THE MITCHELL L.

MCLEAN TRIAL COMPETITION

ELSA IE LAW SCHOOL

UNITED STATES OF AMERICA v. KRISTIN PAX

United States Federal District Court for the Southern District of New York

Cause of Action:
UNITED STATES is bringing charges as recommended by the SEC and FDIC against the Defendant Kristen Pax for
violations of federal criminal laws.

Allegation:
The Defendant was the CFO of Truman, Stein & Co., a publicly traded major banking institution headquartered in
New York City. The Defendant was involved in the preparation and review of the company's financial reports and
projections provided to investors. An individual invested $500,000 in Truman, Stein & Co.'s common stock and
$200,000 in a high-yield certificate of deposit offered by the company, relying on the financial reports and
projections provided by the company. He and other clients suffered severe financial loss due to the drop in stock
price and failure to meet the promised interest rate. The financial reports and projections provided by Truman, Stein
& Co. were the subject of regulatory investigations by the SEC and FDIC. Emails and other correspondence
between the Defendant and other executives regarding the loan portfolio projections were discovered during the
regulatory investigations. Some individuals filed a lawsuit alleging violations of SEC and FDIC regulations. The
Defendant denies any wrongdoing and argues that any discrepancies in the loan portfolio projections were the result
of good faith errors and were not intended to mislead investors. The state argues that the Defendant knew or should
have known about the discrepancies and that their actions constituted securities fraud.

Prosecutorial Witnesses:
● Cleo Anderson, An FBI agent who investigated the case and conducted interviews with witnesses and
reviewed documents.
● Luca Bautista, An investor who lost money as a result of the Defendant's actions and can testify to their
reliance on the false and misleading statements made by the Defendant.
● Dr. Louis Vanderbilt, An expert witness in the field of securities and financial fraud who can provide
testimony regarding the materiality of the false and misleading statements and the defendant's intent to
defraud.

Defendant's Witnesses:
● The Defendant, Kristen Pax.
● Tori Goldman, A senior executive from Truman, Stein, & Co. who can attest to the Defendant's good faith
belief in the accuracy of the financial information and projections provided to investors.
● Alex Rodriguez, An independent accountant who conducted an audit of the company's financial statements
and can testify that they were prepared in accordance with generally accepted accounting principles.
● Carson Simons, An expert witness in the field of financial analysis who can provide testimony regarding
the impact of market conditions and other factors on the company's financial performance.

Issues:
1. Did the Defendant have a duty to disclose to investors any material information about the financial
performance and potential of Truman, Stein, & Co.?
2. Did the Defendant engage in insider trading by selling a significant number of ABC Corporation shares
shortly before the stock price dropped?
3. Did the Defendant breach a fiduciary duty owed to investors by failing to disclose material information and
making false and misleading statements?
 STIPULATED FACTS OF THE CASE.
*These facts are agreed upon by both parties and cannot be disputed.*

1. Truman, Stein, & Co. is a publicly traded major banking institution headquartered in New York
City in the United States.
2. The Defendant was employed by Truman, Stein, & Co. as the Chief Financial Officer from
January 1, 2016 to February 11, 2019.
3. During the Defendant's tenure, Truman, Stein, & Co. issued quarterly and annual financial
reports, as well as revenue and loan portfolio projections, to investors.
4. The Defendant was involved in the preparation and review of the financial reports and projections
provided to investors.
5. Among hundreds of clients, an individual invested $500,000 in Truman, Stein, & Co.'s common
stock on June 1, 2017, relying on the financial reports and projections provided by the company.
a. The individual also invested an additional $200,000 in a high-yield certificate of deposit
offered by Truman, Stein, & Co..
6. Clients suffered severe financial loss as a result of the investment in Truman, Stein, & Co.'s
common stock, when the stock price dropped significantly on December 31, 2018.
7. There were also severe losses as a result of the certificate of deposit investment due to Truman,
Stein, & Co.'s failure to meet its promised interest rate.
8. The financial reports and projections provided by Truman, Stein, & Co. were the subject of
regulatory investigations by the Securities and Exchange Commission (SEC) and the Federal
Deposit Insurance Corporation (FDIC).
9. The Defendant received a total of $600,000 in bonuses and other compensation from Truman,
Stein, & Co.
10. Internal audits performed by Truman, Stein, & Co. revealed discrepancies in the loan portfolio
projections provided to investors.
11. Emails and other correspondence between the Defendant and other Truman, Stein, & Co.
executives regarding the loan portfolio projections were discovered during the regulatory
investigations.
12. Some individuals filed a separate lawsuit alleging violations of SEC Rule 10b-5 regarding the
dissemination of false or misleading information, and violations of FDIC regulations regarding
the management of depositor funds.
13. The Defendant denies any wrongdoing and asserts that they acted in good faith in the preparation
and review of the financial reports and projections provided to investors, and that the drop in
stock price and failure to meet the promised interest rate were due to broader market conditions
and factors outside of their control.
14. The Defendant also argues that any discrepancies in the loan portfolio projections were the result
of good faith errors and were not intended to mislead investors.
15. The individual argues that the Defendant knew or should have known about the discrepancies in
the loan portfolio projections and that their actions constituted securities fraud.
 SUMMARY OF EVENTS

Truman, Stein, & Co. is a publicly traded banking institution headquartered in New York City in the
United States, offering a wide range of banking products and services to its customers. The institution had
a strong reputation for its focus on technology and innovation, and its commitment to delivering
outstanding customer service.

In January 2016, the Defendant was employed by Truman, Stein, & Co. as the Chief Financial Officer, a
senior executive position responsible for overseeing the company's financial operations and strategy.
During their time of employment, the Defendant was involved in the preparation and review of the
financial reports and projections provided by the company to its investors.

On June 1, 2017, a large group of individuals invested in Truman, Stein, & Co.'s common stock, relying
on the financial reports and projections provided by the company. The individuals also invested an
additional sum in a high-yield certificate of deposit offered by Truman, Stein, & Co..

However, the individuals suffered a severe financial loss as a result of the investment in Truman, Stein, &
Co.'s common stock, when the stock price dropped significantly on December 31, 2018. The investors
also suffered financial losses as a result of the certificate of deposit investment due to Truman, Stein, &
Co.'s failure to meet its promised interest rate.

The financial reports and projections provided by Truman, Stein, & Co. were the subject of regulatory
investigations by the Securities and Exchange Commission (SEC) and the Federal Deposit Insurance
Corporation (FDIC). The investigations revealed discrepancies in the loan portfolio projections provided
to investors, and internal audits performed by Truman, Stein, & Co. confirmed these discrepancies.
Emails and other correspondence between the Defendant and other Truman, Stein, & Co. executives
regarding the loan portfolio projections were also discovered during the investigations.

The Defendant received a total of $600,000 in bonuses and other compensation from Truman, Stein, &
Co. during their time of employment.

The individuals filed a class action lawsuit alleging violations of federal securities laws and regulations,
including violations of SEC Rule 10b-5 regarding the dissemination of false or misleading information,
and violations of FDIC regulations regarding the management of depositor funds. The individuals argued
that the Defendant knew or should have known about the discrepancies in the loan portfolio projections
and that their actions constituted securities fraud. That lawsuit is ongoing.

The Defendant denies any wrongdoing and asserts that they acted in good faith in the preparation and
review of the financial reports and projections provided to investors, and that the drop in stock price and
failure to meet the promised interest rate were due to broader market conditions and factors outside of
their control. The Defendant also argues that any discrepancies in the loan portfolio projections were the
result of good faith errors and were not intended to mislead investors
 EXHIBIT 28
AFFIDAVIT OF CONTEST FOR THE DEFENDANT

I, Kristen Pax, being first duly sworn, deposes and says:

I am the defendant in this case and am familiar with the facts and circumstances of the matter.

I am an experienced and knowledgeable banking professional, having worked for many banks for over a
decade. During my time at Truman Stein & Co, I have held various senior management positions,
including serving as the Chief Financial Officer.

In my capacity as the CFO, I was responsible for overseeing the bank's financial reporting processes,
including the preparation and dissemination of periodic financial statements.

I am familiar with the regulations and rules governing the preparation of financial statements, and I take
my obligations to ensure their accuracy and completeness very seriously.

With regards to the financial statements at issue in this case, I can attest that they were prepared in
accordance with generally accepted accounting principles (GAAP) and that they accurately reflected the
financial condition and results of operations of the bank at the time they were prepared.

I was not aware of any illegal or unethical activities taking place within the bank that would have
impacted the accuracy of the financial statements during the relevant time period.

