SEC v. Naufal B. Sanaullah, No. 2:22-cr-20516, Eastern District of Michigan (Jan. 17, 2025) — Complaint

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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN

UNITED STATES SECURITIES
AND EXCHANGE COMMISSION,
Plaintiff,
v.
NAUFAL SANAULLAH,

Defendant

Case No.

JURY TRIAL DEMANDED

COMPLAINT

Plaintiff United States Securities and Exchange Commission (“SEC”), for its
Complaint against defendant Naufal Sanaullah (“Sanaullah”) alleges as follows:
INTRODUCTION

1. Sanaullah, the Chief Macro Strategist and Chief Risk Officer of a
private fund, made and disseminated false and misleading statements to the fund’s
investors and prospective investors concerning the fund’s risk management
practices (claiming the fund had controls in place it followed; it did not) and his
educational background (claiming to have graduated from the University of
Michigan; he did not).

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2. From at least mid-2017 through May 2022, EIA All Weather Alpha
Fund I Partners, LLC (“EIA”) has been the investment adviser and general partner
to the EIA All Weather Alpha Fund I, LP (the “Fund”). EIA solicited and raised
approximately $39 million from over 100 investors for the Fund. On May 18,
2022, the SEC filed an ex parte emergency civil injunctive action against EIA and
Andrew M. Middlebrooks, EIA’s owner and CEO, to stop an on-going offering
fraud. See SEC v. Middlebrooks, et. al., No. 2:22-cv-11073 (E.D. Mich. May 18,
2022) (the “SEC 2022 Complaint”).
3. The SEC brings this Complaint against Sanaullah for his role at EIA.
From at least December 2017 through October 2021 (the “Relevant Period”),
Sanaullah solicited Fund investors and prospective investors. During this period,
he made false and misleading statements to them concerning the Fund’s risk
management practices. Sanaullah made these statements on phone calls and video
calls, and in emails.
4. Additionally, Sanaullah disseminated, or directed others at EIA to
disseminate, to investors and prospective investors false and misleading
information concerning the Fund’s risk management practices and his educational
background.

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5. During the Relevant Period, Sanaullah knew that the represented risk
control protocols of the Fund were not being followed and that he never graduated
college.
6. By engaging in this conduct, Sanaullah violated Section 17(a) of the
Securities Act of 1933 (“Securities Act”), 15 U.S.C. § 77q(a), Section 10(b) of the
Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78j(b), and
Exchange Act Rule 10b-5, 17 C.F.R. § 240.10b-5. Unless restrained and enjoined,
Defendant will continue to violate the federal securities laws.
7. The SEC seeks, among other things, a permanent injunction,
disgorgement of ill-gotten gains from the unlawful activity set forth in this
Complaint, together with prejudgment interest, and a civil penalty pursuant to
Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d) and Section 21(d)(3) of the
Exchange Act, 15 U.S.C. §78u(d)(3). The SEC also seeks an order barring
Sanaullah from serving as an officer or director of a public company pursuant to
Section 20(e) of the Securities Act, 15 U.S.C. 77t(e) and Section 21(d)(2) of the
Exchange Act, 15 U.S.C. 78u(d)(2).
DEFENDANT
8. Naufal B. Sanaullah (“Sanaullah”), age 34, is a resident of Sylvania,
Ohio and, during the Relevant Period, served as EIA’s Chief Macro Strategist and
Chief Risk Officer.

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OTHER RELEVANT INDIVIDUAL AND ENTITIES

9. Andrew M. Middlebrooks (“Middlebrooks”), age 32, was the Chief
Executive Officer (“CEO”) and Chief Investment Officer (“CIO”) of EIA.
Middlebrooks owned and controlled EIA. On May 16, 2022, the SEC charged
Middlebrooks in the SEC 2022 Complaint. In October 2022, Middlebrooks was
criminally charged with one count of wire fraud and pled guilty to an Information
filed in the United States District Court for the Eastern District of Michigan. USA
v. Andrew H. Middlebrooks, No. 2:22-cr-20516 (E.D. Mich. October 11, 2022).
10. EIA All Weather Alpha Fund I Partners, LLC (“EIA”), is a
Delaware limited liability company formed on or about June 12, 2017, with its
principal place of business in Novi, Michigan. EIA is the investment adviser and
general partner of the Fund. EIA has also conducted business under the names
“EIA All Weather Alpha Partners,” “EIA All Weather Alpha Partners, LLC,” “EIA
Alpha Partners Fund Management,” and “Excellence In Investing In Action Alpha
Partners Fund Management LLC.” The term “EIA” incorporates these additional
names under which EIA acted or purported to act. EIA is not registered with the
SEC or any state as an investment adviser. EIA was charged by the SEC in the
SEC 2022 Complaint, as described above.
11. EIA All Weather Alpha Fund I, LP (“the Fund”), is a Delaware
limited partnership, formed on or about June 13, 2017. It is a pooled investment

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vehicle that has sold limited partnership interests to investors. The Fund’s assets
are managed by EIA, which also serves as its general partner. EIA has also referred
to the Fund as “Excellence in Action (EIA) All Weather Alpha Fund I, LP,” “EIA
All Weather Alpha Fund,” and “EIA All Weather Alpha Partners Fund I, LP” in
various Fund documents and marketing materials. The term the “Fund”
incorporates these additional names under which the Fund acted or purported to
act. The Fund is named as a relief defendant in the SEC 2022 Complaint.
JURISDICTION AND VENUE

12. The Court has jurisdiction over this action pursuant to Sections 20(b),
20(d)(1), and 22(a) of the Securities Act, 15 U.S.C. §§ 77t(b), 77t(d)(1), and
77v(a), and Sections 21(d) and 27 of the Exchange Act, 15 U.S.C. §§ 78u(d) and
78aa.
13. The Court has personal jurisdiction over Sanaullah and venue is
proper in this judicial district, because many of the acts and transactions
constituting violations of the Securities Act and Exchange Act occurred in this
district. In addition, from at least mid-2017 through February 2020 EIA and the
Fund had principal places of business in this district and one or more investors in
the Fund reside in this district.
14. In connection with the conduct alleged in this Complaint, Sanaullah,
directly or indirectly, singly or in concert with others, made use of the means or

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instrumentalities of interstate commerce, the means and instruments of
transportation or communication in interstate commerce, or the mails, including
soliciting investors located in other states and obtaining funds from those investors
through wire transfers in interstate commerce.
FACTS

I. FACTS
A. EIA, the Fund, and Middlebrooks
15. Middlebrooks formed EIA and the Fund in June 2017.
16. Middlebrooks and EIA marketed the Fund as a “quantitative relative
value fund” and a “quantitative long/short equity fund which exploits inefficiencies
in the global equity market to achieve attractive absolute returns.”
17. EIA served as the Fund’s general partner and investment adviser and
Middlebrooks managed the Fund’s portfolio and operations on behalf of EIA.
18. Each investor in the Fund was offered and sold a limited partnership
interest in the Fund.
19. The limited partnership interests in the Fund are securities as defined
in Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange Act.
Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange Act
define “security” to include, among other things, “investment contracts.” The
limited partnership interests in the Fund were investment contracts.

