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Commodity Futures Trading Commission 

CEA CASES 

NAME: P. J. TAGGARES COMPANY, CHEF-REDDY FOODS, PETER J. TAGGARES, KENNETH L. 

RAMM, IDAHO POTATO PACKERS CORP., IDAHO POTATO PACKERS OF IDAHO, INC., ROBERT H. 

ABEND, HAROLD ABEND, SAN JACINTO PACKING CO., AGRI-EMPIRE, INC., JAMES MINOR, 

UNIVERSAL LAND-SNAKE RIVER, EDWARD SPIEGEL, MODIE J. SPIEGEL, AND J. R. SIMPLOT 

COMPANY INC., SIMPLOT EASTERN IDAHO PRODUCE COMPANY, INC., AND JACK R. SIMPLOT 

DOCKET NUMBER: 200 

DATE: SEPTEMBER 6, 1972 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: P. J. Taggares Company, a corporation; Chef-Reddy Foods, a corporation; 

Peter J. Taggares, an individual; Kenneth L. Ramm, an individual; Idaho Potato 

Packers Corp., a corporation; Idaho Potato Packers of Idaho, Inc., a 

corporation; Robert H. Abend, an individual; Harold Abend, an individual; San 

Jacinto Packing Co., a proprietorship; Agri-Empire, Inc., a corporation; James 

Minor, an individual; Universal Land -- Snake River, a partnership; Edward 

Spiegel, an individual; Modie J. Spiegel, an individual; J. R. Simplot Company, 

Inc., a corporation; Simplot Eastern Idaho Produce Company, Inc., a corporation; 

Jack R. Simplot, an individual; Respondents 

CEA Docket No. 200 

Complaint and Notice of Hearing Under the Commodity Exchange Act 

There is reason to believe that the respondents attempted to manipulate the 

market price of a commodity for future delivery on or subject to the rules of a 

contract market, in wilful violation of the Commodity Exchange Act (7 U.S.C. 1 

et seq.). In accordance 

with the provisions of section 6(b) and 6(c) of the said Act (7 U.S.C. 9 and 

13b), this complaint and notice of hearing is issued stating the charges in that 

respect as follows: 

I 

Respondents P. J. Taggares Company and Chef-Reddy Foods are corporations 

organized under the laws of the State of Washington with their principal offices 

and places of business at Othello, Washington. The said P. J. Taggares Company 

is now and was at all times material to this complaint engaging in the potato 

growing business and operating as a procurement agent for the said Chef-Reddy 

Foods, its wholly owned subsidiary engaging in the potato processing business. 

At all such times, respondent Peter J. Taggares, whose business address is 1016 

S. Broadway, Othello, Washington, was the owner and president of the said P. J. 

Taggares Company and the owner of the said Chef-Reddy Foods; traded in potato 

futures on the Chicago Mercantile Exchange for the said P. J. Taggares Company; 

and directed, controlled, and was responsible for the said firms' transactions 

herein involved. 

II 

Respondent Kenneth L. Ramm, whose business address is P. O. Box Q, Othello, 

Washington, is the owner and lessor of certain potato farmland in the Othello, 

Washington area. At all times material 
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to this complaint, the said Kenneth L. Ramm engaged in speculative trading in 

potato futures on the Chicago Mercantile Exchange for his own account. 

III 

Respondent Idaho Potato Packers Corp. is a corporation organized under the 

laws of the State of New York with its principal office and place of business at 

999 E. 149th St., Bronx, New York. Respondent Idaho Potato Packers of Idaho, 

Inc., is an affiliate corporation organized under the laws of the State of Idaho 

with its principal office and place of business at Blackfoot, Idaho. The said 

corporations are now and were at all times material to this complaint engaging 

in the potato growing and distributing business. At all such times, respondents 

Robert H. Abend, whose business address is 999 E. 149th St., Bronx, New York, 

and Harold Abend, whose business address is Box 747, Blackfoot, Idaho, were the 

owners of the said corporations; speculatively traded in potato futures on the 

Chicago Mercantile Exchange for the corporate accounts and two other controlled 

accounts; and in their capacities as president and vice-president, respectively, 

of the said corporations, directed, controlled, and were responsible for their 

transactions herein involved. 