I believe that the investor in this case, who lost money, made their investment decision based on their own
independent research and analysis, and that their losses were not caused by any misstatements or
omissions in the financial statements.

I understand that the plaintiff is alleging that I engaged in fraudulent or illegal activities in connection
with the preparation of the financial statements, and I vehemently deny these allegations.

I believe that the financial statements were accurate and complete at all relevant times, and that any losses
sustained by the investor were not the result of any wrongdoing on my part.

I declare under penalty of perjury that the foregoing is true and correct.

Signed this date.

Kristen Pax.
 EXHIBIT 28 CONT.
EVIDENCE STATEMENT
DEFENDANT KRISTEN PAX

I, Kristen Pax, am the defendant in the case brought against me regarding my role as Chief Financial
Officer at Truman, Stein, & Co.. I would like to take this opportunity to provide my side of the story and
share my experiences with the court.

I have always been passionate about finance and the banking industry, and it was an honor for me to be
offered the opportunity to work as CFO at Truman, Stein, & Co.. At the time, Truman, Stein, & Co. was
known for its innovative technology and customer-focused approach, and I was eager to be a part of such
a dynamic and forward-thinking organization.

As CFO, my role was to oversee the company's financial operations and strategy. This involved a great
deal of responsibility, including the preparation and review of financial reports and projections that would
be shared with investors. I took this responsibility very seriously, and I was dedicated to ensuring that the
information we provided was accurate and trustworthy.

In 2017, individuals invested in Truman, Stein, & Co.'s common stock and an additional sum in a
high-yield certificate of deposit. At the time, I had no reason to believe that our financial reports and
projections were anything but truthful and accurate. The individual's investment was based on the
information we provided, and I was confident that they would see a return on their investment.

Unfortunately, things didn't go as planned. The individuals suffered a financial loss as a result of the
investment in Truman, Stein, & Co.'s common stock when the stock price dropped significantly on
December 31, 2018. They also suffered a loss due to our failure to meet the planned interest rate on the
certificate of deposit.

I was shocked and saddened by these events, and I was eager to understand how they could have
happened. That is when the regulatory investigations began, and I was informed that there were
discrepancies in the loan portfolio projections we had provided to investors.

As part of the investigations, emails and other correspondence between myself and other Truman, Stein,
& Co. executives were discovered, including those regarding the loan portfolio projections. I was aware
of these projections and their potential impact on the company and our investors. However, I firmly
believe that I acted in good faith in the preparation and review of these reports and that any discrepancies
were the result of good faith errors, not an intentional effort to mislead anyone.

Despite my beliefs, I have been named as a defendant in this criminal proceeding as well as a lawsuit
alleging violations of federal securities laws and regulations, including violations of SEC Rule 10b-5
regarding the dissemination of false or misleading information and violations of FDIC regulations
regarding the management of depositor funds.
I would like to stress that I deny any wrongdoing and that I acted in good faith at all times. The drop in
stock price and the failure to meet the promised interest rate were due to broader market conditions and
factors outside of my control. I am confident that the court will recognize my innocence and that I will be
exonerated of all charges.

The outcome of this case will have far-reaching implications, not just for myself and the individual
investor, but for the broader securities and banking industries. I appreciate the opportunity to tell my side
of the story and I am committed to seeking a just resolution for all parties involved.

Signed this date.

Kristen Pax.
 EXHIBIT 29
STATEMENT OF ALEX RODRIGUEZ, CPA

My name is Alex Rodriguez and I am a certified public accountant for Charles Schwab. I have over 20
years of experience in the field and have been working as an independent accountant for the past 10 years.
I was engaged by Truman, Stein, & Co. in 2018 to conduct an internal audit of the company's financial
statements for the year ended December 31, 2017.

During my audit, I reviewed the financial reports and projections provided by the company to its
investors, as well as internal records and documentation related to the loan portfolio projections. I found
that the financial statements were prepared in accordance with generally accepted accounting principles
and that they accurately reflected the financial condition of Truman, Stein, & Co. as of December 31,
2017. The company had a relatively strong, yet outdated system of internal controls in place and their
financial reporting processes were fair. I also had the opportunity to review the financial projections and
reports provided by Truman, Stein, & Co. to its investors. I found that the projections were based on
reasonable assumptions and were supported by appropriate documentation.

It is worth noting that the drop in stock price and failure to meet the promised interest rate experienced by
the individual investor in this case were due to broader market conditions and factors outside of the
control of Truman, Stein, & Co. or any of its employees, including the defendant, Kristen Pax. However, I
did notice that some of the internal controls related to the loan portfolio projections were not as robust as
they should have been. For example, I noted that the loan portfolio projections were not independently
reviewed by someone outside of the finance department, which would have provided additional oversight
and reduced the risk of errors.

I also reviewed the emails and other correspondence between the defendant, Kristen Pax, and other
Truman, Stein, & Co. executives regarding the loan portfolio projections. From my review, I found no
evidence of any intentional or deliberate misstatements in the financial reports and projections. In my
professional opinion, any discrepancies in the loan portfolio projections were the result of good faith
errors and were not intended to mislead investors.

Overall, I believe that the financial reports and projections provided by Truman, Stein, & Co. were
prepared in accordance with generally accepted accounting principles and did not contain any intentional
or deliberate misstatements. However, the discrepancies in the loan portfolio projections highlight the
importance of robust internal controls and the need for independent oversight in the preparation of
financial statements.
 EXHIBIT 30
STATEMENT OF CARSON SIMONS

My name is Carson Simons, and I am a witness in the field of financial analysis. I have been asked to
provide testimony regarding the impact of market conditions and other factors on the financial
performance of Truman, Stein, & Co., a publicly traded banking institution.

In 2016, the financial landscape was characterized by a slow but steady economic recovery following the
global financial crisis of 2008. The banking industry faced significant headwinds, including low interest
rates, increased regulatory scrutiny, and ongoing economic uncertainty. Despite these challenges, Truman,
Stein, & Co. was well positioned, with a strong reputation for its focus on technology and innovation and
its commitment to delivering outstanding customer service.

In the period leading up to the events in question, the overall market conditions for financial institutions
were challenging, with the stock prices of many banks fluctuating due to uncertainty surrounding interest
rates and potential changes in monetary policy. Additionally, the banking industry was facing increased
competition from fintech companies and other non-traditional players, which put additional pressure on
financial performance.

Despite these market conditions, Truman, Stein, & Co.'s financial performance remained strong, with
solid growth in both revenue and net income. The company's loan portfolio was well diversified, with a
mix of consumer, commercial, and mortgage loans. The company's financial projections were based on a
careful analysis of market conditions and were supported by detailed financial modeling and scenario
analysis.

It is my expert opinion that the drop in stock price and failure to meet the promised interest rate
experienced by the individual investor were primarily due to broader market conditions and factors
outside of the control of the Defendant or Truman, Stein, & Co.. The discrepancies in the loan portfolio
projections were likely the result of good faith errors, as financial projections are inherently uncertain and
subject to a range of potential risks and uncertainties.

However, it is important to note that while the financial reports and projections provided by Truman,
Stein, & Co. were prepared in accordance with generally accepted accounting principles, there may have
been certain areas where additional caution and attention could have been exercised. For example, the
emails and correspondence between the Defendant and other executives regarding the loan portfolio
projections reveal a degree of pressure to meet certain performance targets and financial expectations,
which could have influenced the accuracy of the financial reports and projections provided to investors.

In conclusion, while the market conditions were challenging and the financial performance of Truman,
Stein, & Co. was impacted by a range of external factors, the discrepancies in the loan portfolio
projections and the emails and correspondence revealed by the investigations raise important questions
about the level of due diligence and care exercised by the Defendant and other executives in the
preparation and dissemination of financial information to investors.
 EXHIBIT 31
STATEMENT OF TORI GOLDMAN

My name is Tori Goldman and I am a senior executive at Truman, Stein, & Co.. I have had the privilege
of working closely with the Defendant, who served as the Chief Financial Officer of Truman, Stein, & Co.
during the relevant time period. I can attest to the Defendant's unwavering commitment to our company,
our customers, and to ensuring that all financial information and projections provided to investors were
accurate and reflective of the best information available at the time.

Throughout the Defendant's tenure at Truman, Stein, & Co., they consistently demonstrated a deep
understanding of our industry, a passion for innovation and a commitment to delivering outstanding
customer service. Our customers love the Defendant and have consistently praised their work and efforts
to provide them with the best banking products and services available.

