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NOTICE OF DUTY TO ANSWER, NOTICE TO SET, NOTICE OF HEARING, AND

NOTICE OF CHARGES, AND NOTICE TO ENGAGE IN ALTERNATIVE


DISPUTE RESOLUTION
IN THE MATTER OF E*TRADE SECURITIES LLC,
Respondent.
TO: E*Trade Securities LLC
135 E. 57
th
Street, 14
th
Floor
New York, NY 10022
NOTICE OF DUTY TO ANSWER
YOU ARE HEREBY NOTIFIED that, pursuant to § 24-4-105(2)(b), C.R.S. (2009),
you are required to file a written answer to the following Notice of Charges set forth below
with the Office of Administrative Courts, 633 Seventeenth Street, Suite 1300, Denver,
Colorado 80202, within thirty (30) days after the mailing date of this Notice of Duty to
Answer, Notice to Set, Notice of Hearing, and Notice of Charges. You must also mail a
copy of such answer to the Colorado Division of Securities’ (“Division”) attorneys of record
in this matter, Sueanna P. Johnson and Alexander C. Reinhardt, Assistant Attorneys General,
Office of the Attorney General, 1525 Sherman Street, 7 th
Floor, Denver, Colorado 80203,
within the same thirty-day time period.
If you fail to file your written answer within thirty days as set forth above, then an
order entering a default decision may be issued against you You are further advised that
issuance of a default decision may grant the relief requested in the Notice of Charges, or such
other relief or penalties that may be provided for by law, or both.
NOTICE TO SET
YOU ARE HEREBY NOTIFIED that the undersigned attorney or a representative of
the Commissioner, will appear on August 17, 2010 at 11:00 a.m. in the Office of the Chief
Administrative Law Judge, Office of Administrative Courts, 633 Seventeenth Street, Suite
NOTICE OF HEARING
YOU ARE HEREBY NOTIFIED that, pursuant to § 11-51-606(1), 24-4-104 and 24-
4-105, C,R.S. (2009), a hearing will be held before an authorized administrative law judge at
a date, time and location to be detennined pursuant to the above Notice to Set. At the
hearing, testimony will be taken and other evidence will be received by the administrative
law judge for the purpose of determining whether any of the sanctions set forth in § 11-51-
4 10(1), C.R,S. (2009) should be imposed upon you, including but not limited to the
revocation of your license as a broker-dealer for violations of 11-51-410 and 501, C.R.S.
(2009).
YOU ARE FURTHER NOTIFIED that at the hearing in this matter you shall have
the right to appear in person and/or by legal counsel, to present evidence on your own behalf,
to cross-examine any witnesses, and to rebut any evidence presented. You may also have
subpoenas issued on your behalf upon request to the administrative law judge. A copy of the
General Rules of Procedure may be obtained at the Division of Administrative Hearings or
by visiting their Internet web site at: http://www.colorado.gov/dpaloac/gen_rules.htm.
RELEVANT LEGAL AUTHORITY
The following statutes and rules are relevant to the allegations and charges made in
the Notice of Charges:
§ 11-51-410. Denial, suspension, or revocation.
(1) The securities commissioner may by order deny an application for a license,
suspend or revoke a license, censure a licensed person, limit or impose conditions on the
securities activities that a licensed person may conduct in this state, and bar a person from
association with any licensed broker-dealer, investment adviser, or federal covered adviser in
the conduct of its business in this state in such capacities, and for such period as the order
specifies. These sanctions may be imposed only if the securities commissioner makes a
finding, in addition to the findings required by section 11-51-704(2), that the applicant or
licensed person or, in the case of a broker-dealer or investment adviser, a partner, officer,
director, person occupying a similar status or performing similar functions, or person directly
or indirectly controlling the broker dealer or investment adviser:
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(i) Has failed to supervise, with a view to preventing violations of this article, another
person who is subject to the.person’s supervision and who commits such a violation
(g) Has willfully engaged in a course of conduct involving the violation of one or
more rules made by the securities commissioner that prohibit unfair and dishonest dealings
by a broker-dealer or sales representative
§ 11-51-501. Fraud and other prohibited conduct.
(1) It is unlawful for any person, in connection with the offer, sale, or purchase of
any security, directly or indirectly:
(a) To employ any device, scheme, or artifice to defraud;
(b) To make any untrue statement of a material fact or to omit to state a material fact
necessary in order to make the statements made, in light of the circumstances under which
they are made, not misleading; or
(c) To engage in any act, practice, or course of business which operates or would
operate as a fraud or deceit upon any person.
