where is the requirement for a pinkie to file Forms 3,4, and 5?
How many pinkies file them?
Some do, some don't. The onus isn't on the company, but on the individual, and the SEC doesn't usually get on their backs about it. But note that when Bob Maheu started working for CMKX, one of the first things he did was to file a Form 3, in which he stated that he didn't own any stock. I guess he wanted to make sure everyone knew where he stood. None of the other officers or directors at that time followed his lead.
My real point is that if Ammerman wants to prove his contention, the best way for him to do that is to file his Forms 3,4, and 5 and get his insiders to do the same.