20.  Plaintiff brings this action as a class action pursuant to Federal Rules of Civil  Procedure 23(a) and (b)(3) on behalf of a Class consisting of all persons who purchased the  common stock of SandRidge during the Class Period and who were damaged thereby.   Excluded from the Class are Defendants, the officers and directors of the Company at all  relevant times, members of their immediate families and their legal representatives, heirs,  successors or assigns, and any entity in which defendants have or had a controlling interest.   22.  Plaintiff’s claims are typical of the claims of the members of the Class, as all  members of the Class are similarly affected by Defendants’ wrongful conduct in violation of  federal law that is complained of herein.     23.  Plaintiff will fairly and adequately protect the interests of the members of the  Class and has retained counsel competent and experienced in class and securities litigation.   24.  Common questions of law and fact exist as to all members of the Class and  predominate over any questions solely affecting individual members of the Class.  Among  the questions of law and fact common to the Class are:  (a)  whether the federal securities laws were violated by Defendants’ acts as  alleged herein;    (b)  whether statements made by Defendants to the investing public during  the Class Period misrepresented material facts about the business, operations and  management of SandRidge; and  (c)  to what extent the members of the Class have sustained damages and the  proper measure of damages.   26.  On March 1, 2013 SandRidge filed its annual report for the fiscal year ended  December 31, 2012 on Form 10-K with the SEC.  The 10-K was signed by Defendants Ward,  Bennett, and Cooley. The 10-K was separately certified by Defendants Ward and Bennett  pursuant to the Sarbanes-Oxley Act of 2002 (“SOX”) attesting to the completeness and  accuracy of the Company’s annual report. The financial statements contained in the 10-K  were materially false and misleading because they failed properly to account for the penalties  SandRidge accrued under the agreement with Occidental.    27.  On May 8, 2013 SandRidge filed with the SEC its quarterly report for the first  quarter of 2013 ended March 31, 2013 on Form 10-Q.  The 10-Q was signed by Defendant  Bennett; and separately certified by Ward and Bennett pursuant to SOX attesting to the  completeness and accuracy of the Company’s quarterly report. The financial statements  contained in the 10-Q were materially false and misleading because they failed properly to  account for the penalties SandRidge accrued under the agreement with Occidental.    29.  On November 6, 2013 SandRidge filed with the SEC its quarterly report for the  third quarter of 2013 ended September 30, 2013 on Form 10-Q.  The 10-Q was signed by  Defendant LeBlanc; and separately certified by Bennett and LeBlanc pursuant to SOX  attesting to the completeness and accuracy of the Company’s quarterly report. The financial  statements contained in the 10-Q were materially false and misleading because they failed to  properly account for the penalties SandRidge accrued under the agreement with Occidental.    30.  On February 28, 2014 SandRidge filed with the SEC its annual report for the  fiscal year ended December 31, 2013 on Form 10-K.  The 10-K was signed by Defendants  Bennett, LeBlanc, and Cooley; and separately certified by Bennett and LeBlanc pursuant to  SOX attesting to the completeness and accuracy of the Company’s annual report. The  financial statements contained in the 10-K were materially false and misleading because they  failed properly to account for the penalties SandRidge accrued under the agreement with  Occidental.    32.  On August 7, 2014 SandRidge filed with the SEC its quarterly report for the  second quarter of 2014 ended June 30, 2013 on Form 10-Q.  The 10-Q was signed by  Defendant LeBlanc; and separately certified by Bennett and LeBlanc pursuant to SOX  attesting to the completeness and accuracy of the Company’s quarterly report. The financial  statements contained in the 10-Q were materially false and misleading because they failed  to  properly account for the penalties SandRidge accrued under the agreement with Occidental.   40.   Plaintiff repeats and realleges each and every allegation contained above as if  fully set forth herein.   41.  This claim is asserted against all Defendants.    43.  Defendants, individually and in concert, directly and indirectly, by the use,  means or instrumentalities of interstate commerce and/or of the mails, engaged and  participated in a continuous course of conduct to conceal adverse material information about  the business, operations and future prospects of SandRidge as specified herein.   44.  These Defendants employed devices, schemes and artifices to defraud, while in  possession of material adverse non-public information and engaged in acts, practices, and a  course of conduct as alleged herein in an effort to assure investors of SandRidge’s value and  performance and continued substantial growth, which included the making of, or the  participation in the making of, untrue statements of material facts and omitting to state  material facts necessary in order to make the statements made about SandRidge and its  business operations and future prospects in light of the circumstances under which they were  made, not misleading, as set forth more particularly herein, and engaged in transactions,  practices and a course of business that operated as a fraud and deceit upon the purchasers  SandRidge’s securities during the Class Period.   46.  Defendants had actual knowledge of the misrepresentations and omissions of  material facts set forth herein, or acted with reckless disregard for the truth in that they failed  to ascertain and to disclose such facts, even though such facts were available to them.  Such  Defendants’ material misrepresentations and/or omissions were done knowingly or recklessly  and for the purpose and effect of concealing SandRidge’s financial condition and future  business prospects from the investing public and supporting the artificially inflated or  distorted price of its securities.  As demonstrated by Defendants’ misstatements of the  Company’s financial condition and business prospects throughout the Class Period,  Defendants, if they did not have actual knowledge of the misrepresentations and omissions  alleged, were reckless in failing to obtain such knowledge by deliberately refraining from  taking those steps necessary to discover whether those statements were false or misleading.   48.  At the time of said misrepresentations and omissions, Plaintiff and other  members of the Class were ignorant of their falsity, and believed them to be true.  Had  Plaintiff and the other members of the Class and the marketplace known the truth regarding  SandRidge’s financial results, which were not disclosed by Defendants, Plaintiff and other  members of the Class would not have purchased or otherwise acquired SandRidge securities,  or, if they had acquired such securities during the Class Period, they would not have done so  at the artificially inflated prices or distorted prices at which they did.   49.  By virtue of the foregoing, Defendants have violated Section 10(b) of the  Exchange Act, and Rule 10b-5 promulgated thereunder.   51.  This action was filed within two years of discovery of the fraud and within five  years of Plaintiff’s purchases of securities giving rise to the cause of action.  52.  Plaintiff repeats and realleges each and every allegation contained above as if  fully set forth herein.   53.  This Second Claim is asserted against each of the Individual Defendants.   55.  In particular, each of these Defendants had direct and supervisory involvement  in the day-to-day operations of the Company and, therefore, is presumed to have had the  power to control or influence the particular transactions giving rise to the securities violations  as alleged herein, and exercised the same.       56.  As set forth above, SandRidge and the certain Individual Defendants each  violated Section 10(b) and Rule 10b-5 by their acts and omissions as alleged in this  Complaint.     57.  By virtue of their positions as controlling persons, the Individual Defendants  are liable pursuant to Section 20(a) of the Exchange Act as they culpably participated in the  fraud alleged herein.  As a direct and proximate result of Defendants’ wrongful conduct,  Plaintiff and other members of the Class suffered damages in connection with their purchases  of the Company’s common stock during the Class Period.   Violation of Section 10(b) of  The Exchange Act Against and Rule 10b-5  Promulgated Thereunder Against All Defendants    Violation of Section 20(a) of   The Exchange Act Against the Individual Defendants  