Free Answer to Complaint - District Court of Arizona - Arizona

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
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SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
-V- i
O3 CV 02323
SECURITY TRUST COMPANY, N.A.,
GRANT D. SEEGER, and
WILLIAM A. KENYON,
Defendant.
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DEFENDANT SEEGER’S ANSWER TO SEC COMPLAINT
Defendant Grant Seeger respectfully submits this Answer to the Security
and Exchange Commission’s Complaint against him:
1. Seeger admits the allegations set forth in Paragraph l.
2. Seeger admits the allegations set forth in Paragraph 2.
3. Seeger denies the allegations set forth in Paragraph 3.
4. Seeger denies the allegations set forth in Paragraph4. .
5. Seeger denies the allegations set forth in Paragraph 5.
6. Seeger denies the allegations set forth in Paragraph 6, except to admit STC
had a compensation arrangement that included a custodial fee and a profit
sharing agreement.
7. Seeger denies knowledge or ir1formation sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 7.
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8. Seeger admits the allegations set forth in Paragraph 8.
9. Seeger denies the allegations set forth in Paragraph 9, except to admit that
Seeger resides in Phoenix, Arizona and served as STC’s CEO from 1998 until
his resignation on October 5, 2003.
10. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 10.
l 1. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 11.
12. Seeger denies knowledge or ir1formation sufficient to form a belief as to the
` truth or falsity of the allegations set forth in Paragraph 12.
13. Seeger admits the allegations set forth in Paragraph 13.
14. Seeger admits the allegations set forth in Paragraph 14.
15. Seeger denies the allegations set forth in Paragraph 15, except to admit that
the hedge ftmds contacted him.
16. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 16.
17. Seeger admits the allegations set forth in Paragraph 17.
18. Seeger denies the allegations set forth in Paragraph 18, except to admit that
the hedge funds opened several accounts at STC in May 2000.
19. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 19.
20. Seeger denies the allegations set forth in Paragraph 20, except to admit that
there was an addendum to STC’s Custody Agreement with the hedge funds.
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21. Seeger denies knowledge or infomation sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 21.
22. Seeger denies the allegations set forth in Paragraph 22.
23. Seeger denies the allegations set forth in Paragraph 23.
24. Seeger denies the allegations set forth in Paragraph 24, except to admit that
STC opened omnibus accounts for the hedge ftmds in 2000.
25. Seeger denies the allegations set forth in Paragraph 25, except to admit that
STC’s tax ID number was used for the omnibus accounts.
26. Seeger denies the allegations set forth in Paragraph 26.
27. Seeger denies the allegations set forth in Paragraph 27, except to deny
knowledge or information sufficient to form a belief as to the truth or falsity
of the allegations set forth regarding McDermott.
28. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 28.
29. Seeger denies knowledge or information sufficient to form a belief as to the
truth or falsity ofthe allegations set forth in Paragraph 29.
30. Seeger denies the allegations set forth in Paragraph 30.
31. Seeger realleges and incorporates by reference {[1] 1-30 above.
32. Seeger denies the allegations set forth in Paragraph 32.
33. Seeger denies the allegations set forth in Paragraph 33.
34. Seeger realleges and incorporates by reference {[1] 1-30 above.
35. Seeger denies the allegations set forth in Paragraph 35.
36. Seeger denies the allegations set forth in Paragraph 36.
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37. Seeger denies knowledge or information suflieient to form a belief as to the
truth or falsity ofthe allegations set forth in Paragraph 37.
· 38. Seeger denies the allegations set forth in Paragraph 38.
_ 39. Seeger realleges and incorporates by reference lll] 1-30 above.
40. Seeger admits the allegations set forth in Paragraph 40.
41. Seeger denies knowledge or information suflicient to form a belief as to the
truth or falsity of the allegations set forth in Paragraph 41.
42. Seeger denies knowledge or niformation sufficient to form a belief as to the
V truth or falsity ofthe allegations set forth in Paragraph 42.
43. Seeger realleges and incorporates by reference 1l‘|[ 1-30 above.
44. Seeger denies the allegations set forth in Paragraph 44.
45. Seeger denies the allegations set forth in Paragraph 45.
Seeger demands a trial by Jury.
Dated: June LZ,-2006
Phoenix, AZ
I Respectthll submitted,
/ grant Seeger B
Pro Se
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