The Defendant has a proven track record of delivering high returns for Truman, Stein, & Co. and its
investors, and I believe that this is due in large part to their relentless drive and dedication to the job.
Despite the fact that the Defendant was facing certain personal challenges, such as their alleged drinking
problem due to a recent loss in the family, they always put the needs of the company first and maintained
their focus on delivering outstanding results.

In my opinion, the Defendant acted in good faith in the preparation and review of the financial reports and
projections provided to investors. I believe that any discrepancies in the loan portfolio projections were
the result of good faith errors and were not intended to mislead investors. The Defendant is a person of
integrity, and I have no reason to believe that they engaged in any wrongdoing or acted with any intention
to defraud investors.

In conclusion, I strongly believe that the Defendant acted in good faith and that the financial information
and projections provided to investors were accurate and reflective of the best information available at the
time. The broader market conditions and other factors outside of the Defendant's control, including the
broader economic and political climate, likely played a significant role in the drop in stock price and the
failure to meet the promised interest rate.
 EXHIBIT 32
STATEMENT OF LUCA BAUTISTA

My name is Luca Bautista and I am a Plaintiff in a civil case against the Defendant, the former Chief
Financial Officer of Truman, Stein, & Co.

In January 2016, I made the decision to invest in Truman, Stein, & Co., a publicly traded banking
institution that I believed was committed to delivering outstanding customer service and innovative
financial products. A friend of mine referred to the Defendant, as they have a well-known reputation for
their commitment to their job and their dedication to their family. I know that despite the stress of their
role at Truman, Stein, & Co., they have been a devoted parent and partner, and have always put the needs
of their family first. This is why I trusted the financial reports and projections provided by the company
and invested a total of $700,000 - $500,000 in common stock and $200,000 in a high-yield certificate of
deposit.

However, by the end of 2018, I had suffered significant financial losses as a result of my investment. The
stock price of Truman, Stein, & Co. dropped dramatically, causing me to lose $250,000. Additionally, the
high-yield certificate of deposit failed to meet the promised interest rate, resulting in a loss of $50,000.
These losses had a significant impact on my personal life and financial wellbeing.

As the investigations by the SEC and FDIC revealed, the financial reports and projections provided by
Truman, Stein, & Co. were not accurate. The discrepancies in the loan portfolio projections were
confirmed by internal audits, and emails and correspondence between the Defendant and other executives
indicated that they were aware of these discrepancies.

I am alleging that the Defendant knew or should have known about these discrepancies and that their
actions constituted securities fraud. The Defendant received a total of $600,000 in bonuses and
compensation during their time of employment, and I believe that this compensation was received as a
result of the Defendant's role in disseminating false or misleading information to investors.

I am seeking justice for the financial losses I have suffered as a result of my investment in Truman, Stein,
& Co.. I am a retired Air Force veteran and my investment in Truman, Stein, & Co. was meant to provide
me with financial security in my golden years. Instead, I have been left with significant debt and have
been forced to return to work to make ends meet.
 EXHIBIT 33
STATEMENT OF DR. LOUIS VANDERBILT

My name is Dr. Louis Vanderbilt and I are a leading expert in the field of securities and financial fraud. I
have over 20 years of experience in the industry and have provided expert testimony in numerous
high-profile cases involving securities fraud and financial reporting irregularities.

Based on my review of the case at hand, I believe that the false and misleading statements made by the
Defendant regarding the loan portfolio projections were material to the investment decisions made by the
individual investor. Materiality is a key component of securities fraud and refers to the significance of the
information to a reasonable investor. In this case, the discrepancies in the loan portfolio projections were
significant and would have impacted the investment decisions made by a reasonable investor.

Additionally, I believe that the Defendant had the intent to defraud. This can be inferred from the
Defendant's direct involvement in the preparation and review of the financial reports and projections, their
receipt of significant bonuses and compensation from Truman, Stein, & Co. during their time of
employment, and the correspondence between the Defendant and other Truman, Stein, & Co. executives
regarding the loan portfolio projections discovered during the regulatory investigations.

However, it is important to note that intent to defraud can be difficult to prove and is often inferred from
circumstantial evidence. In this case, the correspondence between the Defendant and other Truman, Stein,
& Co. executives regarding the loan portfolio projections should be carefully evaluated to determine the
intent behind their actions.

In my opinion, the discrepancies in the loan portfolio projections provided by Truman, Stein, & Co. were
material to investors, as they would have impacted their decisions regarding investment in the company.
The projections were a significant factor in the investment decisions of the individual who lost money, as
demonstrated by their reliance on the information in making their investments.

Additionally, the internal audits performed by Truman, Stein, & Co. and the correspondence between the
Defendant and other executives regarding the loan portfolio projections suggest that the Defendant was
aware of the discrepancies. The Defendant's receipt of substantial bonuses and other compensation from
Truman, Stein, & Co. during their time of employment further supports the conclusion that they acted
with an intent to defraud investors.

It is my professional opinion that the customers losses as a result of their investments in Truman, Stein, &
Co.'s common stock and high-yield certificate of deposit were directly attributable to the false and
misleading statements made by the Defendant.

However, it is important to note that while the Defendant's actions were illegal and unethical, it is also
possible that they were motivated by a desire to maintain the company's financial performance and meet
investors' expectations during a challenging period in the banking industry. This motive, while not
excusing their actions, may suggest that the Defendant's intent to defraud was not necessarily malicious in
nature
 EXHIBIT 34
STATEMENT OF AGENT CLEO ANDERSON

My name is Agent Cleo Anderson and I am an FBI special agent with over 10 years of experience
investigating securities and financial fraud cases. I was assigned to the Truman, Stein, & Co. case in early
2019 and was responsible for leading the investigation into the allegations of securities fraud.

As part of my investigation, I conducted numerous interviews with witnesses, including employees of

Truman, Stein, & Co. and the Defendant, as well as reviewed thousands of pages of internal emails,
financial reports, and other relevant documents. I also worked closely with other law enforcement
agencies, including the SEC and FDIC, to gather additional information and evidence relevant to the case.

One of my key findings was the discovery of discrepancies in the loan portfolio projections provided to
investors by Truman, Stein, & Co., which were confirmed through internal audits performed by the
company. The Defendant, as the Chief Financial Officer of Truman, Stein, & Co., was involved in the
preparation and review of these financial reports and projections.

In addition, my investigation also revealed that the Defendant received a total of $600,000 in bonuses and
other compensation from Truman, Stein, & Co. during their time of employment, despite the fact that the
financial reports and projections provided by the company were later found to be false and misleading.

Despite the Defendant's assertion that any discrepancies in the loan portfolio projections were the result of
good faith errors and were not intended to mislead investors, the evidence gathered during my
investigation supports the conclusion that the Defendant knowingly or recklessly made false and
misleading statements with the intent to defraud investors.

I also reviewed emails and correspondence between the Defendant and other Truman, Stein, & Co.
executives, which revealed discussions and concerns about the loan portfolio projections and the potential
impact on the company's financial performance. These communications indicate that the Defendant was
aware of the discrepancies in the loan portfolio projections and the potential risks to investors.

I did note the fact that there were multiple individuals involved in the preparation and review of the
financial reports and projections provided to investors and that the drop in stock price and failure to meet
the promised interest rate were partly due to broader market conditions and factors outside of the
Defendant's control. However, these details do not change the overall conclusion of my investigation,
which supports the allegations of securities fraud against the Defendant.

In conclusion, the evidence gathered during my investigation supports the conclusion that the Defendant
engaged in securities fraud by knowingly or recklessly making false and misleading statements with the
intent to defraud investors. The impact of this fraudulent conduct on the individual investor, who suffered
financial losses as a result of their investments in Truman, Stein, & Co., cannot be overstated. The
outcome of this case will have significant implications for both the individual investor and Truman, Stein,
& Co., as well as for the broader securities and banking industries.
 EXHIBIT 1

Notes: Email sent by the Defendant on May 5, 2017

Subject: Truman, Stein, & Co.'s financial projections for Q2 2017

Dear Investors,

I hope this email finds you well. I wanted to take a moment to share with you
some exciting news regarding Truman, Stein, & Co.'s financial projections for
Q2 2017. Our loan portfolio is projected to grow by 12% compared to last year,
and we anticipate a strong increase in both our deposit and loan interest
margins.

We have been working tirelessly to improve our technology and customer service
offerings, and I am confident that these efforts will result in even more
substantial growth in the future. Our commitment to delivering outstanding
customer service remains our top priority, and we are confident that this will
continue to drive customer loyalty and result in high returns for our
investors.