3 CCR 704-1, Rule 51-4.7. Unfair and Dishonest Dealings.
The following practices shall be deemed to be “unfair and dishonest dealings” for
purposes of section 1 l-51-410(l)(g), C.R.S.:
B. Recommending to a customer the purchase, sale or exchange of any security
without reasonable grounds for believing that the recommendation is suitable for such
customer upon the basis of the information furnished by the customer after reasonable
inquiry concerning the customer’s investment objectives, financial situation and needs, and
any other information known by the broker-dealer or sales representative;
NOTICE OF CHARGES
YOU ARE HEREBY NOTIFIED of the following allegations:
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New York. At all times relevant to this action, E*Trade has been a licensed broker-dealer in
the state of Colorado.
2. Pursuant to § 11-51-410(1) and 703(1), C.R.S. (2009), the Securities
Commissioner has jurisdiction over Respondent and the subject matter of this proceeding.
STATEMENT OF FACTS
Summary of the Allegations
3. This is an action to revoke, suspend, or otherwise impose conditions on the
broker-dealer license of E*Trade based upon the fraudulent sale of certain “auction rate
securities” (“Auction Rate Securities” or ‘ARS”) in and from Colorado to Colorado investors
in violation of the anti-fraud provisions of the Colorado Securities Act. See § 11-51-501,
C.R.S.
4. ETrade sold ARS to Colorado investors, since at least 2005 and continuing
until the ARS market collapsed completely in February of 2008. In selling ARS, E*Trade
sales representatives told investors that ARS was a short-term, cash-equivalent, liquid
investment. Contrary to these representations, the ARS market depends on a complicated
bidding process called a “Dutch auction.” In the event that a Dutch auction fails because
there are not enough buyers to bid on the sale of ARS at a certain interest rate, then the ARS
become illiquid, long term investments until they can be sold at a future auction. E*Trade
did not disclose to investors the complicated Dutch auction process, that Dutch auctions
could fail and had failed in the past, and that such a failure could result in an illiquid long
term investment. In many instances, E*Trade ARS investors did not even know they were
invested in ARS. And, in truth and material fact and contrary to the statements E*Trade
made, E*Trade knew the risk that ARS auctions could fail when E*Trade sold ARS to
Colorado investors. Due to the widespread Dutch auction failures in February 2008,
Colorado investors cannot liquidate their ARS holdings.
The Securities
5. Auction Rate Securities include a family of investments such as Municipal
Auction Preferred Stock and Auction Preferred Stock, as well as Auction Rate Certificates,
also referred to as Auction Rate Debt Securities. Auction Rate Securities are generally long
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other reset periods exist). The interest rate is reset through a bidding process known as a
“Dutch auction.”
7. A Dutch auction is a process whereby sellers state the amount of Auction Rate
Securities that they wish to sell, and bidders state the amount of Auction Rate Securities they
wish to purchase and the minimum interest rate they are willing to accept. The purchase bids
are ranked, from the lowest to the highest, according to the minimum interest rate each
bidder is willing to accept. The lowest interest rate required to sell all of the Auction Rate
Securities at auction, known as the “clearing rate,” becomes the rate paid to all holders of
that particular bond until the next auction. This process is repeated every 7, 28 or 35 day
cycle, depending upon the reset period specified.
8. The success or failure of a given Dutch auction depends upon whether or not
there are enough buyers for every auction rate being offered for sale. If an auction is
successful, investments in ARS remain liquid because investors can sell their ARS at the
auction. However, if the action fails, investors are required to hold all or some of their
Auction Rate Securities until the next successful auction. Thus, the liquidity of an Auction
Rate Security relies upon the successful operation of the Dutch auction.
9. Broker-dealers frequently acted as auction dealers for the Auction Rate
Securities that they had underwritten and they typically received a percentage of the total sale
for facilitating the auction. The auction dealer solicited the bid and submitted the order
directly to an auction agent. Because the broker-dealer acted as the auction dealer for the
ARS that they had underwritten, the auction dealer would learn ahead of time whether the
ARS auction would be successful, and what the clearing rate would be for that issue of ARS.
