The Crazy EddieFraud

Horizontal Analysis

Crazy Eddie Consolidated Statement of Operations In thousands except for share data

Year Ended Year Ended Change Year Ended Change Year Change Ended 03/03/85 03/03/86 85-86 03/01/87 86-87 02/23/88 87-88 Net Sales 8167,147 $262,268 56.91% $352,523 34.41% $315,339 (10.49)% Cost of Goods Sold 127.619 194.371 5231% 272.255 40.07% 346.791 2738% Gross profit 39,528 67,897 71.77% 80,268 18.22% (31,252) (138.93)% Selling, general & administrative expense 26.431 42.975 62.59% 61341 42.74% 96.195 56.82% Operating Income 13,097 24,922 90.29% 18,927 (24.06)% (127,447) (77336)% Other income 1,418 3,210 126.38% 7,403 130.62% Interest expense {5721 £2221 4336% (5.233^ 538.17% 14.12% Income before pension Contribution and income taxes 13,943 27,312 95.88% 21,097 (22.76)% (133,419) (732.41)%

Pension contribution 600 800 3333% 500 (37.5)% Income before income taxes 13343 26,512 98.70% 20,597 (2231)% (133,419) (747.76)%

Income taxes 6,276 13J268 90.19% 10.001 (24.62)% (243211 (343.19)% Net income 86367 $13.244 108.01% $10.596 (19.99)% ($109.098^ (1129.61)%

Earnings per share $1.10 $0.48 -5636% $034 (29.17)% ($3.52) (1135.29)% Weighted average number of shares 5,796 27,664 31,204 30,957 Source: Crazy Eddie Annual Report 1985.1988, Securities and Exchange Commission. JO-K Reports The Crazy Eddie Fraud

Crazy Eddie Consolidated Balance Sheet (In Thousands) ear ended Year ended Change Year ended Change Year ended Change 03/03/85 03/02/86 85-86 03/01/87 86-87 02/28/88 87-88 Assets Current Assets: Cash $7,216 $13,296 8426% $9347 (29-70)% $5,100 (45.44)% Short-term investments 15,057 26,840 7826% 121,957 354.39% 9,846 (91.93)% Accounts receivable 1,876 2,246 19.72% 6346 182.55% 3,529 (44.39)% Merchandise inventories 26,543 59,864 125.54% 109,072 8220% 59,444 (45.50)% Prepaid expenses & other current assets 1,509 2,363 56.59% 6,613 179.86% 2,846 (56.96)% Income tax refunds receivable 4^00 32,077 612.82% Deferred income taxes 4.026 Total current assets 5231 104,609 100.40% 261,861 150.32% 112,842 (56.91)%

Restricted Cash 7,058 3^56 (52.45)% Deferred Income taxes 1,668 Furniture, fixtures, equipment & leasehold improvements at cost, less accumulated depreciation and amortization 3,696 7.172 94.05% 26,401 268.11% 32,949 24.80%

Construction in process 1,154 6,253 441.85% Other Assets 1,419 5,560 291.83% 4,928 (1137)% 3,008 (38.96)%

Total Assets 865.528 S126.95Q 93.73% $294,858 13226% $148,799 (49.54)% Liabilities and Stockholders1 Equity Current Liabilities Accounts payable $23,078 $51,723 124.12% $50,022 (329)% 42,752 (14.53)% Short-term debt 0 49,286 24300 (5029)% Current maturities of long-term liabilities 423 2,254 432.86% 285 (87.36)% 153 (4632)% Income taxes payable 11,071 0 Unearned service contract revenue 1,173 3,696 215.09% 3,641 (1.49)% 3,861 6.04% Accrued liabilities 8.733 6,035(30.67)% 5.593 (7.63)% 9.332 66.85% Total current liabilities 33,407 74,799 123.90% 108,827 45.49% 80,598 (25.94)%

Long-term liabilities, less current maturities 7,625 7,701 1.00% 8,459 9.84% 632 (92.53)% Convertible subordinated debentures 80,975 80,975 0.00% Unearned service contract revenue 1.829 188.03% 3337 82-45% 5332 59.78% Total Liabilities $41,667 $84329 10239% $201,598 139.06% $167337 (16.90)% Stockholders' Equity Preferred stock - par value SI per share authorized 5,000,000 18 Common stock - par value $.01 per share, authorized 15,000,000 shares, 5,000,000 67 280 317.91% 313 11.79% 315 0.64% outstanding Additional paid-in capital 12365 17,668 42.89% 57,678 226.45% 58,630 1.65% Retained earnings 11,429 24,673 115.88% 35,269 42.95% (73,829) (309.33)% Less treasury stock, at cost, 500,000 shares (3,872) Total stockholders1 equity (deficiency in 23.861 42.621 78.62% 93260 118.81% (18.738) (120.09)% net assets) Total liabilities and stockholders' equity $65.528 S126.950 93.73% $294.858 13226% $148.799 (49.54)% Source: Crazy Eddie Annual Report, 1985, 1988, Securities and Exchange Commission, 10-K Reports Vertical Analysis

Crazy Eddie Consolidated Statement of Operations In thousands except for share data

Year Year Year Year Ended % Ended % Ended % Ended ?/P3fl? ofsales 03/03/863/03/86 ofsales 03/01/87 ofsales 02/28/88 ofsales Net Sales $167,147 100.00% $262,268 100.00% $352,323 100.00% Cost of Goods Sold $315,539 100.00% iaLfil£ 7635% 194.371 74.11% 272.255 77.23% 346.791 109.90% Gross profit 39,528 23.65% 67,897 25.89% 80,268 22.77% Selling, general & (31,252) (9.90)% Administrative expense 26.431 5.81% Operating Income 2,925 1639% 61341 17.40% 96.195 30.49% 13,097 7.84% 24,922 9.50% 18,927 5.37% Other income (127,447) (4039)% 1,418 0.85% 3,210 1^2% 7,403 Interest expense (572) -034% (mi -031% (5233) -1.48% Income before pension (1.89)% Contribution and income taxes 13,943 834% 27,312 10.41% 21,097 5.98% Pension contribution (133,419) (4228)% 600 036% SQSi 031% 500 Income before income taxes 13,343 7.98% 26,512 10.11% 20,597 5.84% (133,419) -4228% Income taxes 4.17% 13,261 5.06% JPJ01 2.84% (2432H -7.71% Net income 21367 3.81% $J3,244 5.05% $10.596 3.01% ($109.0981 -34.58% Earnings per share $1.10 $0.48 $034 Weighted average number ofshares ($3.52) 5,796 27,664 31,204 Source: Crazy Eddie AmualReport. 1985.1988. Securities and Exchange Commission, 10-KReports 30,957 The Crazy Eddie Fraud

