SEC v. Old Naples Securities, Inc. and James Zimmerman
No. 96-304-CIV-FTM-17D (M.D. Fla. 1996)
Matter at a glance
- Year
- 1996
- Agency
- U.S. Securities and Exchange Commission
- Forum
- Federal court
- Mr. Lehrer's role
- Principal litigator
- Docket / file
- No. 96-304-CIV-FTM-17D (M.D. Fla. 1996)
What the matter involved
Misappropriation, securities fraud, and broker-dealer books-and-records violations.
The matter was brought by the U.S. Securities and Exchange Commission and heard as a federal court. Mr. Lehrer worked the file as a principal litigator, which meant building the record on the government's side — the documents, the testimony, and the theory of the violation — rather than responding to it.
- Misappropriation. Misappropriation matters follow customer money out of the account and into the hands of the person who took it — the tracing analysis is usually the case.
- Broker-dealer records. Books-and-records failures at a broker-dealer are frequently the first entry point; the underlying sales-practice conduct surfaces from the records themselves.
- Parallel proceeding. Civil, administrative, and criminal cases can run at the same time on one set of facts. What is said in one forum is used in the others.
Outcome and public record
This matter was resolved on the public record of the U.S. Securities and Exchange Commission under No. 96-304-CIV-FTM-17D (M.D. Fla. 1996). Out of respect for the individuals and entities named, this page does not restate penalties, bars, or sentences. The agency's own release for the matter is the authoritative record of its disposition.
Search the agency's public enforcement records →
Past results in government enforcement matters do not predict or guarantee the result of any future matter. This page describes work performed on behalf of a government agency before Mr. Lehrer entered private practice in 2000.
Why this matters to issuers today
The staff still builds files the same way: start with the public document, test it against the company's own records, and interview the people who signed. Knowing how that record gets assembled is the reason issuers bring this experience in at the drafting stage — before a filing, an offering, or a promotion creates the paper trail a later investigation would follow.
Questions about a filing, an offering, or a promotion?
Talk directly to a former SEC enforcement attorney — no intake staff, no forms.