Historically, broker-dealers acting as the auction dealer have stepped in during the case of
auction failure to place a “cover” or “support” bid on their own behalf, and would carry the
ARS on the firm’s own proprietary account to prevent auction failures. Broker dealers,
therefore, often helped sustain the market for ARS because they stood to profit from the
continuing viability of the ARS Dutch auction process.
10. An ARS issuer should provide prospectuses to investors with each new issue
of ARS. However, secondary ARS buyers that purchase at Dutch auction do not receive
prospectuses.
11. The prospectus typically states that, in the event of an auction failure, the
issuer of the Auction Rate Security pays a default interest rate until the next successful
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return or interest for the investor holding the ARS.
12. At its peak, the Auction Rate Securities market was a multi-billion dollar
nationwide market based in part upon representations that they were a highly liquid “cash
equivalent” that allowed investors to divest their holdings as needed. Investors were led to
believe that they needed only wait until the next regularly scheduled auction to liquidate their
holdings. Issuers were motivated to sell ARS because could receive cash at a relatively low
interest rate, and investors were motivated to purchase ARS because it was understood to be
a liquid investment that was relatively safe and yielded a higher interest rate than other liquid
investments that paid interest, such as money market accounts. Historically, mostly
institutional investors purchased ARS.
The Failure of the Auction Rate Securities Market
13. In February 2008, the Auction Rate Securities market seized, stranding tens of
thousands of investors in billions of dollars worth of long term investments. The freezing of
the Auction Rate Market was the result of repeated failure of Dutch auction process and the
refusal of broker-dealers that had previously perpetuated the illusion of an always-
functioning market to intervene.
14. The systemic auction failures starting in 2008 did not represent the first
example of auction failures. As early as 1987 and 1988, Dutch auctions for ARS had failed
for long term bonds issued by MCorp and Kroger. In 2006, the Securities and Exchange
Commission issued a Cease and Desist Order imposing sanctions upon numerous large
broker-dealers, including Bear, Stearns & Co, Citigroup, Goldman Sachs, J.P. Morgan
Securities, Inc., Lehman Brothers, and numerous others in case number 3-123 10, In the
Matter ofBear, Stearns & Co. Inc. et al, (the “SEC C&D”). The SEC C&D in particular
found that the named broker-dealers conduct in the Dutch auction process included various
examples of interference in the ARS Dutch auction market, including (but not limited to)
bidding to prevent failed auctions.
15. The interference of broker-dealers in the Dutch auction market played a
significant role in the illusion of a smooth-functioning market. Because the auction dealer
knew in advance of a potential failure, the auction dealer could step in to prevent the auction
failure. When broker-dealers stepped in to prevent auction failure, they typically placed a
cover bid and then carried the investment on their proprietary accounts. The willingness of
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s, sales representatives told retail investors that ARS was a short-term,
liquid investment.
17. In the latter part of 2007, several of the underwriters of ARS offerings stopped
submitting cover bids in some types of ARS auctions. This resulted in a significant number
of failed ARS auctions by November 2007.
18. In February of 2008, the market for Auction Rate Securities which had been
sustained in part by the broker-dealers and auction dealers collapsed entirely. Combined
with ongoing market conditions, the result generally was a freeze in the ARS auction market,
and a loss of the only secondary market for liquidating the investments. Retail investors who
held Auction Rate Securities were unable to liquidate their holdings and were left receiving
the default rate of interest, which in certain instances was as low as 0%.
E*Trade’s sale of Auction Rate Securities
19. Although E*Trade markets itself as a low-cost option for self-directed
investing, F-Trade also offers financial advisory services and sells certain financial products,
including ARS.
20. E*Trade registered sales representatives routinely referred customers to
E*Trade financial advisors for investment advice, which included the offer and sale of ARS.
21. To complete a sale of ARS, E*Trade financial advisors are believed to have
submitted a customer’s order to the E*Trade fixed income desk where the order was
reviewed and transmitted to the E*Trade ARS distributor for execution.
22. E*Trade sold ARS to Colorado investors, beginning in at least 2005 and
continuing through at least 2007. E*Trade representatives told Colorado investors that ARS
was a safe, liquid investment, comparable to an investment in a money market account.
E*Trade did not explain the Dutch auction process to investors, that Dutch auctions could
fail and had failed in the past, and that in the event that ARS could not be sold at Dutch
auction that investors would hold an illiquid long-term investment. Investors did not receive
a prospectus or other written disclosures, and some were not even aware that they had
purchased ARS.
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submitting cover bids to sustain the Dutch auction process, and the 2006 SEC C&D which
addressed broker-dealer interference with the Dutch Auction process, among other things.