Crazy Eddie Consolidated Balance Sheet (In Thousands) Yr. Ended Yr. ended Yr. Ended Yr. Ended 03/03/85 03/02/86 03/01/87 02/28/88 Assets Current Assets: Cash $7,216 11.01% $1336 10.47% $9,347 3.17% $5,100 3.43% Short-term investments 15,057 22.98% 26,840 21.14% 121,957 41.36% 9,846 6.62% Accounts receivable 1,876 2.86% 2,246 1.77% 6,346 2.15% 3,529 2.37% Merchandise inventories 26,543 40.51% 59,864 47.16% 109,072 36.99% 59,444 39.95% Prepaid expenses & other current assets 1,509 2.30% 2,363 1.86% 6,613 2.24% 2,846 1.91% Income tax refunds receivable 4,500 1.53% 32,077 21.56% Deferred income taxes 4.026 137% Total current assets 52,201 79.66% 104,609 82.40% 261,861 88.81% 112.842 75.84% Restricted Cash 7,058 10.77% 3,356 2.64% Deferred Income taxes 1,668 0.57% Furniture, fixtures, equipment & lease hold improvements at cost; less accumu lated depreciation and amortization 3,696 5.64% 7,172 5.65% 26,401 8.95% 32,949 22.14% Construction in process 1,154 1.76% 6,253 4.93% Other Assets 1,419 2.17% 5,560 4.38% 4,928 1.67% 3,008 2.02% Total Assets $65.528 100.00% $126,950 100.00% $294,858 100.00% $148,799 100.00% Liabilities and Stockholders1 Equity Current Liabilities Accounts payable $23,078 35.22% $51,723 40.74% $50,022 16.96% $42,752 28.73% Short-term debt 0 49,286 16.72% 24,500 16.47% Current maturities of long-term liabilities 423 0.65% 2^54 1.78% 285 0.10% 153 0.10% Income taxes payable 11,071 8.72% Unearned service contract revenue 1,173 1.79% 3,696 2.91% 3,641 1.23% 3,861 2.59% Accrued liabilities 8.733 13.33% 6.055 4.77% 5.593 1.90% 9.332 627% Total current liabilities 33,407 50.98% 74,799 58.92% 108,827 36.91% 80,598 54.17% Long-term liabilities, less current 7,625 11.64% 7,701 6.07% 8,459 2.87% 632 0.42% maturities Convertible subordinated debentures 80,975 27.46% 80,975 54.42% Unearned service contract revenue &5 0.97% 1.829 1.44% 3.337 1.13% 5.332 3.58% Total Liabilities $41,667 $84,329 $201,598 $167,537 Stockholders' Equity Preferred stock - par value $1 per share authorized 5,000,000 18 0.01% Common stock - par value $.01 per share, authorized 15,000,000 shares, 5,000,000 outstanding 67 0.10% 280 0.22% 313 0.11% 315 0.21% Additional paid-in capital 12,365 18.87% 17,668 13.92% 57,678 19.56% 58,630 39.40% Retained earnings 11,429 17.44% 24,673 19.44% 35,269 11.96% (73,829) (49.62)% Less treasury stock, at cost, 500,000 shares (3,872) (2.60)% Total stockholders' equity (deficiency in 23.86J 36.41% 42.621 33.57% 93.260 31.63% fl8.738U12.59m net assets) Total liabilities and stockholders' equity $65.528 100.00% $126.950 100.00% $294.858 100.00% $148.799 100.00% Source: Crazy Eddie Annual Report, 1985, 1988, Securities and Exchange Commission, 10-K Reports The Crazy Eddie Fraud

Key Ratio Analysis

12S5 1986 1987 2218 Accounts receivable turnover 158.71 113.94 127.25 82.06 Average number of days 63.91 receivables outstanding 2.30 3.20 2.87 4.45 5.71 Inventory turnover 5.2622 5.2618 4.4989 3.2231 4.1158 Average number of days inventory outstanding 69.3622 69.3668 81.1297 113.242 88.6821 Accounts payable turnover 6.84197 6.40773 6.0879 6.3189 6.40616 Average number of days payables outstanding 53.3471 • 56.9623 59.9545 57.7623 56.9763 A/P as a percentage of inventory 82.79% 86.95% 86.40% 45.86% 71.92% The analysis of the financial statements reveals several possible trends that need to be looked into to detemune the cause for changes. For the three years prior to becoming a public company, sales were growing at approximately 20%. After it became public, sales for Crazy Eddie grew at the rate of approximately 45%. This would be highly unusual for any company and in light of the industry havmg a slowdown during this time, the growth should have raised suspicions. Even factoring in that management was skimming sales, the rate of growth would still be highly suspicious. This leads one to beheve that there may be fictitious sales. An increase in accounts receivable might lead further credence to this theory. While the accounts receivable wasn't large, it did exhibit a trend. From 1985 to 1986 accounts receivable increased by 20%, however, in 1987 accounts receivable increased by 182% ending with a $6.3 million balance. Since this was primarily a cash business, one would expect it to be low. Could the balance be due to fraud or to the business that Crazy Eddie did with commercial accounts? That should probably be checked to determine the validity of the balance and make-up ofthe balance. The ratio analysis of accounts receivable, as expected, backs this up. The average number of days receivables outstanding were increasing from 1986 forward, meaning mat customers are paying more slowly, while the receivables turnover ratio was decreasing, meaning that the time between me sale and collection was slowing down. If mere are fictitious sales, then there are probably fictitious receivables. After all, fictitious sales are never collected.

