Page 8 SANCTN funds managed by affiliates of Apollo Global Management, LLC. After receiving this nonpublic information from Whelehan, on January 22, 2016, Tsai purchased 1,500 shares of ADT stock. On that same day, Tsai also recommended to a close relative to purchase ADT stock.

same day, Tsai also recommended to a close relative to purchase ADT stock. Later that day, Tsai's close relative purchased 343 shares of ADT stock. Whelehan did not trade in ADT stock. According to the complaint, when ADT's acquisition was announced on February 16, 2016, its stock price rose 48 percent,

E NUMBER: 1:16-cv-07398 JURISDICTION: Securities and Exchange Commission SOURCE: SEC Admin. Doc(s) & Press Release dated 09/22/16 DATE: 9/22/2016 Whelehan, Colin For internal use only For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0046925 CONFIDENTIAL SDNY_GM_001931