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Case 5:17-cv-01245-SMH-KLH Document 1 Filed 09/29/17 Page 1 of 16 PageID #: 1

UNITED STATES DISTRICT COURT


WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DIVISION

BRENDA ANTEE VISELLI CIVIL ACTION NO.________________

v.

RAYMOND JAMES & ASSOCIATES, INC., JUDGE:


JAMES EDWARD LYONS and
THOMAS G. OBRIEN MAGISTRATE JUDGE:

ORIGINAL COMPLAINT WITH JURY DEMAND

BRENDA ANTEE VISELLI (Plaintiff) alleges the following against RAYMOND

JAMES & ASSOCIATES, INC. (Raymond James), JAMES EDWARD LYONS (Lyons)

and THOMAS G. OBRIEN (OBrien) (Raymond James, Lyons and OBrien are individually

a Defendant, or, collectively, Defendants):

PARTIES

1.

Plaintiff Brenda A. Antee Viselli is a resident of and domiciled in Lexington, Kentucky.

2.

The Defendants herein are:

1. RAYMOND JAMES & ASSOCIATES, INC. Defendant Raymond James is a

Florida corporation with its principal place of business located in St. Petersburg,

Florida, and may be served with process through its registered agent for service of

process in Louisiana, CT Corporation System;


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2. JAMES EDWARD LYONS. Defendant Lyons is domiciled in and a resident of

Shreveport, Louisiana, and was employed by Raymond James at all times relevant

hereto; and

3. THOMAS G. OBRIEN. Defendant OBrien is domiciled in and a resident of

Shreveport, Louisiana, and is the Manager of the Raymond James branch office

located at 401 Market Street, Suite 1400, Shreveport, Louisiana and the Raymond

James Managing Director, Investments.

JURISDICTION AND VENUE

3.

This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 1331

because the claims of Plaintiff arise under federal law. Furthermore, this Court has supplemental

jurisdiction pursuant to 28 U.S.C. 1367 (a) over Plaintiffs ancillary Louisiana state law claims

against Defendants.

4.

Venue is proper in the Western District of Louisiana and the Shreveport Division under

28 U.S.C. 1391 (b)(2) because a substantial portion of the events, actions, conduct and

omissions of the Defendants giving rise to the claims of Plaintiff set forth herein arose in this

District and Division.

Factual Background

5.

On or about March 25, 2004, Plaintiff opened and funded two accounts with Morgan

Keegan & Company, Inc. (Morgan Keegan) located at 401 Market Street, Shreveport,

Louisiana, using her separate property, an IRA account and the investment account at issue

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herein (the IRA account is not at issue in this suit). Plaintiffs broker dealer was Blocker

Thornton, an employee of Morgan Keegan, and was the only Morgan Keegan investment adviser

with whom Plaintiff dealt.

6.

Plaintiff advised Blocker Thornton and Morgan Keegan that the funds were her separate

property and would be needed by her for her retirement and that she needed to avoid risky

investments. The specific investment goal provided to Morgan Keegan and Blocker Thornton

was to seek capital appreciation through investments in companies that had potential for

significant growth and to avoid speculative investments having a high degree of risk, volatility

and/or trading activity. After specific consultation with Plaintiff, Mr. Thornton recommended to

Plaintiff the investment of her savings, approximately $46,591.37, in a variety of funds suitable

for Plaintiff and consistent with her investment goals and desires. From the establishment of the

account at Morgan Keegan, Plaintiff reaffirmed on numerous occasions with Blocker Thornton

the desire to avoid high risk, volatile and speculative investments and Blocker Thornton

appropriately advised and handled Plaintiffs funds and accounts in accordance with her

investment goals and desires. Over the course of time, until Blocker Thorntons death in 2011,

Plaintiff invested additional amounts with Morgan Keegan until at or about the time of Blocker

Thorntons death, her account value had grown to more than $300,000.00, the precise highest

balance to be obtained during discovery herein.

7.