Please let me know if you have any questions or concerns, and I would be happy
to discuss further.

Best regards,

Kristen Pax
Chief Financial Officer

Truman, Stein, & Co.

 EXHIBIT 2

Notes: Email sent by the Defendant on September 1, 2017:

Subject: Truman, Stein, & Co.'s financial projections for Q3 2017

Dear Investors,

I hope this email finds you well. As we approach the end of Q3, I wanted to
provide an update on our financial projections for the quarter. Our loan
portfolio is projected to grow by 15% compared to last year, and we anticipate
a strong increase in both our deposit and loan interest margins.

In light of this growth, I am pleased to announce that we will be offering a

special dividend to our investors in recognition of our strong performance.
This dividend will be paid out on December 31, 2017, and we are confident that
this will be a welcome addition to your investment returns.

Please let me know if you have any questions or concerns, and I would be happy
to discuss further.

Best regards,

Kristen Pax
Chief Financial Officer

Truman, Stein, & Co.

 EXHIBIT 3

Notes: Email sent by the Defendant on November 15, 2017:

Subject: Truman, Stein, & Co.'s financial projections for Q4 2017

Dear Investors,

I hope this email finds you well. As we approach the end of the year, I wanted
to provide an update on our financial projections for Q4 2017. Our loan
portfolio is projected to grow by 20% compared to last year, and we anticipate
a strong increase in both our deposit and loan interest margins.

In light of this growth, I am pleased to announce that we will be offering a

special dividend to our investors in recognition of our strong performance.
This dividend will be paid out on March 31, 2018, and we are confident that
this will be a welcome addition to your investment returns.

Please let me know if you have any questions or concerns, and I would be happy
to discuss further.

Best regards,

Kristen Pax
Chief Financial Officer

Truman, Stein, & Co.

 EXHIBIT 4

RE: PERSONAL SHARES OF TRUMAN, STEIN & CO.

ACCOUNT HOLDER: KRISTEN PAX

Date Stock Shares Price per Share Total Value

10/15/2018 Truman, Stein, & Co. 10,000 $50 $500,000

11/01/2018 Truman, Stein, & Co. 15,000 $52 $780,000

11/15/2018 Truman, Stein, & Co. 20,000 $55 $1,100,000

12/01/2018 Truman, Stein, & Co. 25,000 $57 $1,425,000

12/30/2018 Truman, Stein, & Co. 30,000 $45 $1,350,000

 EXHIBIT 5

MAY 1 2017 16:23:55

MEMO
RE: Loan Portfolio Projections
FROM: Truman, Stein, & Co.

Loan Number | Loan Amount | Projected Interest | Projected Loan Repayment Date

001 | $500,000 | 6% | 12/31/2023

002 | $750,000 | 7% | 01/31/2024
003 | $1,000,000 | 8% | 02/28/2024
004 | $1,250,000 | 9% | 03/31/2024
005 | $1,500,000 | 10% | 04/30/2024

Total Projected Interest Earnings: $67,500

★ Projections are based on current interest rates and loan repayment timelines.
★ Projections may change based on actual loan performance and market conditions.

Notes: These projections are based on the best information available at the time of preparation. Truman,
Stein, & Co. makes no representation or warranty, express or implied, as to the accuracy or completeness
of the information provided. The actual performance of the loan portfolio may differ materially from the
projections provided.

MEMO SENT BY: James Stugard, Finance Intern

 EXHIBIT 6
INTERNAL AUDIT REPORT

Truman, Stein, & Co.

Report Date: 01/01/2018
Report Prepared By: Charles Schwab Internal Services

Executive Summary:
The purpose of this internal audit report is to review and assess the accuracy and
reliability of Truman, Stein, & Co.'s financial reporting practices and internal
control processes related to its loan portfolio operations. The report is based on an
examination of selected transactions, records, and processes for the period of
January 1, 2017 to December 31, 2017.

Key Findings:

1. Lack of effective internal controls over the loan portfolio operations: The
audit found that Truman, Stein, & Co. had no formal policies and procedures in
place to oversee the loan portfolio activities and monitor the accuracy of loan
information and data. This has resulted in an increased risk of inaccuracies in
loan information and data, which could negatively impact the financial
reporting and performance of the company.
2. Inadequate documentation and recordkeeping: The audit found that Truman, Stein,
& Co. had poor documentation and recordkeeping practices, which have led to a
lack of clear evidence of loan origination, processing, and repayment. This has
made it difficult to accurately assess the performance and risk of the loan
portfolio and has increased the risk of loan fraud.
3. Misleading loan portfolio projections: The audit found that Truman, Stein, &
Co. had provided investors with misleading loan portfolio projections, which
overstated the expected performance of the loan portfolio and understated the
risk of loan defaults. The audit found that these projections were based on
unreliable loan data and were not adequately supported by evidence or
documentation.

Recommendations:

1. Implement a formal loan portfolio management policy and procedure to ensure the
accuracy of loan information and data and to monitor the performance of the
loan portfolio.
2. Establish a comprehensive documentation and recordkeeping process to ensure
that loan origination, processing, and repayment information is accurately
recorded and maintained.
3. Refrain from providing misleading loan portfolio projections to investors and
ensure that all financial reporting and projections are based on accurate and
reliable data and are supported by adequate evidence and documentation.

Conclusion:
★ The internal audit of Truman, Stein, & Co.'s loan portfolio operations has
revealed significant issues related to internal controls, documentation and
recordkeeping, and financial reporting. The recommendations outlined in this
report, if implemented, will help improve the accuracy and reliability of
financial reporting and reduce the risk of loan fraud and other financial
irregularities.
 EXHIBIT 7

Notes: Email Sent to CEO

Date: 16 May 2017 at 9:15AM

Subject: Loan Portfolio Projections

From: kpax@tsc.com
To: jharper@tsc.com

Dear Jeff,

I hope this email finds you well. I wanted to bring to your attention the loan portfolio projections for the
next quarter. As you know, these projections are a critical part of our presentation to investors, and I
wanted to make sure that we are presenting them in the best light possible.

I have reviewed the current projections and I have concerns about the accuracy of the data. Some of the
loans are not performing as expected and if these trends continue, it could have a significant impact on
our projections.

I suggest that we have an emergency meeting to discuss this matter and determine the best course of
action. We need to ensure that our projections accurately reflect the performance of the loan portfolio and
that we are not providing false or misleading information to investors.

I look forward to your response and to our meeting to discuss this matter further.

Best regards,
Kristen
 EXHIBIT 8

Notes: CEO response to Email.

Date: 18 May 2017 at 12:44PM

Subject: Re: Loan Portfolio Projections

From: jharper@tsc.com
To: kpax@tsc.com

Kristen,

Thank you for your email and for bringing this to my attention. I agree that we need to be transparent and
accurate with our projections, and I would like to schedule a meeting as soon as possible.

I will arrange for our finance team to review the loan portfolio projections and to determine if any
adjustments need to be made. In the meantime, I would like for you to provide me with any additional
information or data that you have regarding the loans in question. I also want you to swing by my office if
you can, I want some updates on that thing we spoke about regarding Maiden.

I look forward to our meeting and to finding a resolution to this matter.

Best regards,

Jeffrey Harper
CEO
 EXHIBIT 9

Date: 18 May 2017 4:22 PM

Subject: Loan Portfolio Projections Update

From: kpax@tsc.com
To: jharper@tsc.com, finance@tsc.com, legal@tsc.com

Jeff,

I wanted to follow up on our meeting regarding the loan portfolio projections. I have received additional
information regarding the loans in question and I wanted to share it with you in person. I also want to loop
in the rest of the finance and legal teams.

As you know, the loans are not performing as expected and this could have a significant impact on our
projections. I think that we should be fine if we remain diligent. I see no need to relay this information to
our investors, especially considering they may all pull their shares.

Hope the kids are well. Sorry to hear that your daughter Kim has been ill. Please let me know your
thoughts on this matter and if there is anything else that I can do to assist.

Best regards,
Kristen
 EXHIBIT 10

Compensation and Bonuses Report

Name: Kristen Pax

Date of Issue: 12/30/2018

Base Salary: $829,000.00

Performance Bonuses:
I. Bonus 1: $200,000 (for achieving loan portfolio targets)
II. Bonus 2: $200,000 (for exceeding loan portfolio targets)

As per your contract and performance-based incentives, your total compensation for the fiscal year is
$1,429,000.00. This amount takes into account your base salary of $829,000.00, bonuses of $400,000.00,
and stock options of $200,000.00.

