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Commodity Futures Trading Commission 

CEA CASES 

NAME: I. NEIMAN 

DOCKET NUMBER: STIPULATION 4 

DATE: NOVEMBER 15, 1945 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES OF AMERICA 

BEFORE THE SECRETARY OF AGRICULTURE 

In re I. Neiman, 108 Park Street, LaPorte, Indiana 

Stipulation of Compliance Under the Commodity Exchange Act No. 4 

WHEREAS, the Secretary of Agriculture has reason to believe that I. Neiman 

has violated the Commodity Exchange Act, as amended, and the rules and 

regulations of the Secretary of Agriculture promulgated thereunder; and WHEREAS, 

no complaint has been filed with respect to said violation and said I. Neiman 

desires to enter into a stipulation pursuant to the provisions of section 0.4 

(a) of the rules of practice under the Commodity Exchange Act: Now, therefore, 

the said I. Neiman admits that the following facts are true: 

(1) I. Neiman is an individual formerly doing business under the name of 

Chicago Garment Company and controlling the trading in commodity futures 

contracts carried on in his own name, in the name of the Chicago Garment 

Company, and in the name of Gussie Neiman. The Chicago Garment Company was 

originally a sole proprietorship, later incorporated, I. Neiman exercised 

control of the trading carried on in the name of the Chicago Garment Company, 

both while it was a sole proprietorship and also subsequent to its 

incorporation. 

(2) I. Neiman has since 1939 traded actively and in considerable volume in 

his own name and through the accounts controlled by him in futures contracts in 

grain, cotton, eggs, and wool top. 

(3) I. Neiman was advised of the reporting requirements under the Commodity 

Exchange Act applying to persons trading in commodity futures by means of 

letters, printed instruction, and circulars furnished him by the United States 

Department of Agriculture. Among the documents advising of the reporting 

requirements were the following: 

(a) Letter dated October 20, 1939, from H. M. Hoyt, Acting in Charge, 

Division of Record Examination, Commodity Exchange Administration, Washington, 

D. C., enclosing copy of Commodity Exchange Act and rules and regulations 

promulgated thereunder. 

(b) Letter dated November 1, 1939, from John J. Bachmann, in Charge, Division 

of Record Examination, Commodity Exchange Administration, Washington, D. C. 

(c) Letter dated November 10, 1939, from John J. Bachmann. 

(d) Letter dated November 27, 1939, signed by J. W. T. Duvel, Chief, 

Commodity Exchange Administration. 

In addition to the letters and documents above referred to, I. Neiman was 

informed of the reporting requirements and 
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procedure by personal interview in the Chicago office of the Commodity Exchange 

Administration on January 5, 1940. 

(4) I. Neiman has habitually arranged for brokerage houses through which he 

carries his accounts to file for him the reports required to be filed under the 

Commodity Exchange Act with the United States Department of Agriculture. 

Sometime during the year 1939 I. Neiman instructed David A. Noyes and Company of 

Chicago, Illinois, to report his transactions in cotton futures contracts. By 

letter dated September 21, 1944, I. Neiman instructed H. Hentz and Company of 

New York to report his positions in wool top futures contracts. By letter dated 

November 30, 1944, I. Neiman instructed Uhlmann Grain Company, Chicago, 

Illinois, to file reports covering his holdings in cotton contracts. 

(5) I. Neiman was aware that his requests to his brokers to report his 

positions in futures contracts did not relieve him of responsibility for the 

accuracy and prompt submission of the required reports. He was informed of this 

fact by letter dated October 13, 1944, signed by Ralph K. Dawson, Chief, Trading 

Section, Compliance Branch, War Food Administration, and he had previously 

indicated full understanding in a letter dated October 3, 1944, addressed to the 

United States 

Department of Agriculture, War Food Administration, Office of Distribution, New 

York, New York. 

