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Alfred Fait, Et Al. V. Barclays Bank PLC, Et Al. Fait-Complaint for Violation

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Alfred Fait, Et Al. V. Barclays Bank PLC, Et Al. Fait-Complaint for Violation , ' ..,,„ . i .. 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 or other papers as required by law, except as provided by local rules of court. This forrn, 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 ALFRED FAIT, on Behalf of Himself and All Others Similarly BARCLAYS BANK PLC, et al. (Please see attached Situated,Schedule A for additional defendants) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN) .. • ,.,,. Coughlin Stoia Geller Rudman & Robbins, 58 So, Service Road, Suite 200, Melville, NY 11747 (631) 367-7100 CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) Pursuant to Sections 10(b) and 20(a) of the Exchange Act [15 U.S.C. Sections 78j (b) and 78t (a)] and Rule 10b-5 promulgated thereunder by the United States Securities and Exchange Commission [17 C.F.R Section 240.10b-53. Has this or a similar case been previously filed in SONY at any time? No? 111 Yes? 0 Judge Previously Assigned If yes, was this case Vol.E1 Invol, 0 Dismissed. No D Yes 0 If yes, give date & Case No. (PLACE AN [xi IN ONE BOX ONLY) NATURE OF SUIT TORTS ACTIONS UNDER STATUTES CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES [ 1110 INSURANCE [ [ 310 AIRPLANE 1 1 362 PERSONAL INJURY - [ ] 610 AGRICULTURE [422 [ APPEAL ) 400 STATE [ ) 120 MARINE [ 1 315 AIRPLANE PRODUCT MED MALPRACTICE [ ] 620 OTHER FOOD & 28 USC 158 REAPPORTIONMENT [ 1 130 MILLER ACT LIABILITY [ 1 365 PERSONAL INJURY DRUG [ [ 423 WITHDRAWAL ] 410 ANTITRUST [ ] 140 NEGOTIABLE [ 1 320 ASSAULT, LIBEL & PRODUCT LIABILITY [ 1 625 DRUG RELATED 28 USC 157 [430 BANKS & BANKING INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL SEIZURE OF ] 450 COMMERCE [ ] 150 RECOVERY OF [ 1 330 FEDERAL INJURY PRODUCT PROPERTY 1 460 DEPORTATION OVERPAYMENT & EMPLOYERS LIABILITY 21 USC 881 PROPERTY RIGHTS )470 RACKETEER INFLU- ENFORCEMENT LIABILITY [ ] 630 LIQUOR LAWS ENCED & CORRUPT OF JUDGMENT [ ) 340 MARINE PERSONAL PROPERTY [ ] 640 RR & TRUCK [ ] 820 COPYRIGHTS CL—... ORGANIZATION ACT [ [ 151 MEDICARE ACT [ ) 345 MARINE PRODUCT [ [ 650 AIRLINE REGS [ [ 830 PATENT?CONSc) (RICO) [ 1 152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD [ ) 660 OCCUPATIONAL[ 1 840 TRADEMARK s'... ' ] 4 pER CREDIT DEFAULTED [ ] 350 MOTOR VEHICLE [ [ 371 TRUTH IN LENDING SAFETY/HEALTH . [4d CABLE/SATELLITE TV STUDENT LOANS [ ] 355 MOTOR VEHICLE [ 1 380 OTHER PERSONAL [ 1 690 OTHER C.,[.:' 1 8-1-03SELEbtlitE SERVICE (EXCL VETERANS) PRODUCT LIABILITY PROPERTY DAMAGE SOCIAL SECURITY . [K] 875-SECURITI).1. ,ES/ [ ) 153 RECOVERY OF [ [ 360 OTHER PERSONAL [ 1 385 PROPERTY DAMAGE Cf.] (..f :' ,--.000MMOEIITIES/ OVERPAYMENT INJURY PRODUCT LIABILITY1 ]LABOR. 861 HIA (139511) ..---1 --- _,.' e."-JXCHANOIE OF VETERAN'S [ 1 862 BLACK LUNG (9'21),---- ] 877- CUSTOM1R.— BENEFITS [ ] 710 FAIR LABOR [ [ 863 DIWC/DIWW (450(-- HALLENGE [ ] 160 STOCKHOLDERS STANDARDS ACT [ ] 864 SSID TITLE XVI- ., 12 USO 34.10 SUITS [ ) 720 LABOR/MGMT [ 1 865 RSI (405(g)) *e,,,' 1 1890°CDTHERST-ATUTORY [ 1 190 OTHER RELATIONS,...CTIONS' CONTRACT [ ] 730 LABOR/MGMT C),c.., ] 89=GRICUCTIJRAL ACTS 1 ] 195 CONTRACT REPORTING & FEDERAL TAX SUITS 1 ) 8910NOMIt PRODUCT ACTIONS UNDER STATUTES DISCLOSURE ACT ,,. ABILIZATION ACT LIABILITY ] 893." -, VIRONMENTAL [ ] 196 FRANCHISE [ ] 740 RAILWAY LABOR ACT [ ] 870 TAXES (U.S. Plaintiff 01-:rj 1 CIVIL RIGHTS PRISONER PETITIONS 1 ) 790 OTHER LABOR Defendant) ..