Wednesday, January 09, 2019 9:19:16 PM
https://www.sec.gov/litigation/complaints/2017/comp23805.pdf
Norman T. Reynolds Law Firm
Three Riverway
Suite 1800
Houston, TX 77056
7. Sayid also enlisted the substantial participation of a Texas based attorney,
Norman Reynolds (“Reynolds”), who assisted in the scheme involving Nouveau, which caused
more than 4 million shares of the company’s stock to be issued without restrictive legend and
sold into the market in violation of federal securities laws. Sayid hired Reynolds to send
Nouveau’s transfer agent two fraudulent legal opinion letters, which persuaded Nouveau’s stock
Case 1:17-cv-02630 Document 1 Filed 04/12/17 Page 3 of 33
4
transfer agent to remove restrictive legends from millions of shares of Nouveau stock, setting the
stage for the illegal sale of those shares to the public. Reynolds drafted fraudulent legal opinion
letters with the understanding that they would be sent to Nouveau’s transfer agent
notwithstanding that Reynolds knew or should have known that the representations he made in
them were false.
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