bona fide transaction.
33. In addition, during the following quarter, Simon made a number of adjusting journal entries on Medi-Hut's books to make it appear to the Company's independent auditors that Invoice No. 5454 had been paid, when in fact it had not.
34. Approximately eight months later, after the staff of the SEC raised questions concerning Invoice No. 5454, Sanpietro, Simon and Marasco created yet another bogus Acetaminophen sale, as alleged below, designed to cover up the first.
The Fraudulent Cleaning and Paper Products
Transaction (Invoice No. 5351)
35. The second sham transaction related to a fictitious sale of cleaning and paper products to a company called "Development Specialties, Inc."
36. In November 2001, Simon, with Sanpietro's knowledge and approval, created Invoice No. 5351, which was backdated to September 8, 2001. On its face, Invoice No. 5351 showed that Medi-Hut had sold various products, including cleaning and paper products, to Development Specialties for $393,750.
37. To make it appear as if Invoice No. 5351 had been paid, Simon applied a wire transfer for the exact same amount -- $393,750 -- that the company had received for the purchase of stock, in satisfaction of the open account receivable. No cost of goods sold was recorded.
38. The paper products transaction was completely made up, and Invoice No. 5351 did not reflect the terms of a bona fide transaction. This sham transaction enabled Medi-Hut to book an additional $393,750 in gross profit for fiscal year 2001. Sanpietro and Simon knew that Invoice No. 5351 was backdated and did not reflect the terms of a bona fide transaction.
39. In addition to helping create the sham transactions described above, Simon boosted fiscal year 2001 earnings by causing Medi-Hut to recognize two sales prematurely.
40. The first transaction involved the sale of Levoxyl to Larval. Simon changed the terms of a legitimate invoice dated October 30, 2001 (Invoice No. 5501) to enable the premature recognition of $115,070 in revenues in fiscal year 2001, while leaving in the next period the $114,502 cost of goods sold.
41. The second transaction involved the sale of Nasonex Spray to Larval. Again, Simon changed the terms of a legitimate invoice dated October 31, 2001 (Invoice No. 5502) to enable the premature recognition of $320,244 in revenues in fiscal year 2001, while leaving in the next period the $319,198 cost of goods sold.
42. On January 15, 2002 -- just days after Medi-Hut filed its false and misleading Form 10-K for fiscal year 2001 -- Sanpietro sold 100,000 shares of Medi-Hut common stock in a private transaction for $5 per share, for a total of $500 thousand.
43. Sanpietro acquired the stock from the company as part of the reverse merger into a publicly traded shell.
44. The market price for Medi-Hut common stock was approximately $9.50 per share as of January 15, 2002.
45. The market price for Medi-Hut common stock at the close of trading was approximately $6.70 per share as of February 1, 2002, one trading day before the publication of the New York Post article on February 4, 2002. The market price for Medi-Hut common stock at the close of trading was approximately $3.29 per share as of February 4, 2002, the day the New York Post article was published.
46. At a minimum, Sanpietro was unjustly enriched by $171,000, which represents the difference between the proceeds from his stock sales ($500,000) and the value of the stock at market prices ($329,000) after investors were put on notice of possible fraud at Medi-Hut.
47. During the quarter ended January 31, 2002 ("Q1 2002"), Simon used various accounting tricks to inflate revenues and earnings, including booking a cancelled sale (Invoice No. 5623), double billing a customer (Invoice Nos. 5736, 5704 & 5563), backdating invoices (Invoice Nos. 5737 & 5735) and failing to properly record price adjustments (Invoice No. 5649). As a result of these accounting tricks, Q1 2002 revenues and pre-tax earnings were overstated by approximately $1,567,537.
48. In addition, Simon shifted costs and/or revenues on several sales transactions in order to inflate revenues and earnings during Q1 2002. As a result of this shifting of costs and/or revenues, Q1 2002 revenues were overstated by approximately $1,405,390 and pre-tax earnings were overstated by approximately $1,357,610.
49. In total, those accounting irregularities caused Medi-Hut's revenues for Q1 2002 to be overstated by approximately $2,972,927 and pre-tax earnings to be overstated by approximately $2,925,147.
50. On March 15, 2002, Medi-Hut filed its Form 10-Q for Q1 2002 and issued a related press release. Sanpietro and Simon signed the Form 10-Q. Medi-Hut reported Q1 2002 revenues of approximately $10 million and net income of $664 thousand or $.05 per share, a 766% increase over Q1 earnings in the prior year.
