20. During all relevant times, Gamboa drafted, reviewed, and/or approved all of PAIM's press releases and disclosures, and authorized their dissemination to the public. In January 2007, PAIM adopted a written policy that expressly provided Gamboa with sole discretion to approve all press releases.
21. Because Gamboa had total control over all aspects of PAIM's operations, she knew or was reckless in not knowing that PAIM's press releases and other public statements contained materially false and misleading statements.