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attesting

09/15/18 1:29 PM

#28730 RE: Porgie Tirebiter #28729

As well as the 8K announcing the SEC investigation
Much more than 4 days passed, during which extended period the CEO was "gifting" shares to his daughter for her house.

I'd say those known facts are relevant to these legal cases.
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janice shell

09/15/18 3:11 PM

#28733 RE: Porgie Tirebiter #28729

That would also make ZN delinquent in the filing of the last 8-K, the regarding the change in CEO.

It would have been a late filing, but it wouldn't count toward what the SEC considers "delinquency". To become a delinquent filer, you have to fail to file Ks and Qs. Needless to say, many companies are occasionally late with material event reports. But since the SEC doesn't typically read all of any company's 8-Ks, they aren't aware of late reports. Naturally since they've taken an interest in ZN, it's possible they do know it was tardy in reporting Carrillo's departure.

Sometime earlier this year, or late last year--can't find it now--I did see an interesting case in which the SEC actually sued a company for reporting a material event late. But that was very unusual; it's the only instance I've seen.