17.) In the matters at issue here, Respondent Power appears to have acted and invested at all times for Redwood MicroCap. (Tr. 1067-68.) Respondents Power and Calandrella began investing in many of the same companies in 1983 when they were in their early twenties.9 (Tr. 224-25, 228, 233-34, 976.) Before he was an officer and director of the Rockies Fund, Respondent Calandrella was a director of a