From BakerHostelter: Top 10 SEC Enforcement Highlights of 2016

From BakerHostelter 

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Top 10 SEC Enforcement Highlights of 2016

January 20, 2017
This is the third year we are providing our annual Top Ten list of Enforcement Highlights. This time, it occurs towards the end of the tenure of SEC Chair Mary Jo White. Sullivan & Cromwell corporate securities and capital markets partner, Jay Clayton, is being considered for the next Chairmanship. We like Clayton’s nomination. Clayton fits the traditional role of the SEC Chair with his deep federal securities laws knowledge and experience in capital markets and formation, two of the hallmark missions for the SEC which are impactful upon the U.S. and world economies. Below we recount the actions and focus of the SEC under Chair White.
1.  Looking Back on Her Tenure, Outgoing Chair Mary Jo White Touts the SEC’s Aggressive and “Unrelenting” Enforcement Program
SEC Chair White plans to leave her position at the end of the Obama administration.[2] In the press release, an accompanying report, and a published speech she delivered on November 18, 2016, Chair White looked back on her time at the SEC, hailing various changes and developments since she became Chair in April 2013, including an aggressive "new model for enforcement."[3] Among the accomplishments cited:
  • More than 2,800 enforcement actions, including insider trading charges against more than 250 individuals; a record 868 actions in fiscal year 2016 (ended Sept. 30, 2016) alone; judgments and orders in fiscal 2016 totaling more than $4 billion in disgorgement and penalties; and “first of their kind” enforcement cases in asset management, market structure and public finance;
  • Implementation of a new policy requiring admissions of wrongdoing in certain cases;
  • A focus on charging individuals as well as companies, particularly in financial reporting cases;
  • Dedicated groups and task forces focused on financial fraud, microcap abuse, pyramid schemes, and other areas; and
  • Awarding, since 2011, more than $100 million to 34 whistleblowers who provided original information leading to successful enforcement actions.
It will be interesting to see which changes in the Division of Enforcement occur with a new Chair and at least two new Commission members.
2. The Supreme Court’s Affirmance of the Insider Trading Conviction in Salman v. United States
On December 6, 2016, the U.S. Supreme Court unanimously affirmed the insider trading conviction of Bassam Salman in Salman v. United States.[4] In so doing, the Court handed a victory to both criminal prosecutors and the SEC, and appeared to resolve a split in Circuits in favor of the Ninth Circuit’s affirmance below in Salman and against the Second Circuit’s 2014 reversal of insider trading convictions in United States v. Newman.[5] In fact, much of Newman remains intact, and the reach of the Court’s decision in Salman remains to be determined.
Both Salman and Newman centered on the Supreme Court’s holding in Dirks v. SEC[6] that a tippee’s liability for trading on inside information hinges on whether the tipper breached a fiduciary duty by disclosing the information to receive a personal benefit. Dirks instructed courts to focus on “objective criteria,” such as pecuniary gain, in determining whether the insider received a personal benefit, but also held that a jury can infer that the tipper received a personal benefit where the tipper “makes a gift of confidential information to a trading relative or friend.”[7]
In Newman, the Second Circuit reversed the convictions of two portfolio managers who were “several steps removed from the corporate insiders,” where the initial tipper and tippee were merely “casual acquaintances” and friends who were not “close,” and where no evidence was introduced at trial to indicate that the defendants knew the source of the inside information or that the insiders received any personal benefit in exchange for the tips.[8] In that context, the Second Circuit held that an inference that the insiders received a personal benefit was impermissible “in the absence of proof of a meaningfully close personal relationship that generates an exchange that is objective, consequential, and represents at least a potential gain of a pecuniary or similarly valuable nature.”[9]
Salman had made over $1.5 million in profits trading on tips regarding mergers and acquisitions he had received from his friend Michael Kara, who had received the confidential information from Michael Kara's younger brother Maher Kara, an investment banker at Citigroup who was also Salman’s brother-in-law. In contrast to the facts in Newman, the evidence at Salman’s trial established that the initial tipper and tippee (the Kara brothers) had a very close relationship, that the tipper (Maher) provided the tippee (Michael) inside information for the purpose of benefiting him, and that the trading defendant (Salman) had been told the source of the inside information. The Supreme Court affirmed the Ninth Circuit’s judgment affirming Salman’s conviction, finding that Maher’s gift of confidential information to his close relative fit squarely within the Court’s holding in Dirks that a tipper breaches a fiduciary duty by making a gift of confidential information to a “trading relative.”[10]
The Court in Salman rejected as inconsistent with Dirks any application of Newman that would require that a tipper receive something of a “pecuniary or similarly valuable nature” in exchange for a gift to family or friends.[11] Notably, however, the Court did not suggest that Newman was wrongly decided, and it is likely that the Court would have affirmed the Second Circuit’s decision based on the facts in that case. The Court also noted that, while Dirks’s rule concerning tips to a “trading relative” “easily resolves” the issue in Salman, future cases will present courts with more difficult tests in determining the factual question whether an insider personally benefited from a particular disclosure.[12]
3.  FCPA Action Against Hedge Fund Manager Och-Ziff Capital Management Group LLC
On September 29, 2016, the SEC announced its first ever enforcement action charging a hedge fund manager with violations of the Foreign Corrupt Practices Act (FCPA).[13] The SEC’s settled administrative action included charges against hedge fund manager Och-Ziff Capital Management Group LLC, its affiliated registered investment adviser OZ Management LP, and two senior officers of Och-Ziff. An investigation by the SEC had found that Och-Ziff used intermediaries, agents and business partners to pay bribes to high-level government officials in Africa, so as to induce Libya’s sovereign wealth fund to invest in Och-Ziff managed funds and to secure mining rights and influence government officials in five African countries.
In settling the charges, Och-Ziff and OZ agreed to pay one of the largest FCPA fines in history, with disgorgement plus prejudgment interest totaling almost $200 million. Och-Ziff’s CEO agreed to pay disgorgement plus interest totaling over $2 million. Och-Ziff further agreed to implement several specified enhanced internal accounting controls and policies, to retain an independent monitor for a period of at least three years, and to follow recommendations regarding improving the effectiveness of the firm’s FCPA policies and procedures to be made by the monitor in a series of reports.
4. In SEC v. Graham, Eleventh Circuit Applies Five-Year Statute of Limitations to Declaratory Relief and Disgorgement
On May 26, 2016, the Eleventh Circuit issued its opinion in SEC v. Graham, the first ever Circuit Court decision applying the five-year statute of limitations set forth in 28 U.S.C. § 2462 to declaratory relief and disgorgement.[14] Section 2462 governs SEC actions “for the enforcement of any civil fine, penalty, or forfeiture.”
