United States v. Ralph Cioffi and Matthew Tannin Criminal Docket No (FB)
|
|
- Lucas McKinney
- 6 years ago
- Views:
Transcription
1 U.S. Department of Justice United States Attorney Eastern District of New York 271 Cadman Plaza East F.#2007R01328 Brooklyn, New York VIA ECF The Honorable Frederic Block United States District Judge United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York September 25, 2009 Re: United States v. Ralph Cioffi and Matthew Tannin Criminal Docket No (FB) Dear Judge Block: On August 18, 2009, the government moved in limine to admit certain evidence pursuant to Federal Rule of Evidence 404(b). Cioffi opposed this motion on September 1, 2009, and the government now replies. Based on the complete evidence now obtained and set forth below, the government asserts that the proffered evidence is direct proof of the charged crimes. This proof will demonstrate that Cioffi and Tannin used Cioffi s investment in the High Grade Structured Credit Strategies Enhanced Leverage Master Fund Ltd. (the Enhanced Fund or the Fund ) to lie to Busey Bank to secure a $4,250,000 line of credit, which Cioffi needed to complete a construction project in Longboat Key, Florida. The defendants fraudulently pledged Cioffi s interests in the Enhanced Fund and bound Bear Stearns Asset Management ( BSAM ) to the terms of a Consent and Agreement ( pledge agreement ) knowing that BSAM refused to consent to Cioffi pledging his Enhanced Fund investment. Of course, this is the very same investment that Cioffi is charged with illegally redeeming in Count Four of the indictment, and which Cioffi and Tannin are charged with lying about in Counts One and Three of the indictment. As discussed below, the concealment of this fraud is direct evidence of Cioffi s motive to commit insider trading and both defendants motives to commit the remaining crimes charged in the indictment. This evidence is alternatively admissible pursuant to Rule 404(b) of the
2 Federal Rules of Evidence as it is directly relevant to issues of the defendants motive, intent, knowledge and absence of mistake. I. The Facts 1 In no uncertain terms, BSAM refused to consent to Cioffi s request to pledge his investment in the Enhanced Fund as collateral for a $4,250,000 line of credit from Busey Bank. With Tannin s assistance, Cioffi executed the pledge anyway, thereby compelling them to hide the truth from BSAM management and their investors. Cioffi invested in a multi-million dollar building project ( La Firenza ) in Florida that was on the verge of foreclosure in November 2006 ( from Cioffi to bank officials acknowledging, [y]our latest threat was that you would foreclose on 11/13th. BS-SEC ). Cioffi negotiated the use of his Fund investment as collateral to secure a loan (the pledge )(11/3/06 from Cioffi to bank official indicating, I m prepared to secure you with my shares in my Bear Stearns Hedge Fund... As of 10/31/06 the market value is $5.7M. BS-SEC ). Cioffi knew that BSAM management had to consent to the pledge (11/6/06 BS-SEC ; 11/8/06 stating, I m waiting on Bear Stearns to sign and return to me the assignment agreement on one of my BSC accounts that has $5.7M market value in. BS- SEC ). On or within days before November 6, 2006, Tannin contacted an attorney in BSAM s legal department (the 1 By no means does the government intend to offer all of these facts at trial. The government provides the Court with a fullsome recitation of the facts here, however, to refute Cioffi s claim that the government has somehow misrepresented the facts surrounding the pledge agreement. (See, e.g., Supplemental Memorandum Regarding The Government s Motion To Admit Evidence Pursuant To Federal Rule Of Evidence 404(b), dated September 22, 2009). In Section III-E herein, the government outlines the proof it intends to offer during trial on these issues. 2
3 Attorney ) to obtain the necessary documents for the pledge. The Attorney neither approved the pledge nor had the authority to do so. Rather, as set forth below, he provided ministerial editing services on certain documents. On November 6, 2006, the Attorney notified BSAM s Global Head of Hedge Funds (the Global Head ), the Chairman of BSAM s Hedge Fund business, BSAM s General Counsel, and the Director of BSAM s Third Party Seeded Hedge Funds about the pledge. He informed the senior managers that he had discussed the pledge with outside counsel, who did not think the pledge was a disclosable event because Ralph was maintaining a beneficial ownership in the interests, but asked if the managers had any questions. (BS-USAO )(Exhibit #1). Cioffi was not a party to this discussion. Minutes later, the Chairman of the Hedge Funds replied to all who were on the questioning whether Cioffi s outside interest in this real estate concern posed a potential conflict of interest for Cioffi. (BS-USAO )(Exhibit #2). About 30 minutes later, Tannin ed the General Counsel and explained that La Firenza was a real estate partnership, in which Cioffi was 40% investor. (BS- USAO )(Exhibit #3). A few minutes later, Tannin asked the General Counsel Are we ok? (BS-USAO ). The General Counsel responded, not yet. Without addressing whether BSAM would consent to the pledge, he told Tannin that Cioffi would have to complete the Outside Business Interest ( OBI ) process at BSAM. The General Counsel directed Tannin to inform Cioffi that [a]nything else he hasn t disclosed also should be on the table. The General Counsel advised Tannin that [s]ometimes, in times of difficulty, we prohibit managers from removing their investment in favor of clients going first. This [pledge] arrangement has the potential to interfere with that if there was a problem and the bank seized the assets at an inopportune time. (BS-USAO )(Exhibit #4). Minutes after sending the last to Tannin, the General Counsel forwarded the exchange to the Global Head, stating, FYI. The Global Head was 3
4 Cioffi and Tannin s direct supervisor. (BS-USAO )(Exhibit #5). On November 7, 2006, the General Counsel exchanged s with Cioffi and the compliance department regarding Cioffi s involvement in the OBI process. The General Counsel told a compliance officer, who was about to go speak with Cioffi, that after Cioffi s OBI is approved, the next question is whether we agree with him pledging the assets he owns in the fund. We have the right to restrict a withdrawal by any manager at anytime if we feel that investor withdrawals have priority. His arrangement could interfere with that. (BS-USAO )(emphasis supplied)(exhibit #6). In the meantime, the Global Head consulted with a variety of senior managers of BSAM about the propriety of Cioffi s pledge, including the Chief Executive Officer ( CEO ) of BSAM, who delegated the decision on the pledge to the Global Head. As set forth below, the Global Head denied the pledge. For his part, Tannin advocated in favor of Cioffi s pledge to the Global Head. (11/13/06 from Tannin stating [t]his is more than you want to know... but... Ralph s pledge of the hedge fund shares is to cover the $3mm lein [sic]. (BS-SEC )(Exhibit #7). Viewing the decision whether to permit Cioffi to enter into the pledge agreement as a business, rather than a legal decision, the Global Head decided not to grant BSAM s consent to Cioffi s pledge of his investment in the Enhanced Fund. (See 3500 GQ-4 and GQ-5; BS- SEC ). On November 14, 2006, the Global Head sent Cioffi an telling him that he came by Cioffi s office to see him, but that Cioffi was in a meeting. He asked Cioffi to call him re the pledge. (BS-USAO )(Exhibit #8). That same day, the OBI Group informed Cioffi that it had approved his continued interest in La Firenza as an OBI. (BS-USAO ). The OBI group never considered or approved the pledge. On either November 14 or 15, 2006, the Global Head visited Cioffi s office again. He informed Cioffi, in 4