Furthermore, in October 2007, an E*Trade Retail Fixed Income Manager sent an email
referencing an article that detailed the possible collapse of the ARS market. E*Trade
continued to sell ARS to Colorado investors while knowing the risk of failure of the Dutch
auctions, and did not fully disclose that risk and other material facts to investors.
24. E*Trade sold approximately $15 million of ARS to approximately 40
Colorado investors, many of whom have been unable to redeem their ARS holdings since
February of 2008 because of the Dutch auction failures in the ARS markets.
25. The Auction Rate Securities sold to investors are “securities” as contemplated
by § 11-51-201(17), C.R.S., in that they are at least “bonds,” “evidence of indebtedness,” and
“investment contracts.”
Material Misrepresentations and Omissions and Fraud in the Acts, Practices, or Course of
Business
26. In connection with the offer, purchase and sale of securities, Respondent
E*Trade, either directly or indirectly, made oral or written statements to investors, in and
from the State of Colorado, including, but not limited to, the following:
a. That Auction Rate Securities were a fully liquid cash equivalent similar
to a money market.
b. That Auction Rate Securities positions could be liquidated at regularly
scheduled periods such as 7, 28, or 35 days.
c. That Auction Rate Securities were a safe short-term investment.
27. In truth and material fact, and contrary to the statements made by Respondent
E*Trade:
a. Auction Rate Securities are only liquid if there are sufficient
participants in the market ready, willing and able to purchase the security at the next
regularly scheduled auction.
b. That failure of an auction would extend the period necessary for an
investor to wait to liquidate their position in an Auction Rate Security, and that
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28. In connection with the offer and sale of securities, Respondent, directly or
indirectly, failed to disclose material facts to investors, including, but not limited to, the
following:
a. That investors were purchasing auction rate securities and the risks
inherent in such purchases.
b. That the ARS auctions had, in the past, been supported by
broker-dealers acting as the auction dealer.
c. That a withdrawal of support by the auction dealer from the ARS
auction market would result in the elimination of the secondary market for Auction
Rate Securities, thus severely restricting their liquidity.
d. The risk of auction failure.
f. That the liquidity of the investments depended upon a complicated
Dutch auction process.
29. Based on the information currently available to the Commissioner, the
following sub-paragraphs detail the known scheme to defraud investors and the acts,
practices and course of business engaged in by the Respondent to defraud investors.
a. E*Trade Representative Stuart Allen Torrey sold $150,000 of ARS to
Colorado investor J.O. on November 20, 2007. Torrey described the
investment to J.O. as a “cash equivalent” and “short term corporate
paper” that could be sold on a weekly basis. J.O. purchased another
$100,000 in ARS the following month, resulting in a total of $250,000 in
ARS holdings. Neither Torrey nor any other E*Trade representative told
J.O. that he was purchasing ARS, and that ARS actually consisted of long
term investments that could become illiquid if the Dutch auction process
failed. J.O. never received a prospectus or other written disclosures.
These omissions made E*Trade’s statements regarding the investment’s
liquidity misleading. J.O. still holds $250,000 of ARS.
b. E*Trade representative Geoff Greenfield sold Colorado investor D.W.
approximately $4 million worth of ARS in January of 2007. Greenfield
told D.W. that ARS were AAA rated, cash equivalent investments that
could be liquidated at auction on a weekly basis. Greenfield also told
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made statements regarding the liquidity of ARS misleading.
D.W. still has approximately $1.5 million in ARS holdings.
c. Greenfield or other E*Trade representatives sold approximately $1.4
million worth of ARS to Colorado investor G.H. on October 18, 2007,
and 1.2 million to G.H. on December 3, 2007. E*Trade representatives
told Gil. that ARS were safe, liquid, cash-equivalent investments.
Neither Greenfield nor any E*Trade representative explained the Dutch
auction process to G.H., that the process could fail and had failed in the
past, and that ARS were actually long term investments that relied on the
Dutch auction process for their liquidity. G.H. did not receive a
prospectus. These omissions made E*Trade’s statements regarding the
liquidity of ARS misleading. G.H. still owns approximately $1 million in
ARS.
d. Colorado investor H.K., for the benefit of his son’s college trust fund
account, purchased $100,000 worth of ARS in late 2005 from an E*Trade
representative. E*Trade told H.K. that ARS was short-term, safe, and
liquid investment that could be sold every two weeks. E*Trade
representatives did not explain the Dutch auction process to D.W., that
the process could fail and had failed in the past, and that ARS were
actually long term investments that relied on the Dutch auction process
for their liquidity. H.K. did not receive a prospectus. These omissions
made E*Trade’s statements regarding the liquidity of ARS misleading.