The SEC commenced the Graham civil enforcement action in federal court in January 2013, alleging that defendants engaged in securities fraud between November 2004 and July 2008. The SEC requested that the District Court (i) declare that defendants violated federal securities laws; (2) permanently enjoin defendants from future securities law violations; (3) direct defendants to disgorge profits; (4) order defendants to repatriate funds held outside the court’s jurisdiction; and (5) require three defendants to pay civil penalties. The District Court dismissed the case, finding that the SEC’s claims were time-barred under Section 2462.[15] The District Court relied on the U.S. Supreme Court’s 2013 decision in Gabelli v. SEC, which involved an SEC claim for a civil penalty. Gabelli held that, under Section 2462, there was a five-year statute of limitations for the SEC to bring a civil suit seeking a civil penalty and further, it begins to accrue when the fraud occurs, not when it is discovered.[16]
On appeal, the Eleventh Circuit in Graham reversed in part, holding that an injunction is a forward-looking remedy, not a penalty, and therefore not time-barred under Section 2462.[17] But the court affirmed the remainder of the District Court’s ruling, holding that Section 2462 applies to declaratory relief and disgorgement, because both are backward-looking and would operate as penalties under Section 2462.[18] Notably, the Eleventh Circuit created an apparent Circuit split in holding that Section 2462 applies to claims for disgorgement, because the D.C. Circuit and Ninth Circuit previously held, pre-Gabelli, that disgorgement claims were not subject to the statute of limitations.[19] This new issue on disgorgement now seems ripe for consideration by the Supreme Court.
5. Expansive Interpretation of Advisers Act Rule Targets Fund Administrators as Gatekeepers
Fund administrators have been the target of several recent SEC enforcement actions that seek to hold administrators liable for the misconduct of fund managers and their principals. These aggressive enforcement actions are the first of their kind to argue that administrators serve in a gatekeeper role. The most recent ones were brought against Apex Fund Services (US), Inc. in June 2016 for allegedly violating Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (Advisers Act) and Rule 206(4)-8 thereunder in connection with its administrative services for ClearPath Wealth Management, LLC[20] and EquityStar Capital Management, LLC,[21] each of which were subject to separate enforcement actions for fraud.
In both enforcement actions, the SEC alleged that Apex contracted with each of ClearPath and EquityStar to maintain records and prepare financial statements and investor account statements but failed to take reasonable steps in response to red flags indicating each fund manager was misappropriating assets. Those red flags included: (i) undisclosed withdrawals, margin accounts and pledged assets; (ii) a warning from a prior fund administrator; and (iii) a background check on one of the adviser’s principals revealing a previous wire fraud conviction. In each settled order, Apex allegedly continued to prepare inaccurate NAV statements and reports despite being aware of these red flags. Pursuant to the settled orders in which Apex neither admitted nor denied the findings, Apex was required to retain an independent compliance consultant to review and recommend improvements to its policies and procedures and to pay approximately $185,000 in disgorgement, $16,000 in prejudgment interest, and $150,000 in civil penalties.
These enforcement actions, which were not litigated, are significant because they imposed liability on Apex by expansively interpreting existing statutes to regulate its conduct as an administrator where they would not otherwise subject to the SEC’s explicit regulation. In particular, the SEC supported this apparent expansion by citing Section 203(k) of the Advisers Act, which allows the SEC to impose a cease-and-desist order upon, among others, any “person that is, was, or would be a cause of [a violation of the Advisers Act], due to an act or omission the person knew or should have known would contribute to such violation.” In this sense, it appears that the SEC viewed Apex as being complicit in the misconduct because they contributed to the environment that supported the underlying fraud. Indeed, Andrew Ceresney, Director of the SEC Division of Enforcement, noted in the press release announcing these settlements that “Apex failed to live up to its gatekeeper responsibility and essentially enabled the schemes to persist at each of these advisory firms until the SEC stepped in.”[22]
It will be interesting to see if the SEC attempts to use this untested and expansive interpretation to broaden its regulatory purview in the coming year.
6. New Initiative Encouraged Broker-Dealers to Self-Report Violations
In June 2016, the SEC announced a significant regulatory and enforcement initiative for clearing broker-dealers, the Customer Protection Rule Initiative, which seeks to encourage broker-dealers to self-report to the SEC historical and ongoing violations of Section 15(c)(3) of the Securities Exchange Act of 1934 (Exchange Act) and Rule 15c3-3 thereunder by November 2016.[23] The Customer Protection Rule requires that clearing broker-dealers, among other things, maintain a reserve bank account that is at least equal in value to the net cash owed to customers and retain physical possession or control over their customers’ fully paid and excess margin securities.
This initiative is significant because it offered standardized settlement terms for participating broker-dealers, namely a settled order finding violations of Rule 15c3-3 and any applicable books and records and reporting charges where the broker-dealer:
  • Neither admits nor denies the findings minimizing deleterious collateral consequences and investor civil litigation;
  • Undertakes to enhance their compliance program, cooperate with any subsequent investigation regarding the violation (including against individuals), and retain an independent compliance consultant if necessary; and
  • Pays disgorgement and penalties, which may be reduced for cooperation.
For those broker-dealers that did not self-report by the November deadline, the initiative threatens substantial sanctions if they are later found to be not in compliance with the Customer Protection Rule. To emphasize this regulatory risk, the SEC simultaneously announced a settled order with Merrill Lynch, Pierce, Fenner & Smith Incorporated for Customer Protection Rule violations in which Merrill Lynch admitted to the misconduct and paid $415 million in the form of a civil penalty, disgorgement, and prejudgment interest for (i) engaging in complex options trades that did not have any economic basis but reduced the required deposit of customer cash in its reserve account, which allowed Merrill Lynch to use that customer cash to finance its own trading activities and (ii) holding customer securities in accounts that were subject to liens.[24] If Merrill Lynch had not retained an independent consultant prior to the settlement, the order would have also required it to do so as an undertaking.
Since then, there have been no publicized enforcement actions stemming from this initiative or the targeted sweep. It is likely that a few will be announced in 2017 after examination referrals are made to the Division of Enforcement.
7. Private Equity Remained in Enforcement Crosshairs
The SEC continued to scrutinize public equity funds and advisers throughout 2016 by bringing several enforcement actions relating to conflicts of interest, disclosure lapses and compliance failures. One of the most notable of them occurred in August 2016 involving four private equity fund advisers affiliated with Apollo Global Management, LLC.[25] According to the SEC’s settled order, the four Apollo advisers violated Sections Rules 203(e)(6), 206(2), 206(4), and 206(8) of the Advisers Act and 206(4)-7, 206(4)-8, and thereunder in several ways.[26]
First, for nearly four years, the advisers failed to disclose the benefits the funds received from accelerating the payment of future monitoring fees owed by the funds’ portfolio companies upon their sale. Because such fees reduced the amount available for distribution to investors, the SEC viewed them as a conflict of interest that required disclosure.
Second, one of the advisers failed to disclose certain information about how loan interest was allocated between the adviser’s affiliated general partner and five of the adviser’s funds. Instead of allocating the interest to the funds as disclosed in their financial statements, the interest was allocated solely to the general partner thus making those financial statement disclosures misleading.
Third, the advisers failed reasonably to supervise a senior partner who improperly charged personal items and services to their funds and portfolio companies. After repeated reprimands of and repayments by the partner, the advisers voluntarily reported the expense issues to the SEC and executed a formal separation agreement with the partner.