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20. From at least May 2017 through April 2022, EIA raised
approximately $39 million from over 100 investors located across the country.
Investors typically made their investments in the Fund by executing wire transfers
from their financial institutions to EIA’s bank account.
B. Sanaullah’s Role at EIA
21. Middlebrooks hired Sanaullah at EIA in mid-2017. Prior to beginning
work at EIA, Sanaullah attended various colleges, including the University of
Michigan.
22. Sanaullah had not received a college degree at the time he was hired
by EIA and did not receive a college degree at any time while working at EIA.
23. During the Relevant Period, Sanaullah was EIA’s Chief Macro
Strategist and Chief Risk Officer.
24. Sanaullah was held out as a “partner” of EIA to investors.
25. During the Relevant Period, Sanaullah’s job duties included, among
other things, providing oversight of the Fund’s risk management protocols,
soliciting prospective investors, preparing and reviewing written Fund documents,
doing media appearances, and performing macroeconomic analysis.
26. Sanaullah participated in drafting and reviewing Fund documents,
including investor presentations, performance sheets, and a due diligence
questionnaire, that were provided to prospective investors.

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a. The investor presentations were updated quarterly and provided to
prospective investors. Among other things, the investor presentations
set forth the Fund’s risk management protocols and stated Sanaullah
graduated college. Sanaullah participated in drafting and reviewed the
risk management protocol portions and Sanaullah’s education portion
of the investor presentations. Sanaullah also disseminated these
documents to prospective investors.
b. The performance sheets were updated monthly and provided to
prospective investors. Among other things, the performance sheets
stated that Sanaullah graduated college. Sanaullah participated in
drafting and reviewed the statements concerning his college degree in
the performance documents. Sanaullah also disseminated these
documents to prospective investors.
c. The due diligence questionnaire was drafted in 2019 and provided to
certain prospective investors. Among other things, the due diligence
questionnaire discussed the Fund’s risk management protocols and
stated Sanaullah graduated college. Sanaullah participated in drafting
and reviewed the risk management protocols and education portion of
the due diligence questionnaire. Sanaullah also disseminated this
document to prospective investors.

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27. Sanaullah had access to at least a portion of the Fund’s accounts and
Sanaullah traded in at least some of the Fund accounts.
28. From August 2019 through August 2021, Sanaullah received
$553,000 from EIA as compensation.
29. Sanaullah resigned from EIA in October 2021.
30. At the time Sanaullah resigned from EIA in October 2021, the Fund
had received over $34 million in investments from more than 100 investors.
C. Sanaullah Made False and Misleading Statements to Investors
About the Fund’s Risk Management Protocols.
31. During the Relevant Period, Sanaullah solicited new investors for the
Fund and encouraged current Fund investors to invest additional money.
32. Sanaullah communicated with prospective and current investors by
email, phone, and Zoom video calls.
33. During the Relevant Period, Sanaullah told investors that he was the
Chief Risk Officer and he was responsible for the Fund’s overall portfolio risk and
construction.
34. During the Relevant Period, Sanaullah made false and misleading
statements directly to investors on phone and Zoom calls concerning the Fund’s
risk protocols.
a. Sanaullah told investors the Fund adhered to risk management
protocols.

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b. Sanaullah told investors how the risk management protocols were
implemented in the Fund’s overall portfolio.
c. Sanaullah told investors that if the Fund lost 10 or 20 percent of value
in a week, positions would be liquidated to protect the Fund.
35. For example:
a. In January 2020, a prospective investor emailed Sanaullah after a call
and stated: “Thank you for taking the time this morning to speak with
us. I figured your returns would be solid but did not expect this.
Congratulations on the great start.” The investor had at least seven
follow-up calls with Sanaullah. On these calls Sanaullah represented,
among other things, that the Fund had robust risk management
systems. The prospective investor invested in the Fund.
b. In November 2020, Sanaullah directed an EIA employee to send a
potential investor and his son the October 2020 performance sheet.
Sanaullah had several email exchanges and Zoom calls with the
investor and his son over the following months discussing, among
other things, the Fund’s risk management safeguards. The prospective
investor invested in the Fund.
36. In addition to his verbal representations, during the Relevant Period
Sanaullah also made false and misleading statements about the Fund’s risk

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management protocols to investors and prospective investors in emails he wrote
and sent.
a. On July 25, 2019, Sanaullah sent a prospective investor an email
answering due diligence questions, telling the prospective investor
that they [he and Middlebrooks] had updated the answers, reviewed
them, and believed they “got everything.” The due diligence
questionnaire answers in the email stated, in part: “We do have stop
orders always in the book,” and that Middlebrooks and Sanaullah
conduct a weekly review of trading where “[w]e reconcile our trade
log with our positions, as well as make sure available margin is
reconciled with our internal models.”
b. On January 27, 2020, Sanaullah emailed a prospective investor,
stating in part: “As a reminder, we are a hedge fund management
company that is involved in global long/short investing and global
macro trading.  We strive to be able to provide excess returns across
disparate market environments, which is why we use an “all-weather”
and global approach to risk-taking, a proprietary analytics engine
(called GLM Analytics) for long/short equities that is calibrated
differently for different sectors and regions, and a stringent, macro-
influenced approach to portfolio construction and risk management.”

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Sanaullah also provided this wording to another EIA employee to be
used as a template to send to prospective investors, with
Middlebrooks, Sanaullah, and the other employee’s name in the
signature.
37. A reasonable investor would have understood from these verbal and
written statements that the Fund had risk management protocols that were being
implemented and that Sanaullah monitored and controlled the Fund’s risk.
38. These verbal and written statements to investors and prospective
investors about the Fund’s risk management protocols were false and misleading
when made because the Fund was not following the risk management protocols
that had been represented to investors and Sanaullah was not ensuring the risk
management protocols were being followed.
39. Sanaullah’s statements to investors and prospective investors about
the Fund’s risk management protocols were false and misleading when made and
Sanaullah knew or was reckless in not knowing, and should have known, that the
statements were false and misleading. Sanaullah did not always follow the risk
management protocols in his trading for the Fund and from his access to certain
trading accounts Sanaullah could see that Middlebrooks was not following the risk
protocols represented to investors.

