(Id. ¶ 372.) Hayward’s admissions of the breakdowns in BP’s process safety plans further support the inference that he was aware of inadequacies. See, e.g., In re Toyota Motor Corp. Sec. Litig., No. CV 10-922 DSF, 2011 WL 2675395, at *4 (C.D.Cal. July 7, 2011) (finding that “the defects at issue were simply too significant for it to be plausible that top ... management was not aware of the possible ramifications of the problem by the time the statements at issue were made.”); see also Plotkin v. IP Axess Inc., 407 F.3d 690, 700 (5th Cir. 2005) (explaining that “an egregious refusal to see the obvious, or to investigate the doubtful, may in some cases give rise to an inference of recklessness.”); see also In re Enron Corp., 2003 WL 21418157 at *3, *15-16 (S.D.Tex. April 24, 2003) (<HOLDING>). The “number, size, timing, nature, frequency,
recognizing that circumstantial evidence alone can be sufficient to demonstrate a defendants guilt holding that red flags along with the defendants positions within the company were sufficient to demonstrate scienter holding that evidence of intoxication together with the circumstances of the accident were sufficient to demonstrate recklessness holding that plaintiffs adequately pleaded scienter because the allegations supported the inference that the company and the officers were at least reckless in not knowing that the financial statements were false and in failing to disclose internal control weaknesses holding the pslra standard for pleading scienter is more stringent than the second circuits standard prior to the act and that motive and opportunity is not an independent basis to show defendants had scienter