Without admitting or denying the SEC’s findings, the four Apollo advisers agreed to pay approximately $37.5 million in disgorgement, $2.7 million in prejudgment interest, and $12.5 million in civil penalties. It appears that the advisers were able to limit the civil penalty to one-third the possible amount and avoid even stiffer sanctions “based upon their cooperation” that included, among other things, conducting their own reviews of the expense issues, self-reporting those issues to the SEC, and voluntarily and promptly providing documents and information to the staff during the investigation.
Because the SEC has stated that it is deploying more of its staff to focus on examinations of investment advisers in the coming year, it is likely that there will be more enforcement actions in 2017 like the one against the four Apollo advisers.
8. Data Analytics Harnessed to Build Enforcement Actions
Throughout 2016, the SEC increasingly used data analytics to reinforce its enforcement program through the involvement of the Division of Economic and Risk Analysis (DERA). In fact, Chair Mary Jo White emphasized these new capabilities during a November 2016 speech: “There are now huge quantities of data available for nearly all parts of the market, including corporate equity and bond trading, trading in complex financial instruments, municipal bond trading, and other market activity. More than ever, the SEC is developing in-house innovative analytical tools to take advantage of today’s data-rich environment. The result is that the number of cases we are able to originate in-house has risen dramatically.”[27]
One of this past year’s notable analytic enforcement actions was brought against the investment adviser, TPG Advisors, LLC, and its principal, Larry M. Phillips, in December 2016 for systematically and unfairly allocating trades to benefit certain favored clients to the detriment of other clients for over four years.[28] According to the order, the performance of the favored client accounts was a “statistical anomaly” with a less than 1% “likelihood that their profitability originated from random chance.”[29] Pursuant to the order, the defendants admitted to wrongdoing in violating Section 10(b) of the Exchange Act and Rule 10b-5 thereunder and Sections 206(1), 206(2), and 207 of the Advisers Act, and agreed to pay approximately $25,000 in disgorgement, $3,000 in prejudgment interest, and $300,000 in civil penalties. The order also imposed on Phillips a permanent bar. As the SEC continues to develop these in-house capabilities, DERA will continue to play a role in the SEC’s enforcement program in 2017.
9. SEC Charges Investment Adviser with Inaccurate Form ADV Disclosures Regarding Wrap Fee Costs
In its fiscal year ended September 30, 2016, the SEC brought its most ever cases involving investment advisers or investment companies (160) and its most ever standalone cases involving investment advisers or investment companies (98).[30] Included in these were several cases against investment advisers alleging misrepresentations or inadequate disclosures concerning fees and expenses, including fees charged in connection with wrap fee programs. In such programs, clients pay an annual fee intended to cover the cost of services such as custody, trade execution and portfolio management. Transaction charges on trades sent to the broker-dealer designated in the program are typically included in the wrap fee. If, however, the investment adviser “trades away” by sending trades to another broker-dealer for execution, the advisory client typically incurs additional costs.
One example of the SEC’s wrap fee cases was the settled administrative action against registered investment adviser RiverFront Investment Group, LLC.[31] On July 14, 2016, the SEC announced settled charges that RiverFront made materially inaccurate disclosures in its Form ADV, stating that it “will generally” execute transactions for wrap fee clients through the wrap program’s sponsor. In fact, RiverFront traded away for a majority of the volume for its wrap clients. Notwithstanding RiverFront’s position that it did so to seek best execution, the SEC determined that RiverFront’s practice made its Form ADV disclosures materially inaccurate, in violation of Section 204(a) of the Advisers Act and Rule 204-1(a) thereunder. RiverFront was ordered to pay a civil penalty of $300,000.
10. Steps Taken to Further Incentivize and Protect Whistleblowers
Over the past year, the SEC continued to develop its Whistleblower Program by issuing millions of dollars of awards, sanctioning companies for violating the Whistleblower Protection Rule through restrictive severance agreements and retaliatory actions,[32] and conducting a sweep examination of registered investment advisers and broker-dealers to assess their compliance with Dodd Frank’s whistleblower rules.[33]
The SEC’s Office of the Whistleblower further incentivized whistleblowers by handing out over $79 million in awards to 15 whistleblowers in 2016, including, among others:
  • $22 million to “a whistleblower whose detailed tip and extensive assistance helped the agency halt a well-hidden fraud at the company where the whistleblower worked;”[34]
  • $20 million to “a whistleblower who promptly came forward with valuable information that enabled the SEC to move quickly and initiate an enforcement action against wrongdoers before they could squander the money;”[35]
  • $17 million to “a former executive whose tip substantially advanced the agency’s investigation and resulted in a successful enforcement action;”[36]
  • $900,000 to “a whistleblower whose tip enabled the SEC to bring multiple enforcement actions against wrongdoers;”[37] and
  • $700,000 to “a company outsider who conducted a detailed analysis that led to a successful SEC enforcement action.”[38]
The flurry of awards over the past year appears to be the result of the tips working their way through the investigation and enforcement process, suggesting a sign of things to come in 2017. Since inception of the Whistleblower Program, the SEC has awarded more than $136 million to 37 whistleblowers resulting in more than $504 million being ordered in sanctions, including more than $346 million in disgorgement and interest for harmed investors.[39]
If you have any questions about this alert, please contact Marc D. Powers at mpowers@bakerlaw.com or 212.589.4216, Andrew W. Reich at areich@bakerlaw.com or 212.589.4222, Jonathan A. Forman at jforman@bakerlaw.com or 212.847.2855, or any member of BakerHostetler's Hedge Fund Industry and Securities Litigation and Regulatory Enforcement teams.

[1] Marc D. Powers is the national leader of the Securities Litigation & Regulatory Enforcement and Hedge Fund Industry practices at BakerHostetler. He is also a member of the CCH Securities Regulation Advisory Board. Andrew W. Reich and Jonathan A. Forman are both Counsel at Baker & Hostetler LLP and specialize in its Broker-Dealer and Hedge Fund Industry practices.
[2] Press Release, SEC Chair Mary Jo White Announces Departure Plans, Release No. 2016-238 (Nov. 14, 2016), https://www.sec.gov/news/pressrelease/2016-238.html.
[3] Speech, SEC Chair Mary Jo White, A New Model for SEC Enforcement: Producing Bold and Unrelenting Results (Nov. 18, 2016), https://www.sec.gov/news/speech/chair-white-speech-new-york-university-111816.html.
[4] Salman v. United States, No. 15-628, slip op. (Dec. 6, 2016).
[5] United States v. Newman, 773 F.3d 438 (2d Cir. 2014).
[6] Dirks v. SEC, 463 U.S. 646 (1983).
[7] Id. at 663-64.
[8] 773 F.3d at 443.
[9] Id. at 452.
[10] Salman, slip op. at 9.
[11] Id. at 10.
[12] Id. at 8, 11-12.
[13] In the Matter of Och-Ziff Capital Management Group LLC, No. 3-17595 (Sept. 29, 2016), https://www.sec.gov/litigation/admin/2016/34-78989.pdf.
[14] No. 14-13562 (11th Cir. May 26, 2016).
