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1
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REPLY TO COUNTERCLAIMS
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EXTRACTED KEY WORDS
ALLEGATIONS DENY PARTNERSHIP ADMIT CANTOR COUNTERCLAIMANTS EMPLOYEES AGREEMENT CANTOR FITZGERALD RESPONSES LUTNICK REFER RESPONSES SET LOANS MANAGEMENT SOLE GENERAL PARTNER INVESTMENT REPEAT GENERAL PARTNER PURCHASE CFI NAT WEST PARAGRAPHS L-69 DISTRIBUTION UNITS COURT GOVERNMENT BOND HDII UNITS PROSPECTIVE PARTNERS PAYMENTS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CANTOR FITZGERALD, L.P.,
a Delaware limited partnership
Plaintiff,
V. ; C.A. No. 11595 :,
c ' :' -1
GORDON CAMPBELL, IAN HENDRICK, 1 : _
- _
and PHILlP HULSTON, individually c>
I _ _*
1
Defendants.
V.
CANTOR FITZGERALD, L.P.,
HOWARD LUTNICK, and
CANTOR FITZGERALD GROUP
MANAGEMENT,
Counterclaim- i
Defendants. >
REPLY TO COUNTERCLAIMS
Counterclaim Defendants Cantor Fitzgerald, L.P. (the "Partnership"),
Howard Lutnick ("Lutnick"), Cantor Fitzgerald Group Management ("Management"), by
their undersigned attorneys, hereby reply to the counterclaims asserted by defendants as
follows:
1. Deny the allegations of paragraph 52, except admit that
Management is the sole general partner of the Partnership, and that Lutnick is its sole
shareholder.
2. Deny the allegations of paragraph 53.
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2
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DEFENDANTS ANSWER AND COUNTERCLAIMS AGAINST CANTOR FITZGERALD H. LUTNICK AND CANTOR FITZGERALD GROUP MANAGEMENT
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EXTRACTED KEY WORDS
COUNTERCLAIMANTS LUTNICK CANTOR FITZGERALD DEFENDANTS CFI GROUP MANAGEMENT HIGH DISTRIBUTION AGREEMENT INVESTMENT EMPLOYEES HIGH DISTRIBUTION UNITS HENDRICK CAMPBELL AMENDED AGREEMENT GENERAL PARTNER PURCHASE PLAINTIFFS EMPLOYMENT HOWARD LUTNICK SOLE SHAREHOLDER REPRESENTATIONS COUNTERCLAIMANTS REPEAT FACTUAL ALLEGATIONS MERELY SETS INCORPORATE CAPITAL CONTRIBUTION AFFILIATES TERMINATION MISREPRESENTATIONS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CANTOR FITZGERALD L.P.,
Plaintiff,
v.
GORDON CAMPBELL, IAN HENDRICK, : C.A. No. 17595 -.,,_: 3 ..' !
, `/.
and PHILIP HULSTON, . -'
., : L
\ `-j
Defendants and
Counterclaim Plaintiffs, :
V.
CANTOR FITZGERALD, L.P.,
HOWARD LUTNICK, and
CANTOR FITZGERALD GROUP
MANAGEMENT,
Counterclaim Defendants. :
DEFENDANTS' ANSWER AND COUNTERCLAIMS AGAINST
CANTOR FITZGERALD, L.P., HOWARD LUTNICK, AND
CANTOR FITZGERALD GROUP MANAGEMENT
Defendants Gordon Campbell ("Campbell"), Ian Hendrick ("Hendrick"), and Philip
Hulston ("Hulston") (collectively "Defendants" or "Counterclaimants") hereby answer the
complaint of Cantor Fitzgerald, L.P. (the "Limited Partnership") and counterclaim against the
Limited Partnership, Howard Lutnick ("Lutnick"), and Cantor Fitzgerald Group Management
("C.F. Group Management") (the latter three of which sometimes collectively are referred to
herein as "Counterdefendants") as follows:
ANSWER
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3
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS AGREEMENT CANTOR FITZGERALD EMPLOYMENT TERMINATION LIBERTY ACCOUNTS BREACHES AMOUNT PLAINTIFF OBLIGATIONS CAMPBELL DAMAGES DUTY LOYALTY HENDRICK HULSTON BROKERAGE HDII ACCOUNT CONTRACTS ENTITLEMENT PURSUANT DELAWARE GOVERNMENT LIMITED PARTNERSHIP AFFILIATES GERMAN JUDGEMENT AWARDING PLAINTIFF |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CANTOR FITZGERALD, L.P.,
a Delaware limited partnership
Plaintiff,
>
V. > C.A. No.
>
GORDON CAMPBELL, IAN HENDRICK, >
and PHILIP HULSTON, individually >>
Defendants. >
COMPLAINT
Nature of The Action
1. Plaintiff Cantor Fitzgerald, L.P. (the "Partnership") brings this
action for damages and declaratory relief against defendants Gordon Campbell, Ian
Hendrick and Philip Hulston, all former partners, who have caused injury to the
Partnership's business by their breaches of their duty of loyalty to the Partnership and by
their tortious interference with contractual relationships between the Partnership and its
employees. In addition, the Partnerhsip seeks damages against defendant Hendrick, who
has breached the Partnership Agreement by failing to repay his obligations to the
Partnership upon his termination as a partner.
2. Prior to their termination as partners, defendants performed tasks
for the benefit of the Partnership and other entities owned, controlled by or under
common control with the Partnership including Cantor Fitzgerald International, their
WP3:431290.1 52832.1001
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