5 no uncertain or ambiguous terms, that BSAM did not consent to Cioffi s pledge. The Global Head gave Cioffi his reasons for the denial of consent, including his concern that such a pledge would have to be disclosed to Fund investors. Cioffi became enraged, resorting to expletives, and blamed the decision on BSAM s General Counsel. (3500 GQ-4 and GQ-5; BS- SEC or BS-USAO )(Exhibit #9). On November 29, 2006, Tannin ed the Attorney and asked him if him if he was cool with a draft pledge agreement Tannin attached to the . (BS-USAO ). Neither Tannin nor Cioffi advised the Attorney that BSAM had expressly denied the pledge on or about November 14, Later that day, the Attorney responded to Tannin, providing some minor typographical edits to the draft pledge agreement. (BS-USAO ). The Attorney did not and could not have approved the pledge. On a later date after November 29, 2006, (see BS-USAO )(Exhibit #10), Tannin brought the pledge agreement to BSAM s Hedge Fund Middle Office Manager ( Middle Office Manager ). 2 The Middle Office Manager signed the agreement at Tannin s request. Neither Tannin nor Cioffi advised the Middle Office Manager that BSAM had expressly prohibited the pledge on or about November 14, On or about December 20, 2006, a Busey Bank Senior Vice-President, executed the pledge agreement on behalf of Busey Bank thereby finalizing the pledge of Cioffi s Enhanced Fund investment as collateral for the $4,250,000 line of credit to Cioffi. (BUSEY ). 2 In his position, the Middle Office Manager supported the portfolio managers, provided estimates to clients on returns by sector and portfolio, and oversight for administrators. (See 3500-GC-3 at 1). 5
6 The pledge agreement has four signatories: (1) Matthew Tannin on behalf of the Enhanced Fund 3 and as a representative of BSAM; (2) the Middle Office Manager on behalf of BSAM, (3) Ralph Cioffi as the Customer (Borrower) and (4) Busey Bank s Senior Vice-President, on behalf of Busey Bank. Id. The pledge agreement states that: 1. BSAM consented to Cioffi s pledge; 2. BSAM consented to the assignment of Cioffi s security interest in the Enhanced Fund to Busey Bank; 3. BSAM acknowledged that it had been directed by Cioffi to register Busey Bank s partnership interest in the Enhanced Fund as [Busey Bank] as pledgee of [Ralph Cioffi]; 4. BSAM agreed not to change that registration without Busey Bank s written consent; 5. BSAM represented that Cioffi s Enhanced Fund investment was not otherwise encumbered; 6. BSAM agreed not to consider or act upon any request by Cioffi to withdraw all or some of his interest in the Enhanced Fund; 7. BSAM agreed to consider only withdrawal requests made by Busey Bank; 8. BSAM agreed neither to consider nor act upon any request by Cioffi to sell, assign or otherwise dispose of his interest in the Enhanced Fund; and 3 Inexplicably, the form is in the name of the Bear Stearns High-Grade Structured Credit Strategies, L.P. ( High Grade Fund ), despite the fact that, as of December 20, 2006, Cioffi had no investments in the High Grade Fund. Other documents, such as the State of Florida Uniform Commercial Code Financing Statement Form, clarify that the pledge was secured by Cioffi s investment in the Enhanced Fund. (BUSEY ). 6
7 9. BSAM agreed that the agreement would remain in effect until it received written notice from Busey Bank. By the agreement, Tannin, as the Fund s agent, represented that, as of the date of the agreement, the interests of Busey Bank were registered on the books of the Enhanced Fund as [Busey Bank] as pledgee of [Ralph Cioffi]. Tannin also agreed to pay the proceeds of any distributions or withdrawals incurred by Cioffi directly to Busey Bank s account. Contrary to Tannin s representations, the security interests of Busey Bank were never registered on the books of the Enhanced Fund on December 20, 2006, or on any date thereafter. (See Fund Shareholder Register, as of May 31, 2007)(BS-USAO )(Exhibit # 9). Along with the pledge, Cioffi executed a four-page revolving promissory note for the $4,250,000 line of credit, which contained an acceleration clause that provided that if Cioffi defaulted in the performance of or compliance with the Security Agreements or any of the other loan documents securing the note, he would be liable for the entire principal of the loan plus interest on 10 days notice. (BUSEY ) As of April 1, 2007, Cioffi redeemed $2 million (or one-third) of his investment in the Enhanced Fund, which was still, albeit unregistered, subject to the restrictions of the pledge with Busey Bank. Similar to the manner in which he approached the pledge, Cioffi did not personally notify BSAM senior management of his intent to redeem. On July 23, 2007, after inquires by Busey Bank, Cioffi advised the bank that its security interest in the Enhanced Fund was worthless. (BS-SEC ). II. Witness Accounts To verify the above facts, the government interviewed the CEO, the Global Head, the Middle Office Manager, the Attorney and Busey Bank personnel. These interviews have provided the following information. The Global Head stated that he was the highest ranking manager in the hedge fund division of BSAM; he was 7
8 Cioffi s and Tannin s direct supervisor; and he reported directly to BSAM s CEO. The decision to deny the pledge was his to make, and he communicated his decision to Cioffi directly and unequivocally. As his subordinate, the Middle Office Manager, had no authority to overrule the Global Head s decision. As the denial was a business decision, rather than a legal decision, the Attorney had no input in, much less the authority to overrule, the Global Head s denial of consent. Other than the CEO, no other person at BSAM had the authority to overrule the denial, and the CEO did not do so. In fact, the Global Head assumed that Cioffi abided by the denial until only a few days ago. The Attorney stated that he learned about Cioffi s pledge from Tannin. The Attorney alerted BSAM senior management to the pledge because he thought it was unusual and something they should know about. (See BS-USAO ( Matt was being a bit cagey about the purpose of the loan )). The Attorney merely provided the pledge documents to Tannin. He had no contact with Cioffi about the pledge. He did not approve the pledge, nor did he have the authority to do so. Had he been informed by Cioffi, Tannin or anyone else that the Global Head forbade Cioffi s pledge, he would not have assisted Cioffi and Tannin in any way. The Middle Office Manager stated that Tannin brought him the pledge agreement, and he signed it. While he had previously signed investor pledge documents, this was the first and only time he had seen a portfolio manager pledging his or her investment in their own fund. He recalled that he was hesitant to sign the document because Busey Bank had not yet signed the agreement. He recalled offering some push-back to Tannin over signing the pledge. He was confident, nonetheless, that he would have asked Tannin whether Cioffi had obtained the proper approvals for the pledge. Had he been told by Tannin or anyone else, that the Global Head, his superior at BSAM, had denied Cioffi s request to pledge the investment, he is absolutely sure he would have never signed the pledge. For his part, the CEO stated that the Global Head had the authority to deny BSAM s consent to Cioffi s pledge. He stated that neither the Attorney nor the Middle Office Manager had the authority to override the Global Head s decision. He, as the CEO, was the only person at BSAM who was authorized to reverse the Global Head s decision not to permit Cioffi to pledge his investment in the Enhanced Fund, and he did not do so. 8