—"i MATTERS LITIGATION [ 1 871 IRS-THIRD PARTY 1 1 894 ENERGY ( )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/ 20 USC 2255 INFORMATION ACT ACCOMMODATIONS [ ) 530 HABEAS CORPUS IMMIGRATION [ 1900 APPEAL OF FEE [ )210 LAND [ [ 444 WELFARE [ ] 535 DEATH PENALTY DETERMINATION CONDEMNATION [ ] 445 AMERICANS WITH [ [ 540 MANDAMUS & OTHER [ 1 462 NATURALIZATION UNDER EQUAL [ [ 220 FORECLOSURE DISABILITIES - [ 1 550 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 1 240 TORTS TO LAND DISABILITIES -OTHER [ ] 465 OTHER IMMIGRATION [ 1 245 TORT PRODUCT [ ] 440 OTHER CIVIL RIGHTS ACTIONS LIABILITY [ ] 290 ALL OTHER REAL PROPERTY i el , to 3 v V.,,,,, Check if demanded in complaint: CHECK IF THIS IS A CLASS ACTION DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.? el UNDER F.R.C.P. 23 IF SO, STATE: DEMAND $ OTHER JUDGE Paul A. Crotty DOCKET NUMBER 09 CIV 1989 Check YES only if demanded in complaint JURY DEMAND: IZI YES E NO NOTE: Please submit at the time of filing an explanation of why cases are deemed related. (PLACE AN x IN ONE BOX ONL Y) ORIGIN 151 1 Original EIi 2a. Removed from 03 Remanded from El 4 Reinstated or LI 5 Transferred from 6 Multidistrict El 7 Appeal to District Proceeding State Court Appellate Court Reopened (Specify District) Litigation Judge from 2b.Removed from Magistrate Judge El Judgment State Court AND at least one party is pro se. (PLACE AN x ONE BOX ONL Y) BASIS OF JURISDICTION IF DIVERSITY, INDICATE 11 1 U.S. PLAINTIFF1 [ 2 U.S. DEFENDANT al 3 FEDERAL QUESTION 04 DIVERSITY CITIZENSHIP BELOW. (U.S. NOT A PARTY) (28 USC 1322, 1441) CITIZENSHIP OF PRINCIPAL 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 [ 1 1 [ ]1 CITIZEN OR SUBJECT OF A 1 1 3 1 1 3 INCORPORATED and PRINCIPAL PLACE [ 15 [ )5 FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE CITIZEN OF ANOTHER STATE [ 12 1 12 INCORPORATED or PRINCIPAL PLACE 1 14 [ 14 FOREIGN NATION [ ] 6 [ ] 6 OF BUSINESS IN THIS STATE PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES) 420 Narrow Leaf Court Royal Palm Beach, FL 33411 (Palm Beach County) DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) Please 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: Matthew William Barrett Sir Nigel Rudd Sir Richard Broadbent Stephen George Russell Sir Andrew Likierman John Michael Sunderland Check one: THIS ACTION SHOULD BE ASSIGNED TO: E] WHITE PLAINS j MANHATTAN (DO NOT check either box if this a PRISONERRETITION.) DATE 03/20/0 SIGN K.-- bl'1ORN F RECORD ADMITTED TO PRACTICE IN THIS DISTRICT [ NO [X] YES (DATE ADMITTED Mo. 05 Yr. 1995 RECEIPT # Attorney Bar Code # S R7957 Magistrate Judge is to be designated by the Clerk of the Court. Magistrate Judge is so Designated. 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 Marcus Agius 25 Chelsea Square London SW3 6LF Christopher Lucas 78 Waverley Avenue London E4 8HT United Kingdom Gary Ho ffin an Church Farm House Holdenby Road Church Brampton Northampton Northamptonshire NN6 8BN Frederik Seegers 17A Onslow Gardens London SW7 3AW David Booth 15 Garden Place Brooklyn, NY 11201 (New York City) Fulvio Conti c/o Enel Spa Viale Regina Margherita 137 Rome, 13700198 Italy Daniel Cronge 59 Sauvignon, Randburg , Bromhof, Gauteng Johannesburg, South Africa 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 Likienuan 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) Banc of America Securities LLC c/o CT Corp. 111 Eighth Ave NY, NY 10011 (New York City) 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) Pricewaterhousecoopers LLP c/o Corp System 111 Eighth Ave NY, NY 10011 (New York City) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ALFRED FAIT, on Behalf of Himself and All : Civil Action No. Others Similarly Situated, CLASS ACTION Plaintiff, . COMPLAINT FOR VIOLATION OF THE vs. FEDERAL SECURITIES LAWS BARCLAYS BANK PLC, BARCLAYS PLC, JOHN SILVESTER VARLEY, ROBERT EDWARD DIAMOND, JR., SIR RICHARD _ DisTRIcrco -- BROADBENT, RICHARD LEIGH S ° FILED UR *- CLIFFORD, DAME SANDRA J.N. DAWSON, SIR ANDREW LIKIERMAN, SIR . APR 2 0 ?009 NIGEL RUDD, STEPHEN GEORGE , RUSSELL, JOHN MICHAEL S OF t'A.
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