[15] SEC v. Graham, 21 F. Supp. 3d 1300 (S.D. Fla. 2014).
[16] 133 S. Ct. 1216 (2013).
[17] No. 14-13562, slip op. at 7-9.
[18] Id., slip op. at 9-14.
[19] See Riordan v. SEC, 627 F.3d 1230 (D.C. Cir. 2011); SEC v. Rind, 991 F.2d 1486 (9th Cir. 1993).
[20] In the Matter of Apex Fund Services (US), Inc., No. 3-17299 (June 16, 2016), https://www.sec.gov/litigation/admin/2016/ia-4428.pdf.
[21] In the Matter of Apex Fund Services (US), Inc., No. 3-17300 (June 16, 2016), https://www.sec.gov/litigation/admin/2016/ia-4429.pdf.
[22] Press Release, SEC, Private Fund Administrator Charged With Gatekeeper Failures, Release No. 2016-120 ( June 16, 2016), https://www.sec.gov/news/pressrelease/2016-120.html.
[23] Customer Protection Rule Initiative, Division of Trading and Markets and Division of Enforcement (June 23, 2016), https://www.sec.gov/divisions/enforce/customer-protection-rule-initiative.shtml.
[24] In the Matter of Merrill Lynch, Pierce, Fenner & Smith Incorporated and Merrill Lynch Professional Clearing Corp., No. 3-17312 (June 23, 2016), https://www.sec.gov/litigation/admin/2016/34-78141.pdf.
[25] Press Release, SEC, Apollo Charged With Disclosure and Supervisory Failures, Release No. 2016-165 (Aug. 23, 2016), https://www.sec.gov/news/pressrelease/2016-165.html.
[26] In the Matter of Apollo Management V, L.P., Apollo Management VI, L.P., Apollo Management VII, L.P., and Apollo Commodities Management, L.P., No. 3-17409 (Aug. 23, 2016), https://www.sec.gov/litigation/admin/2016/ia-4493.pdf.
[27] Speech, SEC Chair Mary Jo White, A new Model for SEC Enforcement: Producing Bold and Unrelenting Results (Nov. 18, 2016), https://www.sec.gov/news/speech/chair-white-speech-new-york-university-111816.html.
[28] Release, SEC, Investment Adviser Agrees to Settle Cherry-Picking Charges, Release No. 3-17217 (Dec. 15, 2016), https://www.sec.gov/litigation/admin/2016/34-79568-s.pdf.
[29] In the Matter of TPG Advisors LLC d/b/a The Phillips Group Advisors and Larry M. Phillips, No. 3-17217 (Dec. 15, 2016), https://www.sec.gov/litigation/admin/2016/34-79568.pdf.
[30] See Press Release, SEC Announces Enforcement Results for FY 2016, Release No. 2016-212 (Oct. 11, 2016), https://www.sec.gov/news/pressrelease/2016-212.html.
[31] In the Matter of RiverFront Investment Group, LLC, No. 3-17343 (July 14, 2016), https://www.sec.gov/litigation/admin/2016/ia-4453.pdf.
[32] Press Release, SEC, Merrill Lynch to Pay $415 Million for Misusing Customer Cash and Putting Customer Securities at Risk, Release No. 2016-128 (June 23, 2016), https://www.sec.gov/news/pressrelease/2016-128.html; Press Release, SEC, Company Punished for Severance Agreements That Removed Financial Incentives for Whistleblowing, Release No. 2016-164 (Aug. 16, 2016), https://www.sec.gov/news/pressrelease/2016-164.html; Press Release, SEC, Company Paying Penalty for Violating Key Whistleblower Protection Rule, Release No. 2016-157 (Aug. 10, 2016), https://www.sec.gov/news/pressrelease/2016-157.html; Press Release, SEC, SEC Charges Anheuser-Busch InBev With Violating FCPA and Whistleblower Protection Laws, Release No. 2016-196 (Sept. 28, 2016), https://www.sec.gov/news/pressrelease/2016-196.html; Press Release, SEC, SEC: Casino Gaming Company Retaliated Against Whistleblower, Release No. 2016-204 (Sept. 29, 2016), https://www.sec.gov/news/pressrelease/2016-204.html.
[33] SEC Risk Alert, Examining Whistleblower Rule Compliance (Oct. 24, 2016), https://www.sec.gov/ocie/announcement/ocie-2016-risk-alert-examining-whistleblower-rule-compliance.pdf.
[34] Press Release, SEC, $22 Million Whistleblower Award for Company Insider Who Helped Uncover Fraud, Release No. 2016-172 (Aug. 30, 2016), https://www.sec.gov/news/pressrelease/2016-172.html.
[35] Press Release, SEC, SEC Issues $20 Million Whistleblower Award, Release No. 2016-237 (Nov. 14, 2016), https://www.sec.gov/news/pressrelease/2016-237.html.
[36] Press Release, SEC, SEC Issues $17 Million Whistleblower Award, Release No. 2016-114 (June 9, 2016), https://www.sec.gov/news/pressrelease/2016-114.html.
[37] Press Release, SEC, SEC Awards Nearly $1 Million to Whistleblower, Release No. 2016-260 (Dec. 9, 2016), https://www.sec.gov/news/pressrelease/2016-260.html.
[38] Press Release, SEC, SEC Awards Whistleblower More Than $700,000 for Detailed Analysis, Release No. 2016-10 (Jan. 15, 2016), https://www.sec.gov/news/pressrelease/2016-10.html.
[39] Press Release, SEC, SEC Whistleblower Program Surpasses $100 Million in Awards, Release No. 2016-173 (Aug. 30, 2016), https://www.sec.gov/news/pressrelease/2016-173.html.

Baker & Hostetler LLP publications are intended to inform our clients and other friends of the firm about current legal developments of general interest. They should not be construed as legal advice, and readers should not act upon the information contained in these publications without professional counsel. The hiring of a lawyer is an important decision that should not be based solely upon advertisements. Before you decide, ask us to send you written information about our qualifications and experience.