$100,000 worth of ARS remains illiquid in the college trust fund account.
E*Trade’s Failure to Supervise
30. E*Trade associated with numerous financial advisors that engaged in the sale
of Auction Rate Securities, including Greenfield and Torrey, who are licensed sales
representatives in Colorado. As the broker-dealer employing financial advisors making
offers and sales of securities in and from Colorado, E*Trade is required by law to adequately
and properly supervise their conduct with a view to preventing violations. Supervision is an
essential function of the broker-dealer. Every broker-dealer is required to establish,
implement, and maintain a set of written supervisory procedures and a system for
implementing written supervisory procedures which may be reasonably expected to prevent
and detect the violations described herein. Establishment of policies and procedures alone is
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representatives, including Greenfield and Torrey, were providing full disclosure of the
material facts required to be disclosed in connection with the offer and sale of Auction Rate
Securities.
32. E*Trade failed to adequately and properly supervise the conduct of its
registered sales representatives, including Greenfield and Torrey in connection with the offer
and sale of Auction Rate Securities, with a view to preventing violations by the registered
sales representatives. Respondent E*Trade directly or indirectly failed to reasonably
supervise, with a view to preventing violations of the Act, the activities of its retail sales
representatives, or failed to adopt and implement supervisory procedures that could
reasonably be expected to prevent and detect violations of the Act. This lack of supervision
or apparent pervasive ignorance of or circumvention of supervisory policies and procedures
has caused or substantially contributed to the occurrence of the violations described herein.
FIRST CLAIM
Securities Fraud
( 11-51-501, C.R.S.)
33. Paragraphs 1 through 32 are incorporated herein by reference.
34. By engaging in the conduct set forth above, in connection with the offer, sale,
or purchase of securities in Colorado, Respondent E*Trade, diect1y, or indirectly:
a. employed a device, scheme, or artifice to defraud clients or prospective
clients;
b. made written and oral untrue statements of material fact or omitted to
state material facts necessary to make the statements made, in light of
the circumstances under which they were made, not misleading; or
c. engaged in acts, practices or courses of business which operated and
would operate as a fraud and deceit on investors
all in violation of 11-51-501(1), C.R.S.
35. The conduct of Respondent constitutes a violation of 1 1-51-410(1)(b),
C.R.S. under the Colorado Securities Act, and constitutes grounds for the imposition of
sanctions against E*Trade pursuant to § 11-51-410(1), C.R.S., including suspension or
revocation of their broker-dealer license pursuant to § 11-51-410, C.R.S. In addition,
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( 11—51—410(1)(i))
36. Paragraphs 1 through 35 are incorporated herein by reference.
37. During all times relevant to this Notice of Charges, E*Trade was responsible
for the supervision of its financial advisors acting as sales representatives in the state of
Colorado, including Greenfield and Torrey.
38. Respondent E*Trade failed to reasonably supervise its financial advisors
acting as sales representatives, including Greenfield and Torrey, with a view to preventing
violations of the Act. As a result of the Respondent’s failure to reasonably supervise its
financial advisors acting as sales representatives, E*Trade’s financial advisors acting as sales
representatives sold securities in violation of the anti-fraud provisions of the Colorado
Securities Act, § 11-51-501(1), C.R.S.
39. The conduct of Respondent E*Trade constitutes a violation of 11-5 1-
4 10(1)(i), C.R.S. under the Colorado Securities Act, and constitutes grounds for the
imposition of sanctions against E*Trade pursuant to § 11-51-410(1), C.R.S., including
suspension or revocation of E*Trade’s broker-dealer license pursuant to § 11-51-410, C.R.S.
In addition, pursuant to § 11-51-704(2), C.R.S., these sanctions are necessary and appropriate
in the public interest and consistent with the purposes and provisions of the Act.
THIRD CLAIM
Unfair and Dishonest Dealings
Unsuitability
( 11-51-410(1)(g))
40. Paragraphs 1 through 39 are incorporated herein by reference.
41. Respondent E*Trade’s sales representatives systematically recommended the
purchase, sale or exchange of a security without reasonable grounds for believing that the
recommendation was suitable for the investor based on the information furnished by the
investor after reasonable inquiry concerning the customer’s investment objectives, financial
situation, and needs in violation of Colorado Securities Commissioner’s Rule 51 -4.7.B
(unsuitability).
