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Commodity Futures Trading Commission 

CEA CASES 

NAME: GEORGE SIROTA AND SONS, GEORGE SIROTA, NORMAN L. SIROTA, BENJAMIN SIROTA, 

HARRY A. ASPINWALL, AND DYKE CULLUM 

DOCKET NUMBER: 54 

DATE: NOVEMBER 6, 1950 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re George Sirota and Sons, George Sirota, Norman L. Sirota, Benjamin 

Sirota, Harry A. Aspinwall, and Dyke Cullum Respondents 

CE-A Docket No. 54 

Complaint and Notice of Hearing under the Commodity Exchange Act 

The Secretary of Agriculture has reason to believe that the respondents have 

violated the provisions of the Commodity Exchange Act (7 U.S.C., Chapter 1), and 

the rules and regulations made pursuant to its requirements. In accordance with 

the provisions of Section 6(b) of the said Act (7 U.S.C. 9), this complaint is 

issued alleging as follows: 

1. 

George Sirota and Sons is a partnership doing business at 60 Beaver Street, 

New York, New York, and was at the times hereinafter mentioned, and is now, 

registered as a futures commission merchant under the provisions of the 

Commodity Exchange Act. The said partnership was at the times hereinafter 

mentioned and is now a member of several boards 

of trade designated as contract markets under the Commodity Exchange Act, 

including the New York Produce Exchange. 

2. 

George Sirota, Norman L. Sirota, and Benjamin Sirota are members of the 

partnership of George Sirota and Sons, and are registered floor brokers under 

the Commodity Exchange Act. 

3. 

Harry A. Aspinwall is a member of the New York Mercantile Exchange and the 

Chicago Mercantile Exchange, is registered as a floor broker under the Commodity 

Exchange Act, and is authorized to act as agent in the solicitation and 

acceptance of commodity futures orders for, and in the name of, George Sirota 

and Sons. 

4. 

Dyke Cullum is an individual having an office in the Hibos Building, 

Washington, D. C., and during the times hereinafter mentioned engaged in trading 

in commodity futures through the firm of George Sirota and Sons. From May 10, 

1950, to August 15, 1950, the said Dyke Cullum was a member of the Chicago Board 

of Trade, a contract market under the Commodity Exchange Act. 

5. 
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At the times hereinafter mentioned, commodity futures accounts in the names 

of Dyke Cullum, Kiki Cullum, and Jessica K. Jones or Joycette K. Jones were 

being carried on the books of the respondent partnership. Such accounts had 

open contract positions in cottonseed oil and soybean oil futures on the New 

York Produce Exchange on the dates and in the quantities shown in Schedule A, 

which is attached hereto and expressly made a part of this complaint. All the 

respondents agreed and planned with each other to operate and they did operate 

such accounts in a manner calculated to conceal open contract positions and 

evade the reporting requirements of the Commodity Exchange Act, as hereinafter 

described. 

6. 

On or about June 23, 1950, respondent Dyke Cullum purchased for his own 

account through the respondent partnership five contracts or carlots of 

September soybean oil on the New York Produce Exchange, and arranged with the 

said respondent partnership to enter the said purchases in the accounts of Kiki 

Cullum and Jessica K. Jones or Joycette K. Jones for the purpose of concealing 

the said transactions. Pursuant to such arrangement, respondent George Sirota 

and Sons 

entered the purchase of three contracts of September soybean oil in the Kiki 

Cullum account and the purchase of two contracts of September soybean oil in the 

Jones account. By reason of the purchase of these five contracts, respondent 

Dyke Cullum held or controlled 16 or more long contracts in September soybean 

oil on the New York Produce Exchange, and became subject to the requirement 

contained in section 4i of the Commodity Exchange Act and sections 10.10, 10.11 

and 10.21 of the rules and regulations, that he report to the Commodity Exchange 

Authority with respect to all transactions and open contracts in soybean oil 

futures, on or subject to the rules of any contract market, held or controlled 

by the said respondent. Pursuant to these requirements reports were due from 

respondent Dyke Cullum on 14 days during the period from June 23, 1950, to 

August 10, 1950, as specifically set forth in Schedule A, but the said 

respondent wilfully failed to file the required reports in violation of section 

4i of the Commodity Exchange Act and sections 10.10, 10.11 and 10.21 of the 

rules and regulations. 

