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COMPLAINTUNITED STATES DISTRICT COURT

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Russ1725   Thursday, 08/27/15 11:01:58 PM
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COMPLAINT
UNITED STATES DISTRICT COURT
DISTRICT OF NEBRASKA
COR CLEARING, LLC, a Delaware limited
liability company,
Plaintiff,
v.
CALISSIO RESOURCES GROUP, INC., a
Nevada corporation; ADAM CARTER, an
individual; SIGNATURE STOCK TRANSFER,
INC., a Texas corporation; and DOES 1-50.
Defendants.
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Case No. 15-317
COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF
DEMAND FOR JURY TRIAL

COMPLAINT
Plaintiff COR Clearing, LLC (“Plaintiff” or “COR Clearing”), by its attorneys, for its
Complaint against Defendant Calissio Resources Group, Inc. (“Defendant” or “Calissio”), its
President Adam Carter (“Carter”), and its transfer agent Signature Stock Transfer, Inc.
(“Transfer Agent”) (collectively, “Defendants”), alleges as follows:
NATURE OF THIS ACTION
1. This case involves Defendants’ calculated scheme to defraud the marketplace and
the clearing system in order to obtain millions of dollars from unsuspecting market participants
by exploiting a weakness in the dividend payment system of the third-party Depositary Trust
Clearing Corporation (“DTCC”). Specifically, under the guise of what they claim to be a mere
mistake, Defendants have defrauded COR Clearing and its customers by surreptitiously issuing
hundreds of millions of shares of Calissio stock after declaring a dividend on all common shares
outstanding prior to the issuance, then repurchasing hundreds of millions of these new shares
(both on its own and through its affiliates), and relying on DTCC’s dividend payment system to
fail to distinguish between shares entitled to dividends and those not so entitled. Defendants
capitalized on this circumstance when DTCC thereby paid to Calissio and purchasing
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COMPLAINT
shareholders “dividends” with proceeds taken from selling shareholders’ accounts. Calissio’s
feigned mistake hardly serves to conceal what the facts show to be its conscious effort to deceive
its shareholders into selling their shares of Calissio stock back to the company unaware that
DTCC would charge them for the amount of a dividend on shares not so entitled, and then to
claim substantial, yet unwarranted, dividends from unwary sellers and their clearing firms, such
as COR Clearing.
2. Here, Defendant Calissio, through DTCC, has charged COR Clearing as much as
over $4 million to pay dividends presumed by DTCC to be owed to purchasing shareholders of
the hundreds of millions of new shares in connection with Calissio’s buy-back of its own stock
from COR Clearing’s customers. The problem is, Calissio is admittedly not entitled to such
dividends.
3. Specifically, COR Clearing’s customer Nobilis Consulting LLC (“Nobilis”)
purchased over 327 million shares of Calissio’s stock and never received a dividend, as none was
owed on these shares. This customer then sold these shares on the open market. These shares
were sold—with COR Clearing standing in its shoes for the transaction—and Calissio
repurchased hundreds of millions of these shares at a price, based on the information presented
by Calissio, indicating that no dividend was owed on the shares.
4. After the sale, DTCC informed COR Clearing that it would charge it with over
$3.3 million in dividends, and DTCC debited COR Clearing that amount.
5. The day after the debit took place, after COR Clearing informed DTCC that no
dividends were owed for these shares, the president of Calissio, Adam Carter, purported that
there was “a huge glitch/error on how the dividend was supposed to be paid out,” and he pledged
to resolve this supposed inadvertence. He also said, “this was a problem created by FINRA and
not . . . Nobilis Consulting LLC.” Yet, despite this, Calissio has yet to return the money
collected by DTCC to COR Clearing.
6. On information and belief, Defendants perpetrated this scheme against Beaufort
Capital Partners (“Beaufort”), another customer of a COR Clearing client broker, in that instance
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COMPLAINT
improperly retaining as much as $700,000 in dividends.
7. In sum, Calissio’s retention of some or all of the over $4 million charged to COR
Clearing’s accounts, notwithstanding its admission that it is not entitled to same, is an indication
of Calissio’s intent to stall any legal action by COR Clearing, in order to further the fraud being
perpetrated.
