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Defendant was the chief financial officer of Zoltek Companies, Inc. and allegedly circumvented Zoltek’s internal accounting controls and caused Zoltek to make two unauthorized payments totaling $250,000 to an outside consultant who had raised funds for the company in the past. Subsequent concealment of the payments resulted in false entries into Zoltek’s books and records, and false and misleading representations in Schott’s certifications to the public and to Zoltek’s external auditor for the fourth quarter of 2007 and the first quarter of 2008.