Merchandise inventories also present a disturbing concern. Annual increases of22% and 52% prior to going public might be inappropriate, but after the company went public, the inventories really increased. From 1985 to 1986 inventories increased by 125% and from 1986-1987 they increased 82%. The percentages are shocking perhaps, and the actual numbers even more so. The balance went from $26 million to nearly $60 million in one year and men in the following year, it increased to SI 09 million before tumbling to $59 million when the fraud was discovered. Increases of that The Crazy Eddie Fraud

magnitude would probably require closer scrutiny especially at the rate that sales are increasing. Was the increase due to increased purchasing or due to manipulating the inventory count? The ratio analysis also bears this out Whereas inventory was turning over 5.26 and 4.49 times in 1985 and 1986, it decreased to 3.223 times in 1987. The higher the ratio, the less inventory that sits on the warehouse shelves since it is being sold more quickly from the time of acquisition. This is further evidenced by the increased number of days that inventory remained in stock. If sales were growing at the rather high rate reported, why was^ventory turning over more? We now know that the inventory was severely overcounted causing inventory to be overstated. Inventory that is overstated causes the cost of goods sold to be understated. If cost of goods is understated, then gross profit and net income will be overstated and thus a higher profit will be (fraudulently) misstated. The accounts payable ratios also give credence to overstated inventory. In the ratio accounts payable as a percentage of inventory, the percentages drop drastically fiwn fiscal 1986 to 1987. If sales were actually growing as reported, then the percentages should not have decreased but rather remained constant

Selling-OffStock One sign that something was amiss was the selling off of Eddie's stock. Before the public offering Eddie owned 75.4% of the common stock. Aiter the public ofifering, the number of shares owned or controUed by Eddie was 55.2%. However between September 1984 and late 1987, he sold more than 90% of the common stock he owned or controlled. By September 1987 he owned or controlled only 4.7% of the common stock. From 1984 through 1987, Eddie overstated the rate of growth of Crazy Eddie's earnings, to report $45 million in fictitious earnings, and to claim more than $20 million in fictitious sales. With these falsified reports, Eddie was able to sell his own stock at inflated prices for a total of $74,844,000 from September 1984 to November 1987. By taking advantage of Crazy Eddie's materially misrepresented financial condition, Eddie sold his stock at prices substantially higher than what he could have otherwise obtained. Refer to the Appendix for actual Crazy Eddie announcements regarding the sales of Eddie's stock. Notice the reasons for the selling of his stock, reasons, which were frauds in themselves. The following is a summary of Eddie's stock sales. Number of Average Price Total of Date Shares Sold per Share Proceeds

09/13/84 300,000 7.40 2,220,000 . 03/20/85 450,000 19.80 8,910,000 04/04/85 150,000 19.80 2,970,000 09/10/85 428,550 13.63 5,841,137 11/08/85 .600,000 13.00 7,800,000 03/14/86 600,000 25.23 15,138,000 03/20/86 120,000 2553 3,027,600 • .11/18/86 1,500,000 13.88 20,820,000 . 09/15/87 1,400,000 4.38 6,132,000 10/23/87 5,000 2.80 14,003 10/26/87 15,000 2.13 31,950 10/27/87 45,000 2.37 106,550 10/28/87 65,000 1.94 126,100 10/29/87 30,000 1.94 58,200 10/30/87 82,000 1.88 154,160 11/02/87 163,000 109 340,670 11/03/87 45,000 2.20 99,000 11/13/87 55,000 2.60 143,000 11/16/87 470,000 1.94 911,800 Total Source: Criminal No.: 92- 347UnitedStates District Court, District of New Jersey, Superseding Indictment, United States ofAmerica v. Eddie Antar, Mitchell Antar, Allen Antar, Eddie Gindi The Crazy Eddie Fraud

Red Flags All in all many red flags were raised from the adventures of Crazy Eddie. Should the auditor have become suspicious when so many were found? Decide for yourself. Some of the more blatant ones that the auditor could have caught were: 1. Owners selling off massive amounts of stock. Even with the public explanation of why Eddie sold the stock, selling it off that many times especially when the stock was high should have raised suspicions. 2. The growth in sales. Very high increases in sales are uncommon in any industry except perhaps high tech. Very high increases in sales when the industry was experiencing a slowdown should have caused concern enough to check into it further. This is especially true with inventory turnover decreasing at a rapid rate. 3. Checks written in large amounts of money in round figures for merchandise is not common in any industry concerning goods. 4. Checks written out of sequence. That is, some check numbers and check dates didn't coincide. 5. Purchase orders and shipping documents out of sequence. Shipping documents were dated before the purchase order date. 6. Debit memos in round numbers and out of sequence. The dates on debit memos were out of sequence with the number on the debit memo. 7. Changes in accounting policy were made without reference to the previous policy, especially one that could have a significant effect on the financial statements. 8. Inventories in individual stores were "unusually high compared to the total sales for the particular

store. 9. Unit costs for inventory items in the computer system were much higher than the invoice

amount 10. Missing documents. Documents that would be a normal part of recordkeeping were missing. 11. Unexplained discrepancies. Discrepancies were found in account payable balances for many vendors due to the debit memo scam, but not properly checked out. . * 12. High amount of sales at the end of an accounting period. Deposits in transit should have been reviewed to determine if sales were recorded in the proper period.

The End of the Story By the time Eddie's electronics empire folded, Antar and members of his family had distinguished themselves with a fraud of massive proportions, reaping more *h«n $120 million. By the time this case was concluded, the Securities and Exchange Commission was joined by the FBI, the Postal Inspection Office and a U.S. Attorney in tracking Eddie down. The Crazy Eddie Fraud

All m aU, according to federal indictments, the conspiracy inflated the company's earnings during the first year by about $3 million. By selling off shares of the overvalued stock, the partners pocketed more ifcan $282 million. The next year ihey illegally boosted income by $5.5 million and retail sales by $22 million. This time the group cashed in their stock for a cool $422 million windfell. In the last year before the boom went bust, Eddie and his partners inflated income by $37.5 million and retail by $ 18 million. They didn't have that much stock left though, so despite the big blow-up they only cashed hi for about $83 million.

Maybe he knew the end was at hand, but with takeovers looming, Eddie kept fighting. However, in a proxy battle for Crazy Eddie's, the Antars had too little shareholders' power to stave off the bid. They lost For the first time, Crazy Eddie's was out of Eddie's hands.

The new owners didn't have long to celebrate; They discovered that their ship was sinking fast. Stores were alarmingly understocked, shareholders were suing, suppliers were shutting down credit lines because they were either paid late or not at alL An initial review showed the company's inventory had been overstated by $65 million, a number later raised to more than $80 million. In a desperate maneuver, me new management set up a computerized inventory system and established lines of credit They made peace with fee vendors and cut 150 jobs to reduce overhead. But all this to no avail. Less man a year after the take-over, Crazy Eddie, as it was known in its heyday, was dead

Eddie Antar, on the other hand, was very much alive. But nobody knew where. He faded when it became apparent that the takeover was forcing him out He had set up dummy companies in Liberia, Gibraltar and Panama, along with well-supplied bank accounts in Israel and Switzerland. Sensing his days as Crazy Eddie were numbered, he fled the United States, traveling the world with at least a dozen take passports.

