SEC v. WORLD TREE FINANCIAL, LLC; WESLEY KYLE PERKINS; and PRISCILLA GILMORE PERKINS, No. 6:18-cv-01229, Western District of Louisiana (Sept. 20, 2018) — Complaint

COMPLAINT
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
LAFAYETTE DIVISION

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
WORLD TREE FINANCIAL, LLC,
WESLEY KYLE PERKINS, and
PRISCILLA GILMORE PERKINS,
Defendants.

 Case No. 18-cv-1229

JUDGE

MAGISTRATE JUDGE

COMPLAINT

Plaintiff Securities and Exchange Commission (“SEC”) alleges:
SUMMARY OF THE ACTION
1. This case is about a “cherry-picking” scheme carried out by an
investment adviser and its owner.  Investment advisers often trade stocks and other
securities for their clients on a daily basis, and “cherry-picking” happens when the
adviser gives himself or his favored clients the winning trades for that day, and
allocates the losing trades to other clients (the “disfavored” clients).  That is what
defendant World Tree Financial LLC (“World Tree”), and one of its owners,
defendant Wesley Kyle Perkins (“Perkins”), did.  They allocated “cherry-picked”
winning trades to Perkins’ accounts and to accounts held by some clients, while
allocating losing trades to the accounts held by a disfavored client.  In doing so, they
breached the fiduciary duties they owed their clients – Perkins took profits for
himself and others, while at the same time causing substantial losses for the
disfavored client.  Through this scheme, World Tree and Perkins misled the clients

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who received the better trades into thinking World Tree and Perkins were better at
managing their money than they really were.
2. Perkins was World Tree’s chief executive officer and chief investment
officer, and was responsible for all of the firm’s trading.  In those roles, he was able
to disproportionately allocate profitable securities trades to accounts that he and
defendant Priscilla Gilmore Perkins (“Gilmore”) owned and controlled, and to other
accounts.  Gilmore is Perkins’ wife and World Tree’s chief compliance officer.  At
the same time, Perkins saddled two disfavored accounts, held by one client, with a
disproportionate share of the firm’s unprofitable trades.  The brokerage firm handling
the trading for World Tree terminated its relationship with World Tree because it
suspected the firm was engaging in cherry-picking.
3. The defendants also misrepresented how World Tree was trading
securities for its clients.  The firm’s brochures and other disclosures claimed the
trades were being fairly and equitably allocated among the client accounts.  The firm
also claimed that Perkins and Gilmore were not trading in the same securities as
World Tree’s clients.  These claims were false —Perkins was cherry-picking trades,
and he and Gilmore were trading in the same securities as their clients.
4. By engaging in this cherry-picking scheme, and through their
misrepresentations to their advisory clients, defendants World Tree and Perkins
violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and
Rule 10b-5(a) and (c) thereunder;  Section 17(a)(1) of the Securities Act  of 1933
(“Securities Act”); and Sections 206(1) and (2) of the Investment Advisers Act of
1940 (“Advisers Act”).  Also, defendants World Tree, Perkins and Gilmore violated
Section 10(b) of the Exchange Act and Rule 10b-5(b) thereunder and Section 17(a)(2)
of the Securities Act; and defendant Gilmore aided and abetted defendant World
Tree’s violations of the Advisers Act.  The SEC seeks permanent injunctions,
disgorgement with prejudgment interest, and civil penalties against all three
defendants.

COMPLAINT
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JURISDICTION AND VENUE
5. The Court has jurisdiction over this action pursuant to Sections 20(b),
20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§
77t(b), 77t(d)(1) & 77v(a), Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of the
Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1),
78u(d)(3)(A), 78u(e) & 78aa(a), and Sections 209(d), 209 (e)(1) and 214 of the
Investment Advisers Act of 1940 (“Advisers Act”), 15 U.S.C. §§ 80b-9(d), 80b-
9(3)(1) & 90b-14.
6. Defendants have, directly or indirectly, made use of the means or
instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange in connection with the transactions, acts, practices and courses of
business alleged in this complaint.
7. Venue is proper in this district pursuant to Section 22(a) of the Securities
Act, 15 U.S.C. § 77v(a), and Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a)
because certain of the transactions, acts, practices and courses of conduct constituting
violations of the federal securities laws occurred within this district.  In addition,
venue is proper in this district because defendants Perkins and Gilmore reside in this
judicial district, and defendant World Tree has its principal place of business in this
judicial district.
DEFENDANTS
8. Defendant World Tree Financial, LLC is a Louisiana corporation with its
principal place of business in Lafayette, Louisiana.  World Tree was an SEC-
registered investment adviser until June 15, 2012, when it withdrew its SEC
registration.  World Tree is currently registered as an investment adviser with the
State of Louisiana.
9. As of March 2018, World Tree had assets under management of over
$54 million and 161 advisory clients, all of whom are individuals.
10. Defendant Wesley Kyle Perkins is a resident of Lafayette, Louisiana.

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He co-founded World Tree in 2009, and has been the firm’s 60% owner, chief
executive officer, and chief investment officer since World Tree’s inception.  Perkins
holds Series 6, 7, and 66 securities licenses.  Perkins married co-defendant Priscilla
Gilmore Perkins in 2017.
11. Defendant Priscilla Gilmore Perkins is a resident of Lafayette,
Louisiana.  After co-founding World Tree with Perkins in 2009, Gilmore has been the
firm’s 40% owner, chief financial officer, chief compliance officer, and chief
operating officer.  Gilmore holds Series 6, 7 and 66 securities licenses.
FACTS
A. World Tree’s Formation and Operation
12. In 2009, Perkins and Gilmore left a subsidiary of a global financial
services firm, where they had both worked as financial advisers, and co-founded
World Tree.
13. At all relevant times, Perkins has owned 60% of World Tree and
Gilmore has owned the remaining 40% of the firm.
14. World Tree’s advisory clients are individual retail investors.
15. The majority of World Tree’s advisory clients are not high net worth
individuals.
16. For its investment advice, World Tree charges clients an advisory fee
that ranges between 0.5% to 1.5% of the client’s assets under management.
17. From March 2011 through September 2015, World Tree managed
between approximately $40 million and $70 million in client assets.
18. World Tree assigned each of its clients one of five “investment models”
based on the size of the client’s account.
19. Most of World Tree’s clients bought from among the same group of
individual securities, and held between two and ten different stocks in their respective
accounts at one time, depending on the size of their account.
20. Approximately 93% of World Tree’s clients’ investments involved the

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same securities between March 2011 and September 2015.
21. Notwithstanding World Tree’s five “investment models,” it utilized the
same basic trading strategy across the majority of its client accounts.
22. At all relevant times, Perkins and Gilmore have   jointly controlled World
Tree.
23. As World Tree’s chief investment officer, Perkins was solely responsible
for managing all the securities trading, including allocating trades placed through the
firm’s omnibus account to clients.
24. As World Tree’s chief compliance officer, chief financial officer and
chief operating officer, Gilmore ran World Tree’s back office operations and
supervised all aspects of the firm’s compliance program.
B. Perkins’  and World Tree’s Fraudulent Cherry-Picking Scheme
1. Trading in Client Accounts
25. World Tree manages all of its clients’ assets on a discretionary basis,
meaning it has authorization to trade securities on behalf of its clients.
26. Perkins was the only person at World Tree with the authority to make
trades and determine allocations.
27. From December 2009 to October 2015, World Tree traded through the
brokerage platform of a registered broker-dealer (“Broker”).  This Broker also acted
as the custodian for World Tree’s client accounts, meaning that a third-party held the
securities on the clients’ behalf.
28. World Tree generally traded for its clients through an omnibus trading
account held at the Broker and later allocated the purchases to its individual clients’
accounts, generally after the market closed.
29. In general, an omnibus trading account allows an investment adviser to
buy and sell securities on behalf of multiple clients simultaneously, without
identifying to the broker in advance the specific accounts for which a trade is
intended.

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30. As an example, if an adviser separately purchases the same security for
several clients on the same day, the adviser might obtain different prices on each
transaction as a result of normal market fluctuation.  Rather than placing individual
orders in each client account, the adviser can place an aggregated order, or “block
trade,” in the omnibus account and subsequently allocate the trade among multiple
accounts using an average price.  When used properly, an adviser will fairly and
equitably allocate the block trade among client accounts, ensuring that no account
receives preferential treatment over another.
2. The Cherry-Picking
31. From at least March 2011 through September 2015, when World Tree
traded through the Broker’s platform, World Tree and Perkins misused the omnibus
account to engage in a fraudulent scheme to defraud clients by cherry-picking.
32. In fact, in April 2015, the Broker internally determined, based on a
sampling analysis, that when trading in the same security, accounts held by World
Tree, Perkins and Gilmore performed substantially better than their clients’ accounts.
33. The Broker then requested that World Tree provide materials showing
how the firm was allocating trades to client accounts and World Tree and its
principals’ accounts.  Because World Tree did not produce the requested materials,
the Broker terminated its relationship with World Tree based on its suspicions of
cherry-picking in September 2015.
34. From March 2011 to September 2015, World Tree traded equities for
about 277 client accounts and accounts held by Perkins, Gilmore and/or entities they
owned or controlled.
35. During this period, World Tree and Perkins allocated favorable trades to
nine accounts held by Perkins, Gilmore and/or entities they owned or controlled, and
to a lesser degree, the World Tree client accounts (collectively, the “Favored
Accounts”) – except, however, for two client accounts that did not receive an
equitable allocation of favorable trades.

