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The SEC's Continuing Struggle With Stale Claims
A Southern District of New York judge recently dismissed as time-barred an SEC action against two former Citigroup Asset Management executives. Jones Day's Harold K. Gordon and Tracy V. Schaffer write that the decision illustrates the SEC's continuing difficulty in pursuing non-recurrent securities violations -- and the importance to defense counsel of considering the applicability of 28 U.S.C. §2462 when representing individuals or entities in SEC investigations involving isolated and aging conduct.