After more than two years on the run, he walked into a police station in Bern, Switzerland—not to turn himself in, though. Using the alias, David Cohen, he demanded help from the police. He was angry because bank officials refused him access to the $32 million he had on account there. Tie bank wouldn't tell "Mr. Cohen" anything, only that he couldn't access the funds. But officials discreetly informed police that the money had been frozen by the U.S. Department of Justice. It didn't take long to realize that David Cohen, the irate millionaire in toe Bern police station, was Eddie Antar. The Crazy Eddie Fraud

It was the last public part Crazy Eddie would have for a while. He eventually pleaded guilty to racketeering and conspiracy charges and was given 82 months in prison, besides having to repay $ 121 million to bilked investors. Almost $72 million had been recovered torn Eddie's personal accounts. In June 1998 successful litigation by the SEC held Eddie's father, brother, and brother in law responsible for fraudulently raising the value of Crazy Eddie stock. The family was also told to hand over its profits from the sale of stock sold on behalf of Eddie's nieces and nephews.

What happened to the Crazy Eddie stores? They're baaack, Crazy Eddie pitchman Jerry Carroll and all. In 1998 Eddie's nephews held a grand opening for a new store in New Jersey selling what else? Electronics. Crazy Eddie Fraud Summary

'Crazy1 Eddie Antar was termed by US Attorney Michael Chertoff "The Darth Vader of Capitalism"

BY U.S. MAESHALS ill II II ||| I :| SgSS I Up y £« Sj jsg ! li'l i ill

Prior to Going Public: A Securities Fraud Committed by Going Legit

In the years years prior to the Crazy Eddie Initial Public Offering (IPO) the company gradually cut down on its skimming each year to increase to growth of its reported pro forma earnings. The effect of the gradual reduction on skimming had a substantial effect on pro forma earnings growth:

Fiscal Year Fiscal Year Fiscal Year Fiscal Year Ended Ended Ended Ended 05/31/80 05/31/81 05/31/82 05/31/83

Income Before Pension Contribution & Income Taxes $1,709,000 $2,273,000 $3,404,000 $4,637,000 Approximate Skimming $3,000,000 $2,500,000 $1,500,000 $ 750,000 Adjusted Income Before Pension Contribution & Income Taxes $4,709,000 $4,773,000 $4,904,000 $5,387,000 Crazy Eddie Securities Frauds after September 13, 1984 Initial Public Offering

Earnings Inflation Fraud

Pre Tax (In $ 000'S)

Low High Low High Fiscal Fiscal Range Range Range Range Year Year Fiscal Fiscal Fiscal Fiscal Ended Ended Year Year Year Year 02/29/84 03/03/85 Ended Ended Ended Ended 03/02/86 03/02/86 03/01/87 03/01/87

Pretax Earnings as Reported 6,582 13,343 26,512 26,512 20,597 20,597

Warehouse Inventory Inflation 0 (3,000) (6,000) (6,000) 0 0 Defective Merchandise (Reeps) 0 0 (1,000) (2,000) (7,500) (8,000) Inventory Inflation Store Inventory Inflation 0 0 (3,000) (4,000) (15,000) (20,000) accounts Payable Cut Off 0 0 (3,000) (4,000) (5,000) (7,000) Fraud Reeps Cut Off Fraud 0 0 0 0 (1,000) (2,000) Debit Memos 0 0 0 0 (20,000) (20,000) Comparable Store Sales Cash Infusion from Previously 0 0 (2,000) (2,000) 0 0 Skimmed Funds Fraud Subtotal 0 (3,000) (15,000) (18,000) (48,500) (57,000)

Less: Cumulative Effect of 0 0 3,000 3,000 15,000 18,000 Previous Years Fraud Fraud effect on Current Year's Earnings Before Audit 0 (3,000) (12,000) (15,000) (33,500) (39,000) Adjustments

Excess Reserves by Auditors to 0 8,000 8,000 8,000 8,000 Smooth Earnings Fraud Effect on Current Earnings After Adjustments by 0 (3,000) (4,000) (7,000) (25,500) (31,000) Auditors

Cumulative Shortage Claimed by New Management in (70,000) (70,000) December 1987

Please note that the above information is based on my testimony provided in depositions and at trial in the Crazy Eddie civil, SEC, and criminal case. The fraud information provided during testimony was approximate. Highlight on Fiscal Year 1986:

• In 1986, we became even greedier.

• The effect on our growth by reducing our prior skimming had run its course and

was no longer beneficial.

• In 1986 they wanted to sell more stock and of course make millions, more. • I was asked, and I participated gladly in creating fictitious sales to initially to boost Crazy Eddies reported comparable store sales and later to boost earnings and earnings growth. • Monies that were previously skimmed in the 1970's had made its way to secret bank accounts at Bank Leumi in Israel. • Crazy Eddie's Fiscal Year now ended in the first Sunday in March instead of May

31.

• Crazy Eddie's same store sales which were ahead up until Christmas 1985 at a rate of 20% were only running ahead 4% for January and February 1986. • Eddie and his father wanted to sell over $30 million in stock by the first week of

March 1986 at the highest possible price. • They transferred or "maybe" advanced $1,500,000 to Crazy Eddie from their secret bank accounts in Israel which contained the previously skimmed funds by first wiring such funds to another bank secrecy jurisdiction in Panama. • Once the funds were in Panama, another family member withdrew such funds from Bank Leumi in the form of drafts so he would not violate laws on movement of funds into the country and bought such funds into Crazy Eddie's offices in

Brooklyn, New York. • I later took these drafts which were in amounts ranging from $50,000 to $100,000 and caused all $1,500,000 of them to be deposited into stores that

were opened in both fiscal years. • They were deposited after the last day of the fiscal year, which was March 3,

1986 and no invoice was generated. • However, because the drafts were dated before the last day of the fiscal year, the deposit was entered as if it occurred and the sale happened before fiscal year end. • The auditors never noticed anything since they did not do a sales cutoff test at

year end in the 1986 audit. • They could have noticed unusually large deposits in transit since the drafts did not clear the bank before fiscal year end.

They could have also noticed that same store sales increased 75 -100% for no apparent reason.

They never checked.

