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Case 1 15-cv-00758-JMS-MJD Document 1 Filed 05/12/15 Page 1 of 56 PageID 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION AND EXCHANGE COMMISSION Plaintiff v. ITT EDUCATIONAL SERVICES INC. KEVIN M. MODANY and DANIEL M. FITZPATRICK Defendants. Case No. 15-CV-00758 Jury Trial Demanded COMPLAINT Plaintiff the United States Securities and Exchange Commission SEC or Commission alleges as follows NATURE OF THE ACTION Beginning no later than the second quarter of...
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