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Larry Morrison, Et Al. V. Barclays Bank Plc, Et Al. 09-CV-02326-Complaint

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Larry Morrison, Et Al. V. Barclays Bank Plc, Et Al. 09-CV-02326-Complaint , tik. ;Iiti....:2 7 P:. :,ir Pi, r)§ fit i ev, 2 —ov Li S., t' r LAN 09 .323ILI JS 44C/SDNY CIVIL COVER SHEET REV. 1/2008 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings orother 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 use of the Clerk of Court for the purpose of initiating the civil docket sheet. PLAINTIFFS DEFENDANTS Larry Morrison, on behalf of himself and all others similarly Barclays Bank PLC, et al. (see attached Schedule A for situated, additional defendants) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN) Abraham Fruchter & Twersky, LLP, One Penn Plaza, Suuite 2805, NY, NY 10119, (212) 279-5050 CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) 15 USC Sections 77k, 771(a)(2) and 77o. Action for a false and misleading registration statement and prospectus Has this or a similar case been previously filed in SDNY at any time? No? 151 Yes? Ill Judge Previously Assigned If yes, was this case Vol.0 Invol. 0 Dismissed. No 0 Yes 0 If yes, give date & se No. (PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT TORTS ACTIONS UNDER STATUTES CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES [ ] 110 INSURANCE [ [ 310 AIRPLANE [ ] 362 PERSONAL INJURY - [ ] 610 AGRICULTURE ( 1422 APPEAL ( ] 400 STATE [ ] 120 MARINE [ ] 315 AIRPLANE PRODUCT [ ] 130 MED MALPRACTICE [ 1620 OTHER FOOD & 28 USC 158 REAPPORTIONMENT MILLER ACT LIABILITY [ 1365 PERSONAL INJURY DRUG [ ] 140 NEGOTIABLE [ ] 423 WITHDRAWAL [ [410 ANTITRUST [ 1 320 ASSAULT, LIBEL & PRODUCT LIABILITY [ 1625 DRUG RELATED 28 USC 157 [ ] 430 BANKS & BANKING INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL [ 1 150 RECOVERY OF SEIZURE OF [ 1 450 COMMERCE [ ] 330 FEDERAL INJURY PRODUCT PROPERTY [ ] 460 DEPORTATION OVERPAYMENT & EMPLOYERS LIABILITY 21 USC 881 ENFORCEMENT PROPERTY RIGHTS [ j 470 RACKETEER INFLU- LIABILITY [ 1 630 LIQUOR LAWS ENCED & CORRUPT OF JUDGMENT [ 1 340 MARINE PERSONAL PROPERTY [ 1640 RR & TRUCK [ [ 151 MEDICARE ACT [ ] 820 COPYRIGHTS ORGANIZATION ACT [ ] 345 MARINE PRODUCT [ ] 650 AIRLINE REGS [ ] 830 PATENT (RICO) [ ] 152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD [ ] 660 OCCUPATIONAL DEFAULTED 1 ] 840 TRADEMARK 480 CONSUMER CREDIT [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING SAFETY/HEALTH (• 6.: BLE/SATELLITE TV STUDENT LOANS [ ] 355 MOTOR VEHICLE [ ] 380 OTHER PERSONAL [ ] 690 OTHER (EXCL VETERANS) [ ] 810 7- CTIVE SERVICE PRODUCT LIABILITY PROPERTY DAMAGE SOCIAL SECURITY W850 S. RITIES/ [ 1 153 RECOVERY OF [ [360 OTHER PERSONAL [ ] 385 PROPERTY DAMAGE OVERPAYMENT Co , MODITIES/ INJURY PRODUCT LIABILITY LABOR [ ] 861 HIA (1395ff) - HANGE OF VETERAN'S [ ] 875 USTOMER BENEFITS [ ] 862 BLACK LUNG (92 [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g CHALLENGE [ j 160 STOCKHOLDERS STANDARDS ACT 12 USC 3410 SUITS [ ] 864 SSID TITLE XVI [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g)) [ j 890 OTHER STATUTORY [ ] 190 OTHER RELATIONS ACTIONS CONTRACT [ ] 730 LABORJMGMT [ ] 891 AGRICULTURAL ACTS [ ] 195 CONTRACT REPORTING & FEDERAL TAX SUITS [ ] 892 ECONOMIC PRODUCT ACTIONS UNDER STATUTES DISCLOSURE ACT STABILIZATION ACT LIABILITY ENVIRONMENTAL [ [ 196 FRANCHISE [ ] 740 RAILWAY LABOR ACT [ ] 870 TAXES (U.S. Plaintiff or [ [893 CIVIL RIGHTS PRISONER PETITIONS [ ] 790 OTHER LABOR Defendant) MATTERS LITIGATION ( ] 871 IRS-THIRD PARTY ( ] 894 ENERGY [ 1 441 VOTING [ ] 510 MOTIONS TO [ ] 791 EMPL RET INC 26 USC 7609 ALLOCATION ACT [ ] 442 EMPLOYMENT VACATE SENTENCE SECURITY ACT [ 1 895 FREEDOM OF REAL PROPERTY [ ] 443 HOUSING/ 28 USC 2255 INFORMATION ACT ACCOMMODATIONS [ ] 530 HABEAS CORPUS IMMIGRATION ( 1900 APPEAL OF FEE ( 1210 LAND [ [ 444 WELFARE [ ] 535 DEATH PENALTY DETERMINATION CONDEMNATION [ ] 445 AMERICANS WITH [ ] 540 MANDAMUS & OTHER [ 1 462 NATURALIZATION UNDER EQUAL [ j 220 FORECLOSURE DISABILITIES - [ I 550 CIVIL RIGHTS APPLICATION ACCESS TO JUSTICE [ ] 230 RENT LEASE & EMPLOYMENT [ 1 555 PRISON CONDITION [ ] 463 HABEAS CORPUS- [ ] 950 CONSTITUTIONALITY EJECTMENT [ ] 446 AMERICANS WITH ALIEN DETAINEE OF STATE STATUTES 1 1240 TORTS TO LAND DISABILITIES -OTHER [ ] 465 OTHER IMMIGRATION [ [245 TORT PRODUCT [ ] 440 OTHER CIVIL RIGHTS LIABILITY ACTIONS ( [290 ALL OTHER REAL PROPERTY Check if demanded in complaint: rej CHECK IF THIS IS A CLASS ACTION DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CAS OW PENDING IN S.D.N.Y.? la UNDER F.R.C.P. 23 IF SO, STATE: DEMAND $ OTHER JUDGE DOC ET NUMBER Check YES only if demanded in complaint JURY DEMAND: El YES 0 NO NOTE: Please submit at the time of filing an explanation of why cases are deemed related. A IN ONE BOX ONL Y) ORIGIN 151 1 Original 0 2a. Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 1=1 6 Multidistrict 0 7 Appeal to District Proceedi State Court Appellate Court Reopened (Specify District) Litigation Judge from 0 2b.Removed from Magistrate Judge State Court AND Judgment ____ at least one party is pro se. (PLACE AN x IN ONE BOX ONL Y) SIS OF JURISDICTION IF DIVERSITY, INDICATE El 1 U.S. PLAINTIFF El 2 U.S. DEFEND NT GI 3 FE 1AL QUESTION D4 DIVERSITY CITIZENSHIP BELOW. (U. NOT A PARTY) (28 USC 1322, 1441) CITIZENSHI CIPAL PARTIES (FOR DIVERSITY CASES ONLY) (Place an [X] in one box for Plaintiff and one box for Defendant) PTF DEF PTF DEF PTF DEF CITIZEN OF THIS STATE [ 11 [ 11 CITIZEN OR SUBJECT OF A [ 13 [ ] 3 INCORPORATED and PRINCIPAL PLACE 1 15 [ ] 5 FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE CITIZEN OF ANOTHER STATE [ 12 [ ] 2 INCORPORATED or PRINCIPAL PLACE [ 14 [ 14 FOREIGN NATION [ 16 [ 16 OF BUSINESS IN THIS STATE PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES) 8035 Springfield Blvd Queens Village, NY 11427-1217 DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) see attached Schedule A DEFENDANT(S) ADDRESS UNKNOWN REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS: Sir Richard Broadbent, Sir Andrew Likierman, Sir Nigel Rudd, Stephen George Russell, John Michael Sunderland Check one: THIS ACTION