Following the death of Blocker Thornton in 2011, at a time when Plaintiff then resided in

Lexington Kentucky, Morgan Keegan somehow (but without Plaintiffs consent) tapped Lyons

to assume control of Plaintiffs account at Morgan Keegan, Account No. 24204885, presumably

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under the direction, supervision and control of OBrien. Unfortunately for Plaintiff, upon taking

control of her accounts and in blatant disregard of the satisfactory investment of her funds with

Blocker Thornton and in violation of her stated investment objectives and prudent and suitable

investment practices, in late 2012 or 2013 (the exact dates of which are to be obtained in

discovery), Lyons significantly increased the investment of Plaintiffs funds in highly

speculative, volatile and unsuitable energy and energy-related stocks without Plaintiffs consent

or knowledge..

8.

Upon information and belief, Lyons did not consult with Plaintiff prior to liquidating her

investments and purchasing the highly speculative oil and gas company interests, did not contact

or explain to Plaintiff the significant risk associated with such investments, nor did Lyons or

OBrien contact Plaintiff to disclose the fundamental investment risk change from her prior

portfolio by the transactions. Further, without the knowledge, consent or permission of Plaintiff,

Lyons established a margin trading account for Plaintiff and began engaging in significant

margin trading in her account with her investments.

9.

Upon information and belief, and as will be proven at the trial hereof, by 2013, all

Defendants knew, or in the exercise of prudent judgment should have known, that oil and gas

investments were exceedingly risky investments. Certainly by 2013, in addition to other

unpredictable factors, the oil and gas industry in the United States was suffering from lack of

demand and overabundance of supply of domestic natural gas and oil and was, and is, an

extremely speculative and highly volatile investment in which loss of all or a substantial part of

an investors capital can be lost.

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10.

It is believed, and alleged upon information and belief, that until 2012, Morgan Keegan

as the employer of Lyons and OBrien was a controlling party under 15 U.S.C. 78(t)(a) and

other applicable laws.

11.

It is believed, and alleged upon information and belief, that in 2012, Raymond James and

Morgan Keegan merged, with Raymond James surviving as the successor to Morgan Keegan.

Upon information and belief, Lyons and OBrien became employees of Raymond James and

Plaintiffs account previously held at Morgan Keegan was transferred to Raymond James and

given a new account number, 50743188.

12.

It is believed, and alleged upon information and belief, that at all times from and after the

merger, Raymond James, as the employer of Lyons and OBrien, was a controlling party under

15 U.S.C. 78(t)(a) and other applicable laws.

13.

Further, upon information and belief, OBrien, as both the Branch Manager and the

Managing Director, Investments for Raymond James, was a controlling party under 15 U.S.C.

78(t)(a) and other applicable laws.

14.

Subsequent to the merger and the assumption by Raymond James of Plaintiffs account at

issue herein, Lyons continued the careless, reckless, unsuitable and highly speculative

investments, including his illicit margin trading, in highly speculative energy stocks which

grossly over-concentrated Plaintiffs account with the energy stocks. Both Raymond James and

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OBrien failed to monitor, supervise and control the patently illicit trading actions of Lyons.

None of the Defendants ever contacted Plaintiff to review, advise or discuss with her whether the

investments in her account were in accordance with her investment goals and objectives or to

confirm the unilateral decision by Lyons to embark on margin trading within Plaintiffs account.

15.

Compounding the reckless and improper trading of Plaintiffs funds by Lyons as if they

were his personal and discretionary accounts, Lyons increased his investment concentration of

Plaintiffs funds in the highly speculative energy business without the consent, knowledge or

permission of Plaintiff.

16.

As a result of the illicit trading, both in the highly speculative energy stocks and trading

on margin without Plaintiffs knowledge or consent, when the investments failed as a result of

the bankruptcy of at least one of the equity interests in which Lyons invested, on margin no less,

Plaintiff suffered a loss of approximately $300,000, the exact amount of her loss to be proven at

the trial hereof. Upon information and belief, Plaintiff alleges and believes that Lyons, with the

full knowledge, consent and permission of OBrien and Raymond James, engaged in highly

unsuitable and highly speculative energy stocks with Plaintiffs funds in order to generate

commissions and other financial incentives to Lyons, OBrien and Raymond James at the

expense of Plaintiff and without regard to the desires of Plaintiff and without regard to the

damage to Plaintiff of the loss of her funds which she entrusted to Defendants.