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40. While working at EIA, Sanaullah was in daily contact with
Middlebrooks and the two generated numerous WhatsApp and other text message
application threads discussing in real time the Fund’s activity, the Fund’s risk
management practices, and the Fund’s failure to follow the risk management
protocols.
41. Sanaullah repeatedly discussed in his chats with Middlebrooks in
2019 that he was aware of the Fund’s failure to follow any risk management
protocols.
a. On April 3, 2019, Sanaullah wrote to Middlebrooks: (1) “We can’t do
this anymore dude! We just cannot trade without quantifying risks.
Not any longer. Both of us have fucked this up too many times.;”
(2) “I don’t care if we lose money, I care if we are reckless with no
risk mgmt. Yesterday you did not show any risk mgmt.”
b. On April 5, 2019, Sanaullah wrote to Middlebrooks “There’s never
been any risk mgmt. Bc u wanna size everything all the way up
always no matter what. The dumbest fucking thing you’ve done has
been trying to be a heavy every single day since Jan 2018 [.] You
need to realize you hired me and now I have to lie everyday we speak
to ppl ... I feel like a fucking fraud.”

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c. On May 15, 2019, Sanaullah wrote to Middlebrooks: (1) “I’ve told u
for almost two years now. I don’t know how to trade like this. With no
margin, no ability to manage risk.”; (2) “Things will get very very
very fucking bad if don’t utterly crush it. It is absolutely irresponsible
to just assume we will if we work hard enough. It’s utter nonsense.
The opposite of thinking about risk management.”
42. Sanaullah’s false and misleading statements made to Fund investors
and prospective investors concerning the Fund’s risk management practices were
material because they touch upon one of the most fundamental aspects of the
investment, risk analysis, management, and controls. Investors and prospective
investors would want to know if the Fund was failing to provide risk management
of the Fund’s trading decisions and if risk management protocols were not being
monitored or deployed as disclosed.
D. Sanaullah Engaged in Additional Conduct to Mislead Investors
about the Fund’s Risk Management Protocols and his Education.
1. Sanaullah  Disseminated  Materials  with  False  and  Misleading
Statements  to  Investors  About  the  Fund’s  Risk  Management
Protocols.
43. During the Relevant Period, in addition to the material
misrepresentations concerning the Fund’s risk management protocols verbally told
to investors and written in his emails, Sanaullah also participated in drafting and

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reviewing, as well as disseminating, documents with false and misleading
statements concerning the Fund’s risk management protocols.
a. During the Relevant Period, Sanaullah participated in drafting and
reviewing the quarterly investor presentations, which discussed the
Fund’s risk management protocols, and were distributed to investors
and prospective investors. For instance, the December 31, 2017
investor presentation listed Sanaullah as the Chief Macro Strategist,
and stated: “We institute automated portfolio-level risk controls on a
daily-basis....We set hard limits and quantifiable breaks to manage
risk at both the portfolio and position level.... We adhere to a strict
sell discipline.... We employ several techniques to mitigate risk in our
portfolios.”
b. During the Relevant Period, Sanaullah participated in drafting and
reviewing the due diligence questionnaire, which discussed the Fund’s
risk management protocols, and was distributed to investors and
prospective investors. The due diligence questionnaire stated:
i. In response to the question, “What makes your strategy
unique?,” it states: “An intersection of qualitative and
quantitative elements in our process, which allows for a

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disciplined approach to risk management without preventing
the discovery and application of subjective insights”;
ii. Under “Risk and portfolio management”: “We have min/max
ranges for our risk-adjusted exposures across these, and other,
vectors, and our skews within those ranges reflect our
convictions.  We purchased monthly hedges as a rule”;
iii. And, “Our Strategist, [Sanaullah], provides oversight over this
risk management, including alerts from our risk models.”
44. Sanaullah disseminated these documents. Sanaullah sent, or directed
others to send, either before or after phone and Zoom calls with investors and
prospective investors, an email attaching the investor presentations and due
diligence questionnaire that contained false and misleading statements about the
Fund’s risk management.
45. A reasonable investor would have understood from these written
statements that the Fund had risk management protocols that were being
implemented and that the Fund’s risk was being monitored and controlled by
Sanaullah.
46. As explained above, these statements concerning risk management
protocols were false and misleading when made because the Fund was not
following the risk management protocols that had been represented to investors

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and Sanaullah was not ensuring the risk management protocols were being
followed.
47. The statements to investors and prospective investors about the
Fund’s risk management protocols were false and misleading when made and
Sanaullah knew or was reckless in not knowing, and should have known, that the
statements were false and misleading. Sanaullah did not always follow the risk
management protocols in his trading for the Fund and from his access to certain
trading accounts Sanaullah could see that Middlebrooks was not following the risk
protocols represented to investors. As discussed above, Sanaullah discussed the
Fund’s failure to adhere to the disclosed risk management protocols in chats with
Middlebrooks.
48. The false and misleading statements made to Fund investors and
prospective investors concerning the Fund’s risk management practices were
material because they touch upon one of the most fundamental aspects of the
investment, risk analysis, management, and controls. Investors and prospective
investors would want to know if the Fund was failing to provide risk management
of the Fund’s trading decisions and if risk management was not being monitored or
deployed as disclosed.

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2. Sanaullah  Disseminated  Materials  with  False  and  Misleading
Statements to Investors About Having Graduated College.
49. Additionally, Sanaullah participated in drafting and reviewing
documents, and disseminated documents, with false and misleading statements
concerning his educational background, stating he had a college degree, when he
did not.
50. Sanaullah participated in the drafting and review of investor
presentations, performance sheets, and a due diligence questionnaire that were
provided to investors and prospective investors that contained false and misleading
statements about his education.
a. From at least December 2017 through the Relevant Period, quarterly
investor presentations stated Sanaullah “received his degree in 2011
from University of Michigan.”
b. From at least April 2019 through the Relevant Period, performance
sheets stated Sanaullah “studied Mathematics at the University of
Michigan (B.A. 2011)” or that Sanaullah “received his degree in 2011
from University of Michigan.”
c. From at least mid-2019 through the Relevant Period, a due diligence
questionnaire stated Sanaullah “studied Mathematical Sciences at the
University of Michigan, graduating in 2011.”