Total Bonus Compensation: $600,000

Note: The bonuses have been awarded based on the performance of the loan portfolio, which has been
deemed as the most critical aspect of the Defendant's role within Truman, Stein, & Co.. In light of the
recent developments regarding the loan portfolio projections and the subsequent impact on the company's
financials, we would like to remind you of your fiduciary responsibilities and obligations as a CFO. The
Defendant played an instrumental role in exceeding the loan portfolio targets and contributing
significantly to the overall success of the company.

Kindest,

TRUMAN, STEIN, & CO.

Human Resources Department
 EXHIBIT 11

SECURITIES AND EXCHANGE COMMISSION

REPORT ON TRUMAN, STEIN, & CO.
1 February 2019

The Securities and Exchange Commission (SEC) conducted an investigation into

the financial reporting and practices of Truman, Stein, & Co. for the 2017 &
2018 years. Our findings are as follows:

Truman, Stein, & Co. made false and misleading statements to investors
regarding the health of its loan portfolio. This information was included in
the loan portfolio projections provided to investors and was material to
their investment decisions.

KRISTEN PAX was the Chief Financial Officer of Truman, Stein, & Co. at the
time the false and misleading statements were made. Our investigation has
revealed that the defendant had knowledge of the discrepancies in the loan
portfolio and participated in the scheme to defraud investors.

Truman, Stein, & Co.'s internal audit report showed a significant drop in the
value of the loan portfolio, which was not reported to investors. The
defendant was involved in the preparation of this report and had knowledge of
its contents.

The defendant received a bonus of $600,000, which was tied to the performance
of the loan portfolio. This compensation was not disclosed to investors and
raises questions about the defendant's motives in the scheme to defraud.

Based on our findings, we have concluded that Truman, Stein, & Co. and
Kristen Pax engaged in securities fraud in violation of federal securities
laws. We recommend enforcement action be taken against both Truman, Stein, &
Co. and the defendant.
 EXHIBIT 12

FEDERAL DEPOSIT INSURANCE CORPORATION

REPORT ON TRUMAN, STEIN, & CO. | 7 JANUARY 2019

The Federal Deposit Insurance Corporation (FDIC) conducted an examination of

Truman, Stein, & Co. and its loan portfolio practices. Our findings are as
follows:

Truman, Stein, & Co.'s loan portfolio was found to contain a high number of
risky loans, which posed a significant risk to the stability of the company.

Our examination revealed that Kristen Pax may have had knowledge of the risks
associated with the loan portfolio and made false and misleading statements
to investors regarding its health. Although, Kristen’s complete cooperation
should be noted.

Truman, Stein, & Co.'s internal reports showed a significant drop in the
value of the loan portfolio, which was not reported to investors. The
defendant was involved in the preparation of this report and had knowledge of
its contents.

Kristen Pax received a bonus of $600,000, which was tied to the performance
of the loan portfolio. This compensation raises questions about the
defendant's motives in the scheme to defraud.

Based on our findings, we have concluded that Truman, Stein, & Co. and
Kristen Pax may have engaged in practices that posed a risk to the stability
of the financial system and violated federal banking regulations.

We recommend further investigatory action be taken against both Truman,

Stein, & Co. and Kristen Pax.
 EXHIBIT 13

Bank Record #0066128353

Date: July 1, 2017

Transaction Type: Transfer
Description: Transfer from TRUMAN, STEIN, CO. to BAUTISTA, LUCA

Amount: $67,000
Portfolio Balance: $3,000,000
Notes: Payment for Dividends on Portfolio 001009339
 EXHIBIT 14
BANK RECORD #009973128312
Retrieved from PLO. 001009339
Date: August 15, 2017

Transaction Type: Transfer

Description: Transfer from 001009339 Truman, Stein, & Co. to MAIDEN FUND
Corp.

Amount: $1,000,000
Balance: $2,500,000
Notes: Unclear
 EXHIBIT 15

Bank Record #3263739221

Date: January 30, 2018

Transaction Type: Reimbursement

Description: Reimbursement from Truman, Stein, & Co. account.

PAID TO: PAX, K.

Amount: $200,000
Balance: $2,300,000
Notes: 2017 Travel Expenses
 EXHIBIT 16

PORTFOLIO SHARES IN PUBLICLY TRADED COMPANIES

BY THE DEFENDANT KRISTEN PAX AS OF 31 DECEMBER 2018

Company Name Number of Shares Share Price Total Value

Truman, Stein, & Co. 200,000 $32.50 $6,500,000

Tempur Sealy
150,000 $40 $6,000,000
International, INC.

Microsoft Corporation 75,000 $30 $2,250,000

OPEN AI Inc. 100,000 $60 $6,000,000

MAIDEN Corp. 325,000 $35 $11,375,000

TESLA 50,000 $70 $3,500,000

TRUIST Inc. 75,000 $45 $3,375,000

Barclays Limited 100,000 $50 $5,000,000

BECKMANS LLC 75,000 $40 $3,000,000

Miller & Sons Corp. 50,000 $60 $3,000,000

 EXHIBIT 17

Notes: EMAIL on 9 Jan 2019

Subject: Truman, Stein, & Co. SEC Investigation

TO: mdaniels@sec.gov
ATTN: SEC Probe Re: TSC

Mike,

I hope this email finds you well. I am writing to you in regards to the SEC
investigation you had me look into regarding Truman, Stein, & Co. and the
allegations of false and misleading statements made to investors.

After conducting a thorough analysis of the financial statements and other

relevant information, I have come to the conclusion that the statements made
by Truman, Stein, & Co. may not have been material to a reasonable investor.
While the statements in question may have contained errors or misstatements,
the overall impact on the stock price and the value of the investment appears
to be minimal.

It is important to note that the materiality of a statement is determined by

considering various factors, including the magnitude of the misstatement, the
timing of the statement, and the context in which it was made. In the case of
Truman, Stein, & CoThe misstatements appear to be limited in scope and
impact, and may not have influenced the investment decisions of reasonable
investors.

I hope this information is helpful to you as you finish your report. If you
have any further questions or concerns, please don't hesitate to reach out.

Best regards,

Alessandra Frank

Associate Counsel
Securities and Exchange Commission
 EXHIBIT 18

SEC Compliance Certificate

ISSUED JANUARY 2018

To Whom It May Concern,

We, Johnson Compliance Firm, Inc.., certify that during the time period of January 1, 2016 to December
31, 2018, Kristen Pax was employed as the Chief Financial Officer of Truman, Stein, & Co., a publicly
traded major banking institution headquartered in the United States.

As an SEC-authorized compliance firm, we have reviewed the financial reporting practices of Truman,
Stein, & Co., including those of Pax, to ensure compliance with SEC regulations. Based on our review of
documents Dating from 1 Jan 2016 to 1 Jan 2018, we find that Pax acted in good faith and with a high
degree of professionalism in the preparation and review of the financial reports and projections provided
to investors.

We believe that Pax conducted itself in accordance with SEC regulations and made every effort to ensure
the accuracy and reliability of the financial information provided to investors.

We hereby certify that the above information is true and accurate to the best of our knowledge and belief.

Johnson Compliance Firm, PLLC.

SEC Authorized Compliance Review Firm
 EXHIBIT 19

FDIC Regulatory Exam Report

Exam Date: 2 March 2018

Exam Team: Dr. Mitchell, Dr. Pearson, Mr. Miles
Examined Institution: Truman, Stein, & Co.

Introduction:
I. The Federal Deposit Insurance Corporation (FDIC) conducted an
examination of Truman, Stein, & Co. to assess the institution's
compliance with FDIC regulations. The purpose of this examination was
to evaluate the safety and soundness of the institution, as well as its
compliance with consumer protection and anti-money laundering laws.

Findings:
I. During the examination, the FDIC exam team found that Truman, Stein, &
Co. has implemented strong controls to ensure compliance with FDIC
regulations. However, the team also identified areas of concern
regarding the accuracy of the institution's consumer reporting
practices. The team found that there is a risk that the institution may
accidentally mislead consumers due to poor reporting practices.

Defendant's Role:
I. Acting CFO Kristen Pax was found to have played a significant role in
ensuring compliance with FDIC regulations during their tenure at
Truman, Stein, & Co. However, Pax was also actively overseeing the
consumer reporting practices of the institution contrary to the
institution’s claims. The FDIC exam team determined that Pax did not
actively engage in practices that would lead to consumer harm, but they
may have been aware of the risks associated with the poor reporting
practices.