17.

Upon contacting Raymond James, Plaintiff was informed that Lyons was no longer

handling her account and was unavailable for Plaintiff to contact and that another Raymond

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James broker/dealer, Lyons son, Jeff Lyons, had been handed Plaintiffs account by Raymond

James. Plaintiff promptly terminated her relationship with Raymond James and moved her funds

to a competent broker in Lexington, Kentucky.

Count I: Breach of Duties

18.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them in

their entirety into this Count.

19.

At all times material hereto, Defendants Raymond James, Lyons and OBrien were

brokers or broker-dealers, within the meaning of securities laws of the United States and the

State of Louisiana and, therefore, owed duties to Plaintiff, including, without limitation:

a. the duty to recommend a stock only after studying it sufficiently to become

informed as to its nature, price and financial prognosis;

b. the duty to carry out the customers orders promptly in a manner best suited to the

customers interest;

c. the duty to inform the customer of the risks involved in purchasing or selling a

particular security;

d. the duty to refrain from self-dealing;

e. the duty to disclose any personal interest the broker may have in a particular

recommended security;

f. the duty not to misrepresent any fact material to the transaction;

g. the duty to transact business only after receiving prior authorization from the

customer; and

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h. any and all other duties.

20.

Plaintiff trusted and relied upon Defendants in the management of her savings.

21.

Plaintiff entrusted substantial sums of money to Defendants on the advice and

recommendation of Defendants, and paid Defendants substantial fees to manage and monitor the

funds in her accounts with reasonable care, competence, and diligence.

22.

Defendants duties to Plaintiff required them to act at all times in good faith and with fair

dealing toward Plaintiff.

23.

Defendants violated their duties to Plaintiff by placing their own financial interests ahead

of those of their customer, Plaintiff. That is evidenced by Defendants failure to advise Plaintiff

of the true risk inherent in the trades effected by Lyons, the fact that those trades were unsuitable

to Plaintiffs circumstances and goals, the fact that trades were designed to benefit Defendants at

the expense of Plaintiff, and that Defendants actions or inactions were the only reasons her

accounts substantially declined in value, and that Lyons had unintentionally implemented trading

on margin with Plaintiffs funds.

24.

Consequently, Plaintiff suffered losses which include, but are not limited to, loss of past,

present and future investment principal; loss of past, present and future interest on investment

principal; loss of opportunity for reasonable return on investments, and other losses and damages

for which Defendants are liable, in solido.

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Count II: Fraudulent Omissions

25.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them in

their entirety into this Count.

26.

As described above, in connection with the purchase or sale of securities in Plaintiffs

account, Lyons never consulted Plaintiff and failed to communicate critical facts concerning the

risks involved in the trades which Lyons executed in the account. Raymond James and OBrien

failed to monitor or supervise the actions of Lyons and could have prevented the losses sustained

by Plaintiff.

27.

Plaintiff is not a sophisticated investor and did not know of the omissions described

above or the gross mismanagement of her account by Defendants.

28.

Defendants knew, or in the exercise of reasonable diligence should have known, of the

omissions and mismanagement of Plaintiffs account by Lyons.

29.

Plaintiff relied on Defendants fraudulent omissions and misrepresentations by

Defendants to her detriment. Moreover, Defendants profited by omitting the critical information

described above in the form of financial incentives, including fees and commissions earned

through trading activities, about which Plaintiff was not properly informed.

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30.

As a result of the above, Plaintiff suffered losses which include, but are not limited to,

loss of past, present and future investment principal; loss of past, present and future interest on

investment principal; loss of opportunity or reasonable return on investments, and other losses

and damages for which Defendants are liable, in solido.

