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1
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AMENDED COMPLAINT
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EXTRACTED KEY WORDS
REPRESENTATIONS PLAZA ATTORNEY MAILS DAMAGE MASSACHUSETTS SELLS HATCH CHRISTOPHER STREET MANAGEMENT COMPANY PLAINTIFF DAWE WILLIAM |
UNITED STATES DISTRICT COURT
WILLIAM H. DAWE, JR.,
Plaintiff
V. AMENDED
MAIN STREET MANAGEMENT COMPANY, ;
CHRISTOPHER T. HATCH, THE
LIBERTY GROUP, NORTHEAST ;
FINANCIAL SERVICES, WILLIAM T. ) THE PLAINTIFF
CRISWELL, DELOITTE HASKINS 1
& SELLS, Defendants
I. INTRODUCTION
1. This Action arises out of the sale to the
plaintiff, William H. Dawe, Jr., of a limited
interest in Eighty-Eighty Central Partners Ltd.
"the Partnership Unit"). This is an Action for
injunctive relief, for damages and for recision
the Partnership Unit. It is brought against
a result of the defendants' violations, in the sale
Partnership Unit of:
(a) Sec. lob of the Securities
15 U.S.C. Sec. 78j(b) and Rule lob-5 promulgated
(b) Sec. 17(a) of the Securities
(Title 15 U.S.C. Sec. 77q(a));
(c) The Massachusetts Securities
1lOA Sec. 101 et_. a.)
2. This action is also brought to
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2
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ORDER AND MEMORANDUM
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EXTRACTED KEY WORDS
TAURO MEMORANDUM FRAUD |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
*
William H. Dawe, Jr. *
Plaintiff, +
*
V. * CA No.
*
Main Street Management *
Company, et al., *
Defendants. * *
ORDER
May & Y , 1990
TAURO, J.
For the reasons stated in the accompanying
defendant Deloitte Haskins & Sells' Motion To
ALLOWED as to Count III of the Complaint. That
hereby ALLOWED as to the remaining counts,
amending his Complaint within thirty days to cure the
--defects: 1) failure to allege use of the mails
commerce, as required by 15 U.S.C. §§78j(b) and
failure to allege that the limited partnership
llsecuritytv for purposes of 15 U.S.C. §78j(b);
plead fraud with particularity. See Konstantinakos
Deposit Insurance Corp., 719 F. Supp. 35, 38-39 (D. Mass. 1989)
(Tauro, J.).
Defendants Christopher T. Hatch, The Liberty
Northeast Financial Services 1 Motion To Dismiss
ALLOWED, subject to plaintiff's amending his
thirty days to cure the following defects: 1)
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4
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PLF OP TO DEF MTD PLF CMP
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EXTRACTED KEY WORDS
JOHN WHD/CEM PLAINTIFF STREET MANAGEMENT COMPANY |
j
VS. 1
MAIN STREET MANAGEMENT COMPANY
ET AL., ; 3
Defendants
-,, ,.*'
,
I...I,
,'
PLAINTIFF'S
DEFENDANT DELOITTE
MOTION TO DISMISS
The plaintiff, William H. Dawe, Jr.,
to the
motion to dismiss and in support of this
1. The plaintiff believes that the
a claim upon
which relief can be granted on all
contains the
elements of a claim for relief of violations
Laws.
2. The plaintiff believes that his
with enough
particularity under Rule 9(b) in that
of the
defendants which led to his losses are
detail so
the defendants know the basis of the plaintiff's
3. The pendent state law claims
court since
the federal claims should survive.
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6
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ANSWER AND JURY CLAIM OF DEFENDANT
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EXTRACTED KEY WORDS
JURY DEFENDANT CLAIMS OMISSION COMMONWEALTH LAW STREET MANAGEMENT COMPANY PLAINTIFF |
. . +I
UNITED STATES DISTRICT
DISTRICT OF
WILLIAM H. DAWE, JR.,
921-T
8
Plaintiff
MAIN STREET MANAGEMENT COMPANY,
CHRISTOPHER T. HATCH,
THE LIBERTY GROUP,
NORTHEAST FINANCIAL SERVICES,
WILLIAM T. CRISWELL,
DELOITTE HASKINS & SELLS,
Defendants
,, ANSWERAND JURY CLAIM
OF TEIE DE$XJdlhNTS, MAIN STREET
Now comes the defendant, Main Street
matter and in
answering the plaintiff's complaint
follows:
I.
1. The defendant denies that they violated
Securities
Act of 1934 and Rule lOb5 promulgated
17(a)
and 12(2) of the Securities Act of 1933
Securities Act. The remaining
one require
no answer.
2. Deny the allegations in paragraph
II. JURISDICTION
3. No answer is required.
II.
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7
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DF OP PTF MOT FOR ENTRY
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EXTRACTED KEY WORDS
SELLS DELOITTE HASKINS DAWE LIBERTY DISTRICT BOSTON SUMMONS HATCH CHRISTOPHER MASSACHUSETTS PLAINTIFF DISMISS STREET MANAGEMENT COMPLAINT CRISWELL NORTHEAST FILING PRO ENCLOSE JUDGE TAURO UNITED STATES CLERK MTN EXHIBIT DISTRICT COURT APPEARANCE MOTION CIVIL GRACE |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
WILLIAM H. DAWE, JR.,
Plaihiff, )
NO.