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Southern Pacific Bennett Vehicle Vandalism BENNETT VS SBC SERVICES INC Bennett Witness Benny Chetcuti Jr. Bickmore Risk Services Big Law Big O Tires Bill Gates Bill Graham Bill Johnson Bill McGlashan Bill Tauscher Bin Laden Bin Laden Family Bio-Warfare Biological Warfare Blackhawk Country Club Blackhawk Development Blackhawk Network Holdings Blackhawk Network Holdings Inc Blackrock Blackstone Blackstone Group BlakeHunt Blame Pete Bennett Blogger Blogger Labels Blogger Logic Blogger Meta Tags Blogger Open Graph Blogger Posts Blogger Programming Blogger Themes Bloomberg BlueMountain Capital Management LLC Blum Capital Blum Capital Partners BNSF Board of Directors Board of Supervisors Boeing Bomb Squad Bono bootstrap Booz Allen Hamilton Boy Scouts BRAC BRAC Closure List BRACMurders Breitbart Breitbart Author Brian Cherry Bribery BrightSource Energy Brio Broadway Pointe LLC Brookstone Brown Act Buchanan Field Buchanan Field Crashes Buchanan Murders Building 7 Burger King Burglary Burlington Coat Factory BURLINGTON NORTHERN SANTA FE CORPORATION Bus Accidents Business Butte County Butte County District Attorney BYU CA-Berkeley CA-San Bernardino County CA-Santa Clara CA-Walnut Creek CalBay CalFire California Cities California Counties California Department of Elections California Department of Justice California District Attorneys Association California Highway Patrol Special Operations Unit California Judicial Branch California Penal Code 118.1 California Public Employees' Retirement System California Secretary of State California Senate Legislative Homeless Activities California State Senate CalOHSA CalPERS CalSTRS CalTrans Camp Fire Canada Cancer Cape Coral Captain Neil Stratton Car Bomb Catch & Kill Counsel CategoryIII Catellus Catellus Development Corporation CB Richard Ellis CBRE CBRE and Lowes CBS 48 Hours CBS News Cc-courts.org CCCRMC CCSO Cecilia Greenan Ashcroft Centerview Capital Central Intelligence Agency Cerberus Capital CHAPTER 4.5. Peace Officers Charles Kellogg Bobrinskoy Chase Chase Manhattan Bank Cheesecake Factory Chevron Technology Ventures Chicago Chief Alldritt Chief Brian Addington. Pittsburg Police Department Chief Chris Wenzel Chief Christensen Chief Eric Christensen Child Support China China Ukraine Chinatown Chinese Hacking Chinese Hacking. Data Breach Chiquita Blvd CHP CHP Golden Gate CHP Investigations CHP Threat Assessment Unit Chris Butler Chris Wenzel Christopher Bultler CIA CIAI CIO Cisco Systems Inc City Attorneys City Concord City Council of Concord City Council of Walnut Creek City of Antioch City of Benicia City of Berkeley City of Cape Coral City of Castro Valley City of Clayton City of Concord City of Dublin City of El Cerrito City of Lafayette City of Las Vegas City of Martinez City of Oakland City of Orinda City of Orlando City of Palo Alto City of Pittsburg City of Pleasant Hill City of Pleasanton City of Richmond City of San Bruno City of San Francisco City of San Jose City of San Ramon City of Walnut Creek City Walnut Creek Civic Park Claimant Class Action Class of 75 Claycord Clayton Valley High School Clients Projects Connections Clint Eull Clinton Clinton Associates Clinton Foundation Clinton Murders Clinton Presidency - Related Club Locations Club Scene CNET CNET Conspirators CNET Overview CNET SCANDAL CNET Scandal Cases. CNET Scandal Victims and Connections CNET-Tanabe CNN CNWS Coachella Valley Music and Arts Festival Cognizant Technology Solutions Corporation Cold Case Cold Case County Cold Cases Cold Cases Index College Admissions and Testing Bribery Scheme College Admissions Fraud Investigation Colony Global Acquisition Corporation Coming Soon Commerce One Commercial Real Estate Company Company Profiles Compass ComputerLand Computerland Corporate ComputerWorld Conclusions Concord Murders Concord Naval Weapons Station Concord Police ConFire Congress Congressman DeSaulnier Congressman Mark DeSaulnier Connecting the Unions Conservationist Consolidated Fire Contr Contra City of Walnut Creek Contra Cost Contra Costa Contra Costa Arson Network Contra Costa Bar Contra Costa Bar Assoc. contra Costa Bar Association Contra Costa Board of Realtors Contra Costa Board of Supervisors Contra Costa Cases Contra Costa College District Contra Costa Costa County Contra Costa County Contra Costa County Administrator Contra Costa County Board of Supervisors CONTRA COSTA COUNTY CITY ATTORNEYS ASSOCIATION Contra Costa County Indictments Contra Costa County Regional Medical Center Contra Costa County Sheriff Contra Costa County Superior Court Contra Costa Department of Elections Contra Costa District Attorney Contra Costa District Attorney Mark Peterson Contra Costa Family Law Contra Costa Fire Protection District Contra Costa Grand Jury Contra Costa Hate Crimes Network Contra Costa Health Services Contra Costa Homeless Crisis Contra Costa Marine Patrol Contra Costa Murders Contra Costa Narcotics Enforcement Taskforce Contra Costa Narcotics Taskforce (CNET) Contra Costa Probate Court Contra Costa Public Library Contra Costa Republican Party Contra Costa School Districts Contra Costa Search and Rescue Contra Costa Sheriff's Office Contra Costa Sheriffs Office Contra Costa Software Business Incubator Contra Costa Superior Contra Costa Superior Court Contra Costa Times Contra Costa Watch ContraCostawatch.com Conviction Coroner Corporate Raiders Corporations corruption Costa Bar Association Council Meetings County Contra Costa County Counsel County of Butte County of Contra Costa County of El Dorado County of Marin County of San Mateo County of Santa Clara County of Solano County of Sonoma Court Cases courts.ca.gov CPS CPU CPUC Crime Maps Criminal Cops crisis actors Crogans Bar Crunchbase CSAC-EIA Loss Prevention Services CSO CSS Tricks Cuba Cup of Coffee Custom Custom Search CVS Health Cyber-terrorism Cyberterrorism Czechia Dan Helix Dan Rather Dan Van Voorhis Dan White Daniel Horowitz Danville Danville Murders Danville Police Danville Stake Data Breach David Leslie Milne David Rockefeller Jr. David Twa David Wyatt Dorman Dead Witness Dead Activists Dead Attorneys Dead Bankers Dead Bouncer Dead Businesspersons Dead CEO's dead ceos Dead Constituents Dead Customers of Pete Bennett Dead Doctors Dead Employees Dead Homeless Dead Investors Dead Lakers Dead Lists Dead Litigants dead mormons Dead Musicians Dead Officers Dead Officials Dead Pilots Dead Politicians Dead Programmers Dead Public Officials Dead Realtors Dead Reporters Dead Soldiers Dead Student List Dead Students Dead Teachers Dead Tech ~ Programmers and Developers Dead