Conclusion:
I. Overall, the FDIC examination found that Truman, Stein, & Co. has
implemented strong controls to ensure compliance with FDIC regulations,
but the institution is at risk of misleading consumers due to poor
reporting practices. Kristen Pax played a significant role in ensuring
compliance but was aware of the risks associated with the poor
reporting practices. The FDIC will continue to monitor the
institution's compliance with FDIC regulations and consumer protection
laws.
 EXHIBIT 20

2016 POSTING: Truman, Stein, & Co. seeking Chief Financial Officer (CFO)

Truman, Stein, & Co. is seeking an experienced Chief Financial Officer to join our team. The CFO will be
responsible for overseeing the financial operations of the company and ensuring compliance with
regulatory requirements.

Key Responsibilities:

I. Oversee the preparation of financial reports and portfolios to ensure accuracy and completeness
II. Ensure compliance with SEC and FDIC regulations
III. Develop and implement financial strategies to support the company's growth and profitability
goals
IV. Collaborate with other senior leaders to make informed business decisions
V. Evaluate and recommend improvements to financial processes and systems
VI. Manage relationships with external auditors and regulatory agencies

Requirements:

I. Bachelor's degree in finance, accounting, or a related field

II. Master's degree in business administration is preferred
III. 10+ years of experience in financial management, with a minimum of 5 years at a senior level
IV. Strong understanding of SEC and FDIC regulations
V. Excellent analytical and problem-solving skills
VI. Excellent communication and interpersonal skills
VII. Ability to work well in a fast-paced environment
VIII. Ability to lead and motivate a team

Note: The CFO will have oversight of the reports & portfolios but will not have direct supervision of the
team responsible for producing them.

Truman, Stein, & Co. offers a competitive salary and benefits package, as well as opportunities for growth
and advancement. If you are a results-driven and experienced financial leader, we encourage you to apply
for this exciting opportunity.
 EXHIBIT 21 - RESUME

Carson Simons
155 55th Street, NY, NY. | csimons@simonsconsulting.net

Objective:

To obtain a challenging and rewarding role as a financial expert, utilizing my skills and knowledge in
finance to contribute to the growth and success of a reputable organization.

Education:

● Master of Business Administration (MBA), Finance, New York University, 2001

● Bachelor of Science in Economics, Massachusetts Institute of Technology, 1999

Skills:
● Extensive knowledge of financial analysis, reporting, and forecasting.
● Strong ability to develop and implement financial strategies.
● Excellent communication, negotiation and leadership skills.
● Proficient in various financial software and tools such as Microsoft Excel, QuickBooks and SAP.
● Ability to analyze financial data and make strategic recommendations.

Work Experience:

Principal, Simons Financial Consulting, 2015-Present

● Analyzed financial data, trends and market conditions to create accurate financial forecasts.
● Developed and implemented financial strategies that resulted in improved financial performance.
● Managed the preparation of financial statements and reports, including balance sheets, income
statements and cash flow reports.
● Provided expert financial advice to the management team, improving decision-making and
contributing to the overall success of the organization.
● Conducted detailed financial analysis and created presentations for senior management, investors
and stakeholders.

Certifications:

CFA (Chartered Financial Analyst), 2005

FRM (Financial Risk Manager), 2006
CA (Chartered Accountant), 2002
 EXHIBIT 22 - RESUME

Dr. Louis Vanderbilt

665 Jameson Street, Manma, Delaware.
lv@expertfinance.org

Summary:
Highly motivated and experienced financial expert with a PhD in Finance. Skilled in financial analysis,
portfolio management, and risk assessment. Adept at creating and implementing innovative financial
strategies to meet business objectives and drive growth. Demonstrated ability to manage complex
financial projects and effectively communicate financial information to stakeholders. Committed to
ensuring the integrity of financial reporting and maintaining strict compliance with regulatory
requirements.

Education:
● PhD in Finance, Harvard University (2000)
○ Dissertation with Honors: "An Examination of Portfolio Diversification Strategies and
Their Effectiveness in Mitigating Risk"
● MBA in Finance, Yale University (1996)
● Bachelor in Business Administration, IE University (1990)

Work Experience:

Financial Advisor & Analyst, Vanderbilt Expert Finance Solutions (2000-Present)

● Conduct financial analysis and create reports for senior management on a variety of topics
including market trends, investment opportunities, and risk management
● Develop and implement financial models to support decision-making and forecasting
● Collaborate with cross-functional teams to identify and evaluate potential investments
● Ensure strict compliance with regulatory requirements and maintain the integrity of financial
reporting

Certifications:
● Chartered Financial Analyst (CFA), CFA Institute
● Financial Risk Manager (FRM), Global Association of Risk Professionals
● Chairman of the US National Expert Witness Association (NEWA)

Skills:
Financial Analysis, Portfolio Management, Risk Assessment, Financial Modeling, Investment Analysis,
Regulatory Compliance, Financial Reporting, Data Analysis, Project Management, Communication and
Presentation.
 EXHIBIT 23 - RESUME

Alex Rodriguez
arodriguez@charlesschwab.com

Objective: To secure a challenging and dynamic position as an accountant utilizing my skills and
experience to contribute to the success of the organization.

Education:

Bachelor of Science in Accounting, University of North Carolina at Chapel Hill, 1989

- Completed coursework in financial accounting, auditing, taxation, and cost accounting
- Relevant coursework: Financial Statement Analysis, Auditing Principles and Practices, Federal
Taxation

Work Experience:

Senior Accountant, Charles Schwab., New York (June 2009 - Present)

● Responsible for preparing and analyzing financial statements, reconciling accounts, and preparing
tax returns
● Assisted in the implementation of internal control procedures to ensure compliance with GAAP
and internal policies
● Provided support for budgeting and forecasting activities
● Collaborated with cross-functional teams to resolve complex accounting issues

SKILLS:
● Strong knowledge of GAAP and accounting principles
● Excellent analytical and problem-solving skills
● Proficient in Microsoft Excel and QuickBooks
● Strong communication and interpersonal skills
● Ability to work well in a team environment

Certifications:
- Certified Public Accountant (CPA), passed all sections (20XX)
 EXHIBIT 24

“Truman, Stein, & Co: A History of Financial Excellence”

August 2015

Truman, Stein, & Co. has a long and storied history as a leading financial institution in the United States.
Founded in the early 1900s, Truman, Stein, & Co. has grown from its humble roots as a small community
bank to become a major player in the banking industry. Today, Truman, Stein, & Co. is known for its
cutting-edge technology, its commitment to customer service, and its strong financial performance.

In recent years, Truman, Stein, & Co. has made significant investments in technology and innovation,
which has helped it to stay ahead of the curve in an ever-changing financial landscape. From its
state-of-the-art online banking platform to its innovative mobile app, Truman, Stein, & Co. is always
looking for new and better ways to serve its customers.

In addition to its technology investments, Truman, Stein, & Co. is also committed to delivering
outstanding customer service. The company has a team of highly trained and knowledgeable customer
service representatives who are available 24 hours a day, 7 days a week to assist customers with their
banking needs. Whether you need help with a deposit, a loan, or just have a question about your account,
Truman, Stein, & Co. is always there to help.

Despite its growth and success, Truman, Stein, & Co. has remained committed to its roots as a community
bank. The company is deeply involved in its local community, supporting local charities and other
organizations and working to improve the lives of its customers and neighbors.

In conclusion, Truman, Stein, & Co. is a financial institution with a long history of excellence. From its
cutting-edge technology to its commitment to customer service, Truman, Stein, & Co. has proven time
and time again that it is a leader in the banking industry. If you're looking for a bank that you can trust to
keep your finances secure and help you grow your wealth, Truman, Stein, & Co. is the right choice.
 EXHIBIT 25

Internal Audit Report: Year End 2018

Market Condition / Impact on Financial

Evidence Factor Performance

Reputation damage,
Discrepancies in loan
Regulatory investigations by SEC and FDIC potential legal penalties and
portfolio projections
fines

Financial loss for individual

Drop in stock price on December 31, 2018 Market conditions
investor

Financial loss for individual

Failure to meet promised interest rate Market conditions
investor

Total of $600,000 in bonuses and other

Employee compensation N/A
compensation received by the Defendant

Reputation damage,
Discrepancies in loan portfolio projections Internal audits potential legal penalties and
fines

Emails and other correspondence between the Evidence for the

Discrepancies in loan
Defendant and other executives regarding the individual's allegations of
portfolio projections
loan portfolio projections securities fraud

Note: The impact on financial performance may also be influenced by other factors such as investor
confidence, regulatory compliance, and broader economic conditions.
 EXHIBIT 26
From: CFO, Truman, Stein, & Co.
To: Truman, Stein, & Co. finance team
Subject: Loan Portfolio Projections
22 APRIL 2017

Dear Team,

I hope this email finds you well. As you are aware, we are in the process of preparing the quarterly and
annual financial reports for Truman, Stein, & Co.. A key component of these reports is the loan portfolio
projections, which will be reviewed by investors, regulatory agencies, and other stakeholders.