Also, another $500,000 in currency that did not make its way to Israel was deposited in the same store sales.

Finally, a sale of $200,000 to another retailer called "trans shipping" was counted as a retail sale and include in same store sales, thereby artificially increasing same store sales in total by $2,200,000 for the Fiscal Year Ended 1986 and more specifically the last week of that year.

On March 7, 1986 Eddie and his father sold over $30 million dollars of stock and

I was a hero.

The press release issue by Crazy Eddie reported a same store sales increase of

17% for the year and everybody was happy with the news.

However, there was still more sinister plan in action for the Fiscal year End March

2, 1986.

We only issued a same store sales report and the two main principals made a

killing selling their stock.

The audited financial statements for the fiscal year were yet to be issued.

Eddie and his father wanted no earnings surprises.

The effect on our growth by reducing our prior skimming had run its course and was no longer beneficial.

We had already artificially inflated our earnings by $2,000,000 from fictitious sales resulting from monies transferred back to Crazy Eddie that were previously

skimmed.

I helped Eddie, his father and others plan and execute the misstatements of

inventories and accounts payable that taken together with the sales fraud initial

overstated net income by approximately $15 - $18 million.

Inflation of store inventories was particularly easy since the auditor did not supervise the counting of more that 40% of the store units or store inventory

values.

It was also quite easy in a company where the family controlled everything to

receive merchandise weeks before the auditors arrived without any records or

audit trail on Crazy Eddie books and then receive post dated invoices weeks after

the auditors leave. • In the warehouse our conspirators were very accommodating to audit personnel in helping them count merchandise by volunteering to climb over huge stacks of boxes and count all of the units. • They also, helped the audit manager make copies of his test count work papers. • That trick was also done in stores in which the auditors supervised the inventory

counts.

• Fraud by accommodation. • The auditors upon completing the audit believed that Crazy Eddie had substantially understated its profits. • Crazy Eddie's gross margins for the year had been computed at close to 40% when historically it never exceeded 25%. • Our gross margins for the last quarter exceeded 60%. • Eddie and I had discussions with the auditors regarding this so called dilemma. • Never once was the word fraud as a negative connotation toward Crazy Eddie

management considered. • The auditors felt we were the kind of client they could work with. • The partner said, "Nobody got sued for underreporting earnings." • He would set up artificial cushions that he would call "rainy day funds" or "accountants liability insurance." • Therefore, he arbitrarily set up non GAAP conforming allowances of $8 million to offset his perceived $16 million understatement of earnings not knowing the con job that Eddie and I pulled over him. • We rewarded Main Hurdman very dearly after the 1986 audit. • I gave them various contracts for computer system implementation and employee benefit compliance totaling in excess of $1 million per year. • The annual audit fee was approximately $150,000. • Keep your friends close, keep your enemies closer.

Frequently asked questions:

Did Eddie send you to college with the sole intention of making you the company accountant and CFO? Was there ever a time that you thought about changing majors?

He paid me a full time salary because he wanted me eventually to become the Chief Financial Officer of Crazy Eddie. I would have gone to college anyway. I never thought of changing majors. From the age of 12 I read the Wall Street journal and Barron's. I was always intrigued with numbers.

Can you provide me audit procedures that you think would have detected the issues with:

A.) Falsification of inventory

B.) Bogus debit memos

C.) Recording of transshipping transactions as retail sales? (What do they mean by transshipping?)

D.) Inclusion of consign merchandise in year-end inventory?

A. Inventory

1. Store Inventory Frauds for 1986 and 1987: In 1986 we falsified store inventories by $2 - $4 million and in 1987 we falsified store inventories by $15 - $20 million. While the amount of the inventory fraud inflation in the stores may seem low in relation to the frauds being committed today, it is the techniques and the principals employed by the auditors in conducting the audit that could have allowed for potentially a billion dollar inventory fraud had we had the inventory amounts to play with.

The auditors simply did not observe the inventory counts in all of the Crazy Eddie stores. In 1986 they observed the inventory counts in roughly 50% of the stores. When leaving the store premises after the inventory was observed the auditors only took their "test counts" with them and not copies of the entire store inventory. We simply inflated the inventory counts in the stores of which the orders did not observe the inventory counts at year end.

In 1987, we had access to the audit work papers. While the audit work papers where left in locked boxes on Crazy Eddie premises during the audits, the audit manager had left the keys in a small 2" paper clip box and hid it in an unsecured desk.

Therefore, we became more aggressive and increased the store inventories even in greater proportions than the previous years. The reason is that we had the data from the auditors as to how much inventory was in the comparative stores that they observed the inventory counts.

Also, knowing which counts they observed, we than inflated other parts of the inventory in the stores they observed. Therefore we became more aggressive than in 1986 and attempted to increase the store inventories in both observed and non observed stores with the same proportionality. We screwed up and increased the non observed stores by over double the inventory of the observed stores. However, the auditors did nothing!

2. Warehouse Inventories 1985 and 1986: Be nice to your friends and be nicer to your enemies. When boxes were stacked really high and deep we were very courteous to those young kids just out of college who feel that it is beneath them to do physical work. Let the blue collar people do the climbing and counting. When they climb and count and look behind all those rows of cartons in that big 150,000 square foot warehouse they will yell out to those young lazy auditor 200 camcorders (which use to cost $750 each wholesale) when there was actually 150.

This process would go on all night. Afterwards, as the cunning fraudster would build trust with the auditor by buying him coffee during the breaks of doing small errand for the superior intellectual auditor during a moment of little notice he would simply copy the sheet that the auditor used for his test counts. Afterwards, we could inflate the warehouse inventories even more because we knew what not to inflate. By 1987, the warehouse inventory was automated and it as no longer possible to use that method.

B. Debit Memo Fraud 1987: In 1987 $20 million in bogus debit memos were created. There were a total of $28 million in total debit memos in 1987. In previous years the auditors generated an aged schedule of accounts payable.

In 1987 no such analysis was done by the auditors. Had such an analysis been done, the note they mad on their work papers that the reason that accounts payable had been reduced in relation to inventory than in previous years was due to Crazy Eddie using short term commercial paper to pay its vendors more promptly. What was true was that the relative percentage reduction in accounts payable in relation to inventory was due to the large amount of non reconciled bogus debit memos. The true accounts payable without those bogus debit memos was $80 million.