9 III. Argument A. Cioffi Did Not Have BSAM s Permission To Pledge His Investment In the Enhanced Fund As a threshold matter, the government can now put to rest the question of whether Cioffi had BSAM s consent to pledge his investment in the Enhanced Fund as collateral for a loan: Cioffi did not. Cioffi s recent attempts to skew the facts by stringing together s from the Global Head s subordinates are meritless. See Supplemental Memorandum Regarding The Government s Motion To Admit Evidence Pursuant To Federal Rule Of Evidence 404(b), dated September 22, The evidence is also clear that Tannin was in lock-step with Cioffi in his scheme to circumvent BSAM s decision to deny the pledge and, in doing so, bind BSAM to the terms of a pledge agreement of which it did not approve. Tannin was involved in the pre-denial negotiations with the Global Head: he directly advocated that Cioffi be permitted to enter into the pledge. Tannin did all of the legwork to make it appear to Busey Bank that BSAM approved the pledge: (1) he managed all of the contacts with the Attorney to obtain the forms needed to effectuate the pledge; (2) he brought the pledge to the Middle Office Manager for his signature, without informing him that the Global Head forbade the pledge; and (3) by signing the pledge, he represented to Busey Bank that the bank s interests in Cioffi s investment were recorded on the books of the Enhanced Fund. They never were. 4 Moreover, Tannin never raised an objection to Cioffi s redemption of $2 million from the Enhanced Fund when he learned of it in April 2007, even though he knew the proceeds of the redemption were subject to the terms of the pledge agreement that he signed. Tannin also did not deposit the proceeds of the redemption in Busey Bank s 4 Documents show that Tannin was familiar with the pledge registration process, having been involved in another investor s redemption of his pledged assets in the High Grade Fund to effectuate a subscription of the same assets into the the Enhanced Fund only months before. (BS-USAO )(Exhibit #10). Not surprisingly, the existence of that investor s pledge agreement is clearly reflected in the books and records of the Enhanced Fund. (See Exhibit #9, BS-USAO ). 9
10 account as required by the pledge agreement. Tannin, an attorney, did neither of these things because he, like Cioffi, knew that BSAM did not consent to the pledge. In sum, the facts will show that Cioffi and Tannin conspired to circumvent BSAM s denial of consent for Cioffi s pledge. Together, the defendants duped the Middle Office Manager into signing the pledge and later lied to Busey Bank in representing, inter alia, that BSAM consented to the pledge when they knew that was false. As a result of their efforts, Busey Bank was defrauded into granting Cioffi a $4,250,000 line of credit based, in part, on collateral in which the bank did not have a registered interest and was later rendered worthless. 5 B. The Pledge Is Direct Evidence Of The Defendants Motive To Commit Securities Fraud Evidence of Cioffi and Tannin s scheme to circumvent BSAM s denial of Cioffi s pledge coupled with evidence of the fraud they perpetrated on Busey Bank provides probative, direct proof of the defendants motives to commit each and every crime charged in the indictment. This pledge occurred immediately prior to the charged conspiracy and colored every decision and motive of the defendants throughout the spring of 2007 and the securities fraud conspiracy. The defendants had to keep the existence of the pledge a secret from BSAM and the existence of Cioffi s blatant violation of the pledge (i.e., the $2 million redemption of Busey Bank s collateral in the Enhanced Fund) a secret from Busey Bank. Together with their obvious motives to increase their wealth and maintain their lifestyles, their motive to conceal pledge-related frauds drove them to commit additional acts of securities fraud against the investors in the Funds. To be sure, when Cioffi, aware of negative material, non-public information about the prospects of the Funds, redeemed $2 million from the Enhanced Fund in April 2007, he also did so out of concern for the future value of the collateral he had fraudulently pledged to Busey Bank. 5 It should be noted that the Busey Bank loan was subsequently re-paid in full months after the bank s collateral in the Enhance Fund was reduced to zero. 10
11 Having been threatened once with foreclosure by Busey Bank, Cioffi was aware of Busey Bank s willingness to initiate foreclosure proceedings in the event of a default. A foreclosure would have required Cioffi to pay the entire balance of the loan on 10 days notice, which would have been a demand Cioffi was ill-equipped to meet due to the numerous other financial burdens he carried during the same time period (see Govt s September 21, 2009 Letter, p ). Avoiding foreclosure proved to be a strong motive for Cioffi to tell lie after lie to his investors to keep the Enhanced and High Grade Funds in business. That motive was further augmented by Cioffi s reasonable expectation that BSAM would take adverse action against him if it discovered that he pledged his investment against BSAM s explicit orders. As an attorney, Tannin was fully cognizant that if his lies to Busey Bank came to light, he would face potential criminal liability. Indeed, Tannin s misrepresentations to Busey Bank amounted to black-and-white violations of the law (e.g., falsely binding BSAM to the pledge when he knew he did not have the authority to do so and falsely representing that he had registered the securities in the name of Busey Bank when he had not). Like Cioffi, Tannin had a strong motive, therefore, to lie to investors in the hope of propping up the Enhanced Fund and not drawing Busey Bank s or BSAM s attention to the status of Cioffi s investment in the Fund. Greed coupled with fear of exposure motivated Cioffi and Tannin to lie to the Funds investors in their futile attempt to keep the hedge funds alive and, hopefully, keep their fraudulent pledge deal a secret. Without question, had the defendants told investors about Cioffi s $2 million redemption or the collective state of redemptions in the Funds in April and May 2007, these disclosures would have jeopardized the Funds stability, thereby increasing the likelihood of further redemptions and the discovery of the fraudulent pledge. These were eventualities the defendants were loathe to let happen. C. The Pledge Is Inextricably Intertwined Direct Evidence Of The Crimes Charged The government submits that the pledge evidence is not a remote uncharged act committed by the defendants, but part of a continuing offense that contributed to their motives of greed and personal enhancement to commit the crimes on trial. The pledged securities are the same 11