8. Through its fraud, Calissio has retained some or all of $4 million from COR
Clearing to which it has admitted it is not entitled. COR Clearing is entitled to restitution of
these funds, and injunctive relief is warranted to ensure these funds are not disposed of by
Defendants but rather held until they can be repaid to COR Clearing after its ultimate success on
the merits.
PARTIES
9. Plaintiff COR Clearing is a Delaware limited liability company with its principal
place of business in Omaha, Nebraska.
10. COR Clearing is an independent full-service clearing and settlement firm. COR
Clearing serves approximately 90 introducing brokers in all 50 states and holds assets in custody
exceeding $7 billion. COR Clearing provides technology, administrative services, and product
offerings through multiple customized platforms. As a correspondent clearing firm, COR
Clearing’s principal business is the provision of custody and settlement services to introducing
broker dealers such as J.H. Darbie & Co. (“Darbie”) and their end customers such as Nobilis.
11. Defendant Calissio, formerly Amarium Technologies, Inc., is a Nevada
corporation with its principal place of business in Las Vegas, Nevada.
12. On information and belief, Adam Carter in an individual residing in Las Vegas,
Nevada, and he is President of Calissio.
13. Signature Stock Transfer, Inc. is a Texas corporation with its principal place of
business in Plano, Texas.
JURISDICTION AND VENUE
14. This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C.
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COMPLAINT
§ 1332(a), as Plaintiff COR Clearing is a Delaware limited liability company with its principal
place of business in Omaha, Nebraska, Defendant Calissio is a Nevada corporation with its
principal place of business in Nevada, Defendant Carter is an individual residing in Las Vegas,
Nevada, Defendant Signature Stock Transfer, Inc. is a Texas corporation with its principal place
of business in Plano, Texas, and the aggregate amount in controversy, being over $4 million,
exceeds the jurisdictional amount of $75,000.00.
15. This Court has personal jurisdiction over Defendants because Defendants
purposefully directed their actions to Nebraska to harm COR Clearing in this forum by having
DTCC pursue COR Clearing for the funds, which were paid from its accounts in Nebraska.
Because of these contacts with this forum, assertion of jurisdiction to remedy Defendants’
conduct does not offend traditional notions of fair play and substantial justice.
16. Venue is appropriate in the District of Nebraska pursuant to 28 U.S.C.
§ 1391(a)(2), in that a substantial part of the events or omissions giving rise to the claims
occurred in this district.
BACKGROUND
Calissio’s Scheme to Defraud Shareholders
17. On information and belief, on September 30, 2010, Calissio entered into an
agreement with Industrias Calissio SUR SA for a total of 450 million shares to be issued at a cost
basis of $.01.
18. On information and belief, on June 1, 2015, Calissio announced a program to buy
back its shares, and it proceeded to buy back millions of its outstanding shares. On information
and belief, certain of Calissio’s affiliates also purchased shares as part of this program.
19. Calissio announced a quarterly dividend payment to be distributed on August 17,
2015, consisting of a cash dividend of $0.011 per common share, to be paid to the holders of the
issued and outstanding Common Shares as of the close of business on June 30, 2015, and a stock
dividend of 3% to be paid to shareholders of record at the close of business on June 30, 2015 (the
“June 30, 2015 record date”).
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COMPLAINT
20. On information and belief, after the June 30, 2015 record date had come and
gone, Calissio and Transfer Agent converted Calissio’s debt into even more shares, which totaled
approximately four times the number of shares outstanding as of the June 30, 2015 record date.
21. Calissio issued press releases regarding the dividend and the buyback program,
but did not mention this deluge of additional shares, which it also repurchased, on its own and
through affiliates, as part of its buyback program. Instead, Calissio, Carter, and Transfer Agent
kept this issuance silent, notifying no one outside their inner circle of conspirators.
22. Because these new shares were issued after the June 30, 2015 record date, they
were not eligible for the dividends attached to the previous shares.
23. Indeed, due to the massive dump of new stocks after the June 30, 2015 record
date, four out of five Calissio shares were ineligible for a dividend.