Furthermore, the auditors reconciled the accounts payable of only three major vendors. There were significant reconciling items for all of them, most of which were the bogus debit memos. For a certain vendor, that company had said Crazy Eddie owed it $17 million while we said Sony was owed $7 million and most of the $10 million difference was bogus debit memos.

The auditors never contacted any of the companies they reconciled. The person for the auditors who handled the accounts payable part of the audit never had retail accounts payable audit experience. Finally, the audit partner approved the year end audit number for public release at a board meeting before the accounts payable audit was completed.

C. Transshipping sales as retail sales: Transshipping sales are sales made to non retail customers who are not end users such as other retailers and wholesalers. In Crazy Eddie's early days we had trouble getting merchandise direct from the manufactures because we busted the "fair trade" rules which were enforced to keep prices at the same level and stifle competition. Eventually the "fair trade" rules end.

Before that however, we had to purchase inventory from Tran shippers or other retailers who bought directly from the manufacturer and sold us their excess stocks at a small profit. Later, after the "fair trade" laws ended transshipping still was a source of merchandise for retailers who did not have credit to buy direct from the manufacturers in large enough quantities, did not meet the manufactures standards, could not get stock replenished quickly enough from the manufacturer, and for out of the country grey markets. Eventually, Crazy Eddie was buying direct from most manufacturers. One way we inflated our comparable store sales in the 1987 fiscal year way by using such sales to trans-shippers. What made my actions illegal was that the sales originated from the main office. The trans-shipper would issue a series of checks in small denominations for their purchase which would normally be a large amount of money ($10,000 - $1,000,000).

The small checks (usually in denominations of $10,000 - $20,000) would be deposited into the bank accounts of the retail stores and treated as a regular "off the street" customer retail channel sale.

If the trans-shipping sale had been initiated from the store I have no legal opinion as to fraud because our financial reports and comparable store sale only listed sales - NOT RETAIL SALES per se. It was the manipulation which was wrong. There is still no specific regulation or guidance that I know of from the S.E.C. or the accounting profession regarding comparable store sales and transshipping. Other than cut off issues at year end, this kind of fraud is difficult to catch during an audit if it occurs during the year and not near year end.

D. Inclusion of Consignment Merchandise at Year End: A vendor who we did over 10% of our business with and whose volume with us was over 35% of their business would ship us merchandise to be counted in our inventory at year end. After the auditors finished the audit they post dated the bills into the new fiscal year.

Crazy Eddie Criminal Trial Press Coverage

The Associated Press quoted me as testifying in an article by Jeffrey Gold on the Crazy Eddie criminal trial on June 30,1993:

"The financial plan was to make more money every year and commit more fraud."

Crazy Eddie criminal trial atmosphere as reported in the Associated Press by Jeffrey Gold on July 1, 1993:

Lawyers for the founder of Crazy Eddie and his brothers on Wednesday challenged the credibility of the government's key witness in the stock fraud case. However, they were unable to topple the basic assertions of the witness, Sam E. Antar, a cousin of the defendants who also was an executive in the failed discount electronics chain.

During his four days in the witness box, Sam E. Antar has laid out much of the government's case against Crazy Eddie founder Eddie Antar and his brothers, Mitchell and Allen.

They are accused of bilking stockholders in the chain of $80 million by inflating the value of Crazy Eddie stock through a series of schemes, including exaggerating inventory and deferring invoices. .... during two days of cross-examination, they have sparred with Sam E. Antar, who succeeded his father in the mid-1980s as chief financial officer of the booming company.

The witness has complained that the lawyers wouldn't let him finish his answers. The witness has often finished his responses by telling the lawyers, "Go ahead."

"Don't give me instructions/1 shot back Jack Ford, lawyer for Mitchell Antar. "Judge Politan gives me instructions." Sam E. Antar continued the practice anyway.

When Gerald Krovatin, lawyer for Allen Antar, suggested that Sam E. Antar was being evasive, the witness replied that the question wasn't specific: "Ask a proper question and you'll get the answer you want."

Sam E. Antar reiterated how he has already made a deal with the U.S. attorney, pleading guilty to obstruction of justice and conspiracy to commit stock and mail fraud. He could be sentenced to 10 years in prison, as opposed to hundreds if he had been convicted on all charges.

He also has settled suits with the U.S. Securities and Exchange Commission, and Howard Sirota, lawyer for 10,000 Crazy Eddie stockholders.

Ford asked Sam E. Antar whether he hopes the Antar brothers are convicted so he might get a lighter sentence.

"I wouldn't care either way," Sam E. Antar said. "Right now, it's the truth that's important."

Ford pressed the issue. He noted that Sam E. Antar has testified to about 100 meetings and more than 1,600 phone calls with government lawyers and other investigators opposing the Antar brothers.

Ford reported that Sam E. Antar has cheerfully greeted Sirota and Richard Simpson, lawyer for the SEC, outside the courtroom. Aren't you on their team? Ford said. "I'm not part of any team against anyone," Sam E. Antar replied. "This is not a game, sir. This is real life. "The witness also denied his motive for testifying was revenge because his attempt to gain control of Crazy Eddie with an outside investor failed in late 1987.

On July 6, 1993 Edward R. Silverman covering the Crazy Eddie criminal trial in an article he wrote in Newsday:

"It's like the Addams family went public and ended up in court," said one spectator at the trial.

Money was the glue that held these people together," said Sam Antar, a short, intense man who frequently interrupted his testimony to visit the bathroom and, during breaks, munched on ka'ak, a Middle Eastern cookie. Despite bickering, "when it came to money, they knew how to cooperate." He went on to relate meetings, phone calls and family trivia. To laughter, he told how Eddie thought that Raoul Felder, his first wife's divorce lawyer, is a "moron," and how Eddie once warned him not to tell lawyers the truth, "because they'll just plead for you and not fight hard enough."

Results of Criminal Prosecution, Securities and Exchange Litigation, and Other Litigation:

On July 20, 1993 the criminal trial resulted in the conviction of Eddie Antar and his brother Mitchell Antar. Allen Antar was acquitted. On April 12, 1995 the convictions were over turned on appeal.

However, both Eddie and Mitchell both pled guilty to criminal charges and served time in prison rather than face a re-trial. Eddie served over 6 years in prison and Mitchell served approximately 2 years. The government and various civil litigants have recovered over $75 million from Eddie and $2 million from Mitchell.

Allen Antar, his father Sam M. Antar, and brother in law Benjamin Kuzser were found guilty of civil charges when the SEC instituted and prevailed in a civil case in Newark, NJ Federal Court on July 15, 1999. The Court explicitly rejected the defendants' trial testimony that they were unaware of the frauds that were committed at the company, finding that all three defendants "lacked credibility."