12 securities that the defendants are charged with lying about in the indictment. For that reason, the Court should consider evidence of the pledge as inextricably intertwined direct evidence of the crimes charged, making a Rule 404(b) analysis unnecessary. Among other things, evidence of the pledge is inextricably intertwined proof that directly: Proves that the defendants had motives, beyond greed and personal enrichment, for committing securities fraud and insider trading; Belies Cioffi s assertion that he moved $2 million into the Structured Risk Partners Fund ( SRP ) to put his skin in the game in the SRP Fund, something he had intended to do since December 2006; Demonstrates that the defendants never intended, under any circumstances, to reveal Cioffi s $2 million redemption to BSAM or investors in the Funds; and Establishes that the defendants conspired to conceal the fact of Cioffi s redemption after April The Second Circuit has made clear that evidence of uncharged criminal activity is not considered other crimes evidence under Fed. R. Evid. 404(b) if it arose out of the same transaction or series of transactions as the charged offense, if it is inextricably intertwined with the evidence regarding the charged offense, or if it is necessary to complete the story of the crime on trial. See United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000) (quoting United States v. Gonzalez, 110 F.3d 936, 942 (2d Cir. 1997)(emphasis supplied); see also United States v. Baez, 349 F.3d 90, 94 (2d Cir. 2003); United States v. Avendano, 2004 WL , at *2 (S.D.N.Y. Nov. 30, 2004) (finding defendant s agreement to act as a cocaine courier for a cooperating witness to be inextricably intertwined with the evidence regarding the charged heroin conspiracy and necessary to complete the story of that alleged offense, highly probative intrinsic evidence of Defendant s involvement in the conspiracy charged, and not 12
13 other crime evidence within the meaning of Rule 404(b)); accord United States v. Leavitt, 878 F.2d 1329, (11th Cir. 1989) ("Evidence of criminal activity other than the offense charged is not extrinsic evidence under Rule 404(b) if it is inextricably intertwined with the evidence of the charged offense or is necessary to complete the story of the charged offense ). The government will offer evidence of the pledge not to show the defendants propensity to commit fraud, but rather as relevant background evidence to complete the story of the crimes charges and the relationship, including the relationship of trust, that developed between the defendants. See United States v. Langford, 990 F.2d 65, 70 (2d Cir. 1993)( It is within the court s discretion to admit evidence of acts committed prior to the time charged in the indictment to prove the existence of the alleged conspiracy as well as to show its background and history ). This evidence fills out for the jury the manner in which the defendants conducted their affairs at BSAM. Evidence of the uncharged acts completes the story of the crimes charged and helps explain to the jury how the illegal relationship between the participants in the crime developed. See United States v. William, 205 F.3d 23, (2d Cir. 2000). D. The Pledge Is Admissible Under Rule 404(b) In the alternative, the government submits that evidence of the pledge is not only admissible for the reasons set forth above, but is also admissible pursuant to Fed. R. Evid. 404(b) to show motive, intent, knowledge and absence of mistake. See e.g., United States v. Smith, 727 F.2d 214, (2d Cir. 1984) (affirming admission of similar acts of securities fraud to show defendant s knowledge of, and intent to engage in, free-riding securities scheme ); United States v. Lauersen, No. S2 98 Cr (WHP), 2000 WL at *3 (S.D.N.Y. November 8, 2000) (evidence of false diagnoses attributed by defendant to patients not undergoing fertility treatments admitted to show intent and lack of mistake when making identical false representations attributable to patients undergoing fertility treatments). The Second Circuit has adopted the inclusionary or positive approach to the Rule. United States v. Levy, 731 F.2d 997, 1002 (2d Cir. 1984); see also United States v. DeVillio, 983 F.2d 1185, 1194 (2d Cir. 1993). Consistent with this approach, "evidence of other crimes, wrongs, or 13
14 acts is admissible for any purpose other than to show a defendant's criminal propensity." United States v. Brennan, 798 F.2d 581, 589 (2d Cir. 1986) (emphasis added); see also United States v. Pipola, 83 F.3d 556, 565 (2d Cir. 1996) (Second Circuit s inclusionary interpretation of the rule allows evidence of other wrongs to be admitted so long as it is relevant and is not offered to prove criminal propensity ). As the government set forth in its first letter on this topic, see Govt s August 18, 2009 Letter, evidence of Cioffi s involvement in the pledge is relevant to his knowledge of BSAM s dim view of portfolio managers altering their investments in their funds, and his intent to avoid BSAM s scrutiny. The government otherwise relies on its prior arguments as they relate to the pledge s relevance to Cioffi s knowledge and disregard of the compliance procedures at BSAM. E. The Quantity Of Proof Of The Pledge The government has no intention to create a trial within a trial or to offer any proof that will distract the jury s attention away from the crimes charged in the indictment. To prove the existence of the pledge and its relationship to the crimes charged, the government expects to add a limited amount of proof to the trial record. The Global Head is already a noticed trial witness for the government. The government plans to ask him a limited amount of questions about how the pledge came to light and about the day he explicitly denied BSAM s consent for Cioffi s pledge. The government also intends to call the Middle Officer Manager to testify to that the pledge is authentic, that his position at BSAM was subordinate to the Global Head, that he signed the pledge without having been advised that BSAM objected to the pledge, and that, to his knowledge, the pledge was never filed on the books of the Enhanced Fund. 14
15 IV. Conclusion For the foregoing reasons, the government respectfully requests that evidence of the pledge agreement be admitted as direct proof of the crimes charged in the indictment or, in the alternative, be admitted as Rule 404(b) evidence. Respectfully submitted, BENTON J. CAMPBELL UNITED STATES ATTORNEY By: James G. McGovern Ilene Jaroslaw Patrick Sean Sinclair Brian Sano Assistant U.S. Attorneys 15
CRIMINAL. Court: United States District Court, Eastern District of New York Case Title: USA v. Motz Docket Number: 2:08CR00598 Expert(s): n/a
CRIMINAL Court: United States District Court, Eastern District of New York Case Title: USA v. Motz Docket Number: 2:08CR00598 Expert(s): n/a Mark the Correct Category X Crime Type LBL2 White Collar Crime
More informationCase 1:08-cr FB Document 187 Filed 09/25/09 Page 1 of 6
Case 1:08-cr-00415-FB Document 187 Filed 09/25/09 Page 1 of 6 U.S. Department of Justice JM:IJ:PSS:BS United States Attorney Eastern District of New York 271 Cadman Plaza East Brooklyn, New York 11201
More informationCase 1:08-cr FB Document 192 Filed 09/29/09 Page 1 of 17 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK
Case 1:08-cr-00415-FB Document 192 Filed 09/29/09 Page 1 of 17 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. RALPH CIOFFI AND MATTHEW TANNIN, No. 08 Cr. 415 (FB)
More informationFollow this and additional works at:
2014 Decisions Opinions of the United States Court of Appeals for the Third Circuit 9-3-2014 USA v. Victor Patela Precedential or Non-Precedential: Non-Precedential Docket No. 13-2255 Follow this and additional
