The SEC’s “Open Jacket” Policy: What’s Old Is New (and Open) Again Daniel FridmanOctober 29, 2025 Firm News We recently discussed the Wells Process, that procedural crossroads where advocacy and enforcement meet. And as it turns out, what’s old is new—and newly open—again. Under Chair Paul Atkins, the SEC has begun to revisit an idea first floated nearly two decades ago: the “open jacket policy”—a term that, in all my years as both an SEC Trial Attorney and Demystifying the Wells Process Daniel FridmanOctober 29, 2025 Firm News No subject of an SEC investigation wants to be “Wellsed.” A Wells notice from SEC staff signals that an enforcement action is probably coming, and with it, sleepless nights, tough conversations, and a sense that the agency’s spotlight has found you. Yet, unsettling as it is, the Wells Process also opens a narrow but meaningful window—an opportunity for experienced SEC Novel Medicare Advantage Fraud Theory Falters in HealthSun Case Daniel FridmanSeptember 15, 2025 Firm News Defense sought to admit government’s exhibits to educate jury Prosecution didn’t have much to show in the way of motive Prosecutors offered surprisingly little evidence to support their theory of fraud in their failed attempt to convict former HealthSun Health Plans Inc. coding supervisor Kenia Valle Boza last week, attorneys familiar with the case say. The case accusing the employee Miami-Dade healthcare manager found not guilty at Medicare fraud trial Daniel FridmanSeptember 15, 2025 Firm News Two years ago, Kenia Valle Boza’s life was upended when prosecutors accused her of conspiring with others to assign falsified codes to medical diagnoses that caused the federal government to pay out millions of dollars for excessive billing. Valle, a certified professional coder for two Miami-Dade healthcare management companies, was the only defendant named in a conspiracy indictment alleging $12 When SEC Settlements Collide With Criminal Cases: Lessons From Mango Labs Daniel FridmanSeptember 2, 2025 Firm News The Mango Labs dispute underscores a critical challenge in securities enforcement: what happens when a civil SEC settlement intersects with a parallel DOJ criminal investigation? Mango Labs settled with the SEC for nearly $700,000 in late 2024. But after the political winds shifted and a related criminal case involving the Mango Markets exploit changed course, Mango sought relief under Rule Posts navigation Older posts