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36. At the same time, World Tree and Perkins allocated unfavorable trades
to those two remaining client accounts (the “Disfavored Client Accounts”), which
were owned by one client, his wife, and the client’s business entity (the “Disfavored
Client”).
37. Specifically, from March 2011 to September 2015, Perkins allocated:  (i)
a disproportionately high number of profitable trades to the nine favored Perkins
accounts; (ii) a disproportionately high number of the most unprofitable trades to the
Disfavored Client Accounts; (iii) a disproportionately low number of the most
unprofitable trades to the Perkins accounts; and (iv) a disproportionately low number
of the profitable trades to the Disfavored Client Accounts.
38. The Disfavored Client Accounts were World Tree’s largest accounts
between 2011 and 2015, totaling up to $20 million in assets at various points in time.
39. World Tree’s cherry-picking was enabled by the fact that the Disfavored
Client Accounts were large enough to absorb incremental, though steady, trading
losses without arousing client suspicion that the losses were due to fraud.
40. Perkins executed the cherry-picking scheme by trading in the firm’s
omnibus account and then delaying allocation of trades to a specific account until he
had an opportunity to observe the security’s intra-day performance.
41. Typically, after purchasing a block of securities through World Tree’s
omnibus trading account, Perkins delayed allocating the purchase until after the
market closed.
42. If the relevant security’s price closed higher, Perkins generally allocated
the trade to the Favored Accounts, thereby receiving an unrealized gain.
43. Conversely, when the security’s price went down over the course of the
day, Perkins generally allocated the purchase to the Disfavored Accounts, leaving
those accounts with unrealized first-day losses.
44. In some instances, Perkins purchased and sold the securities on the same
day, thus locking in a realized gain or loss, and then disproportionately allocated

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favorable trades to the Favored Accounts, and unfavorable trades to the Disfavored
Accounts.
45. Perkins also cherry-picked when World Tree bought and sold securities
around corporate earnings announcements.
46. To illustrate, from March 2011 through September 2015, about 17% of
World Tree’s trade allocations occurred on the same day that the companies whose
securities were being allocated had issued, after market close, earnings
announcements.
47. On those days, Perkins often waited until after the release of a
company’s post-close earnings report before allocating trades in that company’s
securities.
48. By delaying allocations, Perkins could take into account after-hours
price movements relating to the earnings announcement.
49. On repeated instances, when an earnings announcement had a negative
post-market close impact on the price of the company’s securities, Perkins allocated
the entire block of unprofitable trades to the Disfavored Client Accounts, even though
the Disfavored Client Accounts and many other client accounts who did not receive
any of the unprofitable trades had been assigned the same investment model (called
the “Large Cap” strategy) by World Tree and Perkins.
50. The cherry-picking benefitted Perkins and Gilmore because Perkins
cherry-picked the favorable trades for the accounts they held and controlled.
51. In addition, the cherry-picking not only harmed the Disfavored Client,
whose two accounts received the poor trades, but also made it appear to the other
clients as if World Tree and Perkins were better at trading securities than they really
were.
52. From March 2011 through September 2015, Perkins allocated about
1,865 trades to the nine favored accounts held by the Perkins, Gilmore or their
businesses.  Those trades earned a positive return of about 2.2%  –   as measured by

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actual returns in the case of day trades, and for other trades, the first-day returns
showing the loss or gain between trade price and the closing share price, and where
Perkins and World Tree traded around earnings announcements, the opening price on
the following trading day – on about $16.1 million in notional value invested.
53. During that same period, Perkins allocated about 22,220 trades to client
accounts that were not the two Disfavored Client Accounts.  Those trades earned a
positive return of about 1.0% during that time, as measured by actual returns in the
case of day trades, and for other trades, the first-day returns showing the loss or gain
between trade price and the closing share price, and for trades around earnings
announcements, the opening price on the following trading day.
54. In contrast, during that same period, the trades allocated to the
Disfavored Client Accounts had negative returns.  Perkins allocated about 2,239
trades to these   accounts during this time.  Those trades earned a negative return of
about -1.05% on the approximately $424 million in notional value invested, as
measured by actual returns in the case of day trades, and for other trades, the first-day
returns showing the loss or gain between trade price and the closing share price, and
for trades around earnings announcements, the opening price on the following trading
day.  These trades resulted in first day losses and realized (in the case of a few day
trades) losses of approximately $4.46 million.
55. From March 2011 through September 2015, trading in all accounts
generated an average return of negative return of about -0 .23% on an approximately
$695 million in notional value invested, as measured by actual returns in the case of
day trades, and for other trades, the first-day returns showing the loss or gain between
trade price and the closing share price, and for trades around earnings
announcements, the opening price on the following trading day.
56. According to a statistical analysis of these different returns, there is a
less than 1 in a million chance that the disparate returns between the Favored
Principal Accounts and Disfavored Accounts – an approximate difference of about

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3.25% – are the product of mere random chance.
57. According to a statistical analysis of these different returns, there is a
less than 1 in a million chance that the disparate returns between the Disfavored
Accounts and the other client accounts – an approximate difference of about 2.0% –
are the product of mere random chance.
58. In addition, during this same period from March 2011 to September
2015, Perkins allocated 48 of World Tree’s 50 worst performing trades (as measured
by first-day returns) to the Disfavored Client Accounts.  Those accounts, in turn,
sustained about 92% of the losses associated with those 50 worst-performing trades.
59. Similarly, Perkins allowed the Favored Accounts to participate in all of
World Tree’s 50 best performing trades (as measured by first-day returns) during that
same period March 2011 to September 2015.  In contrast, Perkins allocated only six
of those trades to the Disfavored Client Accounts during that time.
60. As one example, in or about February 2014, Perkins allocated a poor-
performing trade in a social media company to one of the two Disfavored Client
Accounts.  The trade was allocated to the Disfavored Client Account as follows:
(a) At 12:28 p.m. on February 5, 2014, Perkins, on behalf of World
Tree, purchased 5,000 shares of the social media company in the omnibus account at
$66.39 per share.
(b) At 4:29 p.m., in a press release after the market closed, the social
media company announced lower than expected financial results.
(c) Shortly thereafter at 5:40 p.m., Perkins allocated all of these
shares to the Disfavored Client Account at $66.39 per share.
(d) The Disfavored Client Account was invested in the Large Cap
strategy.
(e) No shares were allocated to any other clients who were also
invested in the Large Cap strategy.
(f) The next day, the stock price for the social media company

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opened at $50.61, a 24% decrease from the allocation price from the previous day.
61. As another example, in or about July 2014, Perkins allocated a positively
performing trade in the same social media company to the Favored Accounts:
(a) At 3:48 p.m. on July 29, 2014, Perkins, on behalf of World Tree,
purchased 3,000 shares of the social media company in the omnibus account at
$38.569 per share.
(b) At 4:15 p.m., in a press release after the market closed, the social
media company announced higher than expected financial results.
(c) Shortly thereafter, at    6:15 p.m., Perkins allocated the purchased
shares at $38.569 per share to approximately 23 Favored Accounts, including the
Favored Principal Accounts.
(d) The next day, the social media company opened at $47.01, a 22%
increase from the allocation price.
(e) None of these shares were allocated to the Disfavored Client
Accounts.
62. It would have been important to World Tree’s advisory clients’ decisions
on whether to place their assets under World Tree’s management to know that trades
were not being allocated fairly and equitably.
C. World Tree, Gilmore and Perkins Made False and Misleading Statements
to Clients in the Firm’s Brochures
63. Between March 2011 and February 2015, World Tree made false and
misleading statements in its Forms ADV, Part 2A.
64. A Form ADV is a   document that is filed with the SEC by investment
advisers registered with the SEC.  The filing consists of two parts—Part 1 contains
“check-the-box” information about the firm, and Part 2 is a brochure, in narrative
form, which describes key information about the firm, including the types of services
the firm provides.   An investment adviser’s Form ADV must be updated annually,
and made available to firm clients.