24. Pursuant to standard procedure, the payment date for the dividends on the eligible
shares was August 17, 2015, and the shareholders who were entitled to those dividends were
those that owned the shares as of August 19, 2015 (the “ex-dividend date”).
25. Pursuant to mandatory procedure, if a shareholder of record as of the June 30,
2015 record date sold its shares after the June 30, 2015 record date, but before the August 19,
2015 ex-dividend date, it also sold its right to receive the dividend. The right to receive the
dividend was thus attached to the shares as what is known as a due bill.
26. Because the only information available to an issuer at the ex-dividend date as to
the owner of the shares is the name of the shareholder of record as of the earlier record date, it
issues the dividends to those entities. If that shareholder sold the shares after the record date but
before the ex-dividend date, pursuant to standard procedure, the dividend is withdrawn from the
shareholder of record and paid to the shareholder who had purchased the shares before the exdividend
date.
27. On information and belief, because Calissio, and its affiliates, purchased the vast
majority of the common shares outstanding on the ex-dividend date back from shareholders
before the ex-dividend date as part of its buyback program, a large percentage of the newly
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COMPLAINT
issued shares ineligible for a dividend are owned by Calissio.
28. To collect dividends owed to purchasers of shares after the June 30, 2015 record
date, DTCC collected the due bills from the shareholders of record. According to procedure,
DTCC first paid Calissio and the other purchasers the dividends, then recovered the amounts
paid from the selling shareholders, to cover DTCC’s payout to Calissio.
29. However, as a result of DTCC’s procedures, DTCC paid dividends to Calissio on
all shares on its system—including the 80% of shares that were issued after the June 30, 2015
record date that were not dividend-eligible.
30. Accordingly, DTCC collected dividends from entities that had sold non-dividendeligible
shares to Calissio and its affiliates before the ex-dividend date, even though those sellers
had not received any dividends themselves from Calissio. This obviously created a scenario
where Calissio was being paid dividends on the basis of shares that were not dividend-eligible,
causing a windfall to Calissio and its affiliates, and a loss to the sellers.
31. On information and belief, Calissio, Carter, and Transfer Agent were aware of the
fact that DTCC was collecting dividends for it on non-dividend-eligible shares that Calissio and
its affiliates had repurchased, as Calissio was the one who authorized the dividend and knew
which shares were eligible and which were not eligible. However, Calissio, Carter, and Transfer
Agent intended to defraud the sellers, the clearing system, and indeed the marketplace by failing
to provide this information to DTCC or the sellers of those shares. The reason was simple –
Defendants’ artifice of fraud was to perpetrate this scheme for the precise purpose of collecting
additional dividends from unsuspecting sellers and their clearing firms.
32. On information and belief, Calissio also benefited from this scheme, and harmed
the sellers, in another way. Specifically, Defendants’ fraud on the marketplace allowed Calissio
and its affiliates to purchase shares in Calissio’s buyback program for substantially less than the
value of the dividend payable on each share. Because the sellers of the shares had no reason to
believe that they owed any dividends on these shares, they did not factor these costs into the
consideration of their sale prices to Calissio and its affiliates. Defendants engaged in these
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COMPLAINT
purchases in furtherance of their fraudulent scheme.
33. On information and belief, Calissio repurchased at least 177 million of its shares
by the ex-dividend date (and its affiliates likely purchased additional shares), the majority of
which were not dividend-eligible (a fact known to Calissio, which itself authorized the dividends
in the first place).
Purchase of Calissio Shares by COR Clearing’s Customer & Subsequent Sale to Calissio
34. Relative to COR Clearing, between July 29, 2015, and August 19, 2015, Nobilis,
through its broker Darbie—a customer of COR Clearing—obtained over 327 million shares of
stock in Calissio through a conversion of debt to equity.
35. All 327 million of these shares were issued after the June 30, 2015 record date,
and therefore Nobilis never received a dividend on any of these shares, as none was owed to it.
36. On information and belief, subsequent to obtaining the Calissio shares, Darbie, on
behalf of Nobilis, sold some or all of these shares back to Calissio and/or its affiliates (or other
entities which ultimately sold them to Calissio).
