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LARRY NICHOLS OF DEVON ENERGY COVERS UP CRIME AT THE AMERICAN STOCK EXCHANGE NOW NEW YORK STOCK EXCHANGE

June 23, 2017

CERTIFIED MAIL 7000 0520 0020 5496 3957
RETURN RECEIPT REQUESTED

Edward Manfredonia
8337 St. James Avenue
Apt. 4B
Elmhurst, New York 11373

15 February 2001

Mr. Larry Nichols
Chairman
Devon Energy
22 North Broadway
Oklahoma City, OK 73102
405 235 3611

Dear Mr. Nichols:

I am writing this missive to you because the stock of Devon Energy, which is listed on the American Stock Exchange, has been traded illegally by the specialist of Devon Energy, J. Streicher & Co., on the American Stock Exchange. And this illegal trading has occurred with such regularity and over such a long period of time that the federal government should indict both the specialist unit, J. Streicher & Co., and the American Stock Exchange for its collusion in permitting this massive violation of federal securities laws, under provisions of the Racketeering Influenced Corrupt Organizations Act.

I have written this letter to you to urge you to have the stock of Devon Energy delisted from the American Stock Exchange and moved to the New York Stock Exchange. Furthermore, copies of this letter must be presented to the Board of Directors of Devon Energy. Class action attorneys must be hired to investigate the collusion of the specialist, J. Streicher & Co., and the American Stock Exchange in permitting violations of federal securities laws by the specialist in Devon Energy.

I am the individual portrayed in the 26 April 1999 issue of Business Week as a whistle-blower. The cover story of issue of Business Week was the award winning story, Scandal On Wall Street, which covered a few of the criminal violations of federal securities laws encouraged, permitted, and covered up by the Compliance attorneys and the staff of the American Stock Exchange.

The firm of J. Streicher & Co. on the American Stock Exchange has a long history of violating federal securities laws. The American Stock Exchange has always turned a blind eye towards the criminal activity of its specialist units. And J. Streicher & Co. was an integral part of the AMEX cover up of criminal activity because a partner in J. Streicher & Co., Joel Lovett, was Vice Chairman of the AMEX during the perpetration of major criminal violations of federal securities laws.

Jonathan Quentin Frey is the specialist for Devon Energy. Jonathan Frey is the grandson of the founder of J. Streicher & Co., Joseph Streicher. He is the nephew of the current Chairman of J. Streicher & Co., Judson Streicher.

It is important to know that Joseph Greenwald is the brother of Jonathan Frey. (Same mother, different father.) And it must be noted that Joseph Greenwald is a former attorney who is a convicted felon. In 1994 Joseph Greenwald pleaded guilty to insider trading in Motel 6 and other issues. Joseph Greenwald provided me with inside information in Motel 6, but I have never traded on the basis of inside information. Jonathan Frey received inside information concerning Motel 6 and other issues from his brother, Joseph Greenwald, but the Securities and Exchange Commission, as a favor to Arthur Levitt, and the American Stock Exchange, as a favor to Jonathan Frey, never investigated Frey to determine if Frey had traded on the basis of inside information.

It is important to remember that Joseph Greenwald is a convicted felon and is statutorily disqualified from trading securities, other than as a public customer subject to Reg T. This was part of his consent decree with the Securities and Exchange Commission. It is also important to note that Greenwald paid only a fine of $75,000 for his part in the illegal trading of Motel 6 and other issues when he had earned millions in this insider trading scheme.

In 1994 Joseph Greenwald received three years probation for his role in the insider trading scandal of Motel 6. Immediately Greenwald violated his probation by becoming a professional trader for FNY Corp. His friend Gary Rosen, who received inside information concerning Motel 6 and other issues from Greenwald obtained a position for Greenwald to trade illegally for FNY Corp. Rosen had discussed with Greenwald in my presence trading on the basis of this inside information. Thus, from the outset Greenwald, a convicted felon, was determined to once again violate federal securities laws.

Jonathan Frey knew that his brother, Greenwald, was trading in violation of his probation agreement because he told this to me. The AMEX knew that Greenwald was violating his probation agreement, but refused to report this violation of Greenwald’s probation agreement to the Securities and Exchange Commission.

That is the necessary background information for the following.