51. Simon knew that those financial results were inflated as the result of the numerous accounting irregularities summarized above.
52. During the quarter ended April 30, 2002 ("Q2 2002") Simon prematurely recognized revenue relating to two large shipments of Syntest (Invoice No. 5847), a generic hormone replacement drug for which Medi-Hut had exclusive distribution rights. Medi-Hut did not ship the Syntest until the third quarter, which ended July 31, 2002, but Simon booked the sales in the second quarter. Simon also altered shipping documents to avoid detection by Medi-Hut's independent auditors.
53. Those accounting irregularities caused Medi-Hut's revenues for Q2 2002 to be overstated by approximately $2,026,000 and pre-tax earnings to be overstated by approximately $1,286,000.
54. On June 14, 2002, Medi-Hut filed its Form 10-Q for Q2 2002 and issued a related press release. Simon signed the Form 10-Q. Medi-Hut reported Q2 2002 revenues of $5.3 million and earnings of $587 thousand or $.04 per share, a 370% increase over Q2 2002 earnings in the prior year.
55. Simon knew that those financial results were inflated as a result of the premature recognition of the two large Syntest transactions.
56. During the quarter ended July 31, 2002 ("Q3 2002"), the SEC staff began questioning the bona fides of a number of Medi-Hut's large, period-end invoices, including Invoice No. 5454 relating to the first Acetaminophen transaction. Sanpietro, Simon and Marasco responded by creating a second bogus Acetaminophen transaction, designed to cover up the first.
57. After the close of Q3 2002, Marasco agreed to have Larval purchase 21,000 Acetaminophen 500 mg tabs from Medi-Hut at the inflated price of $29.73 per unit, or a total of $624,308. In exchange, Sanpietro and Simon secretly agreed to cover Marasco's expected loss by channeling sales of Syntest through Larval on favorable terms.
58. Simon backdated an invoice (Invoice No. 6042) and shipping documents relating to the second Acetaminophen transaction in order to record a portion of this sale in Q3 2002 ($468,231 in revenues and $94,500 in expenses).
59. Meanwhile, Simon continued to resort to accounting gimmicks to help Medi-Hut show a profit for Q3 2002. With the knowledge and approval of Sanpietro, Simon moved approximately $1,655,109 in Q3 2002 expenses to the fourth quarter of 2002.
60. Those accounting irregularities caused Medi-Hut's revenues for Q3 2002 to be overstated by $468,231 and pre-tax earnings to be overstated by $2,028,840.
61. On September 17, 2002, Medi-Hut filed its Form 10-Q for Q3 2002 and issued a related press release. Sanpietro and Simon signed the Form 10-Q. Medi-Hut reported Q3 2002 revenues of $6.5 million and earnings of $366 thousand or $.03 per share, a 145% increase over Q3 2002 earnings in the prior year.
62. Sanpietro and Simon knew that earnings were inflated as the result of the moving of expenses into the fourth quarter and improperly recognizing part of the second Acetaminophen transaction in Q3 2002.
63. On September 17, 2002, Medi-Hut restated its financials for fiscal year 2001 and the first and second quarters of fiscal year 2002. The effect of the restatement was to reduce Medi-Hut's revenues for the fourth quarter of 2001 by $624,308 (the amount of Invoice No. 5454) and to reduce annual net income from $0.04 to $0.02 per share. In addition, Medi-Hut's restatement reduced Q1 2002 sales by $404,607 and net income from $0.04 to $0.02 per share. The $404,607 was the aggregate amount of three sales (Invoice Nos. 5736, 5704 and 5623) that were inappropriately double billed to a customer during the first quarter.
64. Simon and Sanpietro knew that the restated financial results failed to fully account for or disclose several other accounting irregularities described above.
65. Plaintiff SEC hereby incorporates ¶¶ 1 through 64 with the same force and effect as if set out here.
66. Defendants Medi-Hut, Sanpietro and Simon knowingly or recklessly failed to disclose that Marasco secretly owned and controlled Larval, one of Medi-Hut's largest customers, as required by generally accepted accounting principles ("GAAP") (Statement of Financial Accounting Standards No. 57) and the rules and regulations of the SEC (Item 404 of Regulation S-K).
67. As set forth above, Defendants Medi-Hut, Sanpietro, Simon and Marasco knowingly or recklessly falsified Medi-Hut's financial statements that were incorporated into the company's Form 10-K and three Forms 10-Q as originally filed with the SEC and published in the company's press releases.