SHOULD BE ASSIGNED TO: 111 WHITE PLAIN SllTMA HATTAN (DO NOT check either box if this a PRISONER PETITION.) DATE 03/12/09 S , TURE 0 TTO- y - OF CORD ADMITTED TO k L11CE IN THIS DISTRICT / NO [ ] 1988 , [ 1 YES (DATE ADMITTED Mo. 12 Yr. , RECEIPT # if: // / / // ---- Attorney Bar Code #JA-2946 ! f Magistrate Ju n • : is t• be designated by the Clerk of the Court. r intl -A01,, . p! ifi Magistrate Judge ,,4 ' it, i I ti is J. Michael McMahon, Clerk of Court by _ Deputy Clerk, DATED . UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN) Schedule A Barclays Bank PLC One Churchill Place London E14 5HP Barclays PLC One Churchill Place London E14 5HP Matthew William Barrett UK John Silvester Varley 9 Luxemburg Gardens Hammersmith London W67EA Naguib Kheraj 2 Cedarland Terrace Copse Hill London SW20 ONB Robert Edward Diamond, Jr. UK Sir Richard Broadbent UK Richard Leigh Clifford 6 St James Square London SW14 4LD Dame Sandra J.N. Dawson The MasterLodge Sidney Sussex College Cambridge CB2 3HU Sir Andrew Likierman UK Sir Nigel Rudd UK Stephen George Russell UK , John Michael Sunderland UK BARCLAYS CAPITAL SECURITIES LIMITED 5 The North Colonnade Canary Wharf UK CITIGROUP GLOBAL MARKETS INC. 388 Greenwich St NY NY 10080 (New York City) MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED 4 World Financial Center NY NY 10080 (New York City) WACHOVIA CAPITAL MARKETS, LLC Corp Service Co 80 State St Albany NY 12207 (Albany County) MORGAN STANLEY & CO. INCORPORATED 1585 Broadway NY NY 10036 (New York City) UBS Securities LLC Corp Service Co 80 State St Albany NY 12207 (Albany County) A.G. EDWARDS & SONS, INC. 600 California St, Ste 1600 San Francisco, CA 94108 (San Mateo County) BNP PARIBAS SECURITIES CORP. HQ: 787 7th Ave NY NY 10019 (New York City) , GOLDMAN, SACHS & CO. 85 Broad St NY NY 10004 (New York City) KEYBANC CAPITAL MARKETS INC. 800 Superior Ave Cleveland OH 44114 (Cuyahoga County) RBC Dain Rauscher Inc. 60 South 6th St Minneapolis MN 55402 (Anoka County) SUNTRUST CAPITAL MARKETS, INC. HQ: 303 Peachtree St NE 24th Fir Atlanta GA 30308 (Cobb County) WELLS FARGO SECURITIES LLC 600 California St, Ste 1600 San Francisco, CA 94108 (San Mateo County) . JS 44C/SDNY CIVIL COVER SHEET REV. 1/2008 The JS-44 civil cover sheet and the Information contained herein neither replace nor supplement the filing and service of pleadings °rather 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 use of the Clerk of Court for the purpose of initiating the civil docket sheet. PLAINTIFFS DEFENDANTS Larry Morrison, on behalf of himself and all others similarly Barclays Bank PLC, et al. (see attached Schedule A for situated, additional defendants) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN) Abraham Fruchter & Twersky, LLP, One Penn Plaza, Suuite 2805, NY, NY 10119, (212) 279-5050 CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) 15 USC Sections 77k, 77I(a)(2) and 770. Action for a false and misleading registration statement and prospectus Has this or a similar case been previously filed in SDNY at any
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