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51. Sanaullah disseminated these documents. Sanaullah sent, or directed
others to send, either before or after the investor calls, an email attaching the
investor presentations, performance sheets, or due diligence questionnaire that
contained false and misleading statements about his education.
52. A reasonable investor would have understood from these statements
that Sanaullah had graduated from college and, specifically, received an
undergraduate degree from the University of Michigan in Mathematics.
53. The statements about Sanaullah receiving his degree from the
University of Michigan were false and misleading because, while Sanaullah did
attend the University of Michigan, he did not graduate or obtain a degree from
University of Michigan or any other college.
54. The statements about Sanaullah in the performance sheets, investor
presentations, and due diligence questionnaire were false and misleading when
made and Sanaullah knew or was reckless in not knowing, and should have known,
that the statements indicating that he received a college degree were false and
misleading because he was aware he had not received a degree from any college.
55. The false and misleading statements Sanaullah made to investors and
prospective investors about his degree from the University of Michigan were
material because reasonable investors and prospective investors would want to

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know about the education of the person responsible for oversight of the Fund’s risk
management protocols, including whether that person had graduated from college.
E. Payments to Sanaullah from EIA
56. From August 2019 through August 2021, Sanaullah received
payments from EIA totaling $553,000.

57. EIA was only able to pay Sanaullah because of the funds obtained
from investors during the Relevant Period.
58. Sanaullah thus obtained this money through the material
misstatements referenced above, which were made “in the offer or sale” of
securities.
CLAIMS FOR RELIEF

First Claim for Relief
Section 17(a) of the Securities Act

59. The SEC realleges and incorporates by reference the above
paragraphs 1 through 58 as though fully set forth herein.
60. Sanaullah, directly or indirectly, in the offer or sale of securities by
the use of means or instruments of transportation or communication in interstate
commerce or by use of the mails, acting with the requisite state of mind:
(a) employed devices, schemes, or artifices to defraud; (b) obtained money or
property by means of untrue statements of a material fact or by omitting to state a
material fact necessary in order to make the statements made, in light of the

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circumstances under which they were made, not misleading; and (c) engaged in
transactions, practices, or courses of business which operated or would operate as a
fraud or deceit upon the purchaser.
61. By engaging in the conduct described above, Sanaullah violated, and
unless restrained and enjoined will continue to violate, Section 17(a) of the
Securities Act. 15 U.S.C. §§ 77q(a).
Second Claim for Relief
Section 10(b) and Rule 10b-5 of the Exchange Act

62. The SEC realleges and incorporates by reference above paragraphs 1
through 58 as though fully set forth herein.
63. Sanaullah, directly or indirectly, in connection with the purchase or
sale of a security, and by the use of means or instrumentalities of interstate
commerce, of the mails, or of the facilities of a national securities exchange,
knowingly and recklessly: (a) employed devices, schemes, or artifices to defraud;
(b) made untrue statements of a material fact or omitted to state a material fact
necessary in order to make the statements made, in the light of the circumstances
under which they were made, not misleading; and (c) engaged in acts, practices, or
courses of business which operated or would operate as a fraud or deceit upon
other persons.
64. By engaging in the conduct described above, Sanaullah violated, and
unless restrained and enjoined will continue to violate, Section 10(b) of the

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Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 thereunder, 17 C.F.R.
§ 240.10b-5.
RELIEF REQUESTED

          WHEREFORE, the SEC respectfully requests that this Court:
I.
 Find that the Defendant committed the violations alleged in this Complaint;
II.
 Enter an injunction, in a form consistent with Rule 65 of the Federal Rules
of Civil Procedure, permanently restraining and enjoining Defendant and his
agents, servants, employees, attorneys, and accountants, and those persons in
active concert or participation with him, who receive actual notice of the Judgment
by personal service or otherwise, and each of them, from engaging in transactions,
acts, practices, and courses of business described herein, and from engaging in
conduct of similar purport and object in violation of Section 17(a) of the Securities
Act, 15 U.S.C. § 77q(a) and Section 10(b) of the Exchange Act, 15 U.S.C. §
78j(b), and Exchange Act Rule 10b-5, 17 C.F.R. § 240.10b-5, thereunder;
III.
 Order Sanaullah to disgorge ill-gotten gains received during the period of
violative conduct and pay prejudgment interest on such ill-gotten gains;

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IV.
 Order Sanaullah to pay a civil money penalty pursuant to Section 20(d) of
the Securities Act, 15 U.S.C. § 77t(d) and Section 21(d)(3) of the Exchange Act,
15 U.S.C. § 78u(d)(3);
V.
 Order that Sanaullah be permanently prohibited from acting as an officer and
director of any public company; and
VI.
 Grant such other and further relief as this Court may deem just and proper.

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JURY DEMAND
The SEC demands a trial by jury on all claims so triable.

Dated:  Januar
y 16, 2025  Respectfully submitted,

 B
y: s/ Zachary T. Carlyle
  Zachary T. Carlyle
U.S. Securities and Exchange
Commission
1961 Stout Street, Suite 1700
Denver, CO 80294-1961
Telephone: 303.844.1084 (Carlyle)
Email: [email protected]
Attorneys for Plaintiff
U.S. Securities and Exchange
Commission

Local Counsel For Plaintiff
          DAWN         N.         ISON
United States Attorney
Kevin R. Erskine (P69120)
Assistant United States Attorney
U.S.   Attorney’s   Office   –   Eastern
District of Michigan
211 West Fort Street, Suite 2001
Detroit, Michigan 48226
Telephone: (313) 226-9610
Email: Kevin.Erskine
@usdoj.gov

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UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF MICHIGAN 

 

 
UNITED STATES SECURITIES 
AND EXCHANGE COMMISSION, 

Plaintiff, 

v. 

NAUFAL SANAULLAH,  
 

Defendant 

 
 
 
 
Case No.  
 
 
JURY TRIAL DEMANDED 
 
 
 
 
 

COMPLAINT  

 
Plaintiff United States Securities and Exchange Commission (“SEC”), for its 

Complaint against defendant Naufal Sanaullah (“Sanaullah”) alleges as follows: 

INTRODUCTION 
 

1. Sanaullah, the Chief Macro Strategist and Chief Risk Officer of a 

private fund, made and disseminated false and misleading statements to the fund’s 

investors and prospective investors concerning the fund’s risk management 

practices (claiming the fund had controls in place it followed; it did not) and his 

educational background (claiming to have graduated from the University of 

Michigan; he did not). 