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WHEREFORE, the Staff respectfully requests that an Administrative Law
Judge enter an initial decision revoking, suspending or otherwise imposing conditions
upon the broker-dealer license of E*Trade pursuant to § 11-51-410, C.R.S., and for
such other and further relief as the Administrative Law Judge deems just and proper.
DATED July 2 1st, 2010.
STAFF OF THE DIVISION OF JOHN W. SUTHERS
SECURITIES ATTORNEY GENERAL
ST E OF C LORADO
(j
GE LDR.IOME Alexander b. Reinhardt, 34970*
Deputy Securities Commissioner Assistant Attorney General
1560 Broadway, Suite 900 Sueanna P. Johnson, 34840*
Denver, Colorado 80202 Assistant Attorney General
Tel: (303) 894-2320 Attorneys for the Staff of the
Fax: (303) 861-2126 Division of Securities
1525 Sherman Street, Floor
Denver, Colorado 80203
Telephone: (303) 866-5255/5576
Facsimile: (303) 866-5395
*counsel of record
CASE NAME: Financial Corporation
CASE NUMBER: XY-2010-
This agency disciplinary proceeding will be scheduled for hearing before an administrative
law judge of the Office of Administrative Courts (the “OAC”). The OAC encourages parties
to use alternative methods of dispute resolution and offers to the agency and respondents the
opportunity to engage in mediation.
Mediation is a process in which a neutral third party meets with the parties to assist them in
reaching a negotiated settlement of the disciplinary proceeding. If the parties are able to
reach an agreement in this way, they will control the outcome of the disciplinary case by
agreeing to a solution, rather than having a solution imposed upon them by an administrative
law judge after a hearing.
In mediation, the mediator facilitates communication between the parties in a private,
confidential and informal meeting. If a party has an attorney, the attorney will participate.
The mediator has no decision-making authority; no settlement or solution to the disciplinary
case will be achieved unless both parties are in agreement. A mediator can often help the
parties generate creative options to resolve the disciplinary case, even though those options
would not be available if the case proceeded to a hearing before an administrative law judge.
Mediators may be able to assist the parties in reaching a settlement even where the parties’
prior, unassisted negotiations have failed to result in an agreement.
If both parties agree to mediate this disciplinary case they may notify the OAC, which will
assign an administrative law judge or other qualified mediator to conduct the mediation. A
mediator acts in a completely confidential manner and has no contact with the judge to
whom the case is assigned for hearing.
The parties should indicate whether they wish to engage in mediation by completing the
information on the reverse side of this form. The respondent should return the completed
form to the OAC, along with the answer to the Notice of Charges or Formal Complaint.
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Administrative Courts.
[JThe agency in the disciplinary proceeding described on the front of this form chooses not
to engage in mediation at this time.
(Signature of Agency Official or (Date)
Assistant Attorney General)
RESPONDENT’S ELECTION TO MEDIATE
(CHECK THE APPROPRIATE BOX)
LiThe respondent named below believes that mediation of this dispute is appropriate and
elects to engage in mediation at the Office of Administrative Courts.
Li The respondent named below chooses not to engage in mediation at this time.
Name of Respondent (Print or Type)
(Signature of Respondent or (Date)
Respondent’s Attorney)
THE RESPONDENT MUST RETURN THIS FORM TO THE OFFICE OF
ADMINISTRATIVE COURTS, ALONG WITH THE ANSWER TO THE NOTICE OF
CHARGES OR FORMAL COMPLAINT, EVEN IF THE RESPONDENT HAS CHOSEN
NOT TO ENGAGE IN MEDIATION. THE ADDRESS OF THE OFFICE OF
ADMINISTRATIVE COURTS IS 633 17TH STREET, SUITE 1300, DENVER, CO 80202.
A COPY OF THIS FORM AND THE ANSWER OF THE RESPONDENT SHOULD
ALSO BE SENT TO THE ATTORNEY GENERAL.
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same in the United States mail, first-class postage prepaid, at Denver, Colorado, this 21st day
of July 2010 addressed as follows:
E*Trade Securities, LLC
135 E. 57
th
Street, 14
th
Floor
New York, NY 10022
()
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