7. 

By reason of the transactions described in paragraph 6 above, the respondent 

partnership became subject to the requirement contained in section 4i of the 

Commodity Exchange Act and sections 10.04, 10.05, 

10.06 and 10.20 of the rules and regulations, that it report to the Commodity 

Exchange Authority with respect to all open contracts in September soybean oil 

held or controlled by respondent Dyke Cullum. Pursuant to these requirements, 

reports were due from the respondent partnership on every business day from June 

23, 1950, to August 10, 1950, as specifically set forth in Schedule A, but the 

said respondent wilfully failed to file any such reports until on or about July 

21, 1950, when, as the result of a controversy between it and respondent Dyke 

Cullum, the respondent partnership abandoned the plan of concealment and evasion 

described in paragraphs 5 and 6 above and filed back reports showing the 

aggregate position in the three accounts through July 21, 1950. By reason of 

such failure, the respondent partnership wilfully violated section 4i of the 

Commodity Exchange Act and sections 10.04, 10.05, 10.06 and 10.20 of the rules 

and regulations thereunder. 

8. 

On or about May 22, 1950, respondent Dyke Cullum deposited with respondent 

George Sirota and Sons the sum of $ 10,500.00 to margin, guarantee and secure 
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trades made in the Dyke Cullum account. Respondent George Sirota and Sons, 

without authority from respondent 

Dyke Cullum, entered $ 3,500.00 of the said sum to the credit of the account 

carried in the name of Jessica K. Jones or Joycette K. Jones, in violation of 

section 4d(2) of the Commodity Exchange Act and of sections 1.20 and 1.22 of the 

rules and regulations. 

9. 

On or about May 6, 1950, respondents Harry A. Aspinwall and George Sirota and 

Sons caused an account to be opened on the books of the respondent partnership 

in the name of Jessica K. Jones or Joycette K. Jones without the authorization 

or consent of the said Jessica K. Jones or Joycette K. Jones, and thereafter, on 

or about May 5, 12 and 22, 1950, June 2, 15 and 16, 1950, and August 7, 8 and 9, 

1950, the said respondents caused purchases and sales of cottonseed oil futures 

and soybean oil futures executed on the New York Produce Exchange by the 

respondent partnership to be entered in the said account. The said transactions 

were actually executed for the account and benefit of a person other than the 

said Jessica K. Jones or Joycette K. Jones. By reason of the said acts, 

respondents Harry A. Aspinwall and George Sirota and Sons confirmed the 

execution of contracts in commodity futures and wilfully failed to evidence such 

contracts by a record in writing showing the true names 

of the parties to such contracts, in violation of section 4 of the Commodity 

Exchange Act and section 1.37 of the rules and regulations. 

10. 

On or about June 23, 1950, respondent George Sirota and Sons caused purchases 

and sales of soybean oil futures executed on the New York Produce Exchange to be 

entered in the accounts of Kiki Cullum and Jessica K. Jones or Joycette K. 

Jones. The said transactions were actually executed for the account and benefit 

of a person or persons other than the said Kiki Cullum and Jessica K. Jones or 

Joycette K. Jones. By reason of the said acts, respondent George Sirota and 

Sons confirmed the execution of contracts in commodity futures and wilfully 

failed to evidence such contracts by a record in writing showing the true names 

of the parties to such contracts, in violation of section 4 of the Commodity 

Exchange Act and section 1.37 of the rules and regulations. 

11. 

The transactions described in paragraphs 9 and 10 above could have been used 

for hedging transactions in interstate commerce in cottonseed oil or soybean oil 

or the products or by-products thereof, 

or determining the price basis of transactions in interstate commerce in such 

commodities, or delivering such commodities in interstate commerce. 