Veterans Dead Witness Dead Witness Club Dead Witnesses Dead Witnesses Danville Stake Deadly Arson Fires by State Deadly REITs deadwitnesses Deaths in Tech Delta Pacific Bank Department of Blum Connections Department of Defense Department of Justice Department of State Deputy Attorney General James M. Cole Deutsche Telekom AG Development Devils Breath DHS DHS Voice Diablo Magazine Dialysis Revenue Enhancement Dick Cheney Disability Discrimination Disbarred Attorneys Discovery Homes Discovery Sales Discrimination Examples dishonesty Division of Corporation Finance Divorce Divorce Case Index Divorce Enforcers DLA DoD Domestic Domestic Terrorism Don Tatzin donations DoubleClick DPD Dragon Global Driscoll Driscoll Murders Drownings Drugging DU Rounds Dunkin' Donuts East Bay East Bay Homicides East Bay Murder Series EAST BAY REGIONAL PARK DISTRICT East Bay Regional Park Police EBAY EBMUD Edgewell Personal Care Edward Siedle EEOC El Cerrito Police Department Election Fraud Electric Grid Elevation Partners Ellen O. Tauscher Ellinwood Farms Elliot Management Elliott Management Elliott Management Corporation Eminent Domain Complaint Emmon Bodfish Employed in Walnut Creek Endorsed by Mark Peterson Energy and Commerce Energy Sector Energy Sector Deaths Energy Terrorism Energy Transportation Systems Energy Transportation Systems Inc English Speaking World ENRON ENRON - World Trade Center Equity One Equity Real Estate Investment Trusts (REITs) Eric Nunn Eric Salvatierra Erik Nunn Erin Valenti Essex Property Trust Europe Executive Profiles Executives Experian plc Exploitation Explosion Explosions Exporting America Facebook Fair Isaac Fair Isaacs Fair Political Practices Commission Fake Visa Interview False Flags False Police Reports Family Law Fatal Fires Fatal Shootings FBI FBI Agent Frank Doyle Jr. FBI Agents FBI Agents Framed FBI Counter Terrorism FBI Evidence Response Team FBI Rewards FBI School Bomb School FBI School Bomb School (West Coast) FCC FDIC Federal Federal Agencies Federal Bank of New York Federal Bureau of Investigation Federal Cases Federal Election Commission Federal Express Corporation Federal Funds Federal Grand Jury Federal Indictments Federal Prosecutors Federal Reserve Federal Reserve Bank Federal Reserve Board of Governors Federal Statutes Federal Statutes Home FedEx Corporation Feinstein fentanyl Fenwal Holdings FERC FICO Fidel Castro Filing False Reports Financial services Fires FIRST AMENDMENT COALITION FL FL-Gainesville Flowers Forbes Ford Motors Foreign Corrupt Practices Act Forensic Medical Group Forgery FPPC Frank Doyle Jr Frank Doyle Jr. fraud Fraud Of The Court Fremont Gorup Fremont Group Fremont Group L.L.C Fremont Private Holdings FremontGroup.com Fresenius Fresenius Kabi Friends of Mitt Romney Ft. Myers Fusion GPS G4S Gambling Gary Collins Gary Vinson Collins Gates Foundation Gavin Newsom Gavin Newsome Gay Bars Gayle Bishop General Contractor George Bush George Driscoll gift cards GIS Glen Eagle Court Global Terrorism Globalism Globalists Go Fund Me Golden Gate Capital Golden State Warriors Goldman Sachs Capital Partners Good Cop / Bad Cop Good Job Governor Newsom Governor of Massachusetts Governor Schwarzenegger Governors Green Valley Elementary Greenan Greenland Icecap Greg Passama Gregory Paul Anspaugh Guitar Center GWB H-1b H-1b Visa Hackers Haight Ashbury Free Medical Clinic Harvard Business School Hate Crimes Havana Havana Bar HCC Health Care Fraud Hedge Funds Hellfire Hercules Capital HGCG HICKS VS SBC SERVICES High Schools Hillary Clinton Hillary Rodham Clinton Hillside Covenant Church Hit & Run Hobbs Act Home Invasion Robbery Homeless Homeless Homicides Homeless Homicides. Hillside Covenant Church Homeless Programmer homeless Support Links Homeless Victims homelesshomicides.com Homelessness Honest Services Mail Fraud Hong Kong Horowitz Connection HorowitzConnection Host Protection Insurance Hostile Takeovers House Committees House of Representatives House Transportation Committee Housing Discrimination Howard V. Golub HTML% Huckleberry Botanic Regional Preserve HUD Hugh Smith Huma Abedin Humboldt Fire HUNSAKER CANYON RD Hunter Properties Hunter Properties Inc Hurwitz I-131 Ian Murdock IBM iHeartMedia IL illegal immigration Immigration Immigration Issues Immigration Solutions Immigration Success Immigration Tragedies Inc Inc. Incident Incident Maps Incidents Index India INDICTED CNET OFFICERS Indicted Customers Indictments Indonesia Infiltrators InfoWorld Infrastructure Insider Traders Insurance Insurance Fraud Intellectual Property International International Boulevard International Terrorism Investigations Investigative Journalist Investments Investor Fraud Investor Fraud Summit Iodine 131 Iraqi Freedom Iron Horse Trail Irrational Exuberance Ivanpah Solar Electric Generating System J Paul Getty Jacob Bauer Jailed Witness Club James Gilliland James Gilliland Jr. James Greenan James Powell Jamey Sheets Jared Tucker Jason Verdow JFK Assassination JFK Assassination. Southern Pacific JFK University Jim Coulter Jim Jones Jimmy Hoffa Job Joe Canciamilla Joe Lawrence John Ashcroft John F. Kennedy John Muir Medical Center John T. Nejedly Joint Chiefs of Staff Joint Powers Authority Jomorson Properties Joseph Arthur Behiel JOSEPH LYNCH Joseph P. Kennedy Judge Alsup Judge Barry Goode Judge Bruce Van Voorhis Judge Golub Judge Joel Golub Judge Peter Spinetta Judi Bari Judi Bari Bombing Connections Judicial Profiles Judicial Watch Judith Williams justice.gov Kaiser Kaiser Patient Kaiser Steel Kaiser Walnut Creek Karaoke Karina Ioffee Kazakhstan KB Toys Keadjian KEITHLEY v. HOMESTORE.COM KEITHLEY v. MOVE.COM Keller Williams Ken Behring Kern County KEVIN D. LALLY Kevin Flanagan Khosla Ventures Kidnapping Kidney Kidney Failure Kidney Transplants Kiev Kilpatrick Townsend and Stockton LLP Kinder Morgan KKK KKR Known to Pete Bennett Kobe Bryant Kohlberg Kravis Roberts Korean War KPIX KRON4 Kushner Companies La Gonda Way Labor Condition Application Laci Peterson Lafayette Larry Ellison Larry Fink Las Lomas High School Las Trampas Creek Las Vegas Last Watch Law and Justice Law Enforcement Law Firms Lawrence Investments LBGT Lee County Legal Shield Legal Cases Lennar Lennar Urban LESHER COMMUNICATIONS Letters to City of Lafayette Leverage Buy Out LGBT LGBT Murders Limo Limousine Limousine Fires LinkedIN Posts Lisa Trapani Litigation Live Nation Entertainment LLHS LLNL Lockerbie Lockheed Martin Locust Street Longs Drug IT Department Longs Drugs Longs Drugs Connections Lord Cobbold Loretta Hale Los Lomas High School Lou Dobbs Louis Lombard Lowes Lt. Dan Terry Lt. David Oberhoffer Lynching Lynchings