More informationCase 0:14-cv WPD Document 28 Entered on FLSD Docket 09/05/2014 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Case 0:14-cv-60975-WPD Document 28 Entered on FLSD Docket 09/05/2014 Page 1 of 8 WENDY GRAVE and JOSEPH GRAVE, vs. Plaintiffs, WELLS FARGO BANK, N.A., UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF
More informationIN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION MEMORANDUM
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION LORRIE THOMPSON ) ) v. ) NO. 3-13-0817 ) JUDGE CAMPBELL AMERICAN MORTGAGE EXPRESS ) CORPORATION, et al. ) MEMORANDUM
More informationFollow this and additional works at:
2009 Decisions Opinions of the United States Court of Appeals for the Third Circuit 7-1-2009 USA v. Gordon Precedential or Non-Precedential: Non-Precedential Docket No. 07-3934 Follow this and additional
More informationUNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA
Case :-cr-000-vap Document Filed 0/0/ Page of 0 Page ID #: 0 0 JOHN NEIL McNICHOLAS, ESQ. STATE BAR #0 McNicholas Law Office Palos Verdes Blvd., Redondo Beach, CA 0 (0) -00 (0) -- FAX john@mcnicholaslawoffice.com
More informationCase 1:10-cr RDB Document 71 Filed 03/11/11 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
Case 1:10-cr-00181-RDB Document 71 Filed 03/11/11 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA * v. * Criminal No. 1:10-cr-0181-RDB THOMAS ANDREWS
More informationCase 2:08-cv PMP-GWF Document 216 Filed 10/08/2009 Page 1 of 10
Case :0-cv-00-PMP-GWF Document Filed 0/0/00 Page of 0 0 0 MTN MARK B. BAILUS, ESQ. Nevada Bar No. GEORGE P. KELESIS, ESQ. Nevada Bar No. 00 BAILUS COOK & KELESIS, LTD. 00 South Fourth Street, Suite 00
More informationDefendant Stephen Kerr, by and through undersigned counsel, herby moves
Case :-cr-0-jat Document Filed 0// Page of Michael D. Kimerer #00 Rhonda Elaine Neff #0 KIMERER & DERRICK, P.C. East Osborn, Suite 0 Phoenix, AZ 0 Telephone: (0) -00 Facsimile: (0) - Attorneys for Defendant,
More informationCase 1:15-cr KAM Document 450 Filed 11/13/17 Page 1 of 5 PageID #: U.S. Department of Justice
Case 1:15-cr-00637-KAM Document 450 Filed 11/13/17 Page 1 of 5 PageID #: 12246 U.S. Department of Justice United States Attorney Eastern District of New York AES/DCP/DKK 271 Cadman Plaza East F.#2014R00501
More informationCase 6:18-cr RBD-DCI Document 59 Filed 08/16/18 Page 1 of 9 PageID 393 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION
Case 6:18-cr-00043-RBD-DCI Document 59 Filed 08/16/18 Page 1 of 9 PageID 393 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION UNITED STATES OF AMERICA, CASE NO. 6:18-cr-43-Orl-37DCI
More informationIN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA,
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE Plaintiff, Case No.: 07-24338-CACE vs. DIVISION: 02. JAMES
More informationUNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION. No. CR
DEBRA WONG YANG United States Attorney SANDRA R. BROWN Assistant United States Attorney Chief, Tax Division (Cal. State Bar # ) 00 North Los Angeles Street Federal Building, Room 1 Los Angeles, California
More informationUNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION
Chapman et al v. J.P. Morgan Chase Bank, N.A. et al Doc. 37 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION BILL M. CHAPMAN, JR. and ) LISA B. CHAPMAN, ) ) Plaintiffs, ) )
More informationCase 1:17-cr ABJ Document 505 Filed 02/13/19 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) )
Case 1:17-cr-00201-ABJ Document 505 Filed 02/13/19 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. PAUL J. MANAFORT, JR., Defendant. Criminal No. 17-201
More informationUNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION
Case 3:16-cr-00093-TJC-JRK Document 188 Filed 06/08/17 Page 1 of 19 PageID 5418 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, )
More informationUSA v. Brian Campbell
2012 Decisions Opinions of the United States Court of Appeals for the Third Circuit 12-7-2012 USA v. Brian Campbell Precedential or Non-Precedential: Non-Precedential Docket No. 11-4335 Follow this and
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY. No.
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY PLAINTIFF, In His Behalf and on Behalf of All Others Similarly Situated, v. Plaintiff, COGNIZANT TECHNOLOGY SOLUTIONS CORPORATION, FRANCISCO D SOUZA,
More informationThis is a securities fraud case involving trading in commercial mortgage-backed
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, Plaintiff, -v- 17-CV-3613 (JPO) OPINION AND ORDER JAMES H. IM, Defendant. J. PAUL OETKEN, District Judge:
More informationCase 4:07-cv RAS Document 359 Filed 05/05/14 Page 1 of 10 PageID #: 11114
Case 4:07-cv-00146-RAS Document 359 Filed 05/05/14 Page 1 of 10 PageID #: 11114 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION ALVERTIS ISBELL D/B/A ALVERT MUSIC,
More informationEBERHARD SCHONEBURG, ) SECURITIES LAWS
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) AND ON BEHALF OF ALL OTHERS ) CASE No.: SIMILARLY SITUATED, ) 7 ) 8 Plaintiff, ) CLASS ACTION vs. ) COMPLAINT 9 ) FOR VIOLATIONS
More informationINDIANA FALSE CLAIMS AND WHISTLEBLOWER PROTECTION ACT
Indiana False Claims and Whistleblower Protection Act, codified at 5-11-5.5 et seq (as amended through P.L. 109-2014) Indiana Medicaid False Claims and Whistleblower Protection Act, codified at 5-11-5.7
More informationTHE GOVERNMENT S MOTION AND MEMORANDUM OF LAW IN SUPPORT OF A PRETRIAL CONFERENCE PURSUANT TO THE CLASSIFIED INFORMATION PROCEDURES ACT
Case 1:17-cr-00544-NGG Document 29 Filed 09/12/18 Page 1 of 14 PageID #: 84 JMK:DCP/JPM/JPL/GMM F. # 2017R01739 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - -
More informationfiled against him on February 2, 1995 from the counts contained in the same indictment against
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION UNITED STATES OF AMERICA, CRIMINAL ACTION NO. Plaintiff, 3:95-CR-030-G v. XXXX XXXX, Defendant. DEFENDANT XXXX XXXX S MOTION FOR
More informationCase 3:10-cr FDW Document 3 Filed 04/07/10 Page 1 of 7
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION UNITED STATES OF AMERICA DOCKET NO. 3:1 OCR59-W v. PLEA AGREEMENT RODNEY REED CAVERLY NOW COMES the United States of America,
More informationIN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:12CR-235
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:12CR-235 UNITED STATES OF AMERICA, ) ) Vs. ) ORDER ) PHILLIP D. MURPHY, ) ) Defendant. ) ) THIS MATTER
More informationDECISION AND ORDER. Ford Motor Credit Company ( Ford ) has filed a Complaint for Foreclosure
Ford Motor Credit Co. v. Natural Bridge Holdings, LLC, No. 32-1-10 Bncv (Wesley, J., Dec. 30, 2010) [The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original.
More informationCase acs Doc 52 Filed 08/20/15 Entered 08/20/15 16:11:30 Page 1 of 14 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF KENTUCKY
Case 14-34747-acs Doc 52 Filed 08/20/15 Entered 08/20/15 16:11:30 Page 1 of 14 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF KENTUCKY In re: ) ) CLIFFORD J. AUSMUS ) CASE NO. 14-34747 ) CHAPTER 7
More informationCase 1:05-cr MGC Document 192 Entered on FLSD Docket 12/22/2008 Page 1 of 13
Case 1:05-cr-20770-MGC Document 192 Entered on FLSD Docket 12/22/2008 Page 1 of 13 UNITED STATES OF AMERICA, v. Plaintiff, GLORIA FLOREZ VELEZ, BENEDICT P. KUEHNE, and OSCAR SALDARRIAGA OCHOA, Defendants.