As the Chief Financial Officer, I am responsible for ensuring the accuracy and integrity of the financial
information we provide to our stakeholders. I am writing to you today to outline the process for creating
the loan portfolio projections and to provide guidance on what is expected from each member of the
finance team.

To create the loan portfolio projections, we will be using the latest data on loan origination, loan balances,
and loan performance. This information will be analyzed to determine the expected loan growth, loan
losses, and loan repayments over the next three to five years.

Each member of the finance team will be responsible for reviewing and verifying the loan data for their
respective areas of responsibility, and for providing updated loan projections for their respective loan
portfolios. The loan projections should be based on a detailed analysis of loan performance and should
take into account any known trends and market conditions.

Once the loan portfolio projections have been finalized, we will review and consolidate the data to ensure
that the projections are consistent and accurate. We will also perform stress tests on the projections to
ensure that they are robust and reliable.

Please send me your completed loan portfolio projections by the end of the week. I will review each
submission and provide feedback as necessary.

If you have any questions or concerns, please do not hesitate to reach out to me.

Best regards,

Kristen
 EXHIBIT 27

QUARTERLY STOCK PROJECTIONS REPORT

Truman, Stein, & Co.
02/20/2017

Prepared per request of Kristen Pax.

Quarter Year Stock Price (per share) Loan Portfolio Projection

Q1 2017 $100 Positive

Q2 2017 $110 Positive

Q3 2017 $120 Positive

Q4 2017 $130 Positive

Q1 2018 $126 Negative

Q2 2018 $126 Neutral

Q3 2018 $110 Negative

Q4 2018 $95 Negative

 FEDERAL BUREAU OF INVESTIGATION
WIRETAP TRANSCRIPT
EXHIBIT 37

Notes: This wiretap was obtained legally through an order by the US DOJ. Obtained 11 FEB 2019

11 February 2019 13:10:22

PHONE CALL INITIATED
212-665-6891 -> 212-777-1001

PAX: Hey Jeff

HARPER: Kristen, what is going on

PAX: I thought that we said that this wouldn’t come up. Now I have the SEC
and the FDIC on my back and it’s freaking the hell out of me.

HARPER: Well, I thought you would do a better job at keeping this tame.

PAX: Well, what do we do now?

HARPER: Just stay silent. You know I have to fire you (pause) but I will
(unintelligible), trust me. It’s just for the press.

PAX: Thanks Jeff.

HARPER: Stay away from the main building. There are reporters everywhere.

PAX: Will do.

HARPER: Good luck. I have a meeting with our attorney today. I suggest you
get one too. I hear Bautista is pissed. I wouldn’t be surprised if he came
after you.

PAX: That’s the least of my worries, do you have my account (unintelligible)

HARPER: Yes. You’re Covered. Got to go.

END OF TRANSMISSION
11 FEB 2019 13:12:58
JANUARY 5, 2016

Truman, Stein & Co, a leading bank in the finance industry, has announced the appointment of Kristen
Pax as their new Chief Financial Officer. Pax brings a wealth of experience in the financial sector, having
led highly successful financial companies.

With over 20 years of experience in finance, Pax has a proven track record of success in driving growth
and maximizing profits for their clients. Their expertise in strategic planning, risk management, and
investment banking has been instrumental in the rapid expansion of Maiden Fund, which has grown to
become one of the largest financial funds in the world.

Pax holds a Bachelor's degree in Business Administration and a Master's degree in Finance, and is a
respected thought leader in the industry. They are known for her innovative approach to financial
management and her ability to lead teams to achieve their goals.

Truman, Stein & Co CEO, Jeffrey Harper, expressed his excitement about the appointment of Pax, stating
that "Their experience and skills will be a valuable asset to our team. We are confident that under their
leadership, Truman, Stein & Co will continue to thrive and deliver exceptional results for our clients."

Pax will be taking over as CFO effective immediately, and will be responsible for overseeing the bank's
financial operations and driving growth strategies. The appointment of Pax is a major step forward for
Truman, Stein & Co, and is a clear indication of their commitment to providing the highest level of
financial services to their clients.

EXHIBIT 36
 RESUME
Name: Kristen Pax
Title: Chief Financial Officer (CFO)

Objective:
To continue a successful career in the finance and banking industry, utilizing my extensive experience in
financial operations, strategic planning, and financial reporting.

Professional Summary:
I am a seasoned finance professional with a passion for financial operations and strategic planning. I have
served as Chief Financial Officer at Truman, Stein, & Co., where I was responsible for overseeing
financial operations and strategy, including financial reporting and projections for investors. I have
extensive experience in the banking industry, with a proven track record of success in financial analysis
and management.

Experience:
➔ Chief Financial Officer, Truman, Stein, & Co. (2015-2018)
◆ Oversaw financial operations and strategy, including financial reporting and projections
for investors.
◆ Worked closely with other executives to develop and execute strategic plans to achieve
the company's goals.
◆ Developed and implemented financial policies and procedures to ensure accuracy and
reliability of financial reporting.
◆ Managed financial risk and ensured compliance with regulatory requirements.
➔ Founder, Maiden Fund (2000-2016)
◆ Oversaw financial operations and strategy for one of the largest financial funds in the
industry.
◆ Developed and implemented financial policies and procedures to ensure accuracy and
reliability of financial reporting.
◆ Managed financial risk and ensured compliance with regulatory requirements.
◆ Led financial due diligence for potential investments and acquisitions.
◆ Successfully managed the fund through various market cycles, delivering strong returns
for investors.

Education:
● Bachelor of Science in Finance, University of California, Los Angeles (UCLA)
○ President, Finance Club
● Masters in Business Administration, Rice University, Texas.
○ Graduated with honors
○ Completed coursework in financial analysis, financial markets, and investment
management

Skills: Financial analysis and reporting, Strategic planning, Risk management, Regulatory compliance,
Team leadership and management
 TORI GOLDMAN
Executive Vice President

Objective:
To continue a successful career in the finance industry, utilizing my extensive experience in strategic
planning, team management, and customer service.

Professional Summary:
I am a seasoned finance professional with a passion for strategic planning, team management, and
customer service. I have served as a senior executive at Truman, Stein, & Co., where I worked closely
with the Chief Financial Officer (CFO) to develop and execute strategic plans to achieve the company's
goals. I have extensive experience in the banking industry, with a proven track record of success in team
leadership and management.

Experience:

Senior Executive Vice President, Finance, Truman, Stein, & Co. (2005-Present)
● Worked closely with the Chief Financial Officer to develop and execute strategic plans to achieve
the company's goals.
● Led cross-functional teams to deliver outstanding customer service and drive business growth.
● Managed financial risk and ensured compliance with regulatory requirements.
● Developed and implemented financial policies and procedures to ensure accuracy and reliability
of financial reporting.

Junior Analyst, Global Finance Corp. (1996-2005)

● Conducted financial analysis for potential investments and acquisitions.
● Assisted senior executives with due diligence on potential investments and acquisitions.
● Prepared financial reports and projections for senior management.

Education:
● Bachelor’s Degree in Economics, University of Central Florida
● Master of Business Administration, University of Virginia (1996)
○ Completed coursework in financial analysis, strategic planning, team management, and
customer service.

Skills: Strategic planning, Team leadership and management, Customer service, Financial analysis,
Regulatory compliance
 CLEO ANDERSON
Law Enforcement Officer

Objective:
To continue a successful career in law enforcement, utilizing my extensive experience in investigating
securities and financial fraud cases.

Professional Summary:
I am an FBI Special Agent with over 10 years of experience investigating securities and financial fraud
cases. I was assigned to the Major Financial Crimes Division in early 2019 and led investigations into the
allegations of securities fraud. I have extensive experience in conducting interviews, gathering evidence,
and analyzing financial data to build strong cases against individuals engaged in fraudulent activities.

Experience:

Special Agent | Federal Bureau of Investigation (2009-Present)

● Investigate securities and financial fraud cases, including those involving Ponzi schemes, insider
trading, and market manipulation.
● Conduct interviews with witnesses and suspects to gather evidence and build a strong case.
● Analyze financial data to identify fraudulent activities and patterns.
● Work closely with other law enforcement agencies, including the SEC and FDIC, to gather
additional information and evidence relevant to cases.