The Court found that the defendants artificially inflated the prices of their Crazy Eddie stock holdings by engaging in an extensive, multifaceted fraud beginning in the 1970s and continuing through 1987. (SEC vs. Sam M. Antar et. al 93-3988 July 16,1998^

Judge Ackerman began is opinion as follows:

There is perhaps no more insidious drain on the overall welfare of society than greed unchecked. The saga of the Antar family and their operation of a major retail consumer electronics business is but a manifestation of that tenet. In this and related cases, it has become evident that various members of the Antar family engaged in a pattern of fraud and deceit in their attempt to enrich themselves by selling securities, the price of which had been artificially inflated through a multitude of schemes. This appears to be the last chapter in a story of a family and its deception of the public.

Some other family and non family members settled litigation issues with the SEC. Various civil judgments against members of the Antar family exceed $500 million. To date the government and various civil litigants have collected approximately $100 million Eddie Antar, Sam M. Antar (his father) Mitchell Antar and Allen Antar (Eddie's brothers) and other members of the Antar family. Other parties such as Crazy Eddie's auditors have also paid millions in litigation settlements. Over $150 million in litigation recoveries has been collected to date.

It is estimated that shareholders recovered over $0.30 per dollar lost on their Crazy Eddie stock. The government collection efforts on its judgments still continue. Summary of my Sentencing:

Guilty Plea: • Conspiracy to Commit Securities Fraud • Conspiracy to Commit Mail Fraud • Obstruction of Justice Criminal Action Sentence by Judge Politan (Major items): • Six months house arrest including costs of monitoring. • 1,200 hours of community service. • Three years of probation. • $10,100 fines and fees. Securities and Exchange Commission Litigation Settlement (Major items): • $80,000 disgorgement for insider trading (while I had lost approximately $8,000 from selling my Crazy Eddie stock, it was determined that I cut my losses by trading on insider information). • Requirement to pay $20,000 of the $80,000 disgorgement based on inability to pay at time of settlement. • Lifetime prohibition from employment as an officer or director of a public company. • Lifetime prohibition from violating securities laws. Note: At sentencing the US Attorney while noting exceptional cooperation recommended jail time for me. I did deserve jail time for my offenses and feel the recommendations for incarceration by the US Attorney was justified. However, I am grateful to the Court and therefore indebted to society for recognizing my exceptional cooperation and not sending me to prison.

See Recent Articles page on this Web Site: New Jersey Law Journal, Article by Tim O'Brien on June 13, 1994, "Footnote to Crazy Eddie Case: You Talk, You Walk"

Major People Involved in Prosecuting and Investigating Crazy Eddie Case (Alphabetical Order):

• Jayne Blumberg (Assistant United States Attorney) - Played a key major role in criminal investigation of Crazy Eddie and examined witnesses at trial. • Michael Chertoff (United States Attorney) - Chief criminal trial counsel. Oversaw Justice Department efforts to prosecute Crazy Eddie fraud case. • Max Folkenflik (Attorney from Folkenflik & McGerity who represented Elias Zinn & Entertainment Marketing, one of the major shareholders who took over Crazy Eddie in a hostile takeover) - Major role in civil investigation of Crazy Eddie fraud. • Howard Hawkins (Attorney from Cadwalader, Wickersham, & Taft who were the Trustees in Bankruptcy for Crazy Eddie) - Major role in civil investigation of Crazy Eddie fraud on behalf of Bankruptcy Court. • Paul Hayes (Special Agent, Federal Bureau of Investigation) - Led the criminal investigation of the Crazy Eddie fraud for the FBI. Played key major roles in the investigation of the frauds and eventual apprehension of Eddie Antar as a fugitive from justice. • Stephen Howard (Attorney from Milbank, Tweed, Hadley, & McCloy who were attorneys for the Oppenheimer-Palmieri fund, L.P. one of the major shareholders who took over Crazy Eddie in a hostile takeover) - Major role in civil investigation of Crazy Eddie fraud. • Richard Ross (Attorney from Carella, Byrne et al, Court Appointed Receiver) - Major role in investigation of the Crazy Eddie fraud and the money trails of the Antar family. • Richard Simpson (Attorney for Securities and Exchange Commission) - Chief trial and litigation counsel for the SEC in its civil cases against the Antar family and other defendants. Led SEC investigation into Crazy Eddie fraud. Played a key and major role in tracking Eddie Antar's whereabouts as a fugitive from justice. • Howard Sirota (Attorney from Sirota & Sirota and Chairman of the Shareholder's Class Action Committee) - Oversaw Civil plaintiff's efforts to prosecute Crazy Eddie case. Led the civil plaintiffs investigation into the Crazy Eddie fraud. Played a key major role in the investigation of the fraud including helping apprehend Eddie as a fugitive. • Richard Wallace (Attorney for Securities and Exchange Commission) - Major role in investigation of the Crazy Eddie fraud. • Paul Weissman (Assistant United States Attorney) - Co-trial counsel with Michael Chertoff in criminal trial. Led the US Attorney's office investigation in the Crazy Eddie fraud. Please note that white collar criminal and civil investigations can be very complex and take years to complete. The SEC began investigating Crazy Eddie in July 1987. The criminal trial began in June 1993. The SEC civil trial was in July 1998. The government is still active in pursuing and collecting judgments against many parties even today. White collar criminal investigations require the resources of many government agencies and many individuals both inside and outside of government over long periods of time.

Any omissions to this list are not intentional and are accidental as others have also played a major role. There were persons from the US Marshalls Service, The US Postal Inspectors Service, Justice Department Inspectors, others plaintiffs attorneys, and other government officials who played major roles. I apologize for any omissions.

Any factual errors and ommissions are unintentional and I apologize for them.