68. In the manner described in ¶¶ 1 through 67, defendants Medi-Hut, Sanpietro, Simon and Marasco, in connection with the purchase or sale of securities, by the use of means or instrumentalities of interstate commerce or of the mails, directly or indirectly (a) employed devices, schemes or artifices to defraud; (b) made untrue statements of material facts or omissions of material facts necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or (c) engaged in transactions, practices or courses of business which operated or would operate as a fraud or deceit upon persons, in violation of Section 10(b) of the Exchange Act [15 U.S.C § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] promulgated thereunder.
69. Plaintiff SEC hereby incorporates ¶¶ 1 through 68 with the same force and effect as if set out here.
70. In the manner described in ¶¶ 1 through 69, defendant Medi-Hut falsified the financial statements that were incorporated into the company's Form 10-K and three Forms 10-Q as originally filed with the SEC in violation of Sections 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1 and 13a-13 promulgated there under [17 C.F.R. §§ 240.12b-20, 240.13a-1 and 240.13a-13].
71. In the manner described in ¶¶ 1 through 70, defendants Sanpietro, Simon and Marasco aided and abetted Medi-Hut's primary violations of Sections 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1 and 13a-13 promulgated thereunder [17 C.F.R. §§ 240.12b-20, 240.13a-1 and 240.13a-13], pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)], by knowingly lending substantial assistance thereto.
72. Plaintiff SEC hereby incorporates ¶¶ 1 through 71 with the same force and effect as if set out here.
73. In the manner described in ¶¶ 1 through 72, defendant Medi-Hut failed to make and keep accurate books and records and to maintain a system of internal accounting controls sufficient to provide reasonable assurances that its financial statements were prepared in accordance with GAAP, in violation of Section 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act [15 U.S.C. §§ 78m(b)(2)(A) and 78m(b)(2)(B)].
74. In the manner described in ¶¶ 1 through 73, defendants Sanpietro, Simon and Marasco aided and abetted Medi-Hut's primary violations of Section 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act [15 U.S.C. §§ 78m(b)(2)(A) and 78m(b)(2)(B)], pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)] by lending substantial assistance thereto.
75. Plaintiff SEC hereby incorporates ¶¶ 1 through 74 with the same force and effect as if set out here.
76. In the manner described in ¶¶ 1 through 75 defendants Sanpietro, Simon and Marasco falsified the books and records of Medi-Hut in violation of Rule 13b2-1 of the Exchange Act [17 C.F.R. § 240.13b2-1]; and lied to Medi-Hut's outside auditors in violation of Rule 13b2-2 of the Exchange Act [17 C.F.R. § 240.13b2-2].
WHEREFORE, the SEC respectfully requests that this Court enter a judgment:
permanently enjoining defendant Medi-Hut, and its officers, agents, servants, employees, attorneys, and those in active concert or participation with it who receive actual notice by personal service or otherwise, from violating Sections 10(b), 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934 ("Exchange Act") [15 U.S.C. §§ 78j(b), 78m(a), 78m(b)(2)(A) and 78m(b)(2)(B)] and Rules 10b-5, 12b-20, 13a-1 and 13a-13 [17 C.F.R. §§ 240.10b-5, 240.12b-20, 240.13a-1 and 240.13a-13], promulgated thereunder;
permanently enjoining defendants Sanpietro, Simon and Marasco, and their agents, servants, employees, attorneys, and those in active concert or participation with them, who receive actual notice by personal service or otherwise, from violating Section 10(b) of the Exchange Act [15 U.S.C. §§ 78j(b)] and Rules 10b-5, 13b2-1 and 13b2-2 [17 C.F.R. §§ 240.10b-5, 240.13b2-1 and 240.13b2-2], promulgated thereunder, and aiding and abetting violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act [15 U.S.C. §§ 78m(a), 78m(b)(2)(A) and 78m(b)(2)(B)], and Rules 12b-20, 13a-1 and 13a-13 [17 C.F.R. §§ 240.12b-20, 13a-1 and 13a-13] promulgated thereunder;
ordering defendant Sanpietro to disgorge all ill-gotten gains from the conduct alleged herein, with prejudgment interest;
permanently barring defendants Sanpietro, Simon and Marasco from serving as an officer or director of a publicly traded company pursuant to Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)]; and
granting such other relief as this Court may deem just and appropriate.
Dated: August 19, 2003
___________________________ Attorneys for Plaintiff |
http://www.sec.gov/litigation/complaints/comp18296.htm
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