(6) I. Neiman on numerous occasions between 1939 and October 1945 failed to 

report, filed delinquent reports, and filed incorrect and incomplete reports 

covering the transactions in commodity futures contracts required to be reported 

under the provisions of the Commodity Exchange Act and the rules and regulations 

promulgated thereunder. 

(7) The errors, omissions, and failures in reporting were called to I. 

Neiman's attention by letter and otherwise on numerous occasions between 1939 

and October 1945. Under date of November 27, 1944, George H. Baston, Supervisor 

in Charge, Commodity Exchange Division, New York, New York, addressed a letter 

to I. Neiman calling attention to his failures and delinquencies in connection 

with filing reports and again furnishing him with a copy of the Commodity 

Exchange Act and the rules and regulations promulgated thereunder. 

(8) At all times between April 12, 1945, and August 24, 1945, I. Neiman held 

or controlled open contracts in one egg future on one contract market in excess 

of 25 carlots. 

(9) I. Neiman filed reports on Form 503 purporting to cover his holdings in 

egg futures contracts during the period set out in (8) above as follows: 

See original document-page 4 

Date report was received in Chicago 

Date covered by report office of Commodity Exchange Authority 

(1945) (1945) 

April 12 September 12 

April 26 May 3 

April 27 May 3 

May 23 May 28 

August 8 August 23 

August 9 August 23 

August 10 August 23 

August 14 August 23 

August 20 August 27 

August 21 August 27 

August 23 August 27 

August 24 August 27 

(10) All of the reports referred to in (9) above were incomplete and 

incorrect, and a number of them were delinquent as to date of filing. The 
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errors ranged from one carlot on the report for April 12, when the original 

report showed 42 carlots short while the corrected report received on September 

12 showed 43 carlots short; to an error of 18 carlots on the report of August 

24, when the original report showed 87 carlots short while the corrected report 

received on September 12 showed 105 carlots short. 

(11) During the entire period from September 10 through September 14, 1945, 

I. Neiman held or controlled open contracts in one egg future on one contract 

market in excess of 25 carlots. Reports on Form 503 were filed by I. Neiman on 

September 12 for September 10, on September 19 for September 13, and on 

September 20 for September 14, purporting to show 

his position in egg futures. These reports were all incomplete and incorrect, 

and were replaced by a second set of reports for the same dates filed on 

September 22, 1945. The reports filed on September 22 were also incomplete and 

incorrect and were replaced by a third set of reports for the same dates filed 

on October 9, 1945. 

(12) At all times during the period from June 20, 1944, to September 30, 

1944, I. Neiman held or controlled open contracts in one cotton future on one 

contract market in excess of 5,000 bales. 

(13) I. Neiman failed to file any reports whatsoever on Form 303 covering his 

holdings in cotton futures contracts as set out in (12) above until his holdings 

were discovered by representatives of the United States Department of 

Agriculture and he was specifically directed by letter dated November 27, 1944, 

from George H. Baston, Supervisor in Charge, New York office of the Commodity 

Exchange Division, to file the delinquent reports. 

(14) At all times during the period from July 21, 1944, to September 29, 

1944, I. Neiman held or controlled open contracts in one wool top future on one 

contract market in excess of 125,000 pounds. 

(15) I. Neiman failed to file any reports whatsoever on Form 803 covering his 

holdings in wool top futures contracts as set out in (14) above until his 

holdings were discovered by representatives of the United States Department of 

Agriculture and he was specifically directed to report. 

In addition to admitting the foregoing facts, I. Neiman agrees to discontinue 

all acts and practices which are in violation of the Commodity Exchange Act, as 

amended, and the rules and regulations promulgated thereunder, and further 

agrees that this stipulation shall be admissible as evidence of acts and 

practices in violation of the Commodity Exchange Act, as amended, and the rules 

and regulations promulgated thereunder, in any subsequent proceeding brought 

against him in the enforcement of the provisions of the said act and 

regulations. 

Done at LaPorte, Indiana, this 15th day of November, 1945. 

/s/ I. Neiman 

I. Neiman 

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