UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
HAROLD BRIMACOMBE,
Plaintiff,
JURY TRIAL DEMANDED
CASE NO.
96-593-CIV-T-25E
v.
DEAN WITTER DISCOVER AND COMPANY,
a foreign corporation;
DEAN WITTER VENTURE, INC.,
a foreign corporation;
DEAN WITTER INTERCAPTIAL, INC.,
a foreign corporation;
DEAN WITTER U.S. GOVERNMENT SECURITIES TRUST,
an open-end diversified management
investment company;
DEAN WITTER SERVICES COMPANY, INC.,
a foreign corporation;
DEAN WITTER DISTRIBUTORS, INC.,
a foreign corporation;
NATIONSBANK CORPORATION, a
foreign corporation and bank
holding company;
NATIONSBANK OF FLORIDA, N.A.,
a national banking association;
NATIONSBANK OF NORTH CAROLINA, N.A.,
a national banking association;
NATIONSSECURITIES, a general partnership;
NATIONSBANC ENTERPRISE, INC.,
a foreign corporation;
NATIONSBANC SECURITIES, INC., n/k/a
NATIONSBANC DISCOUNT BROKERAGE, INC.,
a foreign corporation;
Defendants.
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CLASS ACTION COMPLAINT
Plaintiff, HAROLD BRIMACOMBE, sues defendants, DEAN WITTER
DISCOVER AND COMPANY, a foreign corporation; DEAN WITTER VENTURE,
SNIPPETS:
MIDDLE DISTRICT OF FLORIDA
DEAN WITTER DISCOVER AND COMPANY,
DEAN WITTER U.S. GOVERNMENT SECURITIES TRUST,
a foreign corporation; NATIONSBANK CORPORATION, a foreign corporation and bank holding
NATIONSBANK OF NORTH CAROLINA, N.A.,
a national banking association; NATIONSSECURITIES,
Plaintiff, HAROLD BRIMACOMBE, sues defendants, DEAN WITTER
DISCOVER AND COMPANY, a foreign corporation; DEAN WITTER VENTURE,
DEAN WITTER U.S. GOVERNMENT SECURITIES TRUST,
an open-end diversified management investment company;
CAROLINA, N.A., a national banking association; NATIONSSECURITIES,
NATIONSBANC ENTERPRISE, INC., a foreign
class members who purchased in Florida and elsewhere.
This class action complaint is brought on behalf of a class of
or controversy under Article III of the United States Constitution.
Dean Witter Discover and Company is a foreign corporation
subsidiaries at all times material to the complaint.
Dean Witter Services Company, Inc., is a wholly-owned
Dean Witter Distributors, Inc., as of December 31, 1993,
the NationsBank bank employees making
or that their jobs were to work with bank customers.
The glossy brochure presented the following misleading
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