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65. While it was registered with the SEC, World Tree was required to
deliver its Form ADV, Part 2A brochure to clients at the time it entered into an
advisory contract with them, and to provide clients annually with World Tree’s
current brochure or a summary of any material changes to its existing brochure.
66. While it was registered with the SEC, World Tree’s Forms ADV, Part
2A were available online through the SEC’s website.
67. Once World Tree became a Louisiana state-registered investment
adviser in June 2012, it filed its Forms ADV annually with the Investment Adviser
Registration Depository; those filings were publicly available on the internet.
68. Since founding the firm, Perkins and Gilmore each personally provided
World Tree’s Form ADV brochure to their advisory clients on regular occasions.
69. Before providing them to World Tree’s clients, Gilmore and Perkins
both reviewed drafts of the Forms ADV, made changes when necessary, and
authorized the final version for filing and distribution to World Tree’s clients.
70. Either Perkins or Gilmore signed every World Tree Form ADV from
2011 to 2015.  Each had ultimate control and authority over the contents of the form.
71. World Tree’s Forms ADV filed on March 15, 2011, February 7, 2012,
June 5, 2012, March 25, 2013, March 18, 2014, February 9, 2015, August 7, 2015,
and September 29, 2015 stated that: (i) “World Tree allocates investment
opportunities among its clients on a fair and equitable basis”; (ii) “World Tree may
... combine or ‘batch’ such orders ... to allocate equitably among World Tree’s
clients”; and (iii) “To the extent that World Tree determines to aggregate client orders
... World Tree shall generally do so in accordance with applicable rules promulgated
under the Advisers Act and non-action guidance provided by the staff of the U.S.
Securities and Exchange Commission.”
72. Given the cherry-picking scheme alleged above, each of these statements
was false.  By cherry-picking winning trades to the Favored Accounts and losing
trades to the Disfavored Client Accounts, World Tree did not allocate trades fairly or

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equitably, and did not do so in accordance with the Advisers Act or guidance
provided by the SEC.
73. It would have been important to World Tree’s advisory clients to know
that, contrary to the representations made to clients, World Tree was not allocating
trades fairly or equitably, or in a way that was consistent with the law.
74. World Tree’s Forms ADV filed on March 15, 2011, February 7, 2012,
June 5, 2012, March 25, 2013, March 18, 2014, and February 9, 2015 also stated that:
(i) “none of World Tree’s Access Persons [Perkins and Gilmore] may effect for
themselves or for their immediate family (i.e., spouse, minor children, and adults
living in the same household as the Access Person) any transactions in a security
which is being actively purchased or sold, or is being considered for the purchase or
sale, on behalf of World Tree’s clients”; and (ii) “no Access Person may purchase or
sell ... any Securities ... if the Access Person knows or reasonably should know that
the Security, at the time of purchase or sale (i) is becoming considered for purchase
or sale on behalf of any client Account, or (ii) is being actively purchased or sold on
behalf of any Client Account.”
75. These representations were false as well.  Between March 2011 and
September 2015, Perkins allocated approximately 1,801 securities to accounts under
Perkins’ and Gilmore’s ownership and/or control, while Perkins was buying those
same securities for other World Tree clients through the omnibus account.
76. It would have been important to World Tree’s advisory clients to know
that, contrary to the representations made to clients, World Tree’s principals’
accounts were trading in the same securities as their clients’ accounts, in prohibited
transactions.
D. World Tree, Perkins and Gilmore Acted Unreasonably and With
Fraudulent Intent
77. Perkins knowingly or recklessly engaged in a fraudulent scheme to
cherry-pick securities trades for the benefit of accounts held by his family and his

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clients, to the detriment of the Disfavored Client.  He further acted unreasonably
when carrying out the cherry-picking scheme.
78. Perkins also knew, or was reckless in not knowing that World Tree’s
Forms ADV were false and misleading when they claimed that the trading of
securities would be allocated fairly and equitably among client accounts.  He further
acted unreasonably when making those misstatements to clients and circulating those
false and misleading Forms ADV.
79. Because he is a co-owner and principal of the firm, his scienter and
negligence in carrying out the cherry-picking scheme and defrauding clients in the
Forms ADV are imputed to World Tree about the allocation practices.
80. World Tree maintained a compliance manual, and Perkins certified that
he had read and understood the manual.  In addition, Perkins and Gilmore held annual
compliance meetings.
81. World Tree’s compliance manual states that the firm “maintains strict
compliance with all applicable laws, rules and regulations,” and identifies trade
allocation as an area of potential conflict of interest that required additional
monitoring by the firm’s chief compliance officer.
82. Annual compliance audit reports, which Perkins reviewed and approved,
stressed the importance of fair and equitable trade allocations and stated that “[i]t is
the Firm’s policy, when placing aggregated client orders of securities simultaneously
for more than one client (block trades) to allocate orders in a fair and equitable
manner.”
83. In addition, Perkins and Gilmore each knew, or was reckless in not
knowing, that they were prohibited from trading in the same securities as clients in
their personal accounts, and that World Tree and Perkins’s violation of that
prohibition rendered World Tree’s Forms ADV false and misleading.  Perkins and
Gilmore further acted unreasonably when they issued Forms ADV to clients that
falsely claimed they were not engaging in prohibited personal securities transactions.

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84. Because Perkins and Gilmore are co-owners and principals of the firm,
their scienter and negligence in defrauding clients in the Forms ADV about the
prohibited securities transactions are imputed to World Tree.
85. Pe  rkins and Gilmore have each admitted that they were aware of the
prohibition and that in retrospect, their trading in the same securities as their clients
violated the prohibition.
86. Perkins and Gilmore each signed an annual acknowledgment that they
had read and understood the compliance manual that contained a Code of Ethics,
which explicitly described the prohibition against trading in securities also under
consideration for investment by clients.
87. In addition, among Gilmore’s daily responsibilities as World Tree’s
chief compliance officer, Gilmore was responsible for verifying that Perkins’s trade
allocations had been correctly carried out by the Broker.
88. Gilmore would verify on the following day that trades from the day
before had been allocated as Perkins directed.
89. World Tree’s compliance manual stated that the chief compliance
officer, Gilmore, was responsible for determining whether trade allocations were fair
and equitable.
90. Gilmore failed to take any steps to determine whether trade allocations
were fair and equitable.
E. World Tree’s and Perkins’ Role as Investment Advisers
91. During all relevant times, World Tree and Perkins acted as investment
advisers.
92. World Tree provided investment advice to clients in exchange for a
percentage of assets under management.
93. World Tree was an SEC-registered investment adviser through June
2012, and is currently a Louisiana state-registered investment adviser.
94. Perkins made all of the investment decisions for the securities trading in

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World Tree accounts.
95. Perkins, as World Tree’s 60% owner, chief executive officer and chief
investment officer, was compensated for managing World Tree client accounts and
directly benefitted from the advisory fees World Tree earned.
F. Tolling of the Statute of Limitations
96. Pursuant to tolling agreements between defendants and the SEC, the
statute of limitations applicable to the SEC’s claims against defendants World Tree,
Perkins, and Gilmore was tolled and suspended for the period beginning on August 1,
2017 through September 30, 2018.
FIRST CLAIM FOR RELIEF
Fraud in Connection with the Purchase or Sale of Securities
Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a) and (c)
(against Defendants World Tree and Perkins)
97. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
98. As alleged above, defendants World Tree and Perkins engaged in a
scheme to defraud clients, and engaged in acts, practices or courses of business that
operated as a fraud upon clients, by cherry-picking favorable trades for the Favored
Accounts and allocating poor trades to the Disfavored Client Account, which
sustained substantial losses as a result.
99. By engaging in the conduct described above, defendants World Tree and
Perkins, and each of them, directly or indirectly, in connection with the purchase or
sale of a security, and by the use of means or instrumentalities of interstate
commerce, of the mails, or of the facilities of a national securities exchange:  (a)
employed devices, schemes, or artifices to defraud; and (b) engaged in acts, practices,
or courses of business which operated or would operate as a fraud or deceit upon
other persons.
100. Defendants World Tree and Perkins, with scienter, employed devices,

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schemes and artifices to defraud; and engaged in acts, practices or courses of conduct
that operated as a fraud on the investing public by the conduct described in detail
above.
101. By engaging in the conduct described above, defendants World Tree and
Perkins violated, and unless restrained and enjoined will continue to violate, Section
10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5(a) and 10b-5(c)
thereunder, 17 C.F.R. §§ 240.10b-5(a) & 240.10b-5(c).
SECOND CLAIM FOR RELIEF
Fraud in the Connection with the Purchase and Sale of Securities
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 (b)
(against Defendants World Tree, Perkins and Gilmore)
102. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
103. As alleged above, defendants World Tree, Perkins and Gilmore made
untrue statements of material fact in World Tree’s Forms ADV concerning their
securities trading and trade allocations.  Specifically, World Tree and Perkins made
false and misleading statements in the Forms ADV about the firm’s trade allocation
practices; World Tree, Perkins and Gilmore made false and misleading statements in
the Forms ADV about whether or not Perkins and Gilmore traded in the same
securities as their clients.
104. By engaging in the conduct described above, defendants World Tree,
Perkins and Gilmore, and each of them, directly or indirectly, in connection with the
purchase or sale of a security, by the use of means or instrumentalities of interstate
commerce, of the mails, or of the facilities of a national securities exchange, made
untrue statements of a material fact or omitted to state a material fact necessary in
order to make the statements made, in the light of the circumstances under which they
were made, not misleading.
105. By engaging in the conduct described above, defendants World Tree,

COMPLAINT
18

Perkins and Gilmore violated, and unless restrained and enjoined will continue to
violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5(b)
thereunder, 17 C.F.R. § 240.10b-5(b).
THIRD CLAIM FOR RELIEF
Fraud in the Offer or Sale of Securities
Violations of Sections 17(a)(1) of the Securities Act
(against Defendants World Tree and Perkins)
106. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
107. As alleged above, defendants World Tree and Perkins engaged in a
scheme to defraud clients, and engaged in acts, practices or courses of business that
operated as a fraud upon clients, by cherry-picking favorable trades for the Favored
Accounts and allocating poor trades to the Disfavored Client Account, which
sustained substantial losses as a result.
108. By engaging in the conduct described above, defendants World Tree and
Perkins, and each of them, directly or indirectly, in the offer or sale of securities, and
by the use of means or instruments of transportation or communication in interstate
commerce or by use of the mails directly or indirectly employed devices, schemes, or
artifices to defraud.
109. Defendants World Tree and Perkins, with scienter, employed devices,
schemes and artifices to defraud.
110. By engaging in the conduct described above, defendants World Tree and
Perkins violated, and unless restrained and enjoined will continue to violate, Section
17(a)(1) of the Securities Act, 15 U.S.C. §§ 77q(a)(1) & 77q(a)(3).