Therefore, the said respondents, George Sirota and Sons, George Sirota, 

Norman L. Sirota, Benjamin Sirota, Harry A. Aspinwall, and Dyke Cullum are 

hereby notified to be and appear at a hearing to be held at 10 o'clock a.m., 

eastern standard time, on the 12th day of December, 1950, in Room 144-W, 

Administration Building, United States Department of Agriculture, Washington, D. 

C., before a referee designated to conduct such hearing, and then and there show 

cause, if any there be, why an order should not be made directing that all 

contract markets refuse all trading privileges to the respondents for such 

period of time as may be determined by the Secretary of Agriculture, and 

suspending or revoking the registrations of those respondents who are registered 

as futures commission merchants or floor brokers. 
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The respondents will have 20 days after the receipt of this notice of hearing 

to file in triplicate with the Hearing Clerk, United States Department of 

Agriculture, Washington 25, D. C., an answer fully and completely stating the 

nature of the defense and admitting or denying specifically and in detail each 

material and relevant allegation of the complaint. Allegations that are not 

answered will be deemed admitted for the purpose of this proceeding. 

It is ordered that this complaint and notice of hearing be served on the 

respondents by delivery of a true copy thereof by an employee of the Department 

of Agriculture, or by registered mail, at least 20 days prior to the date set 

for hearing. 

Done at Washington, D. C., this 

6 day of November, 1950 

/s/ Charles F. Brannan 

Secretary of Agriculture 

POSITIONS IN COTTONSEED OIL FUTURES AND SOYBEAN OIL FUTURES CARRIED ON THE 

BOOKS OF GEORGE SIROTA AND SONS IN ACCOUNTS IN THE NAMES OF DYKE CULLUM, KIKI 

CULLUM, AND JESSICA K. JONES DURING THE PERIOD FROM MAY 12, 1950, TO AUGUST 10, 

1950, INCLUSIVE 

(In contracts of 60,000 pounds)>100> >101> 

Cottonseed oil 

July September October December 

Name of Account Date n1 Long Short Long Short Long Short Long Short

1950 

Dyke Cullum 5/12 14 Kiki Cullum 8 3 

Jessica K. Jones 5 

27 3 Dyke Cullum 5/16 12 

Kiki Cullum - 3 Jessica K. Jones 5 17 3 Dyke Cullum 5/17 7 Kiki Cullum 3 Jessica K. Jones 5 

12 3 

Dyke Cullum 5/18 5 Kiki Cullum 1 Jessica K. Jones 5 

10 1 Dyke Cullum 5/19 5 1

Kiki Cullum 1 1

Jessica K. Jones 5 10 1 2

Dyke Cullum 5/20 3 1

Kiki Cullum 1 1

Jessica K. Jones 5 

8 1 2

Dyke Cullum 5/22 3 1

Kiki Cullum - 1

Jessica K. Jones - 

3 - 2

Dyke Cullum 5/24 3 6

Kiki Cullum 1

Jessica K. Jones 3 7

Dyke Cullum 5/26 - 6

Kiki Cullum 1
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 Cottonseed oil 

 July September October December 

Name of Account Date n1 Long Short Long Short Long Short Long Short

1950 

Jessica K. Jones - 7

Dyke Cullum 5/31 6

Kiki Cullum 1

Jessica K. Jones 

7

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

Soybean oil 

May July August 

Long Short Long Short Long Short 

Name of Account Date n1 1950 Dyke Cullum 5/12 8 6 Kiki Cullum Jessica K. Jones 8 6 

Dyke Cullum 5/16 8 6 Kiki Cullum 

Jessica K. Jones 

8 6 Dyke Cullum 5/17 5 6 

Kiki Cullum 

Jessica K. Jones 5 6 Dyke Cullum 5/18 5 

Kiki Cullum Jessica K. Jones 5 6 

Dyke Cullum 5/19 5 6 Kiki Cullum 

Jessica K. Jones 

5 6 Dyke Cullum 5/20 5 6 Kiki Cullum 

Jessica K. Jones 5 6 Dyke Cullum 5/22 5 6 Kiki Cullum Jessica K. Jones 5 6 Dyke Cullum 5/24 7 6 Kiki Cullum 1 