Jonathan Frey has consistently sold stocks in which he is the specialist short on a minus tick. The most prominent of these stocks is Devon Energy, a volume leader on the American Stock Exchange. In December 1999 and January 2000, I was informed that Frey had sold the stock of Devon Energy short on a minus tick. Furthermore, Jonathan Frey boasted to his friends that he could sell the stock of Devon Energy short on a minus tick because the AMEX Compliance Department would never discipline him. (More of this later.)

Jonathan Frey also violated other AMEX rules regarding Devon Energy such as purchasing on plus ticks, etc. When he violated AMEX rules, Frey would merely ask his friend, Frank Winowsky, an AMEX Floor Official whose duty it is to monitor trading so that rules are not violated, to sign the specialist book in which all trades are entered so that it would appear that Frey had received prior approval to violate AMEX rules.

The purpose of selling stock short on a minus tick is to drive the price of the stock down so that the stock which had been sold short can be repurchased at a cheaper price. Thus, Jonathan Frey sold the stock of Devon Energy short on a minus tick, which is a violation of the Securities and Exchange Act of 1934, and for which the specialist has no exemption, to drive the price of Devon Energy down so that he could repurchase the stock at a cheaper price.

The stock of Devon Energy was sold short on a minus tick, when Jonathan Frey knew that sell orders in Devon Energy were to appear. Jonathan Frey thus deprived the public shareholders of Devon Energy of a better price than they could have received for their shares of Devon Energy.

Thus Jonathan Frey cheated the public out of a better price. Jonathan Frey laughed to his friends and said that Steven Lister of AMEX Compliance would never investigate J. Streicher & Co.

And it is here that it must be noted that it is well known to the AMEX that Steven Lister accepted bribes, payoffs, not to discipline firms and individuals for violating federal securities laws. The AMEX, as a stock exchange, is a self regulating organization, and in reality is a racketeering organization which should be indicted under RICO.

But this is not the entire story.

In October 1999, I received a missive in the mail. The missive contained details of trading when a secondary issue of Devon Energy was completed. Now it must be remembered that Joseph Greenwald knew that he was being investigated by the AMEX in its disciplinary decision against FNY Corp. But this did not stop Greenwald. Greenwald knew that the corrupt attorneys of the AMEX Compliance Department would take no action against him.

So while trading in the secondary issue of Devon Energy was taking place, Greenwald, in direct violation of his probation, telephoned his brother, Jonathan Frey, on the floor of the AMEX and asked him many questions.

These questions, which violated Greenwald’s probation agreement with the federal government, included the size of the bid and the offer; the names of the purchasers, Morgan Stanley, etc.; and if Jonathan thought that the stock would go up.

Jonathan Frey gave his brother the requested information even though Jonathan Frey knew that providing his brother, Joseph Greenwald, with this information not only violated Greenwald’s statutory disqualification of trading stocks as a professional, but also was privileged information.

Yet this did not deter Frey, the specialist in Devon Energy. Frey willingly assisted his brother in violating federal law and more importantly this violation of federal law involved a stock, Devon Energy, in which Frey was the specialist.

But there is much more to the racketeering flavor of J. Streicher & Co.

In the article, Scandal On Wall Street, a prescient analysis of price fixing in options is described. This price fixing involves collusion between the specialist and the market makers in fixing option prices to the detriment of the public. And two of the most blatant examples of price fixing in options involved two options in which J. Streicher & Co. is the specialist. These two options are Amgen and AOL. The specialist in Amgen is Barry Telsey, another relative of Joe Streicher, and the specialist in AOL is George Roeser.

After the story appeared many reporters and traders approached me and told me of the price fixing in AOL. The specialist in AOL is George Roeser, a not bright individual. Whenever an order for a spread or size would come in George Roeser would look to the guidance of David Palmer, an AMEX Floor Official and market maker. If David Palmer said that the price was good, Roeser and the other market makers would complete the trade. If David Palmer said that he needed what would be a better price for him, George Roeser and the other market makers would agree.

In Amgen, the situation was different. Barry Telsey is an obnoxious individual. As the specialist in Amgen, Telsey had great power in setting prices. And Telsey used his power as a specialist to the detriment of any market maker who improved the markets which he quoted.

I wish to state that for several years traders and brokers had complained to me of the price fixing of options in Amgen and AOL.

Thus, the AMEX widely permitted violations of federal securities laws.

But there is more.

Evan Lovett is the son of Joel Lovett, the former Vice Chairman of the AMEX. Evan Lovett was a specialist for the firm of J. Streicher & Co.

