Case 1:20-cv-01692-YK Document 1 Filed 09/17/20 Page 1 of 20
 

UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
SECURITIES AND EXCHANGE
COMMISSION,

Case No. 20-CV-_______

Plaintiff,
COMPLAINT

v.
STEVEN J. SHEINFELD,

JURY TRIAL DEMANDED

Defendant.
Plaintiff Securities and Exchange Commission (the “SEC”) files this
Complaint against defendant Steven J. Sheinfeld (“Sheinfeld”) and alleges as
follows:
SUMMARY
1.

Sheinfeld illegally traded on inside information about his employer

Rite Aid Corp. (“Rite Aid”) by selling nearly $1 million in Rite Aid securities in
advance of disappointing news that caused the price of Rite Aid securities to drop
when revealed to the market.
2.

In January 2017, Sheinfeld, who had worked at Rite Aid for over

twenty years, was asked to lead a sensitive project that involved integrating

 Case 1:20-cv-01692-YK Document 1 Filed 09/17/20 Page 2 of 20

company policies related to implementing a publicly-announced merger (the
“Planned Merger”) of Rite Aid with Walgreens Boots Alliance, Inc.
(“Walgreens”).
3.

While working on the project, Sheinfeld learned highly-confidential

information that the Planned Merger was not expected to close by the scheduled
deadline of January 27, 2017. Failure to meet this closing deadline meant that Rite
Aid and Walgreens had not obtained regulatory approval for the Planned Merger,
and that the deal terms would need to be renegotiated. Sheinfeld knew, or
recklessly avoided knowing, that when the market learned this information, Rite
Aid’s stock price would fall.
4.

Sheinfeld also knew that he was prohibited from trading on material

nonpublic information about Rite Aid or the Planned Merger. Indeed, Sheinfeld
oversaw Rite Aid’s compliance with its Code of Business Ethics & Conduct (the
“Code of Conduct”), which explicitly prohibited insider trading.
5.

Nonetheless, in January 2017, when Sheinfeld learned that the

Planned Merger was unlikely to close by the expected date, he liquidated nearly all
of his Rite Aid holdings, thereby avoiding over $140,000 in losses. Sheinfeld also
accessed two different family members’ brokerage accounts and sold off their Rite
Aid holdings, avoiding over $15,000 in losses on behalf of his family members.

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6.

By engaging in the conduct described in this Complaint, Sheinfeld

violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
[15 U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
JURISDICTION AND VENUE
7.

This Court has jurisdiction over this action pursuant to Sections 21(d),

21(e), 21A, and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1, and
78aa].
8.

Venue is proper in this District pursuant to Section 27(a) of the

Exchange Act [15 U.S.C. § 78aa]. Among other things, certain of the acts,
practices, and courses of business constituting the violations of the federal
securities laws alleged herein occurred within the Middle District of Pennsylvania.
Sheinfeld worked for, and improperly traded in the securities of, Rite Aid, a
company that is headquartered in the Middle District of Pennsylvania.
DEFENDANT
9.

Sheinfeld, age 67, lives in Cape Coral, Florida. From 1994 until

April 2017, Sheinfeld worked at Rite Aid at the company headquarters in Camp
Hill, Pennsylvania. During the relevant period, Sheinfeld maintained a residence
in Mechanicsburg, Pennsylvania.

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10.

During the relevant time period, Sheinfeld was Vice President of

Internal Assurance Services, a position that was within Rite Aid’s Internal
Audit/Compliance department.
11.

As Vice President of Internal Assurance Services, Sheinfeld reported

to Rite Aid’s Chief Compliance Officer.
12.

During the relevant time period, Sheinfeld also served as the Chair of

Rite Aid’s Policy Oversight Committee, which was a committee comprised of
personnel from various Rite Aid departments that oversaw all Rite Aid policies,
and Sheinfeld’s responsibilities included overseeing and implementing a range of
employee policies, including the Code of Conduct.
13.

During the relevant time period, Sheinfeld was licensed as a Certified

Public Accountant (“CPA”) in the state of New York. Sheinfeld’s CPA license
lapsed without explanation in August 2017.
RELEVANT ENTITIES
14.

