Greenspan v. U.S. Securities and Exchange Commission

District Court, District of Columbia·Decided March 25, 2025·No. Civil Action No. 2022-1153·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

AARON GREENSPAN, Plaintiff,

v. Case No. 1:22-cv-01153-RCL

UNITED STATES SECURITIES AND EXCHANGE COMMISSION,

Defendant.

MEMORANDUM OPINION

Before the Court in this pro se lawsuit is Plaintiff Aaron Greenspan’s Motion [ECF No.

31] for Leave to File Amended And/Or Supplemental Complaint. For the reasons set forth below, the Court will GRANT IN PART and DENY IN PART Mr. Greenspan’s motion.

I. BACKGROUND On April 26, 2022, Mr. Greenspan filed a Complaint against the United States Securities and Exchange Commission (“SEC”) seeking to compel the agency to produce documents pursuant to multiple Freedom of Information Act (“FOIA”) requests. 5 U.S.C. § 552 et seq.; Compl., ECF No. 1. On July 13, 2022, the SEC filed its Answer. Answer, ECF No. 8. On January 12, 2023, Mr. Greenspan moved to amend his initial complaint, which the SEC did not oppose. See Pl.’s Mot. for Leave to File Am. And/Or Suppl. Compl., ECF No. 20. The Court granted this motion on June 1, 2023. Order, ECF No. 23.

In the First Amended Complaint (“FAC”), Mr. Greenspan alleges that he submitted five FOIA requests to the SEC seeking documents relating to: two investigations into Tesla, Inc.; emails by and from former SEC employee David Misler; SEC correspondence to or from

Columbia Law School professor Joshua Mitts; and the February 2019 deposition video of Meta Platforms, Inc. CEO Mark Zuckerberg, conducted by SEC staff. First Am. Compl., ECF No. 24. Mr. Greenspan claims that, in each instance, the agency stonewalled his requests and either failed to produce documents or provided only unsatisfactory partial production. Id. These actions, according to Mr. Greenspan, violate FOIA’s requirement that agencies promptly produce documents, thus entitling him to relief. Id. Since this case’s inception, eight status conferences have taken place, with the most recent occurring on August 30, 2023. Status Report, ECF Nos. 11, 17, 19, 22, 26–28, 30.

On June 10, 2024, Mr. Greenspan filed the instant motion to amend his complaint for the second time. Pl.’s Mot. for Leave to File Am. And/Or Suppl. Compl. (“Pl.’s Mot.”), ECF No. 31. In the Proposed Second Amended Complaint (“Proposed SAC”), Mr. Greenspan seeks to add twelve new counts to the operative complaint. Proposed Second Am. Compl., ECF No. 31- 1. These counts can be divided into two categories. The first relates to Mr. Greenspan’s efforts to obtain documents from the SEC through FOIA requests.1 Id. The facts alleged in each of these counts follow a similar pattern: Mr. Greenspan alleges that he submitted a FOIA request to the SEC, that the agency stonewalled these requests, and now, after many months of non- compliance or partial compliance, Mr. Greenspan is seeking to add these FOIA requests to the

1 Count II seeks to compel the SEC to produce documents relating to investigations into Bridgewater Associates and/or related Bridgewater companies controlled by Ray Dalio. Counts III through VI are substantially similar to Counts I through IV in the FAC. Count VII seeks the deposition transcript of Meta Platforms, Inc. CEO Mark Zuckerberg conducted by SEC staff. Count VIII is substantially similar to Count V in the FAC. Count IX seeks emails sent by SEC Regional Director Erin Schneider. Count X seeks emails sent to or from specified current and former SEC employees along with emails sent to or from any other .gov email address containing the word “optic.” Count XI seeks emails sent between any individuals with a sec.gov domain name and individuals with a ftx.com or alameda-research.com domain name. Count XII is substantially similar to Count XI in the Proposed SAC. Count XIII seeks documents relating to an SEC investigation into Gaotu Techedu, Inc. Count XIV seeks documents relating to any investigations the SEC conducted into fake and/or duplicate account disclosures or methodology on Facebook.com. Count XV seeks emails relating to a database mishap reported on June 2, 2023, by Reuters.com. Count XVI seeks documents relating to Tesla, Inc.’s response to SEC subpoenas for a specified investigation. Count XVII seeks documents relating to investigations into the Cramer & Co. hedge fund.

current litigation. Id. Mr. Greenspan justifies omitting these counts from the FAC by explaining that, with the exception of one request, he was still in correspondence with the SEC at the time the FAC was filed and did not want to risk creating needless litigation by including those counts in the FAC.2 Pl.’s Reply 6, ECF No. 33.