More informationCALIFORNIA FALSE CLAIMS ACT
CALIFORNIA FALSE CLAIMS ACT The people of the State of California do enact as follows: SECTION 1. Section 12650 of the Government Code is amended to read: 12650. (a) This article shall be known and may
More informationCase 1:10-cr RDB Document 54 Filed 02/25/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND NORTHERN DIVISION
Case 1:10-cr-00181-RDB Document 54 Filed 02/25/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND NORTHERN DIVISION UNITED STATES OF AMERICA * * v. * * THOMAS ANDREWS DRAKE,
More informationCase 8:09-cr CJC Document 54 Filed 05/18/12 Page 1 of 17 Page ID #:143
Case :0-cr-00-CJC Document Filed 0// Page of Page ID #: ANDRÉ BIROTTE JR. United States Attorney DENNISE D. WILLETT Assistant United States Attorney Chief, Santa Ana Branch JENNIFER L. WAIER Assistant
More informationCase 3:18-cr MMH-JRK Document 59 Filed 10/17/18 Page 1 of 5 PageID 149
Case 3:18-cr-00089-MMH-JRK Document 59 Filed 10/17/18 Page 1 of 5 PageID 149 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION UNITED STATES OF AMERICA vs. CASE NO.: 3:18-cr-89-J-34JRK
More informationNew York City False Claims Act
New York City False Claims Act (N.Y.C. Admin. Code 7-801 to 810) i 7-801 Short title. This chapter shall be known as the "New York city false claims act." 7-802 Definitions. For purposes of this chapter,
More informationUSA v. David McCloskey
2015 Decisions Opinions of the United States Court of Appeals for the Third Circuit 4-8-2015 USA v. David McCloskey Follow this and additional works at: http://digitalcommons.law.villanova.edu/thirdcircuit_2015
More informationDistrict of Columbia False Claims Act
District of Columbia False Claims Act 2-308.03. Claims by District government against contractor (a) (1) All claims by the District government against a contractor arising under or relating to a contract
More informationDEPOSITORY COLLATERAL AGREEMENT
Exhibit B DEPOSITORY COLLATERAL AGREEMENT This Depository Collateral Agreement ( Agreement ), dated, is between (the Bank ), having an address at, and (the Public Depositor ), having an address at. WITNESSETH:
More informationEASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) COUNT 1 (Conspiracy) THE DEFENDANTS
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION UNITED STATES OF AMERICA, v. Plaintiff, LEON S. HEARD, STEVEN I. HELFGOTT, DARRYL G. MOORE, ROBERT E. MCNAIR, MARK
More informationU.S. v. CANALE, Cite as 115 AFTR 2d , Code Sec(s) 6531, (DC NY), 06/17/2015. UNITED STATES OF AMERICA, PLAINTIFF v. Peter CANALE, DEFENDANT.
06/17/2015 American Federal Tax Reports U.S. v. CANALE, Cite as 115 AFTR 2d 2015-2249, Code Sec(s) 6531, (DC NY), 06/17/2015 UNITED STATES OF AMERICA, PLAINTIFF v. Peter CANALE, DEFENDANT. Case Information:
More informationUNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. CASE No.: COMPLAINT
Ira M. Press KIRBY McINERNEY LLP 825 Third Avenue, 16th Floor New York, NY 10022 Telephone: (212) 371-6600 Facsimile: (212) 751-2540 Email: ipress@kmllp.com Counsel for Plaintiff UNITED STATES DISTRICT
More informationOKLAHOMA FALSE CLAIMS ACT
. OKLAHOMA FALSE CLAIMS ACT OKLAHOMA MEDICAID FALSE CLAIMS ACT 63-5053. Short title. This act shall be known and may be cited as the "Oklahoma Medicaid False Claims Act". Added by Laws 2007, c. 137, 1,
More informationCase 1:02-cr PKC Document 54 Filed 08/15/08 Page 1 of 6 U.S. Department of Justice
Case 1:02-cr-01231-PKC Document 54 Filed 08/15/08 Page 1 of 6 U.S. Department of Justice United States Attorney Southern District of New York BY HAND TO CHAMBERS United States District Judge Southern District
More informationMARYLAND FALSE CLAIMS ACT. SECTION 1. BE IT ENACTED BY THE GENERAL ASSEMBLY OF MARYLAND, That the Laws of Maryland read as follows:
MARYLAND FALSE CLAIMS ACT SECTION 1. BE IT ENACTED BY THE GENERAL ASSEMBLY OF MARYLAND, That the Laws of Maryland read as follows: 8 101. (a) In this title the following words have the meanings indicated.
More informationIN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
Case 1:17-cr-00229-AT-CMS Document 42 Filed 11/06/17 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES OF AMERICA v. JARED WHEAT, JOHN
More informationLOAN GUARANTEE AGREEMENT. dated as of [ ], 20[ ] among. THE HOLDERS identified herein, their successors and permitted assigns, and
[FLOATING RATE GUARANTEED OBLIGATIONS] LOAN GUARANTEE AGREEMENT dated as of [ ], 20[ ] among THE HOLDERS identified herein, their successors and permitted assigns, and THE UNITED STATES DEPARTMENT OF ENERGY,
More informationEstonian Central Register of Securities Act 1
Issuer: Riigikogu Type: act In force from: 01.01.2015 In force until: 09.01.2017 Translation published: 14.01.2015 Estonian Central Register of Securities Act 1 Amended by the following acts Passed 14.06.2000
More informationUNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA
1 1 1 1 1 1 1 1 0 BARBARA A. MATTHEWS (SBN ) Assistant U.S. Trustee MAGGIE H. MCGEE (SBN 1) Trial Attorney U.S. DEPARTMENT OF JUSTICE Office of the United States Trustee 1 Clay Street, Suite 0N Oakland,
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * * KIRK and AMY HENRY, ) ) 2:08-CV PMP-GWF ) Plaintiffs, ) ORDER ) )
Case :0-cv-00-PMP -GWF Document Filed 0// Page of 0 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * * KIRK and AMY HENRY, ) ) :0-CV-00-PMP-GWF ) Plaintiffs, ) ORDER ) ) vs. ) ) FREDRICK RIZZOLO aka
More informationIN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No. 10-00025-01-CR-W-HFS ) KHALID OUAZZANI, ) ) Defendant. )
More informationmg Doc 9056 Filed 08/25/15 Entered 08/25/15 15:53:55 Main Document Pg 1 of 6. Debtors.