COMPLAINT
19

FOURTH CLAIM FOR RELIEF
Fraud in the Offer or Sale of Securities
Violations of Section 17(a)(2) of the Securities Act
(against Defendants World Tree, Perkins and Gilmore)
111. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
112. As alleged above, defendants World Tree, Perkins and Gilmore obtained
money by means of untrue statements of material fact in World Tree’s Forms ADV
concerning their securities trading and trade allocations.  Specifically, the Forms
ADV contained false statements about the firm’s trade allocation practices and about
whether or not Perkins and Gilmore traded in the same securities as their clients.
113. By engaging in the conduct described above, defendants World Tree,
Perkins and Gilmore, and each of them, directly or indirectly, in the offer or sale of
securities, and by the use of means or instruments of transportation or communication
in interstate commerce or by use of the mails, directly or indirectly obtained money
or property by means of untrue statements of a material fact or by omitting to state a
material fact necessary in order to make the statements made, in light of the
circumstances under which they were made, not misleading.
114. Defendants World Tree, Perkins and Gilmore, with scienter or
negligence, obtained money or property by means of untrue statements of a material
fact or by omitting to state a material fact necessary in order to make the statements
made, in light of the circumstances under which they were made, not misleading.
115. By engaging in the conduct described above, defendants World Tree,
Perkins and Gilmore violated, and unless restrained and enjoined will continue to
violate, Section 17(a)(2) of the Securities Act, 15 U.S.C. § 77q(a)(2).

COMPLAINT
20

FIFTH CLAIM FOR RELIEF
Fraud by an Investment Adviser
Violations of Sections 206(1) and 206(2) of the Advisers Act
(against Defendants World Tree and Perkins)
116. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
117. As alleged above, defendants World Tree and Perkins each had an
adviser-client relationship with, and therefore owed a fiduciary duty to, each of
World Tree’s clients.  World Tree and Perkins both breached their fiduciary duty by
carrying out the cherry-picking scheme and by falsely representing in World Tree’s
Firm Brochures that the firm had equitably and fairly allocated transactions among its
clients, and that World Tree’s principals had not engaged in prohibited transactions.
At all relevant times, defendant Perkins acted knowingly or recklessly when carrying
out this fraud, and his state of mind is imputed to World Tree, which he controlled.
118. By engaging in the conduct described above, defendants World Tree and
Perkins, and each of them, directly or indirectly, by use of the mails or means of
instrumentalities of interstate commerce:  (a) employed devices, schemes or artifices
to defraud clients or prospective clients, and (b) engaged in transactions, practices, or
courses of business which operated as a fraud or deceit upon clients or prospective
clients.
119. By engaging in the conduct described above, defendants World Tree and
Perkins, and each of them, violated, and unless restrained and enjoined will continue
to violate, Sections 206(1) and (2) of the Advisers Act, 15 U.S.C. §§ 80b-6(1) & 80b-
6(2).

COMPLAINT
21

SIXTH CLAIM FOR RELIEF
Aiding and Abetting
Violations of Sections 206(1) and 206(2) of the Advisers Act
(against Defendant Gilmore)
120. The SEC realleges and incorporates by reference paragraphs 1 through
96 above.
121. Gilmore knew or was reckless in not knowing that the representations in
World Tree’s Forms ADV concerning prohibited transactions were false.  She
reviewed the ADVs; she signed acknowledgements that she had read World Tree’s
compliance manual; and she knew or was reckless in not knowing, as she verified
trade allocations, that accounts under her and Perkins’ ownership and control were
trading in the same securities as World Tree’s clients’ accounts, in prohibited
transactions.
122. By engaging in the conduct described above, defendant World Tree and
Perkins violated Sections 206(1) and 206(2) of the Advisers Act, 15 U.S.C. §§ 80b-
6(1) & 80b-6(2).
123. By engaging in the conduct described above, defendant Gilmore
knowingly or recklessly provided substantial assistance to, and thereby aided and
abetted World Tree and Perkins in its violations of Sections 206(1) and 206(2) of the
Advisers Act.  At all relevant times, defendant Gilmore acted knowingly or recklessly
in aiding and abetting World Tree’s and Perkins’ Advisers Act violations.
124. By engaging in the conduct described above, defendant Gilmore aided
and abetted, and unless restrained and enjoined, will continue to aid and abet
violations of Sections 206(1) and 206(2) of the Advisers Act, 15 U.S.C. §§ 80b-6(1)
& 80b-6(2), as prohibited by Section 209(f) of the Advisers Act, 15 U.S.C. § 80b-
9(f).
PRAYER FOR RELIEF
WHEREFORE, the SEC respectfully requests that the Court:

COMPLAINT
22

I.
Issue findings of fact and conclusions of law that Defendants committed the
alleged violations.
II.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, temporarily, preliminarily, and permanently enjoining defendants
World Tree and Perkins, and their officers, agents, servants, employees and attorneys,
and those persons in active concert or participation with any of them, who receive
actual notice of the judgment by personal service or otherwise, and each of them,
from violating Section 17(a) of the Securities Act [15 U.S.C. §77q(a)], Section 10(b)
of the Exchange Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §
240.10b-5], and Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§80b-
6(1) & 80b-6(2)].
III.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, temporarily, preliminarily, and permanently enjoining defendant
Gilmore, and her agents, servants, employees and attorneys, and those persons in
active concert or participation with any of them, who receive actual notice of the
judgment by personal service or otherwise, and each of them, from violating Section
17(a) of the Securities Act [15 U.S.C. §77q(a)], Section 10(b) of the Exchange Act
[15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5 ], and from
aiding and abetting any violation of Sections 206(1) and 206(2) of the Advisers Act
[15 U.S.C. §§80b-6(1) & 80b-6(2)].
IV.
Order Defendants World Tree and Perkins to jointly and severally disgorge all
funds received from their illegal conduct; and order Defendants World Tree, Perkins
and Gilmore to jointly and severally disgorge all funds received from their illegal
conduct; together with prejudgment interest thereon.

COMPLAINT
23

V.
Order Defendants to pay civil penalties under Section 20(d) of the Securities
Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)].
VI.
Retain jurisdiction of this action in accordance with the principles of equity and
the Federal Rules of Civil Procedure in order to implement and carry out the terms of
all orders and decrees that may be entered, or to entertain any suitable application or
motion for additional relief within the jurisdiction of this Court.
VII.
Grant such other and further relief as this Court may determine to be just and
necessary.
 Respectfully submitted,

GARY Y. LEUNG
California Bar No. 302928
DAVID M. ROSEN
California Bar No. 150800
SECURITIES AND EXCHANGE
COMMISSION
444 S. Flower Street, 9th Flr.
Los Angeles, CA 90071
(323) 965-3213
(213) 443-1904 (facsimile)
[email protected]

[email protected]

COUNSEL FOR PLAINTIFF
SECURITIES AND EXCHANGE
COMMISSION

DAVID C. JOSEPH
United States Attorney

COMPLAINT
24

By:  /s/ Karen J. King
KAREN J. KING (#23508)
U.S. ATTORNEY’S OFFICE
WESTERN DISTRICT OF LOUISIANA
800 Lafayette Street, Suite 2200
Lafayette, Louisiana 70501-6832
(337) 262-6618
(337) 262-6693 (facsimile)
[email protected]

Local Counsel

DATED:  September 18, 2018

COMPLAINT 1  
 

UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF LOUISIANA 

LAFAYETTE DIVISION 
 
 
 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

WORLD TREE FINANCIAL, LLC, 
WESLEY KYLE PERKINS, and 
PRISCILLA GILMORE PERKINS, 

Defendants. 
 

 Case No. 18-cv-1229 
 
JUDGE 
 
 
 
MAGISTRATE JUDGE 
 
 
 
COMPLAINT 
 

 
 
 

Plaintiff Securities and Exchange Commission (“SEC”) alleges: 

SUMMARY OF THE ACTION 

1. This case is about a “cherry-picking” scheme carried out by an 

investment adviser and its owner.  Investment advisers often trade stocks and other 

securities for their clients on a daily basis, and “cherry-picking” happens when the 

adviser gives himself or his favored clients the winning trades for that day, and 

allocates the losing trades to other clients (the “disfavored” clients).  That is what 

defendant World Tree Financial LLC (“World Tree”), and one of its owners, 

defendant Wesley Kyle Perkins (“Perkins”), did.  They allocated “cherry-picked” 

winning trades to Perkins’ accounts and to accounts held by some clients, while 

allocating losing trades to the accounts held by a disfavored client.  In doing so, they 

breached the fiduciary duties they owed their clients – Perkins took profits for 

himself and others, while at the same time causing substantial losses for the 

disfavored client.  Through this scheme, World Tree and Perkins misled the clients 

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COMPLAINT 2  
 

who received the better trades into thinking World Tree and Perkins were better at 

managing their money than they really were.   

