1. -. J IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
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`5 ..,/
i IN AND FOR NEW CASTLE COUNTY
CANTOR FITZGERALD L.P.,
Plaintiff,
V.
GREGORY FORDE, MARK HOGBEN, C.A. No. 15690
CHRIS LEE, ANDREW STONE,
and PAUL WILLIAMS,
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 Gregory Forde ("Forde"), Mark Hogben ("Hogben"),
("Lee"), Andrew Stone ("Stone"), and Paul Williams ("Williams")
"Counterclaimants") hereby answer the complaint of Cantor Fitzgerald, L.P.
Partnership") and counterclaim against the Limited Partnership, Howard
and Cantor Fitzgerald Group Management ("C.F. Group Management") (the
sometimes collectively are referred to herein as "Counterdefendants") as
ANSWER
SNIPPETS:
CANTOR FITZGERALD L.P.,
CHRIS LEE, ANDREW STONE,
, Andrew Stone, and Paul Williams
Partnership") and counterclaim against the Limited Partnership, Howard Lutnick,
and Cantor Fitzgerald Group Management ("C.F.
sometimes collectively are referred to herein as "Counterdefendants") as follows:
previously employed Defendants, that the Limited Partnership controls CFI, and that Liberty
Brokerage Investment Corp. is a Delaware corporation.
("Amended Agreement")
Kingdom, that he commenced employment with CFI during or about October 199 1, that he
except admitted that Defendant Lee is a resident of the United
Paragraph 11 states legal conclusions to which no response is required.
The first sentence of Paragraph 13 contains no factual allegations but
merely sets forth legal conclusions to which no responsive pleading is required.
auspices of Cantor Fitzgerald Limited Partnership by its general partner,
capital from employees of affiliates of the Limited Partnership.
as the individual who ultimately controlled Counterclaimants'
Lutnick's representations, upon termination of their employment with CFI the Limited
As the sole shareholder of the sole general partner of the Limited
Distribution" and "High Distribution II Units."
converted their High Distribution Units to High Distribution II Units.
Distribution Units was a sound investment, that purchasers could expect returns of between
reduce their capital contribution amount from $150,000 to $100,000.
to redeem the capital contribution of a Terminated Employee at any time in the near future,
Counterclaimants repeat, reallege and incorporate by reference,
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