Main Point of Entry Mainframe Designs Cabinets & Fixtures Mainstream Media Major Generals Mantech Map Mapbox Examples Maps Maps County of Contra Costa Maps1 Marc Benioff March4Trump Margaret Lesher Mark Coon Mark DeSaulnier Mark Peterson Mark Zuckerberg Martin Nelis Martinez Marvin Bush Mary Hobson Mary Nolan Mass Casualties Massacres Maverick Capital Mayor Dianne Feinstein Mayor Gavin Newsom Mayor Moscone Mayor of Walnut Creek MBS Modeling McAfee McFarland McGregor Scott McGregor W. Scott McKesson McKinsey & Company mcnamaralaw.com Mechanics Bank Medellin Cartels Media Media Contacts Medical Community Mellody Louise Hobson Mena Meningitis Meningitis Murders Mergers and Acquisitions Merisel MERRITT L. WEISINGER Metcalf Station methadone Meyers Nave MeyersNave Michael Flynn Michael Peevey Michael Peterson Michael Sevenau Michael Taugher Microsoft Microsoft Breaches Mid-Atlantic Arena Mid-Atlantic Arena Litigation Mid-Atlantic Arena LLC Middle East Milestone Holdings Milken Missing Persons Mission Bay Mission Bay Fire Mitt Romney Molly's Game MOMA Money Laundering Moraga moral turpitude Mormon Mormon Murders Mormon Polygamy Mormon.org Mormons Mortgage Mortgage Fraud Summit Moscow Mountain Lakes Mountain Lakes NJ MPA BOARD OF DIRECTORS MEETING MPOE Municipal Pooling Authority Murder Murder Conspiracy Murder Stories Murder Suicide Murder Suicides Murder Victim Murdered Moms Murders Murwood Elementary Music MVSC MyVisaJobs N Main Street Nancy Greenan-Hamil Nancy McFadden Nate Greenan National Association of Realtors National CounterTerrorism Center National Rifle Association Naval Air Station Oceana Naval War College NCIB NCIS NCR Corporation NCR Suicide Nearon Nearon Enterprises Nejedly NERC Network World Nevada Gaming Commission Never Forget New York City New York Real Estate NewBridge Capital Inc NIMDA NIMDA Computer Virus NJ No Place like Home Noinvest LLC nomoreh1b Nomoreh1b.blogspot.com nomoreh1b.com North Bay Associates North Korea Northcreek Church Northern California Northern District of California Northgate Capital LLC NOVINVEST LLC NT NTSB NTSB Air Crashes NTSB Aviation Database NTSB Tracker NTSB_Pilots Nuclear Nuclear Engineering NYC NYFD NYPD Oakland Fire Department Oakland Murders Oakland Police Department Oakland Temple Oberhoffer OBIT Obituaries Obstruction of Justice Office of Chief Trial Counsel Office of the Whistleblower Officer Dave Rangel Officer Involved Shootings Officer Lester Garnier Murder Officers Arrested Oklahoma City Federal Building Olin Corporation. Yankee Gas Services Co Olympic Place Onex Open Investigations Open-Mics Operation Varsity Blues opiates Oracle Oracle Corporation Oracle Education Oracle v. PeopleSoft Orange County Organizations Orinda Police Orland Other Outsourcing Outsourcing America Outsourcing Jobs Outsourcing Murders Overstock P2 Capital Partners Pablo Escobar Pablo Escobar. Central Intelligence Agency PacBell PacBell Info Systems Pacific Energy Development Pacific Lumber Pacific Southwest Airlines PACIFIC TELESIS GROUP Pacific Union International Pacific Union Real Estate Pamela Vitale Pandora Pandora Media Panera Bread Parental Abduction Parental Abductions Park Ave Park Smart Inc Parking ParkSmart Patent Attorneys Paterson Teele and Dennis Patterson Paul Graves. Paul Hazen Pavlo Lazarenko PayPal PBS PCB PEDEVCO Pension Funds PeopleSoft Perfectly Framed Pete Bennett Pete Bennett Adversaries Pete Bennett Family History Pete Bennett Friends Pete Bennett Medical Journey Pete Bennett Resume Peter A. Darbee Peter Carver Bennett Peter Spinetta Peter Thiel Peterson Family Trust PG&E PG&E Court Proceedings PG&E Data Breach PG&E Ethics PG&E Executives PG&E Fires PG&E Indictments PG&E Maps PG&E Vendors PG&E Videos PG&E Witness PG7E PGE Pgewitness.com Philip Anschutz Phillip Marshall PHISMA Piedmont Lumber Pierre Nanterme PIMCO pionline.com Pipe Bombs pipelineexplosions.com Pipelines Pittsburg Playtex Playtex New York Stock Exchange Plaza Escuela Point-of-Sale Systems poison Police Police Corruption Police Department Index Politicians Polonium Polygamy Porter Goss Portugal POTUS Pre-Paid Legal President Bush President Clinton President Obama President Trump Priva Private Equity Profile ProLogis Prop 8 Providence Equity Partners Prudential Life Insurance Psychological Warfare Analyst Public Agencies Public Companies Public Corruption Public Law Public Officials Public Sector Pension Investment Board Pulse Nightclub Q-Fever Racketeering Racketeerni Radiation Poisoning Railroads Pipelines and Hazardous Materials Ravenel Enterprises Inc Ray Giacomelli Rays Lounge Real Estate Real Estate Fraud Real Estate Investment Trusts Real Estate Portal Realtor.com Red Hat Software Regency Center Regency Centers Regency Centers Corporation Regional Parking REITS ReMax Rep. Ellen Tauscher Reporters Research Research Portal Retirement Systems Reveal from the Center for Investigative Reporting Rewards Richard Blum Richard Morgan Richard Nixon Richard_Stanford_Kopf Richmond Fire Department Rick Kopf RICO Robert F. Kennedy Robert Hoffman Robert Mueller Robert Vesco Romney Ropes & Gray LLP Rossmoor Round Up Saloon Royal Canadian Mounted Police Rules of Professional Conduct Russ Darby RussDarby Russia Russian Russian Hackers Russian Hacking Russian Investors Russian Mafia Russian Oligarchs S Main Street SA SA Ken Karch Sabotage Safe Policing Safeway Safeway Inc Safeway Inc. Safeway Murders Safeway Pharmacy SAFEWAY STORES INC Salesforce Salt Lake City San Bernardino County San Bruno Explosion San Mateo Bridge San Ramon Fire San Ramon Unified School District San Ramon Valley FIre Protection District Sand Hill Road Sandoval Sanibel Island Santa Clara County Santa Clara DIstrict Attorney Santa Fe Santa Fe Industries Santa Fe Pacific Realty Corporation Santa Fe Pipeline Partners SAP Sare Regis Group SBC Global SBC SERVICES SBC SERVICES INC SBCGlobal SCE Scotland Yard Scott Peterson SE SEC SEC Master Page SEC Violations SEC Whistleblower SEC Whistleblower Protections Secretary of State Securities and Exchange Commission Securities Exchange Act of 1934 Sedgwick Sedgwick Claims Management Services SeeCon Seeno Seeno Construction Seeno Indictments Sen_Feinstein Senate Senate Public Safety Committee Senator Barbara Boxer Senator DeSaulnier Senator Diane Feinstein Senator Dianne Feinstein Senator Mike Lee Senator Nejedly Senator Rainey Senator Rainey. City of Walnut Creek Senior Citizen Sequoia Properties SFBAR SFPD SFSU Sgt. Wenzel Sheriff Silicon Silicon Valley Silver Lake Silver Lake Partners Silverado Council Simon's Hardware Smart Voter smartphone hacks sniper SoCal Edison Soccer Moms