IV 

Respondent San Jacinto Packing Co. is a proprietorship and respondent AgriEmpire, Inc., is a corporation, both of which are organized 

under the laws of the State of California with their principal offices and 

places of business at San Jacinto, California. The said firms are now and were 

at all times material to this complaint engaging in the potato growing and 

merchandising business. At all such times, respondent James Minor was the owner 

and president of the said firms; speculatively traded in potato futures on the 

Chicago Mercantile Exchange in the name of the said San Jacinto Packing Co; and 

directed, controlled, and was responsible for the said firms' transactions 

herein involved. 

V 

Respondent Universal Land- Snake River is a partnership organized under the 

laws of the State of Washington with its principal office and place of business 

at Pasco, Washington. The said partnership is now and was at all times material 

to this complaint engaging in the potato growing business. At all such times, 

respondent Edward Spiegel was a partner in the said partnership; speculatively 

traded in potato futures on the Chicago Mercantile Exchange in the name of the 

said partnership; and directed, controlled, and was responsible for the said 

partnership's transactions herein involved. 

VI 

Respondent Modie J. Spiegel, whose business address is 2511 West 23rd St., 

Chicago, Illinois, was at all times material to this complaint engaged in 

speculative trading in potato futures on the Chicago Mercantile Exchange for his 

own account. 

VII 

Respondents J. R. Simplot Company, Inc., and Simplot Eastern Idaho Produce 

Company. Inc., are corporations organized under the laws of the State of Idaho 

with their principal offices and places of business at Boise and Blackfoot, 

Idaho, respectively. The said J. R. Simplot Company, Inc., is now and was at 

all times material to this complaint engaging in the potato growing, processing, 

and shipping business, much of which was handled by the said Simplot Eastern 

Idaho Produce Company, Inc., its wholly owned subsidiary. At all such times, 

respondent Jack R. Simplot, whose business address is Simplot Bldg., Boise, 

Idaho, was the owner and president of the said corporations; traded in potato 
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futures on the Chicago Mercantile Exchange in the name of the said Simplot 

Eastern Idaho Produce Company, Inc.; and directed, controlled, and was 

responsible for the said corporations' transactions herein involved. 

VIII 

The Chicago Mercantile Exchange is now and has been at all times material to 

this complaint a board of trade duly designated as a contract market under the 

Commodity Exchange Act. 

IX 

The futures transactions referred to in this complaint relate to the May 1971 

potato future on the Chicago Mercantile Exchange. 

Trading in such future commenced on May 11, 1970, and continued until its 

termination on May 10, 1971. A potato futures contract on the exchange is a 

contract for 50,000 pounds of Idaho Russet Burbank potatoes. 

X 

At all times material to this complaint, respondent Jack R. Simplot, trading 

in the manner specified in paragraph VII hereof, sold May 1971 Idaho potato 

futures contracts on the Chicago Mercantile Exchange and obtained, held and 

controlled a "short" position in such future. At all such times, respondents 

Peter J. Taggares, Kenneth L. Ramm, Robert H. Abend, Harold Abend, James Minor, 

Edward Spiegel and Modie J. Spiegel, trading in the manner specified in 

paragraphs I through VI hereof, purchased May 1971 Idaho potato futures 

contracts on the Chicago Mercantile Exchange and obtained, held and controlled 

"long" positions in such future [this group of respondents, as distinguished 

from respondent Jack R. Simplot, shall hereinafter be referred to as the "long" 

respondents]. 

XI 

Beginning some time subsequent to the commencement of trading in the May 1971 

Idaho potato future on the Chicago Mercantile Exchange, the "long" respondents 

entered into a combination, conspiracy, agreement, arrangement or understanding 

among themselves whereby 

they were to take action designed for the purpose and with the intent of raising 

the price of such future to arbitrary and artificial levels. As part of the 

action to be taken pursuant to such combination, conspiracy, agreement, 

arrangement or understanding, the "long" respondents were to purchase in 

transactions on the exchange a substantial amount of contracts of the May 1971 

Idaho potato future, and to establish, maintain and keep open increasingly large 

"long" positions in such future, which they considered to be sufficient to 

enable them to cause an arbitrary and artificial rise in the price of such 

future. In connection therewith, the "long" respondents were also to solicit or 

influence various other individuals to purchase in transactions on the Exchange 

a number of contracts of the May 1971 Idaho potato future, and such other 

individuals were to establish, maintain and keep open in increasing amounts 

"long" positions in such future. 