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2. From at least mid-2017 through May 2022, EIA All Weather Alpha 

Fund I Partners, LLC (“EIA”) has been the investment adviser and general partner 

to the EIA All Weather Alpha Fund I, LP (the “Fund”). EIA solicited and raised 

approximately $39 million from over 100 investors for the Fund. On May 18, 

2022, the SEC filed an ex parte emergency civil injunctive action against EIA and 

Andrew M. Middlebrooks, EIA’s owner and CEO, to stop an on-going offering 

fraud. See SEC v. Middlebrooks, et. al., No. 2:22-cv-11073 (E.D. Mich. May 18, 

2022) (the “SEC 2022 Complaint”). 

3. The SEC brings this Complaint against Sanaullah for his role at EIA. 

From at least December 2017 through October 2021 (the “Relevant Period”), 

Sanaullah solicited Fund investors and prospective investors. During this period, 

he made false and misleading statements to them concerning the Fund’s risk 

management practices. Sanaullah made these statements on phone calls and video 

calls, and in emails. 

4. Additionally, Sanaullah disseminated, or directed others at EIA to 

disseminate, to investors and prospective investors false and misleading 

information concerning the Fund’s risk management practices and his educational 

background. 

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5. During the Relevant Period, Sanaullah knew that the represented risk 

control protocols of the Fund were not being followed and that he never graduated 

college. 

6. By engaging in this conduct, Sanaullah violated Section 17(a) of the 

Securities Act of 1933 (“Securities Act”), 15 U.S.C. § 77q(a), Section 10(b) of the 

Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78j(b), and 

Exchange Act Rule 10b-5, 17 C.F.R. § 240.10b-5. Unless restrained and enjoined, 

Defendant will continue to violate the federal securities laws. 

7. The SEC seeks, among other things, a permanent injunction, 

disgorgement of ill-gotten gains from the unlawful activity set forth in this 

Complaint, together with prejudgment interest, and a civil penalty pursuant to 

Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d) and Section 21(d)(3) of the 

Exchange Act, 15 U.S.C. §78u(d)(3). The SEC also seeks an order barring 

Sanaullah from serving as an officer or director of a public company pursuant to 

Section 20(e) of the Securities Act, 15 U.S.C. 77t(e) and Section 21(d)(2) of the 

Exchange Act, 15 U.S.C. 78u(d)(2). 

DEFENDANT 

8. Naufal B. Sanaullah (“Sanaullah”), age 34, is a resident of Sylvania, 

Ohio and, during the Relevant Period, served as EIA’s Chief Macro Strategist and 

Chief Risk Officer. 

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OTHER RELEVANT INDIVIDUAL AND ENTITIES 
 

9. Andrew M. Middlebrooks (“Middlebrooks”), age 32, was the Chief 

Executive Officer (“CEO”) and Chief Investment Officer (“CIO”) of EIA. 

Middlebrooks owned and controlled EIA. On May 16, 2022, the SEC charged 

Middlebrooks in the SEC 2022 Complaint. In October 2022, Middlebrooks was 

criminally charged with one count of wire fraud and pled guilty to an Information 

filed in the United States District Court for the Eastern District of Michigan. USA 

v. Andrew H. Middlebrooks, No. 2:22-cr-20516 (E.D. Mich. October 11, 2022). 

10. EIA All Weather Alpha Fund I Partners, LLC (“EIA”), is a 

Delaware limited liability company formed on or about June 12, 2017, with its 

principal place of business in Novi, Michigan. EIA is the investment adviser and 

general partner of the Fund. EIA has also conducted business under the names 

“EIA All Weather Alpha Partners,” “EIA All Weather Alpha Partners, LLC,” “EIA 

Alpha Partners Fund Management,” and “Excellence In Investing In Action Alpha 

Partners Fund Management LLC.” The term “EIA” incorporates these additional 

names under which EIA acted or purported to act. EIA is not registered with the 

SEC or any state as an investment adviser. EIA was charged by the SEC in the 

SEC 2022 Complaint, as described above. 

11. EIA All Weather Alpha Fund I, LP (“the Fund”), is a Delaware 

limited partnership, formed on or about June 13, 2017. It is a pooled investment 

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vehicle that has sold limited partnership interests to investors. The Fund’s assets 

are managed by EIA, which also serves as its general partner. EIA has also referred 

to the Fund as “Excellence in Action (EIA) All Weather Alpha Fund I, LP,” “EIA 

All Weather Alpha Fund,” and “EIA All Weather Alpha Partners Fund I, LP” in 

various Fund documents and marketing materials. The term the “Fund” 

incorporates these additional names under which the Fund acted or purported to 

act. The Fund is named as a relief defendant in the SEC 2022 Complaint.  

JURISDICTION AND VENUE 
 

12. The Court has jurisdiction over this action pursuant to Sections 20(b), 

20(d)(1), and 22(a) of the Securities Act, 15 U.S.C. §§ 77t(b), 77t(d)(1), and 

77v(a), and Sections 21(d) and 27 of the Exchange Act, 15 U.S.C. §§ 78u(d) and 

78aa. 

13. The Court has personal jurisdiction over Sanaullah and venue is 

proper in this judicial district, because many of the acts and transactions 

constituting violations of the Securities Act and Exchange Act occurred in this 

district. In addition, from at least mid-2017 through February 2020 EIA and the 

Fund had principal places of business in this district and one or more investors in 

the Fund reside in this district. 

14. In connection with the conduct alleged in this Complaint, Sanaullah, 

directly or indirectly, singly or in concert with others, made use of the means or 

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instrumentalities of interstate commerce, the means and instruments of 

transportation or communication in interstate commerce, or the mails, including 

soliciting investors located in other states and obtaining funds from those investors 

through wire transfers in interstate commerce. 

FACTS 
 
I. FACTS 

A. EIA, the Fund, and Middlebrooks 

15. Middlebrooks formed EIA and the Fund in June 2017. 

16. Middlebrooks and EIA marketed the Fund as a “quantitative relative 

value fund” and a “quantitative long/short equity fund which exploits inefficiencies 

in the global equity market to achieve attractive absolute returns.” 

