1. There are two other defendants and at least six unindicted alleged co-conspirators
At all times relevant to this Indictment, CAMERON COLLINS was in a relationship with (and subsequently became engaged to be married to) a co-conspirator not named as a defendant herein (“CC-1”)....At all times relevant to this Indictment, STEPHEN ZARSKY, the defendant, was the father of CC-1. He was also married to another co-conspirator not named as a defendant herein (“CC-2”) and was the brother of two co-conspirators not named as defendants herein (“CC-3” and “CC-4”). In addition, ZARSKY was longstanding friends with a Florida-based financial advisor, a co-conspirator not named as a defendant herein (“CC-5”).
2. The accused co-conspirators allegedly saved themselves $768,000, but Collins lost far more than that
In total, these trades allowed CHRISTOPHER COLLINS, CAMERON COLLINS, and STEPHEN ZARSKY, the defendants, and CC-1 through CC-6 to avoid over $768,000 in losses that they would have otherwise incurred if they had sold their stock in Innate after the Drug Trial results became public.
3. Collins is also accused of lying to investigators
On or about April 25, 2018, CHRISTOPHER COLLINS, the defendant, was interviewed by a Special Agent from the Federal Bureau of Investigation. During this interview, CHRISTOPHER COLLINS stated, in substance and in part, that he did not tell CAMERON COLLINS, the defendant, the Drug Trial results before the Public Announcement.
4. The alleged scheme wasn’t exactly well hidden
38. At the time of the phone call with his father, Cameron Collins was with his girlfriend at the home they shared. Approximately fifteen minutes after this call ended, his girlfriend logged into the brokerage account in which she held the Innate shares she had bought two days before.39. Approximately 90 minutes after Cameron Collins spoke to Christopher Collins, Cameron Collins and his girlfriend left their home and drove to the home of her parents. They arrived at approximately 9:17 PM ET.40. Approximately five minutes after arriving at his girlfriend’s parents’ house, Cameron Collins logged into his brokerage account. A few minutes later, at approximately 9:28 PM ET, his girlfriend’s mother logged into her brokerage account and unsuccessfully attempted to place an order to sell all of her Innate shares.41. At 9:34 PM ET, Cameron Collins’s girlfriend’s mother called the brokerage firm, and representatives guided her through the process of selling her shares on the ASX. At 9:58 PM ET, while still on the phone with a brokerage firm representative, she placed an online order to sell all of her 50,000 shares of Innate. 30,250 of her shares sold on the ASX between 9:58 and 10:04 PM ET.
25. The U.S. OTC market was closed when CAMERON COLLINS, the defendant, learned the negative Drug Trial results from CHRISTOPHER COLLINS, the defendant, on or about the night of June 22, 2017. The following morning, at approximately 7:42 AM, CAMERON COLLINS placed an online order with his brokerage firm, to sell approximately 16,508 shares of Innate on the U.S. OTC market. This order was executed at approximately 9:30 AM, when the U.S. OTC market opened.26. Later that day, CAMERON COLLINS, the defendant, placed approximately 17 additional orders to sell Innate Stock. On or about June 26, 2017, the following Monday, CAMERON COLLINS placed approximately 36 additional orders to sell Innate stock. Many of the orders that CAMERON COLLINS placed on June 23, 2017, and June 26, 2017, moreover, occurred after additional discussion with CHRISTOPHER COLLINS, the defendant. For example, on Friday, June 23, 2017, at approximately 3:12 PM, CAMERON COLLINS placed a 5:05 minute call to CHRISTOPHER COLLINS. While the two were still on the phone, CAMERON COLLINS placed an online order with his broker to sell approximately 50,000 shares of Innate.27. In total, CAMERON COLLINS, the defendant, sold approximately 1,391,500 shares of Innate stock between the morning of June 23, 2017 and the close of the market on June 26, 2017, when Innate publicly released the Drug Trial results. These sales allowed CAMERON COLLINS to avoid approximately $570,900 in losses.
5. Collins allegedly told people it was a slam dunk
The year before, Cameron Collins’s girlfriend’s parents also invested in Innate after she told her mother by text message in August 2016, “I think we all need to consider investing in innate therapeutics. I might put in $15k and that has a greater than 50% chance of going up to $250k…….that is actually unheard of and cams dad almost guarantees it within the next 1 to 2 years. . . .” The next day she added, “And we’ll always keep in touch with cams dad who I’m guessing would know how things are looking as we get closer to the end of the trial.” A few days later, she told her mother, “I’ll make sure cams dad keeps us in the loop.”