2. Perkins was World Tree’s chief executive officer and chief investment 

officer, and was responsible for all of the firm’s trading.  In those roles, he was able 

to disproportionately allocate profitable securities trades to accounts that he and 

defendant Priscilla Gilmore Perkins (“Gilmore”) owned and controlled, and to other 

accounts.  Gilmore is Perkins’ wife and World Tree’s chief compliance officer.  At 

the same time, Perkins saddled two disfavored accounts, held by one client, with a 

disproportionate share of the firm’s unprofitable trades.  The brokerage firm handling 

the trading for World Tree terminated its relationship with World Tree because it 

suspected the firm was engaging in cherry-picking. 

3. The defendants also misrepresented how World Tree was trading 

securities for its clients.  The firm’s brochures and other disclosures claimed the 

trades were being fairly and equitably allocated among the client accounts.  The firm 

also claimed that Perkins and Gilmore were not trading in the same securities as 

World Tree’s clients.  These claims were false —Perkins was cherry-picking trades, 

and he and Gilmore were trading in the same securities as their clients.  

4. By engaging in this cherry-picking scheme, and through their 

misrepresentations to their advisory clients, defendants World Tree and Perkins 

violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and 

Rule 10b-5(a) and (c) thereunder;  Section 17(a)(1) of the Securities Act  of 1933 

(“Securities Act”); and Sections 206(1) and (2) of the Investment Advisers Act of 

1940 (“Advisers Act”).  Also, defendants World Tree, Perkins and Gilmore violated 

Section 10(b) of the Exchange Act and Rule 10b-5(b) thereunder and Section 17(a)(2) 

of the Securities Act; and defendant Gilmore aided and abetted defendant World 

Tree’s violations of the Advisers Act.  The SEC seeks permanent injunctions, 

disgorgement with prejudgment interest, and civil penalties against all three 

defendants. 

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COMPLAINT 3  
 

JURISDICTION AND VENUE 

5. The Court has jurisdiction over this action pursuant to Sections 20(b), 

20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 

77t(b), 77t(d)(1) & 77v(a), Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of the 

Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1), 

78u(d)(3)(A), 78u(e) & 78aa(a), and Sections 209(d), 209 (e)(1) and 214 of the 

Investment Advisers Act of 1940 (“Advisers Act”), 15 U.S.C. §§ 80b-9(d), 80b-

9(3)(1) & 90b-14. 

6. Defendants have, directly or indirectly, made use of the means or 

instrumentalities of interstate commerce, of the mails, or of the facilities of a national 

securities exchange in connection with the transactions, acts, practices and courses of 

business alleged in this complaint.  

7. Venue is proper in this district pursuant to Section 22(a) of the Securities 

Act, 15 U.S.C. § 77v(a), and Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a) 

because certain of the transactions, acts, practices and courses of conduct constituting 

violations of the federal securities laws occurred within this district.  In addition, 

venue is proper in this district because defendants Perkins and Gilmore reside in this 

judicial district, and defendant World Tree has its principal place of business in this 

judicial district. 

DEFENDANTS 

8. Defendant World Tree Financial, LLC is a Louisiana corporation with its 

principal place of business in Lafayette, Louisiana.  World Tree was an SEC-

registered investment adviser until June 15, 2012, when it withdrew its SEC 

registration.  World Tree is currently registered as an investment adviser with the 

State of Louisiana.   

9. As of March 2018, World Tree had assets under management of over 

$54 million and 161 advisory clients, all of whom are individuals.     

10. Defendant Wesley Kyle Perkins is a resident of Lafayette, Louisiana.  

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COMPLAINT 4  
 

He co-founded World Tree in 2009, and has been the firm’s 60% owner, chief 

executive officer, and chief investment officer since World Tree’s inception.  Perkins 

holds Series 6, 7, and 66 securities licenses.  Perkins married co-defendant Priscilla 

Gilmore Perkins in 2017. 

11. Defendant Priscilla Gilmore Perkins is a resident of Lafayette, 

Louisiana.  After co-founding World Tree with Perkins in 2009, Gilmore has been the 

firm’s 40% owner, chief financial officer, chief compliance officer, and chief 

operating officer.  Gilmore holds Series 6, 7 and 66 securities licenses.     

FACTS 

A. World Tree’s Formation and Operation 

12. In 2009, Perkins and Gilmore left a subsidiary of a global financial 

services firm, where they had both worked as financial advisers, and co-founded 

World Tree. 

13. At all relevant times, Perkins has owned 60% of World Tree and 

Gilmore has owned the remaining 40% of the firm. 

14. World Tree’s advisory clients are individual retail investors.   

15. The majority of World Tree’s advisory clients are not high net worth 

individuals. 

16. For its investment advice, World Tree charges clients an advisory fee 

that ranges between 0.5% to 1.5% of the client’s assets under management.   

17. From March 2011 through September 2015, World Tree managed 

between approximately $40 million and $70 million in client assets.   

18. World Tree assigned each of its clients one of five “investment models” 

based on the size of the client’s account.   

19. Most of World Tree’s clients bought from among the same group of 

individual securities, and held between two and ten different stocks in their respective 

accounts at one time, depending on the size of their account.   

20. Approximately 93% of World Tree’s clients’ investments involved the 

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COMPLAINT 5  
 

same securities between March 2011 and September 2015. 

21. Notwithstanding World Tree’s five “investment models,” it utilized the 

same basic trading strategy across the majority of its client accounts. 

22. At all relevant times, Perkins and Gilmore have jointly controlled World 

Tree.   

23. As World Tree’s chief investment officer, Perkins was solely responsible 

for managing all the securities trading, including allocating trades placed through the 

firm’s omnibus account to clients.   

24. As World Tree’s chief compliance officer, chief financial officer and 

chief operating officer, Gilmore ran World Tree’s back office operations and 

supervised all aspects of the firm’s compliance program.   

B. Perkins’ and World Tree’s Fraudulent Cherry-Picking Scheme 

1. Trading in Client Accounts 

25. World Tree manages all of its clients’ assets on a discretionary basis, 

meaning it has authorization to trade securities on behalf of its clients.  

26. Perkins was the only person at World Tree with the authority to make 

trades and determine allocations. 

27. From December 2009 to October 2015, World Tree traded through the 

brokerage platform of a registered broker-dealer (“Broker”).  This Broker also acted 

as the custodian for World Tree’s client accounts, meaning that a third-party held the 

securities on the clients’ behalf.    

28. World Tree generally traded for its clients through an omnibus trading 

account held at the Broker and later allocated the purchases to its individual clients’ 

accounts, generally after the market closed.      

29. In general, an omnibus trading account allows an investment adviser to 

buy and sell securities on behalf of multiple clients simultaneously, without 

identifying to the broker in advance the specific accounts for which a trade is 

intended.   

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COMPLAINT 6  
 

30. As an example, if an adviser separately purchases the same security for 

several clients on the same day, the adviser might obtain different prices on each 

transaction as a result of normal market fluctuation.  Rather than placing individual 

orders in each client account, the adviser can place an aggregated order, or “block 

trade,” in the omnibus account and subsequently allocate the trade among multiple 

accounts using an average price.  When used properly, an adviser will fairly and 

equitably allocate the block trade among client accounts, ensuring that no account 

receives preferential treatment over another.   

2. The Cherry-Picking 

31. From at least March 2011 through September 2015, when World Tree 

traded through the Broker’s platform, World Tree and Perkins misused the omnibus 

account to engage in a fraudulent scheme to defraud clients by cherry-picking. 

32. In fact, in April 2015, the Broker internally determined, based on a 

sampling analysis, that when trading in the same security, accounts held by World 

Tree, Perkins and Gilmore performed substantially better than their clients’ accounts.   

33. The Broker then requested that World Tree provide materials showing 

how the firm was allocating trades to client accounts and World Tree and its 

principals’ accounts.  Because World Tree did not produce the requested materials, 

the Broker terminated its relationship with World Tree based on its suspicions of 

cherry-picking in September 2015. 

34. From March 2011 to September 2015, World Tree traded equities for 

about 277 client accounts and accounts held by Perkins, Gilmore and/or entities they 

owned or controlled. 

35. During this period, World Tree and Perkins allocated favorable trades to 

nine accounts held by Perkins, Gilmore and/or entities they owned or controlled, and 

to a lesser degree, the World Tree client accounts (collectively, the “Favored 

Accounts”) – except, however, for two client accounts that did not receive an 

equitable allocation of favorable trades.   