37. For this transaction, COR Clearing stood in the shoes of Nobilis, funding all due
bills associated with the sale on behalf of Nobilis.
38. Having no reason to believe any dividend was owed to Calissio for these shares,
because these shares were issued after the June 30, 2015 record date and were thus ineligible for
dividends, Nobilis, through COR Clearing, sold the shares, on information and belief, to Calissio
(or other entities which ultimately sold them to Calissio), with gross proceeds totaling
approximately $700,000.
DTCC’s Improper Demand for Dividend Payments & Attempted Cover-Up
39. On August 21, 2015, DTCC contacted COR Clearing and assessed a bill to
Nobilis for over $3.3 million—significantly more than the amount Nobilis received for the
shares—some or all of which was purportedly owed to Calissio in dividends for the shares sold
by Nobilis through COR Clearing.
40. As a result, on August 24, 2015, DTCC debited COR Clearing over $3.3 million.
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COMPLAINT
41. COR Clearing sent a letter to DTCC, informing it that “such payment would be in
error,” as these shares “were not in existence at the time of the dividend record date of June 30,
2015.” (Exhibit A.) COR Clearing also sent letters to Darbie and Nobilis, among others,
alerting them to this issue.
42. On August 25, 2015, having been alerted that Nobilis, Darbie, and COR Clearing
were aware of the issue with the dividends, Adam Carter, president of Calissio, sent an e-mail to
Michael Yarmish of Darbie and a representative of Nobilis, admitting that no dividend was owed
by Nobilis and asserting that DTCC’s collection of the money from COR Clearing was a
mistake:
Your client Nobilis Consulting LLC has asked me to reach out to
you. As you are aware there has been a huge glitch/error on how
the dividend was supposed to be paid out. We are currently in
conversations with DTCC and will be resolving this issue over the
next couple of days. There is absolutely no reason for closing your
clients account as they are not at fault here. Once again this was a
problem created by FINRA and not your client Nobilis Consulting
LLC.
(Exhibit B.)
43. That same day, Mr. Carter made essentially the same admission to Carlos Salas,
CEO of COR Clearing: “As you are aware there has been a huge glitch/error on how the
dividend was supposed to be paid out. We are currently in conversations with DTCC and will be
resolving this issue over the next couple of days.” (Exhibit C.)
44. On information and belief, Defendants perpetrated this fraud against another
customer as well, Beaufort, who converted over 150 million shares and then sold over $90
million shares during the due bill period. Relative to this customer, Defendants received the
proceeds from the DTCC charge to COR Clearing in the amount of nearly $700,000.
45. Despite this admission, Calissio has yet to return any portion of the over $4
million taken from COR Clearing by DTCC. Calissio’s retention of this money only further
confirms that Calissio’s admission of liability is nothing more than a tactic to stall legal action by
COR Clearing in furtherance of the fraud being perpetrated by Defendants.
46. At this time, there exists the immediate danger that Defendants will abscond with
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COMPLAINT
the improperly-held dividends and make it unlikely or impossible for Plaintiff to obtain complete
relief in this action.
FIRST CLAIM FOR RELIEF
(Declaratory Judgment by Plaintiff Against Defendants)
47. COR Clearing incorporates each and every allegation set forth above as if set
forth fully herein.
48. The 327 million shares (in whole or in part) sold by Nobilis (through COR
Clearing) to Calissio and/or its affiliates were issued after the June 30, 2015 record date, and thus
were ineligible for any dividends. Indeed, Nobilis received no such dividend on the ex-dividend
date.
49. Defendants caused the wrongful charging of Nobilis (through COR Clearing) of a
dividend of over $3.3 million to which it is not entitled, and therefore the over $3.3 million debit
was wrongfully made against COR Clearing’s account. Defendants caused this same harm as to
Beaufort in the amount of nearly $700,000.
50. Defendants, through Carter, purported to Nobilis, Darbie, and COR Clearing that
DTCC’s debiting of the over $4 million was the result of a “huge glitch/error on how the
dividend was supposed to be paid out.” Therefore, Defendants admitted that the shares sold by
Nobilis/COR Clearing were ineligible for the dividends, and COR Clearing should not have been
debited.