Pg 1 of 6 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: RESIDENTIAL CAPITAL, LLC, et al., Debtors. Case No. 12-12020 (MG) Jointly Administered ORDER DENYING MOTION FOR PARTIAL RECONSIDERATION
More informationVOTING AGREEMENT RECITALS
VOTING AGREEMENT THIS VOTING AGREEMENT (this Agreement ) is made and entered into as of April 30, 2015 by and between Optimizer TopCo S.a.r.l, a Luxembourg corporation ( Parent ), and the undersigned shareholder
More informationFORWARD DELIVERY BOND PURCHASE CONTRACT, Utility System Refunding Revenue Bonds, Series 2015
FORWARD DELIVERY BOND PURCHASE CONTRACT, 2014 Peace River Manasota Regional Water Supply Authority Board of Directors c/o Patrick J. Lehman 9415 Town Center Parkway Lakewood Ranch, Florida 34202 Re: $
More informationCase 1:15-cv BAH Document 1 Filed 03/03/15 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Case 1:15-cv-00307-BAH Document 1 Filed 03/03/15 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA : UNITED STATES SECURITES AND : EXCHANGE COMMISSION, : : Case No. : Plaintiff,
More informationCase 1:15-cr KAM Document 306 Filed 08/04/17 Page 1 of 17 PageID #: 5871
Case 1:15-cr-00637-KAM Document 306 Filed 08/04/17 Page 1 of 17 PageID #: 5871 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -----------------------------------------X UNITED STATES OF AMERICA,
More informationCase 1:08-cv ENV -RLM Document 128 Filed 12/10/09 Page 1 of 5. December 10, 2009
Case 1:08-cv-04446-ENV -RLM Document 128 Filed 12/10/09 Page 1 of 5 Ronald D. Coleman Partner rcoleman@goetzfitz.com BY ECF United States District Court Eastern District of New York 225 Cadman Plaza East
More informationCase 1:09-cr WHP Document 900 Filed 03/20/17 Page 1 of 10. -against- : 09 Cr. 581 (WHP) PAUL M. DAUGERDAS, et. al., : OPINION & ORDER
Case 1:09-cr-00581-WHP Document 900 Filed 03/20/17 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------- X UNITED STATES OF AMERICA, : -against- : 09
More informationCase 8:18-cr TDC Document 35 Filed 10/23/18 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
Case 8:18-cr-00012-TDC Document 35 Filed 10/23/18 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA, v. Criminal No. TDC-18-0012 MARK T. LAMBERT, Defendant.
More informationNo. U Ml An WILLODEAN P. PRECISE, COMPLAINT UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION.
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION C WILLODEAN P. PRECISE, V. Plaintiff, No. U4-244 8 Ml An CLASS ACTION JURY DEMAND DUNCAN WILLIAMS, INC. Defendant. COMPLAINT
More informationFILED: KINGS COUNTY CLERK 06/13/ :14 PM INDEX NO /2013 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 06/13/2016
FILED: KINGS COUNTY CLERK 06/13/2016 10:14 PM INDEX NO. 507535/2013 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 06/13/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------x
More informationCENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL ====== PRESENT: THE HONORABLE S. JAMES OTERO, UNITED STATES DISTRICT JUDGE
Case 2:11-cv-04175-SJO -PLA UNITED Document STATES 11 DISTRICT Filed 08/10/11 COURT Page 1 of Priority 5 Page ID #:103 Send Enter Closed JS-5/JS-6 Scan Only TITLE: James McFadden et. al. v. National Title
More informationThe court annexed arbitration program.
NEVADA ARBITRATION RULES (Rules Governing Alternative Dispute Resolution, Part B) (effective July 1, 1992; as amended effective January 1, 2008) Rule 1. The court annexed arbitration program. The Court
More informationWGLO BREAKOUT SESSION - Opinion Issues Relating to the Difference between Amendments and Novations.
WGLO BREAKOUT SESSION - Opinion Issues Relating to the Difference between Amendments and Novations. Bash v Textron Financial Corporation (In re Fair Finance Company) 834 F.3d 651 (6 th Cir. 2016) Does
More informationFIRST AMENDED COMPLAINT
ELECTRONICALLY FILED 12/2/2014 5:31 PM 01-CV-2014-904803.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION Genesis
More informationCase 1:09-cr RJL Document 4 Filed 07/23/2009 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Case 1:09-cr-00181-RJL Document 4 Filed 07/23/2009 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Holding a Criminal Term Grand Jury Sworn in on November 15, 2007 UNITED STATES
More informationIN THE CIRCUIT COURT OF THE 15TH CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO CA XXXX MB
9708 IN THE CIRCUIT COURT OF THE 15TH CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2008 CA 040969XXXX MB THE BANK OF NEW YORK TRUST COMPANY, N.A., AS TRUSTEE FOR CHASEFLEX TRUST SERIES 2007-3,
More informationIN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA EASTERN DIVISION ) ) ) ) ) ) ) ) ) INTRODUCTION
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA EASTERN DIVISION SHOLOM RUBASHKIN, Petitioner, vs. UNITED STATES OF AMERICA, Respondent. No. C13-1028-LRR No. CR08-1324-LRR PETITIONER
More informationMEMORANDUM OF DEPOSIT
MEMORANDUM OF DEPOSIT THIS MEMORANDUM OF DEPOSIT ( Memorandum ) is made on BETWEEN: (1) KGI SECURITIES (SINGAPORE) PTE. LTD., a company incorporated in the Republic of Singapore and having its registered
More informationCase 1:05-cr EWN Document 295 Filed 03/22/2007 Page 1 of 12
Case 1:05-cr-00545-EWN Document 295 Filed 03/22/2007 Page 1 of 12 Criminal Case No. 05 cr 00545 EWN IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Edward W. Nottingham UNITED STATES
More informationALABAMA COURT OF CIVIL APPEALS
REL: 6/15/12 Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate
More informationCONNECTICT FALSE CLAIMS ACT. Title 4, CHAPTER 55e of the General Statutes of Connecticut
As recodified and amended by P.A. 14 217, effective June 13, 2014. CONNECTICT FALSE CLAIMS ACT Title 4, CHAPTER 55e of the General Statutes of Connecticut FALSE CLAIMS AND OTHER PROHIBITED ACTS UNDER STATE
More informationUNITED STATES DISTRICT COURT DISTRICT OF NEVADA ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, DRAFT. Defendants. CLASS ACTION COMPLAINT
UNITED STATES DISTRICT COURT DISTRICT OF NEVADA, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, WYNN RESORTS LIMITED, STEPHEN A. WYNN, and CRAIG SCOTT BILLINGS, Defendants.