Count III: Federal Securities Law Violations

31.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them in

their entirety into this Count.

32.

Defendants knowingly, intentionally, and/or recklessly omitted material facts in their

handling of Plaintiffs account. In engaging in such conduct, Defendants acted with an intent to

deceive, manipulate or defraud or with a reckless disregard for the truth.

33.

By reason of the foregoing, Defendants, directly and indirectly, have violated Section

10(b) of the Securities Exchange Act, 15 U.S.C. 78j(b), and Rule 10b-5 thereunder, 17. C.F.R.

240.10b-5, and any other applicable law.

34.

As a result of the above, Plaintiff suffered losses which include, but are not limited to,

loss of past, present and future investment principal; loss of past, present and future interest on

investment principal; loss of opportunity or reasonable return on investments, and other losses

and damages for which Defendants are liable, in solido.

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Count IV: Louisiana Securities Law Violations

35.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them in

their entirety into this Count.

36.

Because the relationship here at issue was that of broker to client, Defendants are also

subject to the requirements of Louisianas securities laws, Louisiana Revised Statutes 51:712 et

seq., which require, among other things, full and truthful disclosure of all material facts related to

a sale or offer to sell a security and that the broker not engage in any schemes or artifice to

defraud related to the sale or offer to sell a security.

37.

As described above, Defendants, in connection with the offer to purchase or sell

securities, failed to state material facts necessary in order to make their statements not

misleading and intentionally engaged in a scheme to defraud and/or deceive Plaintiff.

38.

Defendants actions violated Louisianas securities laws, Louisiana Revised Statutes

51:712 et seq. and any other applicable law.

39.

Plaintiff did not know of the untruths and omissions or the scheme to defraud and/or

deceive her.

40.

Defendants knew, or in the exercise of reasonable diligence should have known, of the

untruths and omissions by Lyons. Had Raymond James and OBrien properly monitored and

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supervised Lyons and followed up periodically with Plaintiff (which they failed to do), Plaintiffs

losses would have been avoided.

41.

Plaintiff relied on Defendants fraudulent misrepresentations or omissions concerning the

securities purchased by Defendants to her detriment.

42.

As a result of the above, Plaintiff suffered losses which include, but are not limited to,

loss of past, present and future investment principal; loss of past, present, and future interest on

investment principal; loss of opportunity or reasonable return on investments, and other losses

and damages for which Defendants are liable, in solido.

Count V: Liability of Raymond James

43.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them into

this Count.

44.

Defendants Raymond James and/or its predecessor Morgan Keegan and OBrien were at

all relevant times herein employer(s) and principals of Lyons and each was a controlling party

under 15 U.S.C. 78(t)(a) and any other applicable law.

45.

The above described wrongful acts and omissions, which caused damages to Plaintiff,

were perpetrated by Lyons while in the course and scope of his employment with Raymond

James or its predecessor, Morgan Keegan, and under the supervision and control of OBrien.

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46.

As such, Raymond James and OBrien are responsible for the wrongful acts and

omissions of Lyons since they utterly failed to monitor or supervise his actions.

47.

Furthermore, Raymond James and OBrien each have a duty to Plaintiff to monitor and

supervise the actions of Lyons, and they breached that duty.

48.

Upon information and belief, Raymond James and OBrien, each a controlling party,

failed to properly supervise, investigate, monitor, and regulate the actions of Lyons.

49.

Raymond James, a controlling party, failed to create, implement, and enforce procedures

to properly supervise, investigate, monitor, and regulate the actions of Lyons, its employee.

50.

Consequently, Plaintiff suffered losses which include, but are not limited to, loss of past,

present and future investment principal; loss of past, present and future interest on investment

principal; loss of opportunity for reasonable return on investments, and other losses and damages

for which Raymond James and OBrien are liable.

Count VI: Louisiana Unfair and Deceptive Trade Practices Act,


Louisiana Revised Statutes 51:1401 et seq.

51.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them into

this Count.

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52.