17. EIA served as the Fund’s general partner and investment adviser and 

Middlebrooks managed the Fund’s portfolio and operations on behalf of EIA. 

18. Each investor in the Fund was offered and sold a limited partnership 

interest in the Fund.  

19. The limited partnership interests in the Fund are securities as defined 

in Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange Act. 

Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange Act 

define “security” to include, among other things, “investment contracts.” The 

limited partnership interests in the Fund were investment contracts.  

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20. From at least May 2017 through April 2022, EIA raised 

approximately $39 million from over 100 investors located across the country. 

Investors typically made their investments in the Fund by executing wire transfers 

from their financial institutions to EIA’s bank account. 

B. Sanaullah’s Role at EIA 

21. Middlebrooks hired Sanaullah at EIA in mid-2017. Prior to beginning 

work at EIA, Sanaullah attended various colleges, including the University of 

Michigan.  

22. Sanaullah had not received a college degree at the time he was hired 

by EIA and did not receive a college degree at any time while working at EIA. 

23. During the Relevant Period, Sanaullah was EIA’s Chief Macro 

Strategist and Chief Risk Officer.  

24. Sanaullah was held out as a “partner” of EIA to investors. 

25. During the Relevant Period, Sanaullah’s job duties included, among 

other things, providing oversight of the Fund’s risk management protocols, 

soliciting prospective investors, preparing and reviewing written Fund documents, 

doing media appearances, and performing macroeconomic analysis. 

26. Sanaullah participated in drafting and reviewing Fund documents, 

including investor presentations, performance sheets, and a due diligence 

questionnaire, that were provided to prospective investors. 

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a. The investor presentations were updated quarterly and provided to 

prospective investors. Among other things, the investor presentations 

set forth the Fund’s risk management protocols and stated Sanaullah 

graduated college. Sanaullah participated in drafting and reviewed the 

risk management protocol portions and Sanaullah’s education portion 

of the investor presentations. Sanaullah also disseminated these 

documents to prospective investors. 

b. The performance sheets were updated monthly and provided to 

prospective investors. Among other things, the performance sheets 

stated that Sanaullah graduated college. Sanaullah participated in 

drafting and reviewed the statements concerning his college degree in 

the performance documents. Sanaullah also disseminated these 

documents to prospective investors. 

c. The due diligence questionnaire was drafted in 2019 and provided to 

certain prospective investors. Among other things, the due diligence 

questionnaire discussed the Fund’s risk management protocols and 

stated Sanaullah graduated college. Sanaullah participated in drafting 

and reviewed the risk management protocols and education portion of 

the due diligence questionnaire. Sanaullah also disseminated this 

document to prospective investors. 

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27. Sanaullah had access to at least a portion of the Fund’s accounts and 

Sanaullah traded in at least some of the Fund accounts.  

28. From August 2019 through August 2021, Sanaullah received 

$553,000 from EIA as compensation.   

29. Sanaullah resigned from EIA in October 2021.  

30. At the time Sanaullah resigned from EIA in October 2021, the Fund 

had received over $34 million in investments from more than 100 investors.  

C. Sanaullah Made False and Misleading Statements to Investors 
About the Fund’s Risk Management Protocols. 

31. During the Relevant Period, Sanaullah solicited new investors for the 

Fund and encouraged current Fund investors to invest additional money.  

32. Sanaullah communicated with prospective and current investors by 

email, phone, and Zoom video calls.  

33. During the Relevant Period, Sanaullah told investors that he was the 

Chief Risk Officer and he was responsible for the Fund’s overall portfolio risk and 

construction.   

34. During the Relevant Period, Sanaullah made false and misleading 

statements directly to investors on phone and Zoom calls concerning the Fund’s 

risk protocols.   

a. Sanaullah told investors the Fund adhered to risk management 

protocols.   

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b. Sanaullah told investors how the risk management protocols were 

implemented in the Fund’s overall portfolio.   

c. Sanaullah told investors that if the Fund lost 10 or 20 percent of value 

in a week, positions would be liquidated to protect the Fund.   

35. For example: 

a. In January 2020, a prospective investor emailed Sanaullah after a call 

and stated: “Thank you for taking the time this morning to speak with 

us. I figured your returns would be solid but did not expect this. 

Congratulations on the great start.” The investor had at least seven 

follow-up calls with Sanaullah. On these calls Sanaullah represented, 

among other things, that the Fund had robust risk management 

systems. The prospective investor invested in the Fund.   

b. In November 2020, Sanaullah directed an EIA employee to send a 

potential investor and his son the October 2020 performance sheet. 

Sanaullah had several email exchanges and Zoom calls with the 

investor and his son over the following months discussing, among 

other things, the Fund’s risk management safeguards. The prospective 

investor invested in the Fund.   

36. In addition to his verbal representations, during the Relevant Period 

Sanaullah also made false and misleading statements about the Fund’s risk 

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management protocols to investors and prospective investors in emails he wrote 

and sent.   

a. On July 25, 2019, Sanaullah sent a prospective investor an email 

answering due diligence questions, telling the prospective investor 

that they [he and Middlebrooks] had updated the answers, reviewed 

them, and believed they “got everything.” The due diligence 

questionnaire answers in the email stated, in part: “We do have stop 

orders always in the book,” and that Middlebrooks and Sanaullah 

conduct a weekly review of trading where “[w]e reconcile our trade 

log with our positions, as well as make sure available margin is 

reconciled with our internal models.”   

b. On January 27, 2020, Sanaullah emailed a prospective investor, 

stating in part: “As a reminder, we are a hedge fund management 

company that is involved in global long/short investing and global 

macro trading.  We strive to be able to provide excess returns across 

disparate market environments, which is why we use an “all-weather” 

and global approach to risk-taking, a proprietary analytics engine 

(called GLM Analytics) for long/short equities that is calibrated 

differently for different sectors and regions, and a stringent, macro-

influenced approach to portfolio construction and risk management.”  

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Sanaullah also provided this wording to another EIA employee to be 

used as a template to send to prospective investors, with 

Middlebrooks, Sanaullah, and the other employee’s name in the 

signature.   

37. A reasonable investor would have understood from these verbal and 

written statements that the Fund had risk management protocols that were being 

implemented and that Sanaullah monitored and controlled the Fund’s risk. 

38. These verbal and written statements to investors and prospective 

investors about the Fund’s risk management protocols were false and misleading 

when made because the Fund was not following the risk management protocols 

that had been represented to investors and Sanaullah was not ensuring the risk 

management protocols were being followed.   