Rite Aid is a Delaware corporation headquartered in Camp Hill,

Pennsylvania, and is a retail pharmacy chain. At all relevant times, Rite Aid’s
stock was registered with the SEC pursuant to Section 12(b) of the Exchange Act
and traded on the New York Stock Exchange under the symbol “RAD.”
15.

Walgreens is a Delaware corporation headquartered in Deerfield,

Illinois, and is a global holding company that owns the Walgreens, Duane Reade,
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and Boots retail pharmacy chains. At all relevant times, Walgreen’s stock was
registered with the SEC pursuant to Section 12(b) of the Exchange Act and traded
on NASDAQ under the symbol “WBA.”
TERMS USED IN THIS COMPLAINT
16.

A “call option” is a contract that entitles the holder to purchase a

security under specified terms. The holder of a call option has the right, but not the
obligation, to buy the specified security at a set price (the “strike price”) on or
before the expiration date for that option.
17.

One type of call option is an “employee stock option.” Certain

companies award employees employee stock options, which give the employees
the right to buy the company’s stock at a specified price (the “grant price,” a form
of strike price) for a certain period of time.
18.

An “out-of-the-money” call option is a call option with a strike or

grant price that is higher than the market price of the underlying asset.
19.

A “limit order” is an order to buy or sell a stock at a specific price or

better. A sell limit order can only be executed at the limit price or higher. A limit
order is not guaranteed to execute.

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FACTUAL ALLEGATIONS
A. Sheinfeld Knew That Rite Aid Expressly Prohibited Insider Trading
20.

At all relevant times, Rite Aid had in place the Code of Conduct,

which applied to all Rite Aid employees and was reviewed and agreed to by each
employee upon hiring.
21.

Sheinfeld, as a Rite Aid employee, was covered by the Code of

Conduct.
22.

Additionally, in his capacity as the Chair of Rite Aid’s Policy

Oversight Committee, Sheinfeld oversaw compliance with Rite Aid’s Code of
Conduct, including overseeing the design and implementation of required annual
trainings for employees.
23.

During the relevant period, the Code of Conduct stated that employees

may learn confidential information about Rite Aid in the course of their work for
Rite Aid. The Code of Conduct prohibited employees who possess or have access
to confidential information about Rite Aid from using the information for their
own benefit or for the benefit of persons outside the company.
24.

The Code of Conduct contained a provision that expressly prohibited

insider trading (the “Insider Trading Provision”).

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25.

The Insider Trading Provision provided that all employees who

possess material nonpublic information are prohibited from buying or selling Rite
Aid securities.
26.

The Insider Trading Provision also noted that information is

considered material if “there is a substantial likelihood that a reasonable investor
would find the information important in determining whether to trade in a
security,” or if “the information, if made public, would likely affect the market
price of a company’s securities.”
27.

As an employee of Rite Aid, Sheinfeld had reviewed and agreed to

abide by the complete Code of Conduct, including the Insider Trading Provision.
B. Sheinfeld Learned Material Nonpublic Information Through His Work
at Rite Aid
1. The Planned Merger
28.

On October 27, 2015, Rite Aid and Walgreens announced publicly

that they had entered into a definitive agreement (the “Merger Agreement”) under
which Walgreens would acquire all outstanding shares of Rite Aid for $9.00 per
share in cash. The purchase price represented a 48% premium over the closing
price per share of Rite Aid on the previous day. In the press release announcing
the agreement, Rite Aid and Walgreens stated that the Planned Merger was
expected to close in the second half of 2016.

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29.

The Merger Agreement had an end date of October 27, 2016. Under

the terms of the Merger Agreement, either Rite Aid or Walgreens had the right to
extend the end date from October 27, 2016 to January 27, 2017.
30.

The Planned Merger was subject to approval by the Federal Trade

Commission (“FTC”).
31.

By October 2016, the FTC had not yet approved the Planned Merger.

On October 20, 2016, Rite Aid and Walgreens announced that they had mutually
agreed to extend the end date of the Merger Agreement to January 27, 2017,
stating that they expected the Planned Merger would close in early 2017.
32.

On December 20, 2016, Rite Aid and Walgreens announced that they

had entered into an agreement with another pharmacy chain to sell 865 Rite Aid
stores to the pharmacy chain. Rite Aid and Walgreens stated that they entered into
the agreement with the pharmacy chain to respond to concerns identified by the
FTC in its review of the Planned Merger.
33.

