67 At his sworn interview with the SEC, Hainey stated that “McLeary and Bains” told him there was “100-and-something thousand [Sungro] shares” on deposit and the rest were held in certificate form. On further questioning, Hainey agreed that the discussions relating to Sungro's share structure “started” with McLeary.
¶ 68 In his affidavit that he filed with the Commission and during an earlier sworn interview conducted by the SEC, Williams stated that in June 2009, Hainey told him that Sungro was a “potential float lock-down” company, by which he meant a company with a small float and heavy insider trading. On June 17, Williams told a Monk’s Den core group member that the float was 118,000.
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