39. Sanaullah’s statements to investors and prospective investors about 

the Fund’s risk management protocols were false and misleading when made and 

Sanaullah knew or was reckless in not knowing, and should have known, that the 

statements were false and misleading. Sanaullah did not always follow the risk 

management protocols in his trading for the Fund and from his access to certain 

trading accounts Sanaullah could see that Middlebrooks was not following the risk 

protocols represented to investors. 

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40. While working at EIA, Sanaullah was in daily contact with 

Middlebrooks and the two generated numerous WhatsApp and other text message 

application threads discussing in real time the Fund’s activity, the Fund’s risk 

management practices, and the Fund’s failure to follow the risk management 

protocols.  

41. Sanaullah repeatedly discussed in his chats with Middlebrooks in 

2019 that he was aware of the Fund’s failure to follow any risk management 

protocols.  

a. On April 3, 2019, Sanaullah wrote to Middlebrooks: (1) “We can’t do 

this anymore dude! We just cannot trade without quantifying risks. 

Not any longer. Both of us have fucked this up too many times.;” 

(2) “I don’t care if we lose money, I care if we are reckless with no 

risk mgmt. Yesterday you did not show any risk mgmt.”  

b. On April 5, 2019, Sanaullah wrote to Middlebrooks “There’s never 

been any risk mgmt. Bc u wanna size everything all the way up 

always no matter what. The dumbest fucking thing you’ve done has 

been trying to be a heavy every single day since Jan 2018 [.] You 

need to realize you hired me and now I have to lie everyday we speak 

to ppl … I feel like a fucking fraud.”  

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c. On May 15, 2019, Sanaullah wrote to Middlebrooks: (1) “I’ve told u 

for almost two years now. I don’t know how to trade like this. With no 

margin, no ability to manage risk.”; (2) “Things will get very very 

very fucking bad if don’t utterly crush it. It is absolutely irresponsible 

to just assume we will if we work hard enough. It’s utter nonsense. 

The opposite of thinking about risk management.”  

42. Sanaullah’s false and misleading statements made to Fund investors 

and prospective investors concerning the Fund’s risk management practices were 

material because they touch upon one of the most fundamental aspects of the 

investment, risk analysis, management, and controls. Investors and prospective 

investors would want to know if the Fund was failing to provide risk management 

of the Fund’s trading decisions and if risk management protocols were not being 

monitored or deployed as disclosed. 

D. Sanaullah Engaged in Additional Conduct to Mislead Investors 
about the Fund’s Risk Management Protocols and his Education. 

1. Sanaullah Disseminated Materials with False and Misleading 
Statements to Investors About the Fund’s Risk Management 
Protocols. 

43. During the Relevant Period, in addition to the material 

misrepresentations concerning the Fund’s risk management protocols verbally told 

to investors and written in his emails, Sanaullah also participated in drafting and 

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reviewing, as well as disseminating, documents with false and misleading 

statements concerning the Fund’s risk management protocols. 

a. During the Relevant Period, Sanaullah participated in drafting and 

reviewing the quarterly investor presentations, which discussed the 

Fund’s risk management protocols, and were distributed to investors 

and prospective investors. For instance, the December 31, 2017 

investor presentation listed Sanaullah as the Chief Macro Strategist, 

and stated: “We institute automated portfolio-level risk controls on a 

daily-basis.…We set hard limits and quantifiable breaks to manage 

risk at both the portfolio and position level.… We adhere to a strict 

sell discipline.… We employ several techniques to mitigate risk in our 

portfolios.”  

b. During the Relevant Period, Sanaullah participated in drafting and 

reviewing the due diligence questionnaire, which discussed the Fund’s 

risk management protocols, and was distributed to investors and 

prospective investors. The due diligence questionnaire stated: 

i. In response to the question, “What makes your strategy 

unique?,” it states: “An intersection of qualitative and 

quantitative elements in our process, which allows for a 

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disciplined approach to risk management without preventing 

the discovery and application of subjective insights”; 

ii. Under “Risk and portfolio management”: “We have min/max 

ranges for our risk-adjusted exposures across these, and other, 

vectors, and our skews within those ranges reflect our 

convictions.  We purchased monthly hedges as a rule”; 

iii. And, “Our Strategist, [Sanaullah], provides oversight over this 

risk management, including alerts from our risk models.” 

44. Sanaullah disseminated these documents. Sanaullah sent, or directed 

others to send, either before or after phone and Zoom calls with investors and 

prospective investors, an email attaching the investor presentations and due 

diligence questionnaire that contained false and misleading statements about the 

Fund’s risk management.   

45. A reasonable investor would have understood from these written 

statements that the Fund had risk management protocols that were being 

implemented and that the Fund’s risk was being monitored and controlled by 

Sanaullah. 

46. As explained above, these statements concerning risk management 

protocols were false and misleading when made because the Fund was not 

following the risk management protocols that had been represented to investors 

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and Sanaullah was not ensuring the risk management protocols were being 

followed.   

47. The statements to investors and prospective investors about the 

Fund’s risk management protocols were false and misleading when made and 

Sanaullah knew or was reckless in not knowing, and should have known, that the 

statements were false and misleading. Sanaullah did not always follow the risk 

management protocols in his trading for the Fund and from his access to certain 

trading accounts Sanaullah could see that Middlebrooks was not following the risk 

protocols represented to investors. As discussed above, Sanaullah discussed the 

Fund’s failure to adhere to the disclosed risk management protocols in chats with 

Middlebrooks. 

48. The false and misleading statements made to Fund investors and 

prospective investors concerning the Fund’s risk management practices were 

material because they touch upon one of the most fundamental aspects of the 

investment, risk analysis, management, and controls. Investors and prospective 

investors would want to know if the Fund was failing to provide risk management 

of the Fund’s trading decisions and if risk management was not being monitored or 

deployed as disclosed. 

 

 

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2. Sanaullah Disseminated Materials with False and Misleading 
Statements to Investors About Having Graduated College. 

49. Additionally, Sanaullah participated in drafting and reviewing 

documents, and disseminated documents, with false and misleading statements 

concerning his educational background, stating he had a college degree, when he 

did not. 