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COMPLAINT 7  
 

36. At the same time, World Tree and Perkins allocated unfavorable trades 

to those two remaining client accounts (the “Disfavored Client Accounts”), which 

were owned by one client, his wife, and the client’s business entity (the “Disfavored 

Client”). 

37. Specifically, from March 2011 to September 2015, Perkins allocated:  (i) 

a disproportionately high number of profitable trades to the nine favored Perkins 

accounts; (ii) a disproportionately high number of the most unprofitable trades to the 

Disfavored Client Accounts; (iii) a disproportionately low number of the most 

unprofitable trades to the Perkins accounts; and (iv) a disproportionately low number 

of the profitable trades to the Disfavored Client Accounts. 

38. The Disfavored Client Accounts were World Tree’s largest accounts 

between 2011 and 2015, totaling up to $20 million in assets at various points in time. 

39. World Tree’s cherry-picking was enabled by the fact that the Disfavored 

Client Accounts were large enough to absorb incremental, though steady, trading 

losses without arousing client suspicion that the losses were due to fraud. 

40. Perkins executed the cherry-picking scheme by trading in the firm’s 

omnibus account and then delaying allocation of trades to a specific account until he 

had an opportunity to observe the security’s intra-day performance. 

41. Typically, after purchasing a block of securities through World Tree’s 

omnibus trading account, Perkins delayed allocating the purchase until after the 

market closed.  

42. If the relevant security’s price closed higher, Perkins generally allocated 

the trade to the Favored Accounts, thereby receiving an unrealized gain. 

43. Conversely, when the security’s price went down over the course of the 

day, Perkins generally allocated the purchase to the Disfavored Accounts, leaving 

those accounts with unrealized first-day losses. 

44. In some instances, Perkins purchased and sold the securities on the same 

day, thus locking in a realized gain or loss, and then disproportionately allocated 

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COMPLAINT 8  
 

favorable trades to the Favored Accounts, and unfavorable trades to the Disfavored 

Accounts.     

45. Perkins also cherry-picked when World Tree bought and sold securities 

around corporate earnings announcements.   

46. To illustrate, from March 2011 through September 2015, about 17% of 

World Tree’s trade allocations occurred on the same day that the companies whose 

securities were being allocated had issued, after market close, earnings 

announcements. 

47. On those days, Perkins often waited until after the release of a 

company’s post-close earnings report before allocating trades in that company’s 

securities.   

48. By delaying allocations, Perkins could take into account after-hours 

price movements relating to the earnings announcement.  

49. On repeated instances, when an earnings announcement had a negative 

post-market close impact on the price of the company’s securities, Perkins allocated 

the entire block of unprofitable trades to the Disfavored Client Accounts, even though 

the Disfavored Client Accounts and many other client accounts who did not receive 

any of the unprofitable trades had been assigned the same investment model (called 

the “Large Cap” strategy) by World Tree and Perkins.    

50. The cherry-picking benefitted Perkins and Gilmore because Perkins 

cherry-picked the favorable trades for the accounts they held and controlled.   

51. In addition, the cherry-picking not only harmed the Disfavored Client, 

whose two accounts received the poor trades, but also made it appear to the other 

clients as if World Tree and Perkins were better at trading securities than they really 

were.  

52. From March 2011 through September 2015, Perkins allocated about 

1,865 trades to the nine favored accounts held by the Perkins, Gilmore or their 

businesses.  Those trades earned a positive return of about 2.2%  – as measured by 

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COMPLAINT 9  
 

actual returns in the case of day trades, and for other trades, the first-day returns 

showing the loss or gain between trade price and the closing share price, and where 

Perkins and World Tree traded around earnings announcements, the opening price on 

the following trading day – on about $16.1 million in notional value invested.  

53. During that same period, Perkins allocated about 22,220 trades to client 

accounts that were not the two Disfavored Client Accounts.  Those trades earned a 

positive return of about 1.0% during that time, as measured by actual returns in the 

case of day trades, and for other trades, the first-day returns showing the loss or gain 

between trade price and the closing share price, and for trades around earnings 

announcements, the opening price on the following trading day. 

54. In contrast, during that same period, the trades allocated to the 

Disfavored Client Accounts had negative returns.  Perkins allocated about 2,239 

trades to these accounts during this time.  Those trades earned a negative return of 

about -1.05% on the approximately $424 million in notional value invested, as 

measured by actual returns in the case of day trades, and for other trades, the first-day 

returns showing the loss or gain between trade price and the closing share price, and 

for trades around earnings announcements, the opening price on the following trading 

day.  These trades resulted in first day losses and realized (in the case of a few day 

trades) losses of approximately $4.46 million. 

55. From March 2011 through September 2015, trading in all accounts 

generated an average return of negative return of about -0.23% on an approximately 

$695 million in notional value invested, as measured by actual returns in the case of 

day trades, and for other trades, the first-day returns showing the loss or gain between 

trade price and the closing share price, and for trades around earnings 

announcements, the opening price on the following trading day.     

56. According to a statistical analysis of these different returns, there is a 

less than 1 in a million chance that the disparate returns between the Favored 

Principal Accounts and Disfavored Accounts – an approximate difference of about 

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COMPLAINT 10  
 

3.25% – are the product of mere random chance. 

57. According to a statistical analysis of these different returns, there is a 

less than 1 in a million chance that the disparate returns between the Disfavored 

Accounts and the other client accounts – an approximate difference of about 2.0% – 

are the product of mere random chance.   

58. In addition, during this same period from March 2011 to September 

2015, Perkins allocated 48 of World Tree’s 50 worst performing trades (as measured 

by first-day returns) to the Disfavored Client Accounts.  Those accounts, in turn, 

sustained about 92% of the losses associated with those 50 worst-performing trades.   

59. Similarly, Perkins allowed the Favored Accounts to participate in all of 

World Tree’s 50 best performing trades (as measured by first-day returns) during that 

same period March 2011 to September 2015.  In contrast, Perkins allocated only six 

of those trades to the Disfavored Client Accounts during that time.   

60. As one example, in or about February 2014, Perkins allocated a poor- 

performing trade in a social media company to one of the two Disfavored Client 

Accounts.  The trade was allocated to the Disfavored Client Account as follows: 

(a) At 12:28 p.m. on February 5, 2014, Perkins, on behalf of World 

Tree, purchased 5,000 shares of the social media company in the omnibus account at 

$66.39 per share.   

(b) At 4:29 p.m., in a press release after the market closed, the social 

media company announced lower than expected financial results.  

(c) Shortly thereafter at 5:40 p.m., Perkins allocated all of these 

shares to the Disfavored Client Account at $66.39 per share. 

(d) The Disfavored Client Account was invested in the Large Cap 

strategy.   

(e) No shares were allocated to any other clients who were also 

invested in the Large Cap strategy.   

(f) The next day, the stock price for the social media company 

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COMPLAINT 11  
 

opened at $50.61, a 24% decrease from the allocation price from the previous day.     

61. As another example, in or about July 2014, Perkins allocated a positively 

performing trade in the same social media company to the Favored Accounts: 

(a) At 3:48 p.m. on July 29, 2014, Perkins, on behalf of World Tree, 

purchased 3,000 shares of the social media company in the omnibus account at 

$38.569 per share. 

(b) At 4:15 p.m., in a press release after the market closed, the social 

media company announced higher than expected financial results.   

(c) Shortly thereafter, at 6:15 p.m., Perkins allocated the purchased 

shares at $38.569 per share to approximately 23 Favored Accounts, including the 

Favored Principal Accounts.   

(d) The next day, the social media company opened at $47.01, a 22% 

increase from the allocation price.   

(e) None of these shares were allocated to the Disfavored Client 

Accounts.   

62. It would have been important to World Tree’s advisory clients’ decisions 

on whether to place their assets under World Tree’s management to know that trades 

were not being allocated fairly and equitably.  

C. World Tree, Gilmore and Perkins Made False and Misleading Statements 

to Clients in the Firm’s Brochures  

63. Between March 2011 and February 2015, World Tree made false and 

misleading statements in its Forms ADV, Part 2A.  

64. A Form ADV is a document that is filed with the SEC by investment 

advisers registered with the SEC.  The filing consists of two parts—Part 1 contains 

“check-the-box” information about the firm, and Part 2 is a brochure, in narrative 

form, which describes key information about the firm, including the types of services 

the firm provides.   An investment adviser’s Form ADV must be updated annually, 

and made available to firm clients. 

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COMPLAINT 12  
 

65. While it was registered with the SEC, World Tree was required to 

deliver its Form ADV, Part 2A brochure to clients at the time it entered into an 

advisory contract with them, and to provide clients annually with World Tree’s 

current brochure or a summary of any material changes to its existing brochure.   

66. While it was registered with the SEC, World Tree’s Forms ADV, Part 

2A were available online through the SEC’s website. 

67. Once World Tree became a Louisiana state-registered investment 

adviser in June 2012, it filed its Forms ADV annually with the Investment Adviser 

Registration Depository; those filings were publicly available on the internet.   

68. Since founding the firm, Perkins and Gilmore each personally provided 

World Tree’s Form ADV brochure to their advisory clients on regular occasions.    