XII 

Respondent Peter J. Taggares, acting in furtherance of the combination, 

conspiracy, agreement, arrangement or understanding referred to in paragraph XI 

hereof, purchased in transactions on the Chicago Mercantile Exchange over a 

period of time beginning on or about August 13, 1970, and continuing until on or 

about May 7, 1971, numerous contracts of the May 1971 Idaho potato future for 

the account of respondent P. J. Taggares Company, and established, maintained 
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and kept open in increasing quantities over a period of time from on or about 

August 13, 1970, through the expiration of trading on May 10, 1971, a "long" 

position in such future which advanced to as much as approximately 487 open 

contracts by on or about April 30, 1971, and which amounted to approximately 402 

open contracts at the close of trading on May 10, 1971. In addition, respondent 

Peter J. Taggares, acting in furtherance of the combination, conspiracy, 

agreement, arrangement or understanding in question, solicited or influenced at 

least 13 other individuals to purchase in transactions on the Exchange over a 

period of time beginning on or about August 14, 1970, and continuing until on or 

about May 7, 1971, various numbers of contracts of the May 1971 Idaho potato 

future, and these individuals established, maintained and kept open in 

increasing quantities over a period of time from on or about August 14, 1970, 

through the expiration of trading on May 10, 1971, "long" positions in such 

future which amounted in the aggregate to approximately 452 open contracts at 

the close of trading on May 10, 1971. 

XIII 

Respondent Kenneth L. Ramm, acting in furtherance of the combination, 

conspiracy, agreement, arrangement or understanding referred to in paragraph XI 

hereof, purchased in transactions on the Chicago Mercantile Exchange over a 

period of time beginning on or about October 22, 1970, and continuing until on 

or about March 9, 

1971, numerous contracts of the May 1971 Idaho potato future for his own 

account, and established, maintained and kept open in increasing quantities over 

a period of time from on or about October 22, 1970, through the expiration of 

trading on May 10, 1971, a "long" position in such future which advanced to the 

maximum permissible speculative limit of 150 open contracts by on or about March 

9, 1971, and which remained at such level through the close of trading on May 

10, 1971. In addition, respondent Kenneth L. Ramm, acting in furtherance of the 

combination, conspiracy, agreement, arrangement or understanding in question, 

solicited or influenced at least two other individuals to purchase in 

transactions on the Exchange over a period of time beginning on or about 

December 14, 1970, and continuing until on or about May 6, 1971, various numbers 

of contracts of the May 1971 Idaho potato future, and these individuals 

established, maintained and kept open in increasing quantities over a period of 

time from on or about December 14, 1970, through the expiration of trading on 

May 10, 1971, "long" positions in such future which amounted in the aggregate to 

approximately 124 open contracts at the close of trading on May 10, 1971. 

XIV 

Respondents Robert H. Abend and Harold Abend, acting in furtherance of the 

combination, conspiracy, agreement, arrangement or understanding referred to in 

paragraph XI hereof, purchased in 

transactions on the Chicago Mercantile Exchange over a period of time beginning 

on or about March 3, 1971, and continuing until on or about April 29, 1971, 

numerous contracts of the May 1971 Idaho potato future for the accounts of 

respondents Idaho Potato Packers Corp., Idaho Potato Packers of Idaho, Inc., and 

two other controlled accounts, and established maintained and kept open in 

increasing quantities over a period of time from on or about March 3, 1971, 

through the expiration of trading on May 10, 1971, a "long" position in such 

future which advanced to the maximum permissible speculative limit of 150 open 

contracts by on or about April 29, 1971, and which amounted to approximately 126 

open contracts at the close of trading on May 10, 1971. In addition, 

respondents Robert H. Abend and Harold Abend, acting in furtherance of the 

combination, conspiracy, agreement, arrangement or understanding in question, 

solicited or influenced at least two other individuals to purchase in 
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transactions on the Exchange over a period of time beginning on or about March 

3, 1971, and continuing until on or about April 30, 1971, various numbers of 

contracts of the May 1971 Idaho potato future, and these individuals 

established, maintained and kept open in increasing quantities over a period of 

time from on or about March 3, 1971, through the expiration in trading on May 

10, 1971, "long" positions in such future which amounted in the aggregate to 

approximately 33 open contracts at the close of trading on May 10, 1971. 

