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meikodog

10/22/16 8:28 AM

#46049 RE: janice shell #46047

COR's response is out:

https://drive.google.com/file/d/0B4bO_PuRhSJQR0VuRWRFNmlud00/view

Should be interesting to see how the brokers respond. COR mentions enrichment includes interest earned on the dividends, transaction fees and use of the money to apply toward customer debts such as margin calls. Not the strongest of arguments but I'm guessing the bar to overcome a motion to dismiss is relatively low.

meikodog

10/22/16 8:28 AM

#46050 RE: janice shell #46047

'The Brokerage Defendants tell this Court that they were not enriched because, they allege, their customers also received funds; but this suggestion is flatly wrong, because, in addition to being directly enriched by receiving funds to which they did not have a right to in the first instance, it is plausible that the Brokerage Defendants were indirectly enriched by the receipt of these funds (for example, through float on the principal sums, through transaction fees, and to the extent the due bill payment satisfied customers’ debts to the Brokerage Defendants).'