Forensics Officer | New York State Prosecutor’s Office (2001-2008)

● Investigate securities and financial fraud cases, including those involving Ponzi schemes, insider
trading, and market manipulation.
● Conduct interviews with witnesses and suspects to gather evidence and build a strong case.
● Analyze financial data to identify fraudulent activities and patterns.
● Work closely with other law enforcement agencies, including the SEC and FDIC, to gather
additional information and evidence relevant to cases.

Education:
● Bachelor of Science in Criminal Justice, University of Maryland
○ Completed coursework in criminal law, criminology, and investigation techniques.
● Certified in Financial Forensics, Federal Bureau of Investigation (Expires 2024)

Skills: Investigative techniques, Financial analysis, Interviewing and interrogation, Evidence collection
and analysis, Regulatory compliance
 Truman, Stein, and Co.
Financial Stress Test Report

Date: MAY 1, 2017

Time: 16:23:55

Purpose:
To evaluate the accuracy and reliability of the loan portfolio projections provided by Truman, Stein, &
Co.

Procedure:
The finance team conducted a stress test on the loan portfolio projections provided by Truman, Stein, &
Co. The test involved a review of the projections for each loan number, loan amount, projected interest
rate, and projected loan repayment date. The projections were then compared against historical loan
performance data and current market conditions to determine the accuracy and reliability of the
projections.

Findings:
The stress test revealed generally positive results, with the possibility of errors or issues with the loan
portfolio projections provided in the projected interest earnings. The amount of $67,500 may not
accurately reflect the actual earnings that the loan portfolio may generate. The projections are based on
current interest rates and loan repayment timelines, which may change based on actual loan performance
and market conditions.

Recommendation:
The finance team recommends that Truman, Stein, & Co. conduct a comprehensive review of the loan
portfolio projections to ensure their accuracy and reliability. This may involve a review of historical loan
performance data, as well as an analysis of current market conditions and trends. Any discrepancies or
errors in the projections should be promptly addressed to avoid potential negative impacts on the
company's financial performance and investor confidence.

Sent by:
James Stugard, Finance Intern.

Sent to:
Finance Team RE: Tori Goldman
INTERNAL AUDIT REPORT
Year 2018

Truman, Stein, & Co.

Report Date: 01/01/2019
Report Prepared By: Charles Schwab Internal Services

Executive Summary:
The purpose of this internal audit report is to review and assess the accuracy and
reliability of Truman, Stein, & Co.'s financial reporting practices and internal
control processes related to its loan portfolio operations. The report is based on an
examination of selected transactions, records, and processes for the period of
January 1, 2018 to December 31, 2018.

Key Findings:
01. Improved internal controls over the loan portfolio operations: The audit found
that Truman, Stein, & Co. had implemented formal policies and procedures to
oversee the loan portfolio activities and monitor the accuracy of loan
information and data. This has resulted in a decreased risk of inaccuracies in
loan information and data, which could negatively impact the financial
reporting and performance of the company.
02. Better documentation and recordkeeping: The audit found that Truman, Stein, &
Co. had improved documentation and recordkeeping practices, which have led to
clearer evidence of loan origination, processing, and repayment. This has made
it easier to accurately assess the performance and risk of the loan portfolio
and has decreased the risk of loan fraud.
03. Subtle errors in loan portfolio projections: The audit found that Truman,
Stein, & Co. had provided investors with loan portfolio projections that
contained minor and subtle errors, which resulted in a slight overstatement of
the expected performance of the loan portfolio and a slight understatement of
the risk of loan defaults. These errors were due to technical issues in the
projection software and were likely not intentional.

Recommendations:
A. Maintain and continually improve the loan portfolio management policy and
procedure to ensure the accuracy of loan information and data and to monitor
the performance of the loan portfolio.
B. Further establish and enhance the documentation and recordkeeping process to
ensure that loan origination, processing, and repayment information is
accurately recorded and maintained.
C. Refrain from providing misleading loan portfolio projections to investors and
ensure that all financial reporting and projections are based on accurate and
reliable data and are supported by adequate evidence and documentation.

Conclusion:

The internal audit of Truman, Stein, & Co.'s loan portfolio operations has revealed
some minor issues related to loan portfolio projections, but also significant
improvements related to internal controls, documentation and recordkeeping, and
financial reporting. The recommendations outlined in this report, if implemented,
will continue to help improve the accuracy and reliability of financial reporting and
reduce the risk of loan fraud and other financial irregularities.

Notes: Reports of severe losses from account holders on 31 December. We will refer to
the SEC & FDIC for further investigation.
 NYSE Statement of Maiden Corp

We hereby submit for registration, under the Securities Act of 1933, a statement
relating to the proposed offering of Maiden Corp.

General Information
Maiden Corp was founded in 2000 by Kristen Pax, a well-respected and experienced
finance professional in the banking industry. Maiden Corp is a holding company that
invests in a range of businesses, including but not limited to the finance and
technology industries. As of December 31, 2006, Maiden Corp had total assets of $1.5
billion and total liabilities of $750 million. Maiden Corp is registered in the State
of Delaware and has its principal executive office located at 882 South Street,
Wilmington, DE.

Prospectus Summary
The following is a brief summary of some of the key information contained in this
registration statement.

Securities Offered: Common Stock

Proposed Maximum Aggregate Offering Price: $500 million

Use of Proceeds: To fund Maiden Corp's investments in various businesses and to repay
outstanding debt.

Risk Factors: Maiden Corp's business and operations are subject to various risks and
uncertainties, including market conditions, regulatory changes, and the performance
of its portfolio companies.

Management: Kristen Pax is the founder and majority shareholder of Maiden Corp, and
serves as its CEO and Chair of the Board of Directors

Conclusion: Maiden Corp is excited to offer its common stock to the public and
believes that this offering represents an opportunity for investors to invest in a
dynamic and growing holding company. Maiden Corp remains committed to transparency
and accountability, and will take any necessary actions to address any wrongdoing.

SUBMITTED THIS DAY, JUNE 12 2007.

 TRUMAN STEIN & CO
Internal Finance Department

Notes: Truman, Stein, & Co.'s internal finance team's report for Q2 2017

Loan Portfolio Growth Projection for Q2 2017: 12%

Deposit Margin Growth Projection for Q2 2017: 8%
Loan Interest Margin Growth Projection for Q2 2017: 7%

INTERNAL USE ONLY. NOT TO BE DISCLOSED PUBLICLY.

- Tori Goldman
 TRUMAN STEIN & CO
Internal Finance Department
Notes: Truman, Stein, & Co.'s internal finance team's report for Q3 2017

Loan Portfolio Growth Projection for Q3 2017: 15%

Deposit Margin Growth Projection for Q3 2017: 9%
Loan Interest Margin Growth Projection for Q3 2017: 8%

INTERNAL USE ONLY. NOT TO BE DISCLOSED PUBLICLY.

- Tori Goldman
 TRUMAN STEIN & CO
Internal Finance Department
Notes: Truman, Stein, & Co.'s internal finance team's growth report for Q4 2017

Loan Portfolio Growth Projection for Q4 2017: 20%

Deposit Margin Growth Projection for Q4 2017: 12%
Loan Interest Margin Growth Projection for Q4 2017: 11%

INTERNAL USE ONLY. NOT TO BE DISCLOSED PUBLICLY.

- Tori Goldman
 THE NEW YORK STOCK EXCHANGE
OFFICE OF RECORDS

PROVIDED: Report on the stock prices of Truman, Stein & Co. and similar companies in the same sector
(FIN) on December 31, 2018:

Company Name Ticker Price per Share % Change

Truman, Stein & Co. TSC $32.50 -50.00%

First National Bank FNB $35.10 -5.00%

Wall Street Financial Group WSFG $29.80 -3.00%

National City Bank NCB $37.90 -1.50%

American Financial Corporation AFC $42.20 +3.50%

MAIDEN CORPORATION MDN $35.00 +24.00%

As shown in the report, Truman, Stein & Co.'s stock price experienced a significant drop of ~50% on
December 31, 2018, while other companies in the same category experienced much smaller decreases in
their stock prices.

It is worth noting that the drop in Truman, Stein & Co.'s stock price on December 31, 2018, occurred
amidst a broader market downturn. However, the severity of the drop in comparison to other stocks in
the same category suggests that there may have been additional factors at play.