Special Acknowledgement:

I also note the excellent legal representation I received in the Crazy Eddie case:

Criminal Attorney: Anthony Mautone in East Orange, NJ and now also a part time Federal Magistrate in Newark, NJ

Civil Attorney for SEC and Class Action Litigation: Jonathan D. Warner from Warner & Scheuerman in New York, NY Some of the Biggest Crazy Eddie Auditor Errors:

Under educated, under skilled and under experienced audit staff. Lack of investigative skills by auditors. Failure to ask proper questions. Failure to know who to ask proper questions of. Assuming the answers to good questions is correct. Failure to verify answers to questions. Lack of professional skepticism. Allowing company staff to distract auditors from doing filed work by engaging in social conversations thereby wasting time during audits. Failure to observe inventories in all locations. The auditors form 1984 to 1987 did not observe all store inventories or inventories at all locations. Failure to observe inventories simultaneously in all locations. Failure to take copies of full inventories taken when leaving the premises. Failure to conduct proper test counts of inventories by allowing relying on company staff to count boxes. Allowing company staff to take possession of test counts to make copies on behalf of auditors. Failure to follow through on analytical test issues. Failure to conduct all required analytical testing. • Failure to conduct sales cut off testing at year end. Failure to examine items listed as deposits in transit at year end. Failure to age accounts payable. Failure to conduct adequate verification of accounts payable balances. Failure to contact vendors when major discrepancies were identified as vendors sent back verification requests. Failure to secure audit work papers left on premises during the audit by leaving keys to trunks containing audit documents on company premises. Allowing company personnel to view audit work papers in process. Allowing company personnel to distract audit staff conducting the audit to slow them down and thereby have to rush their work in the end to meet the audit deadline. Auditors signed off on financial reports to out directors and allowed issuance of financial statements before audit was completed and backed into numbers. Auditors made misrepresentations to the outside directors about certain questionable practices and directions from the outside directors to investigate them. Auditors made misrepresentations to the SEC about directions from the audit committee to investigate questionable accounting practices. Much, much, more.

Some Crazy Eddie Red Flags:

Virtual absolute control over all aspects of the business by a tight knit family. Very poor internal controls. Virtually unchecked management over ride of internal controls. Very poor audit trails and documentation. Major self dealing transactions and related party transactions by family members. • Absurd raises from absurd below market wages before the company went public in a cash based business. • Big increases in gross margins, profits, inventories, debit memos etc. from prior periods for no logical reason. • Use of "gross margin method" to value inventories during interim periods. • Change of accounting methods for purchase discounts and trade allowances in 1987 from cash basis to accrual basis noted in footnotes with no accounting adjustments. • Small CPA firm that conducted Crazy Eddie audits before (then big eight firm took over audits) had a significant revenue base from Crazy Eddie. • Controller and later CFO for Crazy Eddie (Sam E. Antar) worked for small CPA firm that audited Crazy Eddie books. • Insiders were unloading major amounts of their stock holdings.

Some Certain Lessons for Investors

• Crazy Eddie's internal control issues were disclosed in its footnotes. • Many of the self dealings by principals were fully disclosed. • Barron's had written a critical article about Crazy Eddie that had little long term impact in 1984. • Good analysis of the financial statements and disclosures would have raised some red flags. • Never takeover a retailer in a hostile takeover that has family based management and/or poor internal controls.

Certain Realities Shown by Crazy Eddie Fraud that Everyone Should Heed:

• Both firms that audited Crazy Eddies' books provided significant consulting services and the argument that consulting services helps accounting firms know clients better proved unhelpful in mitigating any fraud. • Crazy Eddie had a former staff member from its "big eight" auditor as its Chief Internal Auditor in 1987 the year of its biggest fraud misstatement. • Therefore, having former staff members of accounting firms join clients easily had no impact in mitigating the fraud. • Certain Sarbanes Oxley provisions should apply to "small market capitalization companies." • Frauds start small and Crazy Eddie had a $40 million market capitalization when it had its initial public offering. The "success" of the fraud increased its market capitalization to over $600 million at one point. • Size does not matter - Crazy Eddie was audited by a small accounting firm, the number 9 accounting firm which then merged into a "big eight" accounting firm which is a "big four" accounting firm today. • Disclosure does not always work - The auditors and the investment community missed the change in accounting method for purchase discounts and trade allowances in 1987. • Good news reporting does not always work - Barron's did a great article on Crazy Eddie exposing a lot of weaknesses to the extent it could prior its IPO in 1984. • Wall Street Analysts do not provide valuable insights to companies - they are at the mercy of management ho provide them with "whisper numbers." • Underwriters perform only surface level (no depth) due diligence and are at the mercy of the negative assurances of accounting firms which is a recipe for disaster since many public registrations take place during interim periods and include non audit information. The public assumes all the information contained in the registrations and presented has been thoroughly examined

Crazy Eddie Auditors:

• 1976 to 1983: Penn & Horowitz (Small Firm). • 1984 to 1986: Main Hurdman (Nineth Largest Firm). • 1987: Peat Marwick (Main Hurdman had merged with Peat Marwick - part of the "Big Eight" accounting firms). Today Peat Marwick is part of KPMG (It is part of the "Big Four" accounting firms). Some Things I Learned the Hard Way:

Crime does not pay and do not commit crime. Crime hurts people and society. Never lie to your attorney. Never lie to the government or in any way obstruct justice. Never lie under oath. The costs of defending a white collar criminal and civil prosecution are onerous and substantial. • Over 85% of persons indicted by the federal government end up pleading guilty or being found guilty in court. • If you are guilty it is better to cut your losses and settle all litigation (criminal and civil) early since the process of white collar investigations are very costly and time consuming and the odds are substantially against you getting away with it. • If you hesitate to settle, the government may cut deals with other persons making matters more difficult for you later on and increasing the likelihood of prison and more jail time and expenses. • The government can almost force people to testify against you (if you are guilty and the witness has such information) by imposing immunity on that witness. • If the witness than refuses to testify with immunity such witness may face prison if convicted for contempt of court. • This process will exact a huge toll on you personally, financially, psychologically, and worst of all on your family members and loved ones.

Note: When new management took over Crazy Eddie on November 6, 1987 to March 8, 1989 I originally stonewalled and obstructed the governments investigation. I lied to my own attorney, to the government under oath, and helped cause others to lie. On March 8, 1989 after I decided to cooperate with the government I changed lawyers since I had no credibility with the lawyer we had represented me. Other Advice from my Experience:

• Neither you nor your lawyer should speak to the press until after the investigation, trial, and sentencing. My lawyers and I gave no comments until after I was sentenced. • Trying your case in public or presenting your side of the story in public does not help you. • It is good free publicity for your attorney and it tips your hand. • It also raises the stakes.

Things I have Come to Learn:

• In the United States of America second chances are possible to those who take responsibility not only in words but also in their deeds and actions. That is just another reason why the United States is the greatest country in the world.

whitecollarfraud.com

Sam E. Antar