51. By reason of the foregoing, COR Clearing is entitled to a declaration that
Defendants are not entitled to the over $4 million in dividends for the purchase of the shares
from Nobilis, and therefore the $4 million debits were wrongfully made against COR Clearing’s
account.
52. In addition to all other forms of relief, COR Clearing seeks injunctive relief
precluding Defendants from disposing of the amount Calissio charged in dividends to COR
Clearing, because COR Clearing is likely to succeed on the merits of this claim, COR Clearing
would be irreparably harmed if Defendants were to prevent COR Clearing from being able to
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COMPLAINT
recover this money after a favorable judgment, and preventing Defendants from succeeding in its
fraud is in the public interest.
SECOND CLAIM FOR RELIEF
(Unjust Enrichment by Plaintiff Against Defendants)
53. COR Clearing incorporates each and every allegation set forth above as if set
forth fully herein.
54. There is no contract between Calissio and COR Clearing.
55. COR Clearing, standing in the shoes of Nobilis and Beaufort, provided a benefit
to Defendants in the form of the shares of stock sold, which ultimately came under the ownership
of Calissio. It also provided a benefit in the form of the over $4 million debited by DTCC, some
or all for the benefit of Calissio.
56. Defendants also received and accepted the benefit of the shares from Nobilis and
Beaufort, and some or all of the over $4 million from COR Clearing.
57. Calissio admitted, by and through its President, that it was not entitled to this
dividend from Nobilis or COR Clearing.
58. Because no dividend was owed to Calissio for the shares sold by COR Clearing
on behalf of Nobilis and Beaufort, it would be inequitable and unjust for Defendants to retain the
over $4 million it debited from COR Clearing, through DTCC.
59. COR Clearing is entitled to restitution in an amount equal to the amount debited
by DTCC, over $4 million.
60. In addition to all other forms of relief, COR Clearing seeks injunctive relief
precluding Defendants from disposing of the amount Calissio charged in dividends to COR
Clearing, because COR Clearing is likely to succeed on the merits of this claim, COR Clearing
would be irreparably harmed if Defendants were to prevent COR Clearing from being able to
recover this money after a favorable judgment, and preventing Defendants from succeeding in its
fraud is in the public interest.
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COMPLAINT
THIRD CLAIM FOR RELIEF
(Fraud by Plaintiff Against Defendants)
61. COR Clearing incorporates each and every allegation set forth above as if set
forth fully herein.
62. Calissio and Carter omitted from any public press releases that Calissio issued
hundreds of millions of shares of stock after the June 30, 2015 record date.
63. Calissio and Carter intentionally omitted this material fact knowing that it would
cause confusion among record shareholders, and would make it easier for Calissio to
misrepresent the dividend eligibility of 80% of the outstanding shares.
64. Then, Calissio and Carter took advantage of this confusion by allowing DTCC,
pursuant to its usual procedures, to provide Calissio with dividends from dividend-ineligible
shares. Calissio and Carter intentionally omitted this information in order to deceive and gain
access to funds to which they were not entitled. Having omitted this information, Defendants
then pursued and obtained payments from entities, such as Nobilis, Beaufort, and COR Clearing,
that had sold these dividend-ineligible shares to Calissio before the ex-dividend date.
65. Although Defendants knew that DTCC was improperly providing Calissio with
the dividends for these dividend-ineligible shares, Defendants did nothing to rectify this
circumstance, but rather allowed DTCC to continue to provide Calissio with funds to which they
knew it was not entitled.
66. Nobilis—and thus COR Clearing, who stood in the shoes of Nobilis for the sale to
Calissio—sold its shares of Calissio stock back to Calissio for a lower price than it otherwise
would have, relying on its reasonable and correct belief that these shares were not eligible for
dividends. This is evidenced by the fact that the net proceeds for the sale of shares were only
$700,000, while the dividends were over $3.3 million.
67. The same fraud was perpetrated against Beaufort, resulting in wrongful retention
of dividends in the amount of nearly $700,000.