50. Sanaullah participated in the drafting and review of investor 

presentations, performance sheets, and a due diligence questionnaire that were 

provided to investors and prospective investors that contained false and misleading 

statements about his education.   

a. From at least December 2017 through the Relevant Period, quarterly 

investor presentations stated Sanaullah “received his degree in 2011 

from University of Michigan.”    

b. From at least April 2019 through the Relevant Period, performance 

sheets stated Sanaullah “studied Mathematics at the University of 

Michigan (B.A. 2011)” or that Sanaullah “received his degree in 2011 

from University of Michigan.”  

c. From at least mid-2019 through the Relevant Period, a due diligence 

questionnaire stated Sanaullah “studied Mathematical Sciences at the 

University of Michigan, graduating in 2011.”   

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51. Sanaullah disseminated these documents. Sanaullah sent, or directed 

others to send, either before or after the investor calls, an email attaching the 

investor presentations, performance sheets, or due diligence questionnaire that 

contained false and misleading statements about his education.   

52. A reasonable investor would have understood from these statements 

that Sanaullah had graduated from college and, specifically, received an 

undergraduate degree from the University of Michigan in Mathematics. 

53. The statements about Sanaullah receiving his degree from the 

University of Michigan were false and misleading because, while Sanaullah did 

attend the University of Michigan, he did not graduate or obtain a degree from 

University of Michigan or any other college.  

54. The statements about Sanaullah in the performance sheets, investor 

presentations, and due diligence questionnaire were false and misleading when 

made and Sanaullah knew or was reckless in not knowing, and should have known, 

that the statements indicating that he received a college degree were false and 

misleading because he was aware he had not received a degree from any college. 

55. The false and misleading statements Sanaullah made to investors and 

prospective investors about his degree from the University of Michigan were 

material because reasonable investors and prospective investors would want to 

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know about the education of the person responsible for oversight of the Fund’s risk 

management protocols, including whether that person had graduated from college.   

E. Payments to Sanaullah from EIA 

56. From August 2019 through August 2021, Sanaullah received 

payments from EIA totaling $553,000.  

57. EIA was only able to pay Sanaullah because of the funds obtained 

from investors during the Relevant Period.  

58. Sanaullah thus obtained this money through the material 

misstatements referenced above, which were made “in the offer or sale” of 

securities.  

CLAIMS FOR RELIEF 
 

First Claim for Relief 
Section 17(a) of the Securities Act 

 
59. The SEC realleges and incorporates by reference the above 

paragraphs 1 through 58 as though fully set forth herein. 

60. Sanaullah, directly or indirectly, in the offer or sale of securities by 

the use of means or instruments of transportation or communication in interstate 

commerce or by use of the mails, acting with the requisite state of mind: 

(a) employed devices, schemes, or artifices to defraud; (b) obtained money or 

property by means of untrue statements of a material fact or by omitting to state a 

material fact necessary in order to make the statements made, in light of the 

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circumstances under which they were made, not misleading; and (c) engaged in 

transactions, practices, or courses of business which operated or would operate as a 

fraud or deceit upon the purchaser. 

61. By engaging in the conduct described above, Sanaullah violated, and 

unless restrained and enjoined will continue to violate, Section 17(a) of the 

Securities Act. 15 U.S.C. §§ 77q(a). 

Second Claim for Relief 
Section 10(b) and Rule 10b-5 of the Exchange Act  

 
62. The SEC realleges and incorporates by reference above paragraphs 1 

through 58 as though fully set forth herein. 

63. Sanaullah, directly or indirectly, in connection with the purchase or 

sale of a security, and by the use of means or instrumentalities of interstate 

commerce, of the mails, or of the facilities of a national securities exchange, 

knowingly and recklessly: (a) employed devices, schemes, or artifices to defraud; 

(b) made untrue statements of a material fact or omitted to state a material fact 

necessary in order to make the statements made, in the light of the circumstances 

under which they were made, not misleading; and (c) engaged in acts, practices, or 

courses of business which operated or would operate as a fraud or deceit upon 

other persons. 

64. By engaging in the conduct described above, Sanaullah violated, and 

unless restrained and enjoined will continue to violate, Section 10(b) of the 

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Exchange Act, 15 U.S.C. § 78j(b), and Rule 10b-5 thereunder, 17 C.F.R. 

§ 240.10b-5. 

RELIEF REQUESTED 
 

 WHEREFORE, the SEC respectfully requests that this Court:  

I. 

 Find that the Defendant committed the violations alleged in this Complaint;  

II. 

 Enter an injunction, in a form consistent with Rule 65 of the Federal Rules 

of Civil Procedure, permanently restraining and enjoining Defendant and his 

agents, servants, employees, attorneys, and accountants, and those persons in 

active concert or participation with him, who receive actual notice of the Judgment 

by personal service or otherwise, and each of them, from engaging in transactions, 

acts, practices, and courses of business described herein, and from engaging in 

conduct of similar purport and object in violation of Section 17(a) of the Securities 

Act, 15 U.S.C. § 77q(a) and Section 10(b) of the Exchange Act, 15 U.S.C. § 

78j(b), and Exchange Act Rule 10b-5, 17 C.F.R. § 240.10b-5, thereunder; 

III. 

 Order Sanaullah to disgorge ill-gotten gains received during the period of 

violative conduct and pay prejudgment interest on such ill-gotten gains; 

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IV. 

 Order Sanaullah to pay a civil money penalty pursuant to Section 20(d) of 

the Securities Act, 15 U.S.C. § 77t(d) and Section 21(d)(3) of the Exchange Act, 

15 U.S.C. § 78u(d)(3);  

V. 

 Order that Sanaullah be permanently prohibited from acting as an officer and 

director of any public company; and 

VI. 

 Grant such other and further relief as this Court may deem just and proper. 

 

 

 

 

 

 

 

 

 

 

 

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JURY DEMAND 

The SEC demands a trial by jury on all claims so triable.   

 
Dated:  January 16, 2025  Respectfully submitted, 
   
 By: s/ Zachary T. Carlyle 
  Zachary T. Carlyle 

U.S. Securities and Exchange 
Commission 
1961 Stout Street, Suite 1700 
Denver, CO 80294-1961 
Telephone: 303.844.1084 (Carlyle) 
Email: [email protected] 
Attorneys for Plaintiff 
U.S. Securities and Exchange 
Commission 
 
Local Counsel For Plaintiff 

  DAWN N. ISON 
United States Attorney 
Kevin R. Erskine (P69120) 
Assistant United States Attorney 
U.S. Attorney’s Office – Eastern 
District of Michigan 
211 West Fort Street, Suite 2001 
Detroit, Michigan 48226 
Telephone: (313) 226-9610 
Email: [email protected] 

 

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