Confidential Software Solano County Sony sos South America Southern California Edison Southern Pacific SOUTHERN PACIFIC COMPANY Southern Pacific Pipeline Partners Southern Pacific Railroad SOUTHERN PACIFIC RAILROAD COMPANY Southern Pacific Railroad. Southern Pacific Transportation Spc James Coon Special Counsel Spinal Meningitis Victims Sports Authority Springville UT Spygate Spygate Investigation SRVUSD Staged Incidents Staged Murder/Suicides Stanford Stanford University Stanislaus County Staples Starbucks Starbucks Board Starbucks Murders State Agencies State Attorney General State Attorney General of Southern District of New York state bar State Bar Court State Farm State Farm Automobile Insurance State of California State of Missouri Statutes Stead Motors Stephen Tanabe Stephens Property Management Steve Burd Steve Skinner Stone Valley Road StonePoint Capital Structure Structure Fires Students Success Factors suicide Suicides Suicides Students SUITE 3300 Sullenberger Sully Sun Microsystems Sun Valley Mall Superior Court Supervisor Candace Andersen Supervisor Federal Glover Supervisor Mark DeSaulnier Supervisor Mitchcoff SUPREME COURT Susan Kennedy Suspicious Suspicious Death SW Florida Symantec T T-Mobile Tactical Policing TAMMY-LYN GALLERANI Tanabe links Target Target Data Breach Target Data Dreach Target Employee Target Investors Target Murders Tarrant Capital Advisors Inc Tarrant v. Bennett TAU Tauscher Teamsters Teamsters 856 TEAVANA HOLDINGS INC Tech Murders Technology Telecommunications Templates Terrorism Terrorism - Telecom Terrorism Americas Terrorism Files Terrorist Texas Pacific Group TGP TGP Capital THe The Agora The Albert D. Seeno Stories THE ALLIANT CRIME INSURANCE PROGRAM The American Killed in Barcelona The Anthony Banta Jr. Police Shooting The ANTHRAX Files The Arrested Investors The Bacteria Killers The Beltway Murders The Beltway Sniper The Bennett Kidnapping The Bennett Kidnapping Incidents The Bennett Witness Murder Stories ~ The Southern Pacific Murders The Bogus Tow of the SEC Whistleblower The Brandon Marshall Story The Buchanan Family Murders The Bush Files The Cabbage Patch Murders The Cartels The CIA Murders The CIA Runways The Clinton Body Count The Clinton Files The Clinton Machine The Clinton Murders the CNET Scandal The Cold Case Files The Computer Virus Attacks The Contra Costa Arsonist The COOP Grocery Store Transactions The Country Club Murders The Cynthia Kempf Murder The David Bremer Murder The Dead Series The Deadly Paradise Wildfire Terrorism Argument The Death Docket The Deceased Residents of Walnut Creek The Dirty DUI The Dirty DUI Judge The Discredited FBI Agent The Doc's Pharmacy Bio-Terrorism Story The Doc's Pharmacy Story The Dr. Kim Fang Murders The Driscoll Murders The Dubious Coroner The Dubious Elizabeth Stratton Parental Abduction Story The Dubious Investigations of Chief Wenzel The East Bay Murder Series The East Contra Costa Prostitute Killers The Ecstasy Deception The Elizabeth Anne Stratton Parental Abduction The Ellinwood Farm Murders The Emmon Bodfish Murder The Energy Sector The Epstein Files The Eric Nunn Story The FCC Files The Ford Files The Freeway Murders. Dead Officers. The Gary Vinson Collins Murder Investigation The GhostShip Fire The Greenan Murder The Greenan Murder Mystery The Grocery Sector . Merger & Acquisitions The Homeless Programmer The Immigration Debate The Immigration Files The Impeachment Hearings The Iran/Contra Affair The Jared Tucker Story The Jaycee Dugard Story The Jeffrey Epstein Investigation The John T. Nejedly Incident The Jonestown Massacre The Judi Bari Bombing The Karaoke Murders The Kennedy Assassination The Kennedy Files The Kidney Killers The Kinder Morgan The King of England The Leslie Milne Bennett Trust The Lester Garnier Murder The Locust Street Murders The Margaret Lesher Murder The Metcalf Substation Attack The Missing Geary Road Farmers The Mormon Murders The Mueller Investigation The Murder of Margaret Lesher The Murder of Officer Lester Garnier The Murders Impossible The Northern District of California The Officers of Contra Costa County Police Scandal The Oracle and the Bloodied Activist The Orphan Factory The Pamela Vitale Murder The People Temple Finances The Peoples Temple The Peter Branagh Investigation The Peterson Conspiracy The PG&E Investigation Portal The Phillip Garrido Story The Phillip Marshall Story The Pittsburg Officer Wade Derby Civil Case The Presidential Murders The Public Official Murders The Pulitzer Prize The Pulse Nightclub Files The Queen of England The Real Estate Investing Series The Ringheim Murders The Rise Fund The Russia Files The Russian Connections to Bennett The Safeway Conspiracy The Scherer Murders The Scott Dyleski Story The Scott Peterson Story The Scott Shepherd Story The Scott Shepherd Tragedy The Sealed Federal Indictments The Seeno Family Criminal Saga The Serial Arsonist The Sniper Files The Southern Pacific Conspiracy The Sports Authority The Star Chamber The Starbucks Murders The State Bar The State Bar of California The Story Series The Strack Family Murders The Strack Murders The Strack Story The Suicide Files The Susan Kennedy Murder The Susan Polk Files and Analysis The Susan Polk Murder The Susan Polk Story The SW Florida Cartels The Taiwanchik-Trincher Organization The Terrorism Files The Texas State Bar The Theranos Money Machine The Three Suicide Story The Ticket Masters The Tiki Toms Murders The Torres Family Murders The Torres Murders The Tragedy Tracker The Tragic Tales of Ratliff family The Transgender Murders The Unarmed Candidate The Unarmed Constituent The Unionized Trusts The United States Attorney's Offices The Unusual Ratliff Family Deaths The Van Vorhiss Collection The Virus Files The Visa Wars The Walker Family Murders The Wall Street Journal The Welfare Makers The White House Theranos TheSerialArsonist.com TheSniper Thoma Bravo Thomas C. Wales Thomson Reuters Corporation in TIMELINEJS Timelines Tinker Ventures TITLE 18 Title 18 Constituent Discrimination Services Title 18. CRIMES AND CRIMINAL PROCEDURE Todd Cambra TODO Together Building a Better California Tom Van Voorhis Torres Murders TOSCO CORPORATION Towing Town of Danville Town of Danville. TODO Town of Moraga Town of Orinda Town of Paradise Toys "R" Us TPG TPG Energy TPG Capital TPG Companies TPG Energy TPG GLOBAL 301 COMMERCE STREET TPG Growth TPG Newbridge TPG Newbridge Capital TPG Pace Energy Holdings (“TPGE”) i TPG Pace Holdings Corp Trammell Crow.Category III Development Transcripts Transgender Treasuries Trinity Center Trinity Center Walnut Creek Trump Trump Towers Turton