Defendants knowingly and intentionally violated the provisions of the Louisiana Unfair

Trade Practices Act (LUTPA) in the offer and sale of the high risk speculative investments to

Plaintiff as described above in that Defendants (a) employed a device, scheme and artifice to

defraud Plaintiff; (b) engaged in transactions, practices and courses of business which operated

as a fraud and deceit on Plaintiff; and (c) engaged in fraudulent, deceptive and manipulative acts,

practices and courses of business in soliciting and selling the unsuitable investments to Plaintiff.

All of such conduct enriched Defendants and impoverished Plaintiff and resulted in actual,

sustained loss by Plaintiff due directly to the fraud, misrepresentation, deception, breach of

fiduciary duty and other unethical conduct of Defendants. The conduct of Defendants was

immoral, unethical, oppressive, unscrupulous and substantially injurious to consumers, including

Plaintiff. Consequently, Defendants violated the provisions of the LUTPA, Louisiana Revised

Statutes 51:1405 (A).

Count VII: Bad Faith Breach of Contract

53.

Plaintiff hereby adopts all prior allegations in this Complaint and incorporates them into

this Count.

54.

Defendant Lyons represented to Plaintiff that the investments were suitable and

appropriate for her expressed investment goals. Based upon the representations and promises of

Lyons, Plaintiff contracted with Morgan Keegan, through its duly authorized agent, Lyons, to

allow Morgan Keegan, through Lyons, to select and purchase the investments with Plaintiffs

funds. Defendants breached the agreement with Plaintiff to use the funds to acquire suitable

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investments and instead diverted the Plaintiffs funds to the purchase of the high risk speculative

stocks under the fraudulent circumstances set forth above. Defendants breached their agreement

with Plaintiff by the knowingly false, and intentionally misleading, promises and representations

about the investments and in diverting the funds to the purchase of the unsuitable stocks.

DEMAND FOR JURY TRIAL

55.

Plaintiff requests a trial by jury on all of her claims.

Prayer For Relief

56.

Based on the foregoing, Plaintiff respectfully prays that after due proceedings are had

herein, there be Judgment in favor of Plaintiff and against Defendants and award Plaintiff:

1. All damages to which Plaintiff shows herself entitled under the law and the
evidence;

2. All costs, fees and expenses incurred in the preparing, filing and prosecution of
this action, including reasonable attorneys fees, investigation costs, and all costs
and litigation expenses;

3. Disgorgement of all fees, commissions and bonuses received by Raymond James,


OBrien, and Lyons from Plaintiff or related to the offer of sale and sale of the
unsuitable investments described herein; and

4. Award any other relief equitable and appropriate under the circumstances.

Respectfully submitted,

BRADLEY MURCHISON KELLY & SHEA LLC

By: _/s/ David R. Taggart____________________


David R. Taggart
Louisiana Bar Roll No. 12626

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Ashley G. Gable
Louisiana Bar Roll No. 35783

401 Edwards Street, Suite 1000


Reception Ninth Floor
Shreveport, Louisiana 71101
Telephone: (318) 227-1131
Facsimile: (318) 227-1141

- - Attorneys for Plaintiff, Brenda Antee Viselli

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JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS


Brenda Antee Viselli Raymond James & Associates, Inc., James Edward Lyons and
Thomas G. O'Brien
(b) County of Residence of First Listed Plaintiff Caddo County of Residence of First Listed Defendant Caddo
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Bradley, Murchison, Kelly & Shea
401 Edwards Street, Suite 1000
Shreveport, Louisiana 71101 - 318-227-1131

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6


Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veterans Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 490 Cable/Sat TV
u 160 Stockholders Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 891 Agricultural Acts
u 362 Personal Injury - Product Liability u 751 Family and Medical u 893 Environmental Matters
Medical Malpractice Leave Act u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRSThird Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
15 U.S.C 78
VI. CAUSE OF ACTION Brief description of cause:
Breach of Securities Laws, Federal and State
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 300,000.00 JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
09/29/2017 David R. Taggart
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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