Depo fact pattern

By Sanchez00

  • Boots & Cats, Inc. was incorporated in Delaware

  • Kyle/Kylie Hudson was hired in 2014

  • SEC began its investigation into BC pursuant to Hudson's report

  • Period: to

    176,766 shares of BC were sold

  • Period: to

    SEC alleges Lens engaged in a scheme to defraud aided by Castellano

    BC's senior accountant Lens engaged in a situation, aided by chief financial officer Castellano, to defraud BC's shareholders. The scheme involved a
    fraudulent accounting model, against generally accepted accounting principles (“GAAP”)
    and various provisions of federal securities laws.

  • WB Complaint B

    WB submitted accounting to Lens on July 12, 2021 via email in anticipation of
    BC’s upcoming board meeting on August 14, 2021;

  • WB Complaint C

    WB’s accounting noted that a substantial amount of BC’s publicly traded shares
    were sold during fiscal year 2021 (“FY21”) due, at least in part, to BC’s delay in
    releasing its highly-sought product, hEARo

  • Kyle/Kylie Hudson submitted an accounting to Charlotte/Charlie Lens ("Lens")

  • WB Complaint L, M, N

    1. Lens submitted the fraudulent accounting to Castellano
    2. Lens made Castellano aware of the fraudulent accounting model via email
    3. Castellano knowingly and willingly approved the fraudulent accounting

  • WB Complaint P

    BC’s publicly traded stock was valued at $75 per share

  • WB Complaint O

    Castellano presented the fraudulent accounting to BC’s board

  • WB Complaint S

    BC’s had 300,000 outstanding and available shares for purchase on the public
    securities exchange

  • WB complaint Q

    Simone made a public statement regarding its projections for FY22 and FY 2023

  • WB Complaint R

    BC’s publicly traded stock was valued at $188 per share

  • Kyle/Kylie Hudson reported the accounting to Chase Ahmed ("Ahmed")

  • BC and its agents, represented by Marx Brothers file its answer

  • Confidential Whistleblower complaint is filed to the commission

  • Chase Ahmed concluded his investigation

  • Kyle/Kylie Hudson reported the accounting to the SEC

  • Boots & Cats, Inc. went public

  • Period: to

    WB Complaint A

    WB created an accounting of BC’s projected sales, working capital, outstanding
    shares, and made predictions for BC’s financial position for fiscal year 2022
    (“FY22”) and fiscal year 2023 (“FY23”);

  • Lens and Castellano resigned

  • Hudson was fired

  • SEC filed its complaint against BC and its agents