69. Before providing them to World Tree’s clients, Gilmore and Perkins 

both reviewed drafts of the Forms ADV, made changes when necessary, and 

authorized the final version for filing and distribution to World Tree’s clients. 

70. Either Perkins or Gilmore signed every World Tree Form ADV from 

2011 to 2015.  Each had ultimate control and authority over the contents of the form. 

71. World Tree’s Forms ADV filed on March 15, 2011, February 7, 2012, 

June 5, 2012, March 25, 2013, March 18, 2014, February 9, 2015, August 7, 2015, 

and September 29, 2015 stated that: (i) “World Tree allocates investment 

opportunities among its clients on a fair and equitable basis”; (ii) “World Tree may 

… combine or ‘batch’ such orders … to allocate equitably among World Tree’s 

clients”; and (iii) “To the extent that World Tree determines to aggregate client orders 

… World Tree shall generally do so in accordance with applicable rules promulgated 

under the Advisers Act and non-action guidance provided by the staff of the U.S. 

Securities and Exchange Commission.”   

72. Given the cherry-picking scheme alleged above, each of these statements 

was false.  By cherry-picking winning trades to the Favored Accounts and losing 

trades to the Disfavored Client Accounts, World Tree did not allocate trades fairly or 

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COMPLAINT 13  
 

equitably, and did not do so in accordance with the Advisers Act or guidance 

provided by the SEC. 

73. It would have been important to World Tree’s advisory clients to know 

that, contrary to the representations made to clients, World Tree was not allocating 

trades fairly or equitably, or in a way that was consistent with the law. 

74. World Tree’s Forms ADV filed on March 15, 2011, February 7, 2012, 

June 5, 2012, March 25, 2013, March 18, 2014, and February 9, 2015 also stated that:  

(i) “none of World Tree’s Access Persons [Perkins and Gilmore] may effect for 

themselves or for their immediate family (i.e., spouse, minor children, and adults 

living in the same household as the Access Person) any transactions in a security 

which is being actively purchased or sold, or is being considered for the purchase or 

sale, on behalf of World Tree’s clients”; and (ii) “no Access Person may purchase or 

sell … any Securities … if the Access Person knows or reasonably should know that 

the Security, at the time of purchase or sale (i) is becoming considered for purchase 

or sale on behalf of any client Account, or (ii) is being actively purchased or sold on 

behalf of any Client Account.”   

75. These representations were false as well.  Between March 2011 and 

September 2015, Perkins allocated approximately 1,801 securities to accounts under 

Perkins’ and Gilmore’s ownership and/or control, while Perkins was buying those 

same securities for other World Tree clients through the omnibus account.   

76. It would have been important to World Tree’s advisory clients to know 

that, contrary to the representations made to clients, World Tree’s principals’ 

accounts were trading in the same securities as their clients’ accounts, in prohibited 

transactions.  

D. World Tree, Perkins and Gilmore Acted Unreasonably and With 

Fraudulent Intent 

77. Perkins knowingly or recklessly engaged in a fraudulent scheme to 

cherry-pick securities trades for the benefit of accounts held by his family and his 

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COMPLAINT 14  
 

clients, to the detriment of the Disfavored Client.  He further acted unreasonably 

when carrying out the cherry-picking scheme.   

78. Perkins also knew, or was reckless in not knowing that World Tree’s 

Forms ADV were false and misleading when they claimed that the trading of 

securities would be allocated fairly and equitably among client accounts.  He further 

acted unreasonably when making those misstatements to clients and circulating those 

false and misleading Forms ADV.   

79. Because he is a co-owner and principal of the firm, his scienter and 

negligence in carrying out the cherry-picking scheme and defrauding clients in the 

Forms ADV are imputed to World Tree about the allocation practices. 

80. World Tree maintained a compliance manual, and Perkins certified that 

he had read and understood the manual.  In addition, Perkins and Gilmore held annual 

compliance meetings. 

81. World Tree’s compliance manual states that the firm “maintains strict 

compliance with all applicable laws, rules and regulations,” and identifies trade 

allocation as an area of potential conflict of interest that required additional 

monitoring by the firm’s chief compliance officer.   

82. Annual compliance audit reports, which Perkins reviewed and approved, 

stressed the importance of fair and equitable trade allocations and stated that “[i]t is 

the Firm’s policy, when placing aggregated client orders of securities simultaneously 

for more than one client (block trades) to allocate orders in a fair and equitable 

manner.”     

83. In addition, Perkins and Gilmore each knew, or was reckless in not 

knowing, that they were prohibited from trading in the same securities as clients in 

their personal accounts, and that World Tree and Perkins’s violation of that 

prohibition rendered World Tree’s Forms ADV false and misleading.  Perkins and 

Gilmore further acted unreasonably when they issued Forms ADV to clients that 

falsely claimed they were not engaging in prohibited personal securities transactions. 

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COMPLAINT 15  
 

84. Because Perkins and Gilmore are co-owners and principals of the firm, 

their scienter and negligence in defrauding clients in the Forms ADV about the 

prohibited securities transactions are imputed to World Tree. 

85. Perkins and Gilmore have each admitted that they were aware of the 

prohibition and that in retrospect, their trading in the same securities as their clients 

violated the prohibition.   

86. Perkins and Gilmore each signed an annual acknowledgment that they 

had read and understood the compliance manual that contained a Code of Ethics, 

which explicitly described the prohibition against trading in securities also under 

consideration for investment by clients.   

87. In addition, among Gilmore’s daily responsibilities as World Tree’s 

chief compliance officer, Gilmore was responsible for verifying that Perkins’s trade 

allocations had been correctly carried out by the Broker.  

88. Gilmore would verify on the following day that trades from the day 

before had been allocated as Perkins directed. 

89. World Tree’s compliance manual stated that the chief compliance 

officer, Gilmore, was responsible for determining whether trade allocations were fair 

and equitable. 

90. Gilmore failed to take any steps to determine whether trade allocations 

were fair and equitable.   

E. World Tree’s and Perkins’ Role as Investment Advisers 

91. During all relevant times, World Tree and Perkins acted as investment 

advisers. 

92. World Tree provided investment advice to clients in exchange for a 

percentage of assets under management. 

93. World Tree was an SEC-registered investment adviser through June 

2012, and is currently a Louisiana state-registered investment adviser. 

94. Perkins made all of the investment decisions for the securities trading in 

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COMPLAINT 16  
 

World Tree accounts. 

95. Perkins, as World Tree’s 60% owner, chief executive officer and chief 

investment officer, was compensated for managing World Tree client accounts and 

directly benefitted from the advisory fees World Tree earned. 

F. Tolling of the Statute of Limitations 

96. Pursuant to tolling agreements between defendants and the SEC, the 

statute of limitations applicable to the SEC’s claims against defendants World Tree, 

Perkins, and Gilmore was tolled and suspended for the period beginning on August 1, 

2017 through September 30, 2018. 

FIRST CLAIM FOR RELIEF 

Fraud in Connection with the Purchase or Sale of Securities 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a) and (c) 

(against Defendants World Tree and Perkins) 

97. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

98. As alleged above, defendants World Tree and Perkins engaged in a 

scheme to defraud clients, and engaged in acts, practices or courses of business that 

operated as a fraud upon clients, by cherry-picking favorable trades for the Favored 

Accounts and allocating poor trades to the Disfavored Client Account, which 

sustained substantial losses as a result.    

99. By engaging in the conduct described above, defendants World Tree and 

Perkins, and each of them, directly or indirectly, in connection with the purchase or 

sale of a security, and by the use of means or instrumentalities of interstate 

commerce, of the mails, or of the facilities of a national securities exchange:  (a) 

employed devices, schemes, or artifices to defraud; and (b) engaged in acts, practices, 

or courses of business which operated or would operate as a fraud or deceit upon 

other persons. 

100. Defendants World Tree and Perkins, with scienter, employed devices, 

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COMPLAINT 17  
 

schemes and artifices to defraud; and engaged in acts, practices or courses of conduct 

that operated as a fraud on the investing public by the conduct described in detail 

above. 

101. By engaging in the conduct described above, defendants World Tree and 

Perkins violated, and unless restrained and enjoined will continue to violate, Section 

10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5(a) and 10b-5(c) 

thereunder, 17 C.F.R. §§ 240.10b-5(a) & 240.10b-5(c). 

SECOND CLAIM FOR RELIEF 

Fraud in the Connection with the Purchase and Sale of Securities 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(b) 

(against Defendants World Tree, Perkins and Gilmore) 

102. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

103. As alleged above, defendants World Tree, Perkins and Gilmore made 

untrue statements of material fact in World Tree’s Forms ADV concerning their 

securities trading and trade allocations.  Specifically, World Tree and Perkins made 

false and misleading statements in the Forms ADV about the firm’s trade allocation 

practices; World Tree, Perkins and Gilmore made false and misleading statements in 

the Forms ADV about whether or not Perkins and Gilmore traded in the same 

securities as their clients. 

104. By engaging in the conduct described above, defendants World Tree, 

Perkins and Gilmore, and each of them, directly or indirectly, in connection with the 

purchase or sale of a security, by the use of means or instrumentalities of interstate 

commerce, of the mails, or of the facilities of a national securities exchange, made 

untrue statements of a material fact or omitted to state a material fact necessary in 

order to make the statements made, in the light of the circumstances under which they 

were made, not misleading. 

