United States District Court Eastern District of New York
Case 2:14-cv-05169-JMA-ARL Document 15 Filed 10/27/14 Page 1 of 42 PageID #: 122 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK MICHELLE F. HARTLEY, STEVEN TOMLINSON, individually and on behalf of all others similarly situated, and MARIA DEGENNERO, Civil Action No. Plaintiffs, AMENDED CLASS ACTION COMPLAINT FOR DAMAGES, vs. RESTITUTION AND INJUNCTIVE RELIEF WELLS FARGO & COMPANY; WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC; JURY TRIAL DEMAND and WELLS FARGO ADVISORS, LLC, all as successors in interest to Wachovia Securities, LLC, Defendants. Plaintiffs, individually and on behalf of all others similarly situated, by their attorneys, The Law Offices of Christopher Q. Davis, PLLC, alleges, upon personal knowledge and upon information and belief as to other matters, as follows: NATURE OF ACTION 1. This is a collective and class action brought by Individual and Lead Plaintiffs and Putative Class Representative Plaintiffs Michelle F. Hartley and Steven Tomlinson, Individual and Lead Plaintiff Maria DeGennero (together, the “Lead Plaintiffs” or “Named Plaintiffs”) and all putative plaintiffs (collectively, “Plaintiffs”), on their own behalf and on behalf of the proposed classes identified below. Plaintiffs and the Putative Class members were or are employed by Defendant Wells Fargo & Company, Defendant Wachovia Securities Financial Holdings, LLC, and Defendant Wells Fargo Advisors, LLC, as successor in interest to former 1 Case 2:14-cv-05169-JMA-ARL Document 15 Filed 10/27/14 Page 2 of 42 PageID #: 123 employer Wachovia Securities, LLC, (collectively, “Wells Fargo” or the “Defendants”). Plaintiffs were employed by Defendant Wells Fargo & Company in their registered broker- dealer, Wells Fargo Advisors, LLC, as Financial Advisors in the Private Client Group.1 2.
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