The December 20, 2016 announcement stated that Walgreens was

actively engaged in discussions with the FTC regarding the Planned Merger and
was working toward a close of the Planned Merger in early 2017.
34.

As the January 27, 2017 Merger Agreement end date approached,

information concerning the Planned Merger and the FTC’s approval was highly
material to the market.
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35.

Based on the terms of the Merger Agreement, if the FTC did not

approve the Planned Merger by January 27, 2017, Rite Aid and Walgreens would
need to agree to amend the Merger Agreement in order to extend the end date.
36.

Rite Aid, Walgreens, and investors understood that should the Merger

Agreement need to be amended in order to satisfy FTC concerns, Rite Aid and
Walgreens would likely be required to divest additional stores and therefore the
price per share paid by Walgreens would likely be reduced.
37.

In early January 2017, senior executives at Rite Aid learned—contrary

to the generally positive public speculation—that the FTC remained concerned
about the antitrust implications of the merger of Rite Aid and Walgreens.
38.

On or around January 6, 2017, Rite Aid’s board of directors held a

meeting which was attended by various high-level executives at Rite Aid. At the
January 6, 2017 board meeting, Rite Aid’s outside counsel stated the FTC would
likely not approve the Planned Merger by the January 27 end date.
39.

Meanwhile, overnight on January 10, 2017, the New York Post

published a detailed article, citing sources close to the case and reporting that the
FTC was expected to approve the Planned Merger prior to the presidential
inauguration on January 20, 2017. On January 11, 2017, when trading resumed,
Rite Aid’s stock price reached a high of $8.69 —a 4.4 percent increase over the
prior day’s closing price.
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2. Sheinfeld had Confidential Information About the Planned
Merger
40.

In mid-January, 2017, through his position at Rite Aid, relationships

with senior Rite Aid executives, and work helping to prepare for the Planned
Merger, Sheinfeld had access to, and learned, confidential information that the
merger was unlikely to obtain the FTC approval needed for the Planned Merger to
close in time for the January 27 end date.
41.

After the Planned Merger was announced in late 2015, Rite Aid and

Walgreens formed an Integration Management Office (“IMO”), staffed by teams of
employees at each company who worked to prepare to integrate the two companies
should the Planned Merger be approved.
42.

Though Sheinfeld was not a member of the IMO, starting in early

2016, he was asked to assist the IMO with certain matters relating to compliance or
employee policies.
43.

Rite Aid treated information about the Planned Merger as highly

confidential, and all IMO members were told at the outset that everything they
would be working on was confidential, should not be shared with anyone, and was
only to be used to facilitate implementing the Planned Merger.
44.

When members of the IMO turned to other Rite Aid employees for

assistance with IMO tasks, these employees were also provided with the same
warning regarding the highly confidential nature of the work.
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45.

Sheinfeld was warned regarding the confidentiality of the IMO’s work

in or about March 2016, when he began providing assistance to the IMO.
46.

Particularly as the end date in January 2017 approached, among other

tasks, the IMO worked to implement changes that would be necessary for “Day
One” of the newly merged company.
47.

On January 11, 2017, Sheinfeld was tasked with assisting the IMO

with evaluating Walgreens’ “Day One” policies—Walgreens’ corporate policies
that would immediately apply to all Rite Aid employees when the Planned Merger
closed (the “Day One Policy Project”).
48.

On January 13, 2017, Sheinfeld complained to a colleague about his

role on the Day One Policy Project: “I now have over 150 pages of policies (each
policy is incredibly long) that have to be read and analyzed and it has to be done
pronto. These policies all get sent to the many members of the Policy Oversight
Committee for their immediate review as if they have nothing else to do.”
49.

Later that day, Sheinfeld sent an email to the members of the Policy

Oversight Committee attaching Walgreens’ policies for review, emphasizing the
following:
We must have your feedback no later than Friday, January 20th, so that
the additional efforts required to communicate them (or in some cases,
to develop CBTs to create electronic acknowledgements) can be
completed in time for Day One. Send your responses directly to me and
I will pass them on as appropriate.
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50.

From January 13-16, 2017, Sheinfeld continued to work on the Day

One Policy Project, including after hours and over the weekend.
51.