Jessica K. Jones 8 6 Dyke Cullum 5/26 12 6 

Kiki Cullum 1 

Jessica K. Jones 13 6 Dyke Cullum 5/31 12 6 

Kiki Cullum 1 Jessica K. Jones 

13 6 

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

Soybean oil 
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September October 

Long Short Long Short

Name of Account Date n1 1950 Dyke Cullum 5/12 9 11 Kiki Cullum 2 Jessica K. Jones 5 

14 13 Dyke Cullum 5/16 9 11 

Kiki Cullum 2 

Jessica K. Jones 5 14 13 

Dyke Cullum 5/17 9 11 Kiki Cullum 2 Jessica K. Jones 5 

14 13 

Dyke Cullum 5/18 9 11 Kiki Cullum 2 

Jessica K. Jones 5 14 13 Dyke Cullum 5/19 9 11 Kiki Cullum 2 Jessica K. Jones 5 14 13 Dyke Cullum 5/20 9 11 

Kiki Cullum 2 Jessica K. Jones 5 

14 13 Dyke Cullum 5/22 9 11 Kiki Cullum 2 

Jessica K. Jones 5 14 13 Dyke Cullum 5/24 10 11 

Kiki Cullum 4 Jessica K. Jones 5 15 15 Dyke Cullum 5/26 12 14 

Kiki Cullum 7 Jessica K. Jones 5 

17 21 Dyke Cullum 5/31 12 14 Kiki Cullum 8 Jessica K. Jones 5 17 22 

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

>100> >101> 

Cottonseed oil 

July September October December 

Name of Account Date n1 Long Short Long Short Long Short Long Short

1950 Dyke Cullum 6/2 6

Kiki Cullum 6

Jessica K. Jones 5

17

Dyke Cullum 6/15 12

Kiki Cullum 14

Jessica K. Jones 11

37

Dyke Cullum 6/20 12

Kiki Cullum 3 14
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 Cottonseed oil 

 July September October December 

Name of Account Date n1 Long Short Long Short Long Short Long Short

1950 

Jessica K. Jones 11

3 37

Dyke Cullum 6/23 12

Kiki Cullum 3 14

Jessica K. Jones 11

3 37

Dyke Cullum 6/26 12

Kiki Cullum 3 10

Jessica K. Jones 7

3 29

Dyke Cullum 6/27 14

Kiki Cullum 3 10

Jessica K. Jones 7

3 31

Dyke Cullum 6/29 3 14

Kiki Cullum 3 15

Jessica K. Jones 7

3 3 36

Dyke Cullum 7/5 3 14

Kiki Cullum 3 15

Jessica K. Jones 5

3 3 32

Dyke Cullum 7/11 - 14

Kiki Cullum 3 6

Jessica K. Jones 2

3 - 22

Dyke Cullum 7/26 14

Kiki Cullum 3 6

Jessica K. Jones 2

3 22

Dyke Cullum 7/27 14

Kiki Cullum - -

Jessica K. Jones 2

- 16

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

Soybean oil 

May July August 

Name of Account Date n1 Long Short Long Short Long Short 

1950 Dyke Cullum 6/2 12 6 Kiki Cullum 1 Jessica K. Jones 

13 6 

Dyke Cullum 6/15 12 6 Kiki Cullum 1 

Jessica K. Jones 13 6 Dyke Cullum 6/20 12 6 Kiki Cullum 1 

Jessica K. Jones 13 6 

Dyke Cullum 6/23 7 6 

Kiki Cullum 1 Jessica K. Jones 

8 6 

Dyke Cullum 6/26 7 6 Kiki Cullum 1 
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 Soybean oil 