vs. :
MAIN STREETMANAGEMENT COMPANY, :
ET AL,,
;
Defendants. )
DEFENDANT DELOITTE HASKINS & SELLS' OPPOSITION
MEMORANDUM) TO PLAINTIFF'S MOTION FOR ENTRY OF
Defendant Deloitte Haskins & Sells
submits this Memorandum in Opposition to PlaintiffIs
Entry of Default. Such motion should be denied
because the motion is based on an untrue recital
motion has never been served on the attorneys
as required by Fed. R. Civ. P. 5 and Local Rules
Further, because the motion as to DHStS is entirely
substance, the Court should impose on plaintiff
sanction, including an order to pay to DH&S its
expenses incurred because of the motion, pursuant
P. 11.
I
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8
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DEF 2 ANSWER AND JURY CLAIM
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EXTRACTED KEY WORDS
LAW JURY DEFENDANTS CLAIM OMISSIONS REALLEGE DEFENDANTS REPEAT SELLS DELOITTE HASKINS NORTHEAST FINANCIAL SERVICES HATCH CHRISTOPHER STREET MANAGEMENT COMPANY PLAINTIFF |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSET!G& 3
,!':7
I !:-
WILLIAM H. DAWE, JR., ) CIVIL
Plaintiff
1
vs 1
MAIN STREET MANAGEMENT COMPANY,
CHRISTOPHER T. HATCH,
THE LIBERTY GROUP, i
NORTHEAST FINANCIAL SERVICES,
WILLIAM T. CRISWELL, i
i DELOITTE HASKINS & SELLS,
Defendants
ANSWER AND JURY CLAIM
OF THE DEFENDANTS CHRISTOPHER T. HATCH,
THE LIBERTY GROUP AND NORTHEAST FINANCIAL
Now comes the defenants, Christopher T.
The Liberty
Group and Northeast Financial Services in
matter and in answering the plaintiff's
admit, deny
and allege as follows:
I. INTRODUCTION
1. The defendants deny that they violated
10b of the
Securities Act of 1934 and Rule lOb5 promulgated
thereunder,
Sections 17(a) and 12(2) of the Securities
the Massachusetts Securities Act. The remaining
allegations
of paragraph one require no answer.
I
2. Deny the allegations in paragraph 2.
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9
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DF MEM IN SUP MTD PLT CO
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EXTRACTED KEY WORDS
SLANDER COMPETENCE PARTICULARITY MEMORANDUM SELLS DEFENDANT DELOITTE HASKINS |
UNITED STATES DISTRICT
: . I..
DISTRICT OF MASSACHUSETTS
;'; "
"/ ;,$
;, ) ', ,
-4
., 1, :
WILLIAM H. DAWE, JR.,
Plaintiff, >
vs.
MAIN STREET MANAGEMENT COMPANY, :
ET AL., 1
>
Defendants. >
DEFENDANT DELOITTE HASKINS 6 SELLS' MEMORANDUM IN
SUPPORT OF ITS MOTION TO DISMISS PLAINTIFF'S
Defendant Deloitte Haskins h Sells
this Memorandum in support of its Motion to
Complaint (the "complaint") under Rules
the
Federal Rules of Civil Procedure.1
INTRODUCTION
This action arises out of the sale
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11
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DEF MTD PLTF COMP
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EXTRACTED KEY WORDS
MATTER JURISDICTION SLANDER COMPETENCE PARTICULARITY DAWE WILLIAM |
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
WILLIAM H. DAWE, JR.,
Plaintiff,
;
VS. ) CIVIL
NO.
MAIN STREET MANAGEMENT COMPANY, ;
ET AL.,
;
Defendants. )
DEFEhDANTDELOI%TEHASKINS &
MOTION TO DISMISS PLAINTIFF'S
Pursuant to Rules 12(b)(6) and 9(b) of the
Rules of Civil Procedure, defendant Deloitte
("DHLS") hereby moves for dismissal of all
against it in plaintiff's Complaint filed in
As more fully discussed in the accompanying
of Law, DH&S is entitled to dismissal of all
for the following reasons:
1. Counts I, II and III, brought under
of the Securities Act of 1933 ("Securities Act")
Section 10(b) of the Securities Exchange Act of
Act") and Rule lob-5 thereunder, fail to state
which relief cati be granted.
2. Counts I, II and VIII, brought
of the Exchange Act and Rule lob-5 thereunder
common law fraud, fail to satisfy the requirement
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12
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT DECEPTIVE STATEMENTS MATERIAL OMISSIONS LOB-5 JUFTY PLAINTIFF CLAIMS PROPER RULE LOB-5 INVESTMENT MASSACHUSETTS PARTNERSHIP UNIT SALE FACTS SECURITIES ACT SELLS DELOITTE HASKINS STREET MANAGEMENT |
WD120202.CMP
UNITED STATES: DISTRICTCOUHT
' &
, `*
Jr> ,' `,
FOR THE DISTRICT OF
,,I "
WILLIAM H. DAWE, JR.,
Plaintiff,
1
V.
MAIN STREET MANAGEMENT COMPANY.'
CHRISTOPHER T. HATCH, THE LIBERTY j
GROUP, NORTHEAST FINANCIAL SERVKES )
WILLIAM T. CRISWELL,
DELOITTE HASKINS & SELLS,
Defendants.
COMPLAINT
I. INTRODUCTION
1. This action arises out of the sale
William H. Dawe, Jr., of a limited
Eighty-Eighty Central Partners Ltd.,(hereinafter
I
Unit") . This is an action for declarutory
for damages and for recision of the E':I~.~ of
It is brought against the defendants,
defendants' violations, in the sale of ;-.he
(a) Sec. lob of the Securities AC*:
Sec. 78j(b) and Rule lob-5 promulgated
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