UNITEDSTATES
DISTRICTCOURTDISTRICT
OF
NEW
JERSEY
UNITEDSTATES
OF
AMERICA
CRIMINAL
COMPLAINT
V
Hon.
Madeline
Cox
ArleoROBERTRAMNARINE
CaseNo.:
12-8121
I.
StephanieDavis.beingdulysworn,statethe
following
is
trueand
correct
to
the
best
of
my
knowledge
and
belief:
SEE
ATTACHMENT
A
I
further
state
that
I
am
a
SpecialAgent
with
theFederalBureau
of
Investigation,
and
that
this
complaint
is
basedonthe
following
facts:
SEE
ATTACHMENT
B
continued
on
the
attached
pageandmade
a
parthereof.
Steph
a’is,
Special
\gent
FederalBureau
of
In
estigation
Sworn
to
before
me
and
subscribed
inmy
presence,
August
1.
2012Date
at
HONORABLEMADELINE
COX
ARLE()
UnitedStates
Magistrate
j4ge
Newark,
NewJerseyCityand
4ate,
£
/
_\
//
Signature
of
JudicialOfficer
Name
&
Title
of
Judicial
Officer
Case 2:12-mj-08121-MCA Document 1 Filed 08/01/12 Page 1 of 10 PageID: 1
ATTACHMENT
A
Counts
1
through
3
(Securities
Fraud
—
InsiderTrading)
On
or
about
thedatessetforth
below,
in
the
District
of
NewJersey
and
elsewhere.defendant
ROBERT
RAMNARINE
byuse
of
the
means
and
instrumentalities
of
interstate
commerce,
themails,andfacilities
of
nationalsecurities
exchanges,
directlyandindirectly,
knowingly
and
willfully
used
manipulative
and
deceptive
devices
and
contrivances
in
contravention
of
Title
17,
Code
of
Federal
Regulations,
Section
240.lOb-5in
connection
with
the
purchases
and
sales
of
securities
by
(a)
employingdevices,
schemes,and
artifices
to
defraud
members
of
the
investing
public;and
(b)
engaging
in
acts,
practices.
and
a
course
of
business
which
operated
and
would
operate
as
a
fraud
and
deceit
upon
persons,in
thatdefendant
RAMNARINE
executed
and
caused
the
execution
of
thesecurities
transactions
listed
belowbasedupon
material,nonpublic
information
that
defendant
RAMNARINE
obtainedthrough
his
employment
atBristol-MyersSquibbCompany:
COUNTAPPROXIMATEDATESSECURITIESTRANSACTIONS
1
August
25,
2010
through
Purchase
and
sale
of
approximately
80
call
September
8,
2010
options
in
ZymoGenetics,
Inc.
stock
2
November
8,
2011
through
Purchase
andsale
of
approximately
59
call
November
21,
2011
options
of
Pharmasset,
Inc.
stock
3
May
24,2012
through
July
2,
Purchaseand
sale
of
approximately
710
2012put
options
and
130
call
options
in
AmylinPharmaceuticals,
Inc.
stock
In
violation
of
Title
15,
UnitedStatesCode,Sections78j(b)and78ff(a),
and
Title
17,
Code
of
Federal
Regulations.Section
24010b-5.
Case 2:12-mj-08121-MCA Document 1 Filed 08/01/12 Page 2 of 10 PageID: 2
ATTACHMENT
B
I.
StephanieDavis.havebeen
a
SpecialAgent
of
theFederal
Bureau
of
Investigation
C’FBI”)
for
over
a
yearandhalf,and
I
havebeenpersonallyinvolvedinthe
investigation
of
thismatter.Theinformation
contained
in
thisComplaint
is
basedupon
my
personalknowledge,
as
well
as
informationobtained
fromothersources,including:
a)
statementsmade
or
reported
by
variouswitnesseswithknowledge
of
relevant
facts;
b)
my
review
of
publiclyavailable
information
relating
to
Bristol-MyersSquibbCompany.ZvmoGenetics,
Inc..
Pharmasset,
Inc.,
andAmylin
Pharmaceuticals,
Inc.:
and
c)
documents,includingbrokeragerecords
and
business
recordsobtainedfromvariousentities.Becausethis
Complaint
is
beingsubmitted
for
the
limited
purpose
of
establishing
probable
cause,
it
does
not
includeevery
fact
that
I
havelearned
during
the
course
of
theinvestigation.
Where
thecontent
of
documents
and
theactions,
statements,
and
conversations
of
others
are
reportedherein,
theyare
reported
in
substanceand
in
part,
except
whereotherwiseindicated.
INTRODUCTION
1.
Asset
forth
inmoredetailbelow,there
is
probablecause
to
believethat
defendant
ROBERT
AMNAR1NE,
in
violation
of
his
fiduciaryduties
and
duties
of
trustand
confidence
to
hisemployer,Bristol-MyersSquibbCompany
C’BMS”).
traded
on
material,
nonpublicinformation
regardingBMS’santicipatedacquisitions
of
certain
publiclytraded
companies
(the
‘BMS
Acquisition
Targets”).
Thisinformationenabled
defendant
RAMNARINE
to
reapsubstantialprofits
by
engaging
in
lucrativetrading
in
stock
options
of
the
BMS
Acquisition
Targetsshortlybeforetheywereeitheracquired
byBMSor
anothercompany,and
before
theBMS
Acquisition
Targets’stockpricesincreased
in
value.Between
in
orabout
August
2010
and
in
oraboutJune
2012.
defendant
RAMNARINEgenerated
approximately
$311,361in
illicit
profits
pursuant
to
thisscheme.
RELEVANTPARTIES
AND
ENTITIES
2.
At
all
timesrelevant
to
thisComplaintunlessotherwiseindicated:
a.
Bristol-MyersSquibbCompanyor“BMS”
was
a
global
pharmaceuticals
company
with
officesinPrinceton.
New
Jersey,PiainsboroTownship,
New
Jersey.and
New
Brunswick
New
Jerse
amongotherlocations
BMS
s
k
productsincluded
Plaix
‘\bilth
andReyataz,and
its
netsalesexceeded
$21
billion
in2011.BMS’
s
stock
was
registeredwith
the
L
S
Securities
and
F\change
Commissionandtraded
onthe
New
York
Stock
E’change
underthesymbol“BMY”.
b.
Defendant
RAMNARiNE,
a
resident
of
EastBrunswick,
New
Jersey,
was
employed
by
BMS
beginning
in
oraboutDecember
1997.
From
inor
aboutMarch
2008
through
in
oraboutJune
2011,
defendant
RAMNARTNE
served
as
BMS’s
Director
of
Pensionsand
Savings
Investments,
working
at
BvlS
‘S
Princeton,
New
Jersey
office.
In
or
aboutJune2011,defendant
RAMNARLNE
was
promoted
to
BMS’sExecutive
Director
of
Pensions
and
Savings
Case 2:12-mj-08121-MCA Document 1 Filed 08/01/12 Page 3 of 10 PageID: 3
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