On the morning of Tuesday, January 17, 2017, Sheinfeld received an

email from a Rite Aid executive who reported directly to Rite Aid’s general
counsel and who was also a member of the Policy Oversight Committee
(“Executive 1”). Executive 1 informed Sheinfeld that he had communicated with
the high-level Rite Aid executive who was leading Rite Aid’s merger efforts, and
that there was “no urgency because we likely will not make the 1/27 date. We
should continue working on [the Day One Policy Project] but please do not feel
this is urgent.”
52.

Sheinfeld responded to Executive 1’s email explaining that it had been

Walgreen’s team that had been rushing him on the Day One Policy Project.
Executive 1 responded to Sheinfeld that he would talk to Walgreens.
53.

At approximately 4:30 pm on Tuesday, January 17, 2017, after the

close of trading on the New York Stock Exchange, Executive 1 forwarded to
Sheinfeld an email that Executive 1 sent to an individual at Walgreens. The email
read, “I understand you have given Steve Sheinfeld a deadline of this Friday with
respect to policies for Day 1 prep. I think we can relax this deadline some since it
is doubtful closing will occur by 1/27. Thanks!”

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C. Sheinfeld Traded Rite Aid Securities Based on Material Nonpublic
Information
54.

On January 17, 2017, when Sheinfeld received the emails from

Executive 1 stating that the Planned Merger was unlikely to meet the January 27,
2017 closing date, Sheinfeld owned 124,550 vested Rite Aid employee stock
options. On January 18, 2017, Sheinfeld liquidated nearly all of his Rite Aid
holdings based on the material nonpublic information he had learned about the
Planned Merger. On January 19, 2017, Sheinfeld accessed two of his family
members’ brokerage accounts and sold their Rite Aid stock based on material
nonpublic information about the Pending Merger.
55.

On January 18, 2017, the opening price for Rite Aid stock was $8.65

per share. That morning, at approximately 9:31 a.m., Sheinfeld logged in to the
brokerage account where he held his Rite Aid options.
56.

About six minutes later, at approximately 9:37 a.m., Sheinfeld called

the customer support number for his brokerage account.
57.

During this January 18, 2017 recorded call, Sheinfeld stated that he

was looking to exercise all of his Rite Aid options—amounting to 124,550 Rite
Aid shares—and sell those shares at a limit price of $8.60 per share (approximately
four cents below the current market price at the time). The broker told Sheinfeld
that 1,400 of the options were “out of the money”, but that he could exercise the
rest of the Rite Aid options.
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58.

During the January 18, 2017 call, the broker told Sheinfeld that the

sale of 123,150 shares of Rite Aid would constitute about 50% of the trading
volume of Rite Aid at that time, and an order of that size could put negative
pressure on the stock price and result in a lower price per share. The broker
explained that the trading desk would “work the trade,” to try to avoid this negative
effect. The broker then asked whether Sheinfeld wanted the trading desk to work
the trade to ensure the best price, which could take longer to accomplish, or
whether Sheinfeld wanted to ensure the trade was worked in the best way to
complete it (regardless of price). Sheinfeld chose best way to complete, in order to
sell the shares quickly.
59.

On January 18, 2017, between approximately 9:46 a.m. and 11:45

a.m., the trading desk executed the order, selling all 123,150 Rite Aid shares from
the exercisable options at prices ranging from $8.62 to $8.65.
60.

By exercising and selling 123,150 Rite Aid employee stock options,

Sheinfeld netted approximately $872,275 after paying $185,062 to cover the grant
prices of the stock options (which ranged from $1.07 to $7.08 per share).
61.

On January 19, 2017, at approximately 3:28 p.m., Sheinfeld logged in

to the brokerage account of a family member (“Family Member 1”). Family
Member 1 had previously given Sheinfeld access to her brokerage account and
allowed him to place trades on her behalf.
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62.

After logging in to Family Member 1’s account, Sheinfeld placed a

limit order to sell all 6,500 shares of Rite Aid in the account at a limit price of
$8.59 per share. The order was fully executed almost immediately, and 6,500 Rite
Aid shares were sold from Family Member 1’s account at prices ranging from
$8.59 to $8.60 per share, for a total of $55,841.
63.

