T4 B1 Team 4 Workplan Fdr- Outline- Undated- Workplan- Investigation Re Alleged Insider Trading 124

Work Plan: Investigation re alleged Insider Trading I.

Review any SEC reports or memoranda summarizing results of investigation (to the extent they exist): A. Key Issues: 1. What companies were investigated for unusual stock trading patterns: a. b. c. d. e.

United, American Other Airlines Insurance Cos Other companies based in WTC Any others (how selected for analysis)

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2. What period used (i.e., how far before September 11 did investigators look) 3. Were any unusual trading patterns detected a. short-selling b. put options or other stock derivative trading c. large sales 4. To extent any relevant equities can be traded on any overseas exchange, what was done to investigate any such trading. 5. Non-Company Specific Derivatives: a. In addition to specific companies, was there any unusual trading in any index-based or whole market derivatives (e.g., S&P futures or similar products) b. What if anything was done to investigate potential trading on foreign exchanges in whole market derivatives or similar products linked to broad U.S.indices 6. Follow-Up by SEC a. How many suspicious traders identified i. ii.

any offshore unidentified traders

b. What document requests or subpoenas were issued

c. What witnesses interviewed d. Was any testimony taken e. Any refusals to cooperate; Fifth Amendment Assertions f. Did any other agency play any role in investigation 7. SEC Conclusions a.

Suspicious trading; satisfactory explanations

b.

Suspicious trading; no compelling explanations, but no link to 9/11

c. Are there any issues not resolved, still pending investigation n.

Meet w/ SEC Enforcement Staff who led investigation A.

Get answers to questions unresolved by any reports or memos.

B.

Follow up on questions unresolved by reports, memos.

m.

To the extent necessary, review "raw" investigative data: account statements, interview memos, testimony transcripts, etc.: This review would be limited to resolving any questions or conflicts raised by the above.

IV.

Other Agencies/Entities w/ potential information regarding illicit securities trading A.

DOT/FBI: need to determine if any criminal investigation initiated; pursue if it exists; to learn of existence, we can serve document requests or ask SEC.

B.

Chicago Board/other options exchanges: could be source of information, but likely anything useful provided to SEC

C.

Secret Service: press has reported USSS investigating an unusually high volume of 5-year U.S. Treasury notes, purportedly a good investment in the event of a world economic crisis.

D.

Broker-dealers/Banks etc: could be source of information, but likely anything useful provided to SEC.

E.

Foreign securities regulators/prosecutors: need to assess their role based on information provided by SEC or DoJ

V.

Non-stock securities: To investigate allegations of illicit speculation in precious metals, oil or other non-stock based derivatives, we will likely need to pursue inquiry with the CFTC, along the lines of the SEC investigation described above.