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addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead attempted to disguise as an asset sale transaction. VONVJ . sec ov https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773 scl3g.htin www.sec.gov (i) Sole power to vote or to direct the

SECURITIES AND EXCHANGE COMMISSION . 17 CFR Parts 240 and 249 [Release No. 34-89963; File No. S7- 16-18] RIN 3235-AM11 . Whistleblower Program Rules VONVJ . sec ov New Rule 240.21F-18 Summary Disposition (3) The information you submitted was never provided to or used by the staff handling the covered

Exchange Act requires, among other things, that broker-dealers make and keep for prescribed periods such records, furnish such copies thereof, and VONVJ . sec .c) ov In 80 MILLION instances. That's right EIGHTY MILLION instances CDEL submitted inaccurate TIME STAMP info to Blue Sheets. Looks like AN