68. For its part in this fraudulent scheme, Calissio issued the dividend-ineligible
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COMPLAINT
stocks, omitted material information about dilutive share issuances, and misrepresented the
dividend eligibility of the shares. It then reaped the rewards of its fraud by collecting dividends
on the dividend-ineligible shares, and attempted to cover up the scheme when discovered, by
feigning a “glitch” in the system.
69. For his part in this fraudulent scheme, Adam Carter, as president of Calissio,
orchestrated the scheme by causing the dilutive share issuance without any notice, hiding from
DTCC the fact that not all shares were dividend eligible, and failing to correct DTCC’s dividend
collection, thereby causing DTCC to collect dividends on all shares. He then covered up this
fraud by communicating to COR Clearing, Darbie, and Nobilis that it was all the result of a
“glitch” in the system.
70. For its part in this fraudulent scheme, Transfer Agent acted as the instrumentality
used by the other Defendants to carry out the fraud. Transfer Agent should have known that not
all shares were entitled to dividends, but it kept this silent from purchasers and shareholders, and
it made no effort to alert DTCC of this dividend issue, allowing the other Defendants to
perpetrate the fraud without alerting their victims.
71. This fraud was committed with malice and the intent to deceive COR Clearing.
72. COR Clearing was proximately harmed by Defendants’ material
misrepresentations and omissions, in the form of the over $4 million in funds debited by DTCC.
73. When confronted with this fraud, Calissio, through Carter, perpetrated yet another
fraud by asserting that this was a simple technical glitch. However, Defendants have still yet to
remedy the issue, making it evident that it was simply furthering its deception to delay legal
action.
74. The aforementioned conduct of Defendants constituted deceit or concealment of
material facts known to them with the intent of thereby depriving COR Clearing of property or
legal rights or otherwise causing injury, and was despicable conduct that subjected COR
Clearing to cruel and unjust hardship in conscious disregard of COR Clearing’s rights, so as to
justify an award of exemplary and punitive damages.
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COMPLAINT
75. In addition to all other forms of relief, COR Clearing seeks injunctive relief
precluding Defendants from disposing of the amount Calissio charged in dividends to COR
Clearing, because COR Clearing is likely to succeed on the merits of this claim, COR Clearing
would be irreparably harmed if Defendants were to prevent COR Clearing from being able to
recover this money after a favorable judgment, and preventing Defendants from succeeding in its
fraud is in the public interest.
PRAYER FOR RELIEF
WHEREFORE, COR Clearing prays for judgment against Defendants as follows:
1. That pending the final hearing of this case, this Court issue an order for a
temporary restraining order, preliminary and permanent injunction prohibiting
Defendants from disposing of the over $4 million referenced herein until those
funds can be repaid to COR Clearing after success on the merits;
2. For declaratory judgment that Defendants are not entitled to the over $4 million
dividend from Calissio’s purchase of Calissio shares from Nobilis;
3. For restitution of the money debited by DTCC;
4. For punitive damages;
5. For costs of suit incurred herein, including attorneys’ fees; and,
6. For such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiff COR Clearing, LLC demands a trial by jury on all issues so triable. Plaintiff
COR Clearing, LLC requests that the trial take place in Omaha, Nebraska.
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COMPLAINT
Respectfully submitting this 26th day of August, 2015.
By: __s/ Michael T. Hilgers_____________
Michael T. Hilgers (#24483)
mhilgers@goberhilgers.com
Carrie S. Dolton (#24221)
cdolton@goberhilgers.com
GOBER HILGERS PLLC
14301 FNB Parkway, Suite 100
Omaha, NE 68154
Telephone: (402) 218-2106
Facsimile: (877) 437-5755
David L. Aronoff*
daronoff@winston.com
Saul S. Rostamian*
srostamian@winston.com
Andrew G. Smith*
agsmith@winston.com
WINSTON & STRAWN LLP
333 S. Grand Avenue, 38th Floor
Los Angeles, CA 90071-1543
Telephone: (213) 615-1700
Facsimile: (213) 615-1750
* pro hac vice applications forthcoming
Attorneys for Plaintiff COR Clearing, LLC
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