 May July August 

Name of Account Date n1 Long Short Long Short Long Short 

 1950 

Jessica K. Jones 8 6 Dyke Cullum 6/27 7 6 

Kiki Cullum 1 Jessica K. Jones 8 6 

Dyke Cullum 6/29 7 6 Kiki Cullum 1 

Jessica K. Jones 8 6 Dyke Cullum 7/5 7 6 

Kiki Cullum 1 

Jessica K. Jones 8 6 

Dyke Cullum 7/11 7 6 Kiki Cullum 1 Jessica K. Jones 

8 6 Dyke Cullum 7/26 2 6 Kiki Cullum 1 Jessica K. Jones 

3 6 Dyke Cullum 7/27 2 6 

Kiki Cullum 1 Jessica K. Jones 3 6 

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

Soybean oil 

September October 

Name of Account Date n1 Long Short Long Short

1950 Dyke Cullum 6/2 12 14 Kiki Cullum 8 Jessica K. Jones 5 17 22 Dyke Cullum 6/15 12 14 Kiki Cullum 8 Jessica K. Jones 5 17 22 

Dyke Cullum 6/20 12 14 Kiki Cullum 8 Jessica K. Jones 5 

17 22 

Dyke Cullum 6/23 12 14 Kiki Cullum 3 8 

Jessica K. Jones 7 

22 22 Dyke Cullum 6/26 12 14 Kiki Cullum 3 8 

Jessica K. Jones 7 22 22 

Dyke Cullum 6/27 12 14 

Kiki Cullum 3 8 Jessica K. Jones 7 

22 22 

Dyke Cullum 6/29 12 14 Kiki Cullum 3 8 
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 Soybean oil 

 September October 

Name of Account Date n1 Long Short Long Short

1950 

Jessica K. Jones 7 22 22 Dyke Cullum 7/5 12 14 

Kiki Cullum 3 8 Jessica K. Jones 7 

22 22 

Dyke Cullum 7/11 12 14 Kiki Cullum 3 8 

Jessica K. Jones 7 22 22 Dyke Cullum 7/26 12 14 

Kiki Cullum 3 8 

Jessica K. Jones 7 22 22 

Dyke Cullum 7/27 12 14 Kiki Cullum 3 7 Jessica K. Jones 7 22 21 

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

 

>100> >101> 

Cottonseed oil 

July September October December 

Name of Account Date n1 Long Short Long Short Long Short Long Short

1950 

Dyke Cullum 7/28 14

Kiki Cullum Jessica K. Jones 2

16

Dyke Cullum 7/31 14

Kiki Cullum Jessica K. Jones 2

16

Dyke Cullum 8/7 14

Kiki Cullum Jessica K. Jones 1

15

Dyke Cullum 8/8 14

Kiki Cullum 

Jessica K. Jones -

14

Dyke Cullum 8/9 14

Kiki Cullum 

Jessica K. Jones 14

Dyke Cullum 8/10 14

Kiki Cullum 14

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

Soybean oil 

May July August 

Name of Account Date n1 Long Short Long Short Long Short 

1950 Dyke Cullum 7/28 - 6 
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 Soybean oil 

 May July August 

Name of Account Date n1 Long Short Long Short Long Short 

 1950 

Kiki Cullum 1 Jessica K. Jones 1 6 

Dyke Cullum 7/31 6 Kiki Cullum - 

Jessica K. Jones - 6 Dyke Cullum 8/7 6 

Kiki Cullum Jessica K. Jones 6 

Dyke Cullum 8/8 6 

Kiki Cullum Jessica K. Jones 

6 Dyke Cullum 8/9 6 Kiki Cullum 

Jessica K. Jones 6 Dyke Cullum 8/10 6 Kiki Cullum 1 

7 Soybean oil 

September October 

Name of Account Date n1 Long Short Long Short

1950 

Dyke Cullum 7/28 12 14 Kiki Cullum 3 6 Jessica K. Jones 7 

22 20 Dyke Cullum 7/31 12 14 Kiki Cullum 3 6 Jessica K. Jones 7 

22 20 Dyke Cullum 8/7 12 14 

Kiki Cullum 3 6 Jessica K. Jones 4 19 20 Dyke Cullum 8/8 12 14 Kiki Cullum 3 6 Jessica K. Jones 4 

19 20 

Dyke Cullum 8/9 12 14 Kiki Cullum 3 6 

Jessica K. Jones - 

15 20 Dyke Cullum 8/10 12 14 

Kiki Cullum 3 6 15 20 

n1 Positions shown remain unchanged from close of business on dates 

indicated until opening of business on next date indicated. 

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