The 6,500 shares of Rite Aid that Sheinfeld sold from Family Member

1’s account were all of Family Member 1’s Rite Aid holdings.
64.

Just a few minutes later, at approximately 3:35 p.m. on January 19,

2017, Sheinfeld logged in the brokerage account of another family member
(“Family Member 2”). Family Member 2 had previously given Sheinfeld access to
her brokerage account and allowed him to place trades on her behalf.
65.

After logging in to Family Member 2’s account, Sheinfeld placed an

order to sell all 7,200 shares of Rite Aid in the account at a limit price of $8.59 per
share. The order was fully executed almost immediately, and 7,200 Rite Aid
shares were sold from Family Member 2’s account at $8.59 per share, for a total of
$61,851.
66.

The 7,200 shares of Rite Aid that Sheinfeld sold from Family Member

2’s account were all of Family Member 2’s Rite Aid holdings.

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D. Rite Aid’s Share Price Fell as the Market Learned That the Planned
Merger Would Not Close by January 27, 2017
67.

The next day, January 20, 2017, at approximately 10:40 am,

Bloomberg published an article reporting that FTC officials were concerned that
Walgreens’ and Rite Aid’s current efforts to preserve competition were not
sufficient, and that the FTC likely would not be approving the Planned Merger by
the January 27, 2017 end date.
68.

After the Bloomberg article became public, Rite Aid’s stock price fell,

closing on January 20, 2017 at $7.46 per share—approximately 13% lower than
the prior day’s closing price.
69.

On January 30, 2017, Rite Aid and Walgreens officially announced an

amended merger agreement, extending the end date to July 31, 2017 and lowering
the price that Walgreens would pay per share of Rite Aid from $9.00 to $6.50 to
$7.00.
70.

By liquidating the vast majority of his position in Rite Aid in advance

of the public disclosure of the failure to obtain FTC approval for the Planned
Merger by the January 27, 2017 deadline, Sheinfeld avoided losses of at least
$140,000. By liquidating his family members’ Rite Aid positions in advance of the
public disclosure of the information about the Planned Merger, Sheinfeld avoided
losses for Family Member 1 and Family Member 2 of at least $7,000 and $8,000,
respectively.
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E. Sheinfeld Violated the Federal Securities Laws
71.

As the Vice President of Internal Assurance Services at Rite Aid,

Sheinfeld had a duty to Rite Aid and its shareholders not to trade Rite Aid
securities, either in his own account or in the accounts of his family members, on
the basis of material nonpublic information.
72.

On January 17 and 18, 2017, information about the Planned Merger,

including information about FTC approval of the Planned Merger and the likely
timing of the Planned Merger, was confidential. Rite Aid established policies and
procedures designed to protect such information and to prohibit its employees from
trading on such information.
73.

A reasonable investor would have viewed information relating to the

Planned Merger, including information about FTC approval of the Planned Merger
and the likely timing of the Planned Merger, as being important to his or her
investment decision and/or significantly altering the total mix of information
available to the public.
74.

Sheinfeld knew, or was reckless in not knowing, that he had a duty

not to trade Rite Aid securities on the basis of confidential information about the
Planned Merger, including information about FTC approval of the Planned Merger
and the likely timing of the Planned Merger.

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75.

In breach of his duty to Rite Aid and its shareholders, Sheinfeld traded

Rite Aid securities, in his own account and in the accounts of Family Member 1
and Family Member 2, on the basis of material nonpublic information relating to
the Planned Merger.
CLAIM FOR RELIEF
Violation of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder
76.

The SEC re-alleges and incorporates by reference the allegations in

paragraphs 1 – 75, as if they were fully set forth herein.
77.

By engaging in the conduct described above, Sheinfeld directly or

indirectly, in connection with the purchase or sale of securities, and by use of
means or instrumentalities of interstate commerce, or the mails, or the facilities of
a national securities exchange, has, knowingly or recklessly:
(a) employed a device, scheme, or artifice to defraud;
(b) made an untrue statement of material fact or omitted to state material
facts necessary in order to make the statements made, in the light of
the circumstances under which they were made, not misleading;
and/or
(c) engaged in an act, practice, or course of business which operated or
would operate as a fraud or deceit upon any person.

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78.