Harbor Securities was a day trading firm which went out of business in October 1999. This occurred when two men, Al Chalem and Maier Lehmann, were murdered. Al Chalem was manipulating stocks through Harbor Securities. Of course, I had reported Harbor Securites for violating federal securities laws to the American Stock Exchange prior to the demise of Harbor Securities. The missive was addressed to Steven Lister, Executive Vice President of the American Stock Exchange and dated 27 June 1999, certified mail Z 405 940 163.

Now why would I report Harbor Securities to the American Stock Exchange? Well, Evan Lovett, while acting as a specialist for J. Streicher & Co., was illegally trading stocks in which he was the specialist for the account of Gene Neale at Harbor Securities. In other words, Evan Lovett made up orders and traded for Gene Neal in violation of federal securities laws.

Now who would inform me of Evan Lovett violating federal securities laws? I shall name two individuals: Jonathan Frey, the specialist for J. Streicher & Co., and Guy Velardi, an investor in Harbor Securities and a day trader for Harbor Securities. (George Roeser, a personal friend of Evan Lovett and an options specialist for J. Streicher & Co., also discussed several aspects of Evan Lovett’s personal life to AMEX members who relayed the information to me.)

I had known of this illegal trading by Evan Lovett and Gene Neale and had reported it to the Department of Justice in 1998, but Mary Jo White, as a favor to Arthur Levitt, took no action. Levitt as former Chairman of the AMEX did not wish any crimes at the AMEX to be reported because I knew many crimes which had occurred during Levitt’s tenure as Chairman of the AMEX.

Evan Lovett had entered into an illegal trading agreement whereby Evan Lovett would trade stocks in which he specialized for the account of Gene Neale and pass along information in other stocks in which the firm of J. Streicher & Co. specialized. Evan Lovett and Gene Neale would then share the profits of this illegal scheme.

Circa 1989, Gene Neale had entered into another illegal transaction with an AMEX market maker in which Neale had traded with an AMEX market maker, who was employed by a major market making firm and thus did not trade his own capital, for the account of the market maker’s wife at Charles Schwab. The charges against Neale were fraud and favorable pricing, but these were never pursued by Steven Lister who inexplicably dropped the investigation.

Note: It was widely known that Lister accepted bribes, including a payoff from a convicted felon, Al Avasso, who in 1992 engineered with the cooperation of Steven Lister, a stock fraud, PNF, on the premises of the AMEX. You can read the article which appeared in a front page story in a July 1992 article about PNF and Avasso. I had informed Lister of the stock fraud in January 1992, but Lister had taken payoffs from Avasso and had permitted the stock fraud, PNF, to be listed on the AMEX.

To return to Evan Lovett, in his bankruptcy filing of December 1997 in White Plains, New York, Evan Lovett listed debts of
$220,000 to Gene Neale
$15,000 to Harbor Securities
and owed money to the mob.
Evan Lovett listed his employer as J. Streicher & Co. and his position as a specialist.

But who else knew that Evan Lovett was trading illegally for Harbor Securities? Joel Lovett, the father of Evan Lovett, knew. Joel Lovett was an investor in Harbor Securities and frequently visited the offices. According to both Frey and Velardi, a former AMEX member who currently owns a seat on the AMEX, Joel Lovett knew that his son, while employed as a specialist for J. Streicher & Co., was illegally trading for the account of Gene Neale at Harbor Securities.

Finally because of many crimes I had exposed at the AMEX including the illegal trading of his son, Joel Lovett was forced to retire from the AMEX and sold his few stocks to J. Streicher & Co.

As you can readily understand it is imperative that the stock of Devon Energy no longer be listed on the American Stock Exchange. The stock of Devon Energy must be listed on the New York Stock Exchange. As I have readily demonstrated the American Stock Exchange and especially the specialist firm of J. Streicher & Co. are racketeering organizations and should be indicted under RICO.

If you do not agree with me, please inform me that you intend to maintain the listing of Devon Energy on the AMEX. I feel that it is imperative that the shareholders know that the specialist firm, J. Streicher & Co., acted as a racketeering organization in the specializing of the stock of Devon Energy. And it must be remembered that this illegal trading and manipulation of the price of Devon Energy by Jonathan Frey occurred with the connivance of an AMEX Floor Official, Frank Winowsky, and of the AMEX Compliance Department.

Sincerely,

Edward Manfredonia

I have enclosed for your perusal:
Relevant documents from the bankruptcy of Evan Lovett
Article from Business Week discussing Motel 6, dated 10 August 1992
Scandal On Wall Street, Business Week, 26 April 1999

I now wish to demonstrate the true racketeering nature of the American Stock Exchange. In the article, Scandal On Wall Street, GHM and Joseph Giamanco are linked to illegal trading by a specialist in stocks in which his firm specialized. I had reported Joseph Giamanco in numerous letters to the AMEX Compliance Attorneys, Steven Lister and Philip Axelrod, for trading stocks in which his firm, GHM, specialized for his personal account. Both refused to investigate Giamanco and Axelrod would frequently taunt me by stating that he would not investigate Giamanco.

Because of the corruption of the AMEX Compliance Department and letters from the Honorable John Dingell to the SEC, NASD was forced to take over the investigation. NASD discovered that Giamanco had massively violated federal securities laws, but has now granted Giamanco a thirty day window to sell his specialist unit before the decision banning Giamanco from the securities business is announced so that he may reap tens of millions of dollars from the sale of his specialist unit.

For a minimum of fifteen years Joseph Giamanco has traded for his personal account stocks in which he was the specialist. For fifteen years Giamanco has been cheating the public and NASD grants him thirty days to sell his specialist unit so that he can reap tens of millions of dollars in illegally made money. Do you wish Devon Energy to be listed on such a racketeering stock exchange?

Edwin Crooks is a governor of the American Stock Exchange, in April 1985 Edwin Crooks told me that he had received inside information on the movement of the XMI on expiration day. Crooks stated that he would receive this information from a source at Morgan Stanley which at the time was the premier program trading firm. Morgan Stanley knew the precise movement of the XMI on expiration day and Crooks’ source would tell him precisely which options, whether puts or calls, and which strike price to purchase. I reported this to Jules Winters, head of Trading Analysis, but Winters refused to investigate. Furthermore, when I reported this to Winters, his subordinates in Trading Analysis told me that there had been many complaints from AMEX members concerning Crooks’ insider trading scheme, but that Jules Winters had refused to investigate because Crooks was a powerful governor of the AMEX. In 1995, fully ten years after I had reported Crooks for insider trading, the AMEX investigated Crooks and he bragged before the hearing that the AMEX would never discipline him.

Perhaps you have heard of the illegal trading of New York Stock Exchange floor brokers for the Oakford Corp. and William Killeen. This resulted in the conviction of seven NYSE floor brokers for illegal trading. Killeen in tape recorded conversations informed me that he had a massive illegal trading scheme on the floor of the American Stock Exchange. Killeen stated that he had thirty AMEX floor brokers trading for him and that he had accounted for 10% of the volume of AMEX stocks.

After the debacle of Bullseye Securities (see article, Scandal On Wall Street) , Steven Lister asked Killeen to stop his illegal trading. No sanctions were imposed by the AMEX on Killeen and Oakford. This occurred in 1995, fully three years before the indictment of Killeen on charges of running an illegal trading scheme on the New York Stock Exchange.

Among those brokers who had traded illegally for Killeen and Oakford Corp. was Peter Orloff whom I had reported for illegal trading for another account which cleared through First Options Corporation in 1991. In 1995 Steven Lister, he of the great payoffs, cleared Orloff for trading illegally even though it was known to Lister that Peter Orloff had been trading illegally for Oakford.

Thus, three years before the indictment of Killeen for running an illegal trading scheme on the NYSE, the American Stock Exchange knew that Killeen was running an identical illegal trading scheme on the AMEX. Furthermore, the AMEX, because of my widespread dissemination of information concerning Bullseye Securities was investigating some of the illegal trading by AMEX members. And some brokers such as Bobby Lewis were disciplined by the AMEX for illegally trading for Bullseye Securities and this was the identical trading as Peter Orloff did for Oakford Corp. This is not to mention that seven NYSE floor brokers have pleaded guilty to felony charges of illegal trading for trading in the identical matter as Peter Orloff.

Peter Orloff traded illegally in violation of federal securities laws and the American Stock Exchange refused to discipline Peter Orloff.

Do you truly wish to have Devon Energy listed on an Exchange where criminality in stock trading is permitted and encouraged?

Your shareholders would not

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