XV 

Respondent James Minor, acting in furtherance of the combination, conspiracy, 

agreement, arrangement or understanding referred to in paragraph XI hereof, 

purchased in transactions on the Chicago Mercantile Exchange over a period of 

time beginning on or about October 29, 1970, and continuing until on or about 

April 30, 1971, numerous contracts of the May 1971 Idaho potato future for the 

account of respondent San Jacinto Packing Co., and established, maintained and 

kept open in increasing quantities over a period of time from on or about 

October 29, 1970, through the expiration of trading on May 10, 1971, a "long" 

position in such future which advanced to the maximum permissible speculative 

limit of 150 open contracts by on or about April 27, 1971, and which amounted to 

approximately 121 open contracts at the close of trading on May 10, 1971. 

XVI 

Respondent Edward Spiegel, acting in furtherance of the combination, 

conspiracy, agreement, arrangement or understanding referred to in paragraph XI 

hereof, purchased in transactions on the Chicago Mercantile Exchange over a 

period of time beginning on or about January 8, 1971, and continuing until on or 

about April 30, 1971, numerous contracts of the May 1971 Idaho potato future for 

the account of respondent Universal Land-Snake River, and established, 

maintained and kept open in increasing quantities over a period of 

 

time from on or about January 8, 1971, through the expiration of trading on May 

10, 1971, a "long" position in such future which advanced to the maximum 

permissible speculative limit of 150 open contracts by on or about April 30, 

1971, and which remained at such level through the close of trading on May 10, 

1971. 

XVII 

Respondent Modie J. Spiegel, acting in furtherance of the combination, 

conspiracy, agreement, arrangement or understanding referred to in paragraph XI 

hereof, purchased in transactions on the Chicago Mercantile Exchange over a 

period of time beginning on or about April 21, 1971, and continuing until on or 

about May 4, 1971, numerous contracts of the May 1971 Idaho potato future for 

his own account, and established, maintained and kept open in increasing 

quantities over a period of time from on or about April 21, 1971, through the 

expiration of trading on May 10, 1971, a "long" position in such future which 

advanced to the maximum permissible speculative limit of 150 open contracts by 

on or about May 4, 1971, and which remained at such level through the close of 

trading on May 10, 1971. 

XVIII 

Respondents Edward Spiegel and Modie J. Spiegel, acting in furtherance of the 

combination, conspiracy, agreement, arrangement 

 

or understanding referred to in paragraph XI hereof, solicited or influenced at 

least three other individuals to purchase in transactions on the Chicago 

Mercantile Exchange over a period of time beginning on or about April 28, 1971, 

and continuing until on or about May 6, 1971, various numbers of contracts of 
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the May 1971 Idaho potato future, and these individuals established, maintained 

and kept open over a period of time from on or about April 28, 1971, through the 

expiration of trading on May 10, 1971, "long" positions in such future which 

amounted in the aggregate to approximately 112 open contracts at the close of 

trading on May 10, 1971. 

XIX 

At the expiration of trading on May 10, 1971, the open interest on the 

Chicago Mercantile Exchange in the May 1971 Idaho potato future amounted to 

approximately 2,034 contracts. As a result of the "long" respondents' trading 

activities described in paragraphs XII through XVIII hereof, the "long" 

respondents held, controlled or influenced at such time "long" positions in such 

future which amounted in the aggregate to approximately 1,820 contracts. The 

positions of the "long" respondents at the close of trading comprised, 

therefore, approximately 90% of the total open interest in the May 1971 Idaho 

potato future. 

XX 

In the belief that their combined "long" open positions were in excess of the 

"deliverable" supply of potatoes, the "long" respondents, acting in furtherance 

of the combination, conspiracy, agreement, arrangement, or understanding 

referred to in paragraph XI hereof, failed and refused to liquidate or offset 

their "long" positions in such future prior to the expiration of trading on May 

10, 1971. In addition, the "long" respondents, acting in furtherance of the 

combination, conspiracy, agreement, arrangement or understanding in question, 

solicited or influenced most of the individuals referred to in paragraphs XII, 

XIII, XIV, and XVIII hereof to refrain from liquidating or offsetting their 

"long" positions in the May 1971 Idaho potato future prior to the expiration of 

trading on May 10, 1971. 