The second category relates to the SEC’s alleged violations of Mr. Greenspan’s civil rights under 42 U.S.C. § 1983. Proposed SAC ¶¶ 234–53. In the Proposed SAC, Mr. Greenspan claims that he is a data journalist and short-seller who investigates the world’s rich and powerful to uncover wrongdoing. Id. at ¶ 1, 24. As part of that role he will, at times, submit tips to the SEC’s Office of the Whistleblower pursuant to Section 922 of the Dodd-Frank Act. Id. at ¶ 1. On November 21, 2021, Mr. Greenspan submitted a tip that he claims contained evidence of securities fraud, accounting fraud, tax fraud, and other misconduct by Tesla, Inc. Id. at ¶¶ 10–12. However, on March 13, 2023, the SEC closed the internal ticket associated with this tip, allegedly without ever having examined the evidence. Id. at ¶ 17. According to Mr. Greenspan, this inaction is due to an unspoken animus the SEC harbors toward pro se tipsters and a reluctance by the agency to appear supportive of short-sellers. Id. at ¶¶ 20–25. In failing to properly process his tip, Mr. Greenspan alleges that the SEC violated his civil rights. See id. at ¶ 253.

The SEC opposes Mr. Greenspan’s motion for leave to amend, arguing that the proposed amendment would radically alter the scope and nature of the litigation, would cause an undue delay of this action, and would prejudice the SEC by adding new claims that were available to Mr. Greenspan at the time he filed the FAC. Def.’s Opp’n 3–5, ECF No. 32. Mr. Greenspan has

2 Mr. Greenspan alleges that his last correspondence with the SEC regarding the FOIA request in Count IX was on January 12, 2023, 140 days before he filed the FAC. Pl.’s Reply 6.

filed a reply. Pl.’s Reply, ECF No. 33. Mr. Greenspan’s Motion is therefore ripe for this Court’s review.

II. LEGAL STANDARDS A. Motion for Leave to Amend the Complaint Federal Rule of Civil Procedure 15(a) provides that “[a] party may amend its pleading once as a matter of course no later than” 21 days after service of a responsive pleading. Fed. R. Civ. P. 15(a)(1); James V. Hurson Assocs., Inc. v. Glickman, 229 F.3d 277, 282 (D.C. Cir. 2000). Otherwise, “a party may amend its pleading only with the opposing party’s written consent or the court’s leave.” Fed. R. Civ. P. 15(a)(2). If asked, “[t]he court should freely give leave when justice so requires.” Id. The grant or denial of leave lies in the sound discretion of the district court. Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996).

While Rule 15(a)(2) prescribes a “liberal amendment policy,” leave to amend will not be granted automatically. 6 Wright & Miller, Federal Practice & Procedure § 1487 (3d ed.). Instead, leave to amend should be freely given absent the presence of “undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, [or] futility of [the] amendment.” Foman v. Davis, 371 U.S. 178, 182 (1962).

Free access — add to your briefcase to read the full text and ask questions with AI

Greenspan v. U.S. Securities and Exchange Commission, (D.D.C. 2025).

Greenspan v. U.S. Securities and Exchange Commission (Greenspan v. U.S. Securities and Exchange Commission) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
James v. Hurson Associates, Inc. v. Glickman
229 F.3d 277 (D.C. Circuit, 2000)
Richard Atchinson v. District of Columbia
73 F.3d 418 (D.C. Circuit, 1996)
Myrna O'Dell Firestone v. Leonard K. Firestone
76 F.3d 1205 (D.C. Circuit, 1996)
DOES I THROUGH III v. District of Columbia
815 F. Supp. 2d 208 (District of Columbia, 2011)
Wharf, Inc. v. District of Columbia
321 F.R.D. 25 (District of Columbia, 2017)
Mississippi Ass'n of Cooperatives v. Farmers Home Administration
139 F.R.D. 542 (District of Columbia, 1991)