105. By engaging in the conduct described above, defendants World Tree, 

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COMPLAINT 18  
 

Perkins and Gilmore violated, and unless restrained and enjoined will continue to 

violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5(b) 

thereunder, 17 C.F.R. § 240.10b-5(b). 

THIRD CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

Violations of Sections 17(a)(1) of the Securities Act 

(against Defendants World Tree and Perkins) 

106. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

107. As alleged above, defendants World Tree and Perkins engaged in a 

scheme to defraud clients, and engaged in acts, practices or courses of business that 

operated as a fraud upon clients, by cherry-picking favorable trades for the Favored 

Accounts and allocating poor trades to the Disfavored Client Account, which 

sustained substantial losses as a result. 

108. By engaging in the conduct described above, defendants World Tree and 

Perkins, and each of them, directly or indirectly, in the offer or sale of securities, and 

by the use of means or instruments of transportation or communication in interstate 

commerce or by use of the mails directly or indirectly employed devices, schemes, or 

artifices to defraud. 

109. Defendants World Tree and Perkins, with scienter, employed devices, 

schemes and artifices to defraud. 

110. By engaging in the conduct described above, defendants World Tree and 

Perkins violated, and unless restrained and enjoined will continue to violate, Section 

17(a)(1) of the Securities Act, 15 U.S.C. §§ 77q(a)(1) & 77q(a)(3). 

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COMPLAINT 19  
 

FOURTH CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

Violations of Section 17(a)(2) of the Securities Act 

(against Defendants World Tree, Perkins and Gilmore) 

111. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

112. As alleged above, defendants World Tree, Perkins and Gilmore obtained 

money by means of untrue statements of material fact in World Tree’s Forms ADV 

concerning their securities trading and trade allocations.  Specifically, the Forms 

ADV contained false statements about the firm’s trade allocation practices and about 

whether or not Perkins and Gilmore traded in the same securities as their clients. 

113. By engaging in the conduct described above, defendants World Tree, 

Perkins and Gilmore, and each of them, directly or indirectly, in the offer or sale of 

securities, and by the use of means or instruments of transportation or communication 

in interstate commerce or by use of the mails, directly or indirectly obtained money 

or property by means of untrue statements of a material fact or by omitting to state a 

material fact necessary in order to make the statements made, in light of the 

circumstances under which they were made, not misleading. 

114. Defendants World Tree, Perkins and Gilmore, with scienter or 

negligence, obtained money or property by means of untrue statements of a material 

fact or by omitting to state a material fact necessary in order to make the statements 

made, in light of the circumstances under which they were made, not misleading. 

115. By engaging in the conduct described above, defendants World Tree, 

Perkins and Gilmore violated, and unless restrained and enjoined will continue to 

violate, Section 17(a)(2) of the Securities Act, 15 U.S.C. § 77q(a)(2). 

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COMPLAINT 20  
 

FIFTH CLAIM FOR RELIEF 

Fraud by an Investment Adviser 

Violations of Sections 206(1) and 206(2) of the Advisers Act 

(against Defendants World Tree and Perkins) 

116. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

117. As alleged above, defendants World Tree and Perkins each had an 

adviser-client relationship with, and therefore owed a fiduciary duty to, each of 

World Tree’s clients.  World Tree and Perkins both breached their fiduciary duty by 

carrying out the cherry-picking scheme and by falsely representing in World Tree’s 

Firm Brochures that the firm had equitably and fairly allocated transactions among its 

clients, and that World Tree’s principals had not engaged in prohibited transactions.  

At all relevant times, defendant Perkins acted knowingly or recklessly when carrying 

out this fraud, and his state of mind is imputed to World Tree, which he controlled.   

118. By engaging in the conduct described above, defendants World Tree and 

Perkins, and each of them, directly or indirectly, by use of the mails or means of 

instrumentalities of interstate commerce:  (a) employed devices, schemes or artifices 

to defraud clients or prospective clients, and (b) engaged in transactions, practices, or 

courses of business which operated as a fraud or deceit upon clients or prospective 

clients.     

119. By engaging in the conduct described above, defendants World Tree and 

Perkins, and each of them, violated, and unless restrained and enjoined will continue 

to violate, Sections 206(1) and (2) of the Advisers Act, 15 U.S.C. §§ 80b-6(1) & 80b-

6(2). 

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SIXTH CLAIM FOR RELIEF 

Aiding and Abetting  

Violations of Sections 206(1) and 206(2) of the Advisers Act 

(against Defendant Gilmore) 

120. The SEC realleges and incorporates by reference paragraphs 1 through 

96 above. 

121. Gilmore knew or was reckless in not knowing that the representations in 

World Tree’s Forms ADV concerning prohibited transactions were false.  She 

reviewed the ADVs; she signed acknowledgements that she had read World Tree’s 

compliance manual; and she knew or was reckless in not knowing, as she verified 

trade allocations, that accounts under her and Perkins’ ownership and control were 

trading in the same securities as World Tree’s clients’ accounts, in prohibited 

transactions. 

122. By engaging in the conduct described above, defendant World Tree and 

Perkins violated Sections 206(1) and 206(2) of the Advisers Act, 15 U.S.C. §§ 80b-

6(1) & 80b-6(2). 

123. By engaging in the conduct described above, defendant Gilmore 

knowingly or recklessly provided substantial assistance to, and thereby aided and 

abetted World Tree and Perkins in its violations of Sections 206(1) and 206(2) of the 

Advisers Act.  At all relevant times, defendant Gilmore acted knowingly or recklessly 

in aiding and abetting World Tree’s and Perkins’ Advisers Act violations.   

124. By engaging in the conduct described above, defendant Gilmore aided 

and abetted, and unless restrained and enjoined, will continue to aid and abet 

violations of Sections 206(1) and 206(2) of the Advisers Act, 15 U.S.C. §§ 80b-6(1) 

& 80b-6(2), as prohibited by Section 209(f) of the Advisers Act, 15 U.S.C. § 80b-

9(f). 

PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court: 

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COMPLAINT 22  
 

I. 

Issue findings of fact and conclusions of law that Defendants committed the 

alleged violations. 

II. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, temporarily, preliminarily, and permanently enjoining defendants 

World Tree and Perkins, and their officers, agents, servants, employees and attorneys, 

and those persons in active concert or participation with any of them, who receive 

actual notice of the judgment by personal service or otherwise, and each of them, 

from violating Section 17(a) of the Securities Act [15 U.S.C. §77q(a)], Section 10(b) 

of the Exchange Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 

240.10b-5], and Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§80b-

6(1) & 80b-6(2)]. 

III. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, temporarily, preliminarily, and permanently enjoining defendant 

Gilmore, and her agents, servants, employees and attorneys, and those persons in 

active concert or participation with any of them, who receive actual notice of the 

judgment by personal service or otherwise, and each of them, from violating Section 

17(a) of the Securities Act [15 U.S.C. §77q(a)], Section 10(b) of the Exchange Act 

[15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and from 

aiding and abetting any violation of Sections 206(1) and 206(2) of the Advisers Act 

[15 U.S.C. §§80b-6(1) & 80b-6(2)]. 

IV. 

Order Defendants World Tree and Perkins to jointly and severally disgorge all 

funds received from their illegal conduct; and order Defendants World Tree, Perkins 

and Gilmore to jointly and severally disgorge all funds received from their illegal 

conduct; together with prejudgment interest thereon. 

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COMPLAINT 23  
 

V. 

Order Defendants to pay civil penalties under Section 20(d) of the Securities 

Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 

78u(d)(3)]. 

VI. 

Retain jurisdiction of this action in accordance with the principles of equity and 

the Federal Rules of Civil Procedure in order to implement and carry out the terms of 

all orders and decrees that may be entered, or to entertain any suitable application or 

motion for additional relief within the jurisdiction of this Court. 

VII. 

Grant such other and further relief as this Court may determine to be just and 

necessary. 

 Respectfully submitted, 
 
GARY Y. LEUNG 
California Bar No. 302928 
DAVID M. ROSEN 
California Bar No. 150800 
SECURITIES AND EXCHANGE 
COMMISSION 
444 S. Flower Street, 9th Flr. 
Los Angeles, CA 90071 
(323) 965-3213 
(213) 443-1904 (facsimile) 
[email protected] 
[email protected] 
 
COUNSEL FOR PLAINTIFF 
SECURITIES AND EXCHANGE 
COMMISSION 
 
DAVID C. JOSEPH 
United States Attorney 
 

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mailto:[email protected]
mailto:[email protected]


COMPLAINT 24  
 

 By:  /s/ Karen J. King 
KAREN J. KING (#23508) 
U.S. ATTORNEY’S OFFICE 
WESTERN DISTRICT OF LOUISIANA 
800 Lafayette Street, Suite 2200 
Lafayette, Louisiana 70501-6832 
(337) 262-6618 
(337) 262-6693 (facsimile) 
[email protected] 
Local Counsel 
 
 
 
 
DATED:  September 18, 2018 

 

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mailto:[email protected]