XXI 

Beginning some time subsequent to the termination of trading in the May 1971 

Idaho potato future on the Chicago Mercantile Exchange, the "long" respondents, 

acting in furtherance of the combination, conspiracy, agreement, arrangement or 

understanding referred to in paragraph XI hereof, and for the purpose and with 

the intent of diminishing the total available supply of "deliverable" potatoes, 

induced many of the "short" traders in question to desist from 

 

packing and shipping actual carlots of the requisite potatoes in satisfaction of 

their outstanding open commitments in such future by offering to sell to such 

"short" traders actual carlots of potatoes which were to be "retendered," or 

redelivered, to the "long" respondents in settlement of the "short" traders' 

outstanding open commitments; and thereafter, by withdrawing such offer despite 

the "short" traders' reliance thereon. 

XXII 

By reason of the acts and transactions described in paragraphs XI through XXI 

hereinabove, the "long" respondents attempted to manipulate the market price of 

a commodity for future delivery on or subject to the rules of a contract market, 

in wilful violation of sections 6(b), 6(c), and 9 of the Commodity Exchange Act 

(7 U.S.C. 9, 13b, and 13). 

XXIII 

Respondent Jack R. Simplot sold in transactions on the Chicago Mercantile 

Exchange over a period of time beginning on or about March 22, 1971, and 

continuing until on or about April 30, 1971, numerous contracts of the May 1971 

Idaho potato future for the account of respondent Simplot Eastern Idaho Produce 

Company, Inc., and established, maintained and kept open in increasing 

quantities over a period of time from on or about March 22, 1971, through the 
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expiration of trading on or about May 4, 1971, a "short" position in such future 

which advanced to 260 open contracts by on or about April 30, 1971, and which 

remained at such level through the close of trading on or about May 4, 1971. 

Beginning on or about May 5, 1971, and continuing until on or about May 7, 1971, 

respondent Jack R. Simplot, acting for the purpose and with the intent of 

depressing or preventing a rise in the market price of the May 1971 Idaho potato 

future, increased the "short" position of the respondent Simplot Eastern Idaho 

Produce Company, Inc., to approximately 783 open contracts by selling in 

transactions on the Exchange approximately 523 contracts of such future. 

Thereafter, and through the expiration of trading on May 10, 1971, respondent 

Jack R. Simplot maintained and kept open, failing and refusing to liquidate or 

offset, the respondent Simplot Eastern Idaho Produce Company's "short" position 

in the May 1971 Idaho potato future of approximately 783 open contracts. 

XXIV 

By reason of the acts and transactions described in paragraph XXIII 

hereinabove, respondent Jack R. Simplot attempted to manipulate the market price 

of a commodity for future delivery on or subject to the rules of a contract 

market, in wilful violation of sections 6(b), 6(c), and 9 of the Commodity 

Exchange Act (7 U.S.C. 9, 13b, and 13). 

WHEREFORE, it is hereby ordered that this complaint and notice of hearing be 

served upon the respondents and this proceeding shall be governed by sections 

0.1, 0.2, 0.4(b), 0.5 through 0.22 and 0.28 of the rules of practice under the 

Commodity Exchange Act (17 CFR 0.1, 0.2, 0.4(b), 0.5 through 0.22, 0.28). The 

respondents will have twenty (20) days after the receipt of this complaint in 

which to file with the Hearing Clerk, United States Department of Agriculture, 

Washington, D. C. 20250, an answer with an original and five copies, fully and 

completely stating the nature of the defense and admitting or denying, 

specifically and in detail, each allegation of this complaint. Allegations not 

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

file an answer will constitute an admission of all allegations of this complaint 

and a waiver of hearing. The filing of an answer in which all of the material 

allegations of fact contained in this complaint are admitted likewise shall 

constitute a waiver of hearing unless a hearing is requested. The respondents 

are hereby notified that unless a hearing is waived, a hearing will be held in 

Chicago, Illinois, at a place therein and date to be specified later, before a 

referee designated to conduct such hearing. At such hearing, the respondents 

will have the right to appear and show cause, if any there be, why an 

appropriate order should not be issued in accordance with the Commodity Exchange 

Act, 

 

(1) prohibiting the respondents from trading on or subject to the rules of any 

contract market, and directing that all contract markets refuse all trading 

privileges to the respondents for such period of time as may be determined, and 

(2) directing that the respondents shall cease and desist from violating the 

Commodity Exchange Act in the manner alleged herein. 

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

respondents at least twenty (20) days prior to the date set for hearing. 

Done at Washington, D. C. 

September 6, 1972 

[SEE SIGNATURE IN ORIGINAL] 

Richard E. Lyng 
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Assistant Secretary 

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