More informationLIMITED OFFICIAL USE
Case 2:09-cr-00335-JFC Document 6 Filed 02/12/10 Page 1 of 8 U.S. Department of Justice United States Attorney Western District ofpennsylvania u.s. Post Office & Courthouse 700 Granl Sireel Suite 4000
More informationCase 3:07-cr MRK Document 175 Filed 01/11/2008 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
Case 3:07-cr-00057-MRK Document 175 Filed 01/11/2008 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA : Crim. No. 3:07-CR-57 (MRK) : v. : : January 11, 2008 HASSAN
More informationUSA v. Fabio Moreno Vargas
2015 Decisions Opinions of the United States Court of Appeals for the Third Circuit 11-18-2015 USA v. Fabio Moreno Vargas Follow this and additional works at: http://digitalcommons.law.villanova.edu/thirdcircuit_2015
More informationDISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT KRISTY S. HOLT, Appellant, v. CALCHAS, LLC, Appellee. No. 4D13-2101 [January 28, 2015] On Motion for Rehearing Appeal from the Circuit Court
More informationSEMINOLE TRIBE OF FLORIDA
SEMINOLE TRIBE OF FLORIDA Tribal Court Small Claims Rules of Procedure Table of Contents RULE 7.010. TITLE AND SCOPE... 3 RULE 7.020. APPLICABILITY OF RULES OF CIVIL PROCEDURE... 3 RULE 7.040. CLERICAL
More informationAffiliate Partnership Terms & Conditions
Affiliate Partnership Terms & Conditions FXCC PROVIDES THE FOLLOWING: 1. WHEREAS the Affiliate is entitled to refer new clients to the Company subject to the terms and conditions of the present agreement;
More informationDISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT July Term 2014
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT July Term 2014 KRISTY S. HOLT, Appellant, v. CALCHAS, LLC, Appellee. No. 4D13-2101 [November 5, 2014] Appeal from the Circuit Court for
More informationMULTIPLE-PARTY ACCOUNTS UNDER THE NEBRASKA PROBATE CODE
MULTIPLE-PARTY ACCOUNTS UNDER THE NEBRASKA PROBATE CODE RONALD R. VOLKMER* INTRODUCTION The drafters of the Probate Code evidently thought that it would be advisable to clarify the law relating not only
More informationUNITED STATES DISTRICT COURT DISTRICT OF COLORADO ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. Plaintiff, Defendants. CLASS ACTION COMPLAINT
UNITED STATES DISTRICT COURT DISTRICT OF COLORADO, Individually and On Behalf of All Others Similarly Situated, RIOT BLOCKCHAIN, INC., JOHN R. O ROURKE III, and JEFFREY G. McGONEGAL, v. Plaintiff, Defendants.
More informationCase 1:14-cv FB-RLM Document 492 Filed 11/17/16 Page 1 of 11 PageID #: 13817
Case 1:14-cv-04717-FB-RLM Document 492 Filed 11/17/16 Page 1 of 11 PageID #: 13817 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------------------------------x
More informationRULES GOVERNING ALTERNATIVE DISPUTE RESOLUTION
RULES GOVERNING ALTERNATIVE DISPUTE RESOLUTION A. GENERAL PROVISIONS Rule 1. Definitions. As used in these rules: (A) Arbitration means a process whereby a neutral third person, called an arbitrator, considers
More informationFinancial Services. New York State s Martin Act: A Primer
xc Financial Services JANUARY 15, 2004 / NUMBER 4 New York State s Martin Act: A Primer New York State s venerable Martin Act gives New York law enforcers an edge over the Securities and Exchange Commission.
More informationZervos v. OCWEN LOAN SERVICING, LLC, Dist. Court, D. Maryland In Re: Defendant's Motion to Dismiss (ECF No. 10)
Zervos v. OCWEN LOAN SERVICING, LLC, Dist. Court, D. Maryland 2012 MEMORANDUM JAMES K. BREDAR, District Judge. CHRISTINE ZERVOS, et al., Plaintiffs, v. OCWEN LOAN SERVICING, LLC, Defendant. Civil No. 1:11-cv-03757-JKB.
More informationIN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA
6:14-cr-00020-JHP Document 126 Filed in ED/OK on 05/11/15 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA UNITED STATES OF AMERICA, ) Plaintiff, ) ) vs. ) Case No.
More informationCase 1:12-cv CM Document 50 Filed 10/26/12 Page 1 of 12
Case 1:12-cv-04873-CM Document 50 Filed 10/26/12 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK U.S. BANK NATIONAL ASSOCIATION, SUCCESSOR TO WELLS FARGO BANK, N.A., SUCCESSOR
More informationIN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION PLEA AGREEMENT
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES OF AMERICA, Plaintiff, v. Cr. No. H-02-0665 BEN F. GLISAN, JR., Defendant. PLEA AGREEMENT Pursuant
More informationCase 1:10-cr RDB Document 75 Filed 03/15/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
Case 1:10-cr-00181-RDB Document 75 Filed 03/15/11 Page 1 of 9 UNITED STATES OF AMERICA * IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND v. * Criminal No. 10-0181-RDB THOMAS ANDREWS DRAKE
More informationCase 1:07-cr RPP Document 335 Filed 08/22/11 Page 1 of 37 GOVERNMENT S IN LIMINE MOTION
Case 1:07-cr-00971-RPP Document 335 Filed 08/22/11 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, S15 07 CR 971 (RPP) - v. - CHRISTOPHER MICHAEL COKE,
More informationFILED: NEW YORK COUNTY CLERK 08/17/ :58 AM INDEX NO /2016 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/17/2016 SUPREME COURT OF THE STATE OF NEW
FILED: NEW YORK COUNTY CLERK 08/17/2016 10:58 AM INDEX NO. 654332/2016 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/17/2016 SUPREME COURT OF THE STATE OF NEW COUNTY OF NEW YORK COBY EMPIRE, LLC x - Plaintiff/Petition
More informationFollow this and additional works at:
2010 Decisions Opinions of the United States Court of Appeals for the Third Circuit 3-29-2010 USA v. Eric Rojo Precedential or Non-Precedential: Non-Precedential Docket No. 09-2294 Follow this and additional
More informationCase 1:10-cr LAK Document 77 Filed 09/30/11 Page 1 of 2. CASE NO.: 10-cr-0336 (LAK)
Case 110-cr-00336-LAK Document 77 Filed 09/30/11 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK William R. Cowden Steven J. McCool MALLON & MCCOOL, LLC 1776 K Street, N.W., Ste
More informationIN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION. Plaintiff, ) v. ) No CR-W-FJG. Defendant.
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No. 08-000297 03-CR-W-FJG ) RONALD E. BROWN, JR., ) ) Defendant.
More informationCase 5:18-cv C Document 53 Filed 10/26/18 Page 1 of 79 PageID 669
Case 5:18-cv-00234-C Document 53 Filed 10/26/18 Page 1 of 79 PageID 669 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS LUBBOCK DIVISION FIRST BANK & TRUST, Plaintiff. v. Cause No. 5:18-cv-00234-C
More informationChicago False Claims Act
Chicago False Claims Act Chapter 1-21 False Statements 1-21-010 False Statements. Any person who knowingly makes a false statement of material fact to the city in violation of any statute, ordinance or
More informationUNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN. v. Case No. 14-C-966 DECISION AND ORDER
Bourbonnais et al v. Ameriprise Financial Services Inc et al Doc. 45 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN WILLIAM BOURBONNAIS, et al., Plaintiffs, v. Case No. 14-C-966 AMERIPRISE
More informationCase: 1:14-cr Document #: 67 Filed: 10/19/15 Page 1 of 9 PageID #:1049
Case: 1:14-cr-00551 Document #: 67 Filed: 10/19/15 Page 1 of 9 PageID #:1049 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff,
More informationStreamlined Arbitration Rules and Procedures
RESOLUTIONS, LLC s GUIDE TO DISPUTE RESOLUTION Streamlined Arbitration Rules and Procedures 1. Scope of Rules The RESOLUTIONS, LLC Streamlined Arbitration Rules and Procedures ("Rules") govern binding
More information