By reason of the foregoing, Sheinfeld has violated and, unless

enjoined, will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C.
§ 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
PRAYER FOR RELIEF
WHEREFORE, the SEC respectfully requests that the Court enter a Final
Judgment:
I.
Permanently restraining and enjoining Sheinfeld from directly or indirectly
engaging in conduct in violation of Section 10(b) of the Exchange Act [15 U.S.C.
§ 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Sheinfeld to pay a civil penalty pursuant to Section 21A of the
Exchange Act [15 U.S.C. § 78u-1]; and
III.
Granting such other and further relief as this Court may deem just, equitable,
or necessary in connection with the enforcement of the federal securities laws.

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Respectfully submitted,
Date: September 17, 2020
s/ Julia C. Green
Julia C. Green NY 4257481
Jennifer C. Barry
Scott A. Thompson
Megan Ryan
U.S. SECURITIES AND EXCHANGE
COMMISSION
Philadelphia Regional Office
1617 JFK Boulevard, Suite 520
Philadelphia, PA 19103
(267) 602-2133 (Green)
(215) 597-2740 (fax)
greenju@sec.gov

20
 

 IS 44 (Rev. 02/19)

Case 09/17/20 Page 1 of 1

The 44 civil cover sheet and the information contained herein neither replace nor supplement the ?ling and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

 

I. PLAINTIFFS

U.S. SECURITIES AND EXCHANGE COMMISSION

County of Residence of First Listed Plaintiff
(EXCEPT IN US, PLAINTIFF CASES)

Attorneys (Firm Name, Address, and Telephone Number)
Ju Ia C. Green, Jennifer Chun Barry, Megan

 

US. Securities and Exchange Commission
1617 JFK Blvd, Ste 520, Philadelphia, PA 19103 (215) 597-3100

8. Ryan

NOTE:

 

DEFENDANTS
STEVEN J. SHEINFELD

Attorneys (If Known)
Amy Carver and Catherine Recker
Welsh Recker, PC.

306 Walnut Street, Philadelphia, PA 19106

County of Residence of First Listed Defendant

LEE

 

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CI 362 Personal Injury - Product Liability El 751 Family and Medical El 890 Other Statutory Actions
Medical Malpractice Leave Act El 891 Agricultural Acts
I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS El 790 Other Labor Litigation FEDERAL TAX SUITS El 893 Environmental Matters
El 210 Land Condemnation El 440 Other Civil Rights Habeas Corpus: El 791 Employee Retirement El 870 Taxes (US. Plaintiff El 895 Freedom of Information
El 220 Foreclosure El 441 Voting El 463 Alien Detainee Income Security Act or Defendant) Act
El 230 Rent Lease Ejectment El 442 Employment El 510 Motions to Vacate El 871 IRS?Third Party El 896 Arbitration
240 Torts to Land CI 443 Housing;l Sentence 26 USC 7609 El 899 Administrative Procedure
El 245 Tort Product Liability Accommodations El 530 General Actheview or Appeal of
290 All Other Real Property CI 445 Amer. w/Disabilities CI 535 Death Penalty INIMIGRATION Agency Decision
Employment Other: 462 Naturalization Application El 950 Constitutionality of
CI 446 Amer. w/Disabilities CI 540 Mandamus Other 465 Other Immigration State Statutes
Other El 550 Civil Rights Actions
CI 448 Education 555 Prison Condition
El 560 Civil Detainee -
Conditions of
onfinement

 

 

 

 

 

 

V. ORIGIN (Place an in One Box Only)

1 Original CI 2 Removed from El 3 Remanded from El 4 Reinstated or Cl 5 Transferred from El 6 Multidistrict CI 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(speci??) Transfer Direct File

 

VI. CAUSE OF ACTION

 

Securities fraud

Cite the U.S. Civil Statute under Which you are ?ling (Do not cite jurisdictional statutes unless diversity):

15 use. 78j(b)

Brief description of cause:

 

VII. REQUESTED IN

El CHECK IF THIS

IS A CLASS ACTION



CHECK YES only if demanded in complaint:

 

 

 

 

 

COMPLAINT: UNDER RULE 23, F-R-CV-P- JURY DEMAND: Yes 
RELATED 
(See instructions):
IF ANY IUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD 
09/ 1 7/2020
FOR OFFICE USE ONLY 5
RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE