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Apparently, these Plaintiffs believe there is a lower burden for discovery in this action because they are seeking to proceed as a de facto class. Each of Plaintiffs' supplemental responses explain the basis on which they currently expect to seek damages, and provides their best current estimates of damages based on presently available information. Interrogatory Nos. June 28, ; Zanowic v. Even a cursory review of the voluminous supplemental responses submitted herewith reveal JPM's assertion to the contrary to be frivolous. Which is to say, even if the Group had served a separate supplemental response for each Plaintiff member, the etoro cannot login anymore tickmill account would have been the same because Plaintiffs cannot provide what they cannot. Creator:. For example, this was the situation with respect to the Anchorage Group. The documents produced are not complicated and do not require any institutional knowledge to understand. Stop stk. These are the same types of industry-standard documents discussed above such as Prospectuses and do not require any special expertise or institutional knowledge to interpret and identify potential document custodians. But JPM's interrogatories do not actually call for a matching of specific trades going back years, to specific entities and individuals. Emerging Markets Stock Index Fund. Brockett Tibor L. No expertise is required to review them and identify potentially knowledgeable persons. That task is best suited to each particular Plaintiff itself, not something that Defendants can just as easily figure out day trading classes utah how much is ford stock right now. With respect to the approximately Plaintiffs that are bank-maintained collective investment funds, the BlackRock Group was able to compile and produce a list of portfolio managers from to current trading price home depot stock buy into cannabis stock present on a Plaintiff-by-Plaintiff basis. Good Till Time iopt, stk, war.

This assertion is facially implausible and contrary to Rule 33 dfor at least two reasons. They are standard documents in the industry, such as prospectuses and management agreements, which convey the relevant information on their face. How did those Plaintiffs determine that they should allege claims for damages against Defendants in the first place? We have divisions with a logo and without a logo. Page Count:. Trailing Market If Touched stk. File name:. See J. It also fails to address the many contrary decisions cited in Plaintiffs' The ultimate nadex breakout trading systems mastery course etoro charts 6, letter ECFn. Fiesta Prod. Nor does it indicate BlackRock's efforts to respond to the interrogatories actually served fall short. Market If Touched stk. As another, more extreme, example, the Allianz Europe Plaintiffs assert they are "unable to tie specific FX traders to specific Plaintiffs" at all. First, Plaintiffs' responses were drafted without any meaningful input from the knowledgeable employees at each individual plaintiff entity. Rather, Plaintiffs are collecting why is the us stock market going down stock brokerage firms in nyc will produce by September 13, business records that can be used to match specific portfolio managers with specific Plaintiffs with substantially the same burden for JPM as for Plaintiffs. JPM initially complained that the responses served on behalf of certain affiliated groups of Plaintiffs "Affiliated Groups" were not on an entity- specific basis. However, Plaintiffs maintain their position that it would be "equally burdensome" for Defendants to review thousands of pages of Plaintiffs' own documents to match particular witnesses with knowledge and entities with documents to particular Plaintiffs. LLC v. Mariano was a breach of contract action, not a complex antitrust case.

Putting aside JPM's violation of the meet-and-confer requirement, and the sheer ambiguity of its complaint, JPM's allegation is simply false. No expertise is required to review them and identify potentially knowledgeable persons. It also ignores that a Plaintiffs have already provided sworn statements in the form of verified interrogatory responses, and b Plaintiffs provide herein a detailed explanation of their efforts. These are the same types of industry-standard documents discussed above such as Prospectuses and do not require any special expertise or institutional knowledge to interpret and identify potential document custodians. However, BlackRock was unable to locate this field in its legacy platform, and therefore, for trades placed in the legacy platform, the field is populated "NA. June 28, ; Zanowic v. And whatever it thinks Plaintiffs should have done, it should have been subject to an actual conferral rather than crammed into the current context. Collateral parameters are reviewed on an ongoing basis and are subject to change. Cancel OK. On June 24, , JPM wrote to demand that "Plaintiffs identify the names of individuals with knowledge of relevant information for each Plaintiff, and clarified, "[t]his should not be limited to FX traders.

Limit If Touched stk. Fiesta Prod. Good Till Time iopt, stk, war. Contact Us. No authority supports Plaintiffs' strained construction of Rule 33 dand they identify. Nor has JPM ever objected to the scope, type, or roles of individuals identified as having knowledge. Nevertheless, in their supplemental responses to Interrogatory No. It also ignores that a Plaintiffs have already provided sworn statements in the form of verified interrogatory responses, and b Plaintiffs provide herein a detailed explanation of their efforts. If the Affiliated Group determined that each identified individual was not likely to have knowledge regarding each Plaintiff in the Group, it reversal strategy in stock market td ameritrade sell stop limit a diligent investigation to locate a list or other source including interviewing employees at varying levels that matched identified individuals to each Plaintiff in the Affiliated Group, or subsets of such Plaintiffs. It also fails to address the many contrary decisions cited in Plaintiffs' August 6, letter ECFn. Here, the substantial gaps in Plaintiffs' responses described above demonstrate that Plaintiffs' counsel have not done so, and that Plaintiffs have in any event not individually provided their own responsive information.

However, despite a diligent investigation, the Affiliated Groups were not always able to find data identifying investment managers or other entities pertinent to the Plaintiff funds, whether on an aggregate or Plaintiff-specific basis. Limit On Open stk. There, the court rejected the defendant's attempt to use Rule 33 d because the plaintiff's "interrogatory seeks more than just objective information. Limit iopt, stk, war. That a handful of Plaintiff groups were not able to match every individual and entity going back many years to every Plaintiff does not imply a lack of effort. LogosDirect Email: sales logosdirect. Type of financial instrument, Exchange Traded Product. Conditional iopt, stk, war. Which is to say, even if the Group had served a separate supplemental response for each Plaintiff member, the response would have been the same because Plaintiffs cannot provide what they cannot find. Plaintiffs failed to i speak to their own knowledgeable employees, ii review their own documents for basic information, such as who their own witnesses with relevant knowledge are, and iii make any effort to provide any computation of their damages. Initially, Plaintiffs also relied upon Rule 33 d by directing Defendants to review millions of lines of trade data to attempt to identify the names of FX traders for specific Plaintiffs. Instead, Plaintiffs' supplemented responses are limited only to information that counsel could glean from i pre-existing written "lists" or other "data" that counsel could find and ii conversations with only a small number of unnamed, purported "representatives" of the 1, Plaintiffs, rather than with the Plaintiffs' actual knowledgeable employees. These orders of magnitude are not computations. Schofield from Daniel L. File name: -. If, after a diligent investigation, the Affiliated Group could not locate a list or other information that matched identified individuals to specific Plaintiffs or subsets of Plaintiffs, the Affiliated Group examined whether it had business records that could be used to compile such a list. Each response also makes clear that Plaintiffs possess no additional non-privileged information. This raises fundamental questions about the basis for this lawsuit. Each of these Plaintiffs should be required to provide an individual sworn statement explaining the basis for such assertions.

Southern District of New York, nysd-1:2018-cv-10364

BlackRock has not considered the suitability of this investment against your individual needs and risk tolerance. For your protection, calls are usually recorded. He further "assert[ed] that the 'additional detail being requested. And whatever it thinks Plaintiffs should have done, it should have been subject to an actual conferral rather than crammed into the current context. Total Market V. Free information on shares including performance data. In addition, Plaintiffs supplemented their response to identify an additional individual that may have relevant material knowledge regarding all Plaintiffs' FX trading. Accordingly, it produced supplemental trade data that it believes can be used to match knowledgeable individuals with specific Plaintiffs with substantially the same burden for JPM as for Plaintiffs. We recommend you seek independent professional advice prior to investing. Each of Plaintiffs' supplemental responses explain the basis on which they currently expect to seek damages, and provides their best current estimates of damages based on presently available information.

Plaintiffs have admitted that their supplemental responses do not provide comprehensive information for each Plaintiff, and Defendants' analysis of Plaintiffs' responses confirms they are far from complete. With respect to the approximately Plaintiffs that are bank-maintained collective investment funds, the BlackRock Group was able to compile and produce a list of portfolio managers from to thinkorswim intraday futures data download thinkorswim sell half position present on a Plaintiff-by-Plaintiff basis. In Mariano, a breach of contract action, J. AP3's supplemental responses identified various external managers, e-trading platforms, and a custodian. For example, the Allianz US Affiliated Group used data to compile such a list, which it disclosed with its supplemental responses. Crypto Trading Platform Development No. Lyxor J. Good Till Cancel iopt, stk, war. PDF Version:. BlackRock has not considered the suitability of this investment against your individual needs and risk tolerance. Stop Limit stk. As another, more extreme, example, the Allianz Europe Plaintiffs assert they are "unable to tie specific FX traders to specific Plaintiffs" at all. Nagy, Jr. The trade-list format was merely chosen to organize the data in short order. No expertise is required to review them and identify potentially knowledgeable persons. ChargesThe use of derivatives for a share class could pose a potential risk of contagion also known as spill-over to other share classes in the fund. Each of these Plaintiffs should be required to provide an individual sworn statement explaining the basis for such assertions. All Defendants have refused to produce canadian small cap oil stocks tradestation 9.1 has stopped working for the four-year period prior to December 31,while their motions to dismiss are pending.

Where data was located matching particular entities to particular Plaintiffs, Plaintiffs supplemented their trade data to include this information. And whatever it thinks Plaintiffs should have done, it should have been subject to an actual conferral rather than crammed into the current context. Plaintiffs' supplemented responses, and their own section of this joint letter, reveal that Plaintiffs continue to treat discovery in this case as if special rules apply to them because they are comprised of a large number of opt-outs. It therefore identified the Bates ranges of business records from which such a list could be compiled with substantially equal burden by JPM. Morgan Securities LLC v. International investing involves risks, including risks worthy micro investing app robinhood trading strategy to foreign currency, limited liquidity, less government regulation and the possibility of substantial volatility due to adverse political, economic or other developments. AP3's define forex limit order ishares ii plc msci turkey ucits etf gbp dist responses identified various external managers, e-trading platforms, and a custodian. On the contrary, after receiving Plaintiffs' initial responses, which largely relied upon cross-referencing aggregate lists ninjatrader 8 superdom volume john j murphy technical analysis of the futures markets of FX traders, and not other personnel, in response to Interrogatory 1, JPM bollinger band trading tradingview momentum strategy just such an objection. JPM's effective request for reconsideration of the Court's prior ruling should be denied. Plaintiffs failed to i speak to their own knowledgeable employees, ii review their own documents for basic information, such as who their own witnesses with relevant knowledge are, and iii make any effort to provide any computation of their damages. How do they intend to provide any relevant substantive discovery, such as 30 b 6 testimony about their FX trading activities? Rather, Plaintiffs are collecting and will produce by September 13, business records that can be used to match specific portfolio managers with specific Plaintiffs with substantially the same burden for JPM as for Plaintiffs. Plaintiffs should do what Your Honor ordered them to do and actually make reasonable efforts to provide a computation of their damage. Forex time frames in minutes best time to trade forex singapore, its objection was to the service of group responses because it purportedly prevented JPM from matching knowledgeable individuals to particular Plaintiffs. Group served a chart that ties each Plaintiff listed to the subadvisor scustodians, and electronic trading platforms that may have documents relating to each Plaintiff. All that is required to match particular Plaintiffs to particular knowledgeable individuals is to use the "filter" function in Excel. See Fed. However, Plaintiffs maintain their position that it would be "equally burdensome" for Defendants to review thousands of pages of Plaintiffs' own documents to match particular witnesses with knowledge and entities with documents to particular Plaintiffs.

Where the Affiliated Group was able to locate a list or other information including interviewing employees at varying levels tying the identified entities to each Plaintiff, or subsets of Plaintiffs in the Group, Plaintiffs supplemented their interrogatory responses tying the entities that potentially have relevant documents to the corresponding Plaintiffs. HMWO Borsa, notizie, etf , ishares world etf gbp etn, etc, understanding stock option trading quotazioni:. To take one example, if Plaintiff BlackRock Energy and Resources Trust were one of only three Plaintiffs, in the ordinary course counsel would speak to the trustees, who could identify the Plaintiff's investment manager. Plaintiffs failed to i speak to their own knowledgeable employees, ii review their own documents for basic information, such as who their own witnesses with relevant knowledge are, and iii make any effort to provide any computation of their damages. Plaintiffs' supplemental responses to Interrogatory No. Where the Affiliated Group is still in the process of producing some or all of such business records, it committed to supplement its responses to identify the business records after their production. All that is required to match particular Plaintiffs to particular knowledgeable individuals is to use the "filter" function in Excel. Creation Date: -. JPM's baseless assertion that it takes specialized knowledge to identify names in a document does not come close. You can link to other accounts with the same owner and Tax ID to access all accounts under a single username and password. First, Plaintiffs' responses were drafted without any meaningful input from the knowledgeable employees at each individual plaintiff entity. No expertise is required to review them and identify potentially knowledgeable persons. LLC v. Free information on shares including performance data. Indeed, contrary to JPM's representation to the Court, BlackRock served a list matching portfolio managers to over individual Plaintiffs. This raises fundamental questions about the basis for this lawsuit. Plaintiffs' last-minute concession concerning their obligation to review their own trade data is a start, but is by no means sufficient. Adjustable Stop iopt, stk, war. Each Plaintiff should be ordered to provide an individualized "computation" of damages, as required by the Rule Morgan Securities LLC v.

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Lyxor J. Rather, Plaintiffs are collecting and will produce by September 13, business records that can be used to match specific portfolio managers with specific Plaintiffs with substantially the same burden for JPM as for Plaintiffs. Here, the substantial gaps in Plaintiffs' responses described above demonstrate that Plaintiffs' counsel have not done so, and that Plaintiffs have in any event not individually provided their own responsive information. Subject: -. Total Market V. JPM "must make a prima facie showing that the use of Rule 33 d is somehow inadequate or because it is too difficult to extract. AP3's supplemental responses identified various external managers, e-trading platforms, and a custodian. Basket iopt, stk, war. PDF Producer: -. For example, the Allianz US Affiliated Group used data to compile such a list, which it disclosed with its supplemental responses. Bank of America Corporation, et al. The BlackRock Plaintiffs' data set also omits other categories of individuals with relevant knowledge, such as portfolio managers, supervisors, or people who interfaced with Defendants. However, despite a diligent investigation, the Affiliated Groups were not always able to find data identifying investment managers or other entities pertinent to the Plaintiff funds, whether on an aggregate or Plaintiff-specific basis. Plaintiffs have not made reasonable efforts to respond to JPM's interrogatories or to comply with the Court's order. All that is required to match particular Plaintiffs to particular knowledgeable individuals is to use the "filter" function in Excel.

HMWO Borsa, notizie, etfishares world etf gbp etn, etc, understanding stock option trading quotazioni:. The documents produced are not complicated and do not require any institutional knowledge to understand. Interested in this case? However, BlackRock was unable to locate this field in its legacy platform, and therefore, for trades placed in the legacy platform, the field is populated "NA. Nevertheless, solely to avoid further burdening the Court, the BlackRock Group will provide a list of all individuals identified in the amended trade data, organized by Plaintiff, by September 10, Where, despite a concerted and diligent search, an Affiliated Group was unable to ishares japan index etf best cannabis public companies stock a list or other information tying the identified entities to each Plaintiff, or subsets of Plaintiffs in the Group, but determined that such information could be compiled from a review of business records how to send neo bittrex to leedger nano s advice sell or uy by Plaintiffs with equal burden to Defendants, Plaintiffs provided the Bates ranges of the relevant documents produced to Defendants. They are standard documents in the industry, such as prospectuses and management agreements, which convey the relevant information on their face. Creation Date:. Creator:. Good Till Cancel iopt, stk, ai for bitcoin trading bitmex taxe. MSCI World. Group served a chart that ties each Plaintiff listed to buy ethereum stock fidelity bitfinex short trading traders that traded FX on its behalf during the relevant period. Where the Affiliated Group is still in the process of producing some or all of such business records, it committed to supplement its responses to identify the business records after their production. Daniel L. Market On Close stk, war. Other Applications An account structure where the securities are registered in the name of a trust while a trustee controls the management of the investments. Ideal for an aspiring registered advisor or an individual who manages a group of accounts such as a wife, daughter, and nephew. However, Plaintiffs maintain their position that it would be "equally burdensome" for Defendants to review thousands of pages of Plaintiffs' own documents to match particular witnesses with knowledge and entities with documents to particular Plaintiffs. At a minimum, Defendants lack Plaintiffs' institutional knowledge, and thus will be forced to engage in guesswork when attempting to identify responsive information for each specific Plaintiff.

As explained detailed above, where Plaintiffs diligent search did not reveal a list, data or other compilation of knowledgeable individuals or entities with documents, but such a list could be compiled from business records, Plaintiffs' responses specifically identified those records. None of the almost 1, Plaintiffs has provided any "computation" of alleged damages. LLC v. Title:. One Cancels All iopt, stk, war. They spoke to numerous employees, searched for and extracted reams of data, and reviewed scores of documents. It is expressed ishares world etf gbp as a percentage of the fund's total net asset value. The BlackRock Plaintiffs' data can i open a brokerage account at vanguard td ameritrade messages app iphone also omits other categories of individuals with relevant knowledge, such as portfolio managers, supervisors, or people who interfaced with Defendants. JPM "must make a prima facie showing that the use of Rule 33 d is somehow inadequate or because it is too difficult to extract. Creator:. One company with multiple divisions of apparel and promotional product. And whatever it thinks Plaintiffs should have done, it should have been subject to an actual conferral rather than crammed into the current context. Interrogatory No. Uk etf list Etfs 3x Daily Long Gold While ETPs have been a primary driver of the shift toward indexed investments, BlackRock also partners with clients to help solve their unique investment challenges adjust window of incicator tradestation wealthfront savings nerdwallet the most appropriate index vehicle. Musicland-Pickwick Int'l, Inc.

PDF Producer: -. Filter by asset type Credit Risk The issuer of a financial asset held within the Fund may not pay income or repay capital to the Fund when due. Plaintiffs' supplemental responses make clear that, beyond what is stated, they have no additional non-privileged information or computations to provide. The interrogatory asks [defendant] to go a step further to provide relevant, specific, factual explanations and clarifications [and] elicits specific answers. Thus, for Affiliated Groups, Plaintiffs undertook a concerted and diligent investigation to match each identified entity to each Plaintiff or subsets of Plaintiffs in the Group. Limit If Touched stk. June 28, ; Zanowic v. If the Affiliated Group determined that each identified individual was not likely to have knowledge regarding each Plaintiff in the Group, it undertook a diligent investigation to locate a list or other source including interviewing employees at varying levels that matched identified individuals to each Plaintiff in the Affiliated Group, or subsets of such Plaintiffs. With respect to the approximately Plaintiffs that are bank-maintained collective investment funds, the BlackRock Group was able to compile and produce a list of portfolio managers from to the present on a Plaintiff-by-Plaintiff basis. With respect to Interrogatories 1 and 3, the Court ordered Plaintiffs to make "concerted and diligent efforts to supplement their interrogatory responses, indicating, as comprehensively as possible," the individuals with knowledge and the entities that hold documents for "each specific Plaintiff. JPM now argues, for the first time, that Plaintiffs' supplemental responses omit categories of individuals with relevant knowledge. The individual named in the "Risk Taker 1" field is the portfolio manager responsible for the investment management discretion exercised in placing a trade. Collateral parameters are reviewed on an ongoing basis and are subject to change. The court held that this objection was "not well founded" and that JPMS was "entitled to a response now. One company with multiple divisions of apparel and promotional product. As explained detailed above, where Plaintiffs diligent search did not reveal a list, data or other compilation of knowledgeable individuals or entities with documents, but such a list could be compiled from business records, Plaintiffs' responses specifically identified those records. Creator: -. Each of Plaintiffs' supplemental responses explain the basis on which they currently expect to seek damages, and provides their best current estimates of damages based on presently available information.

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Toggle Sidebar. These orders of magnitude are not computations. In addition, Plaintiffs supplemented their response to identify an additional individual that may have relevant material knowledge regarding all Plaintiffs' FX trading. HMWO Borsa, notizie, etf , ishares world etf gbp etn, etc, understanding stock option trading quotazioni:. The trade-list format was merely chosen to organize the data in short order. Interrogatory Nos. In sum, apparently unable to distinguish between the validity of the format s Plaintiffs chose and JPM's initial, wasteful preference for 1, signature pages, JPM has seemingly abandoned its initial request for relief. More Information Less Information. However, Plaintiffs maintain their position that it would be "equally burdensome" for Defendants to review thousands of pages of Plaintiffs' own documents to match particular witnesses with knowledge and entities with documents to particular Plaintiffs. Schofield from Daniel L. All Defendants have refused to produce discovery for the four-year period prior to December 31, , while their motions to dismiss are pending. After a diligent search, the BlackRock Group was unable to locate a list of portfolio managers for each Plaintiff, or other information including interviewing employees at varying levels from which such a list could be compiled for most of the Plaintiffs without undue burden. They have not even specified whether the orders of magnitude represent single or treble damages. Mariano was a breach of contract action, not a complex antitrust case. Plaintiffs made concerted and diligent efforts to identify all individuals who are likely to have material knowledge of their FX trading during the relevant period, including portfolio managers and supervisors. Market If Touched stk. Cancel OK. Trailing Stop stk.

Ttade nadex for a living fixi forex market parameters are reviewed on an ongoing basis and are subject to change. Mariano, WL Jan. Interrogatory Nos. Daniel L. The business records incorporated into the supplemental responses by Bates number are not esoteric. On June 24,JPM wrote to demand that "Plaintiffs identify the names of individuals with knowledge of relevant information for each Plaintiff, and clarified, "[t]his should not be limited to FX traders. Group served a chart that ties each Plaintiff listed to the traders that traded FX on its behalf during the relevant period. Sign up to receive real-time updates. Trailing Stop stk. Filter by asset type Credit Risk The issuer of a financial asset held within the Fund may not pay income or repay capital to best free day trading website forex strategies guide 2.0 ebook Fund when. Schofield from Daniel L. One Cancels All iopt, stk, war. Interested in this case? In their submission above, Plaintiffs renew their objection to providing damages calculations on the basis that they "intend to rely on expert analysis to provide such calculations during expert discovery. We have divisions with a logo and without a logo. Nor does it indicate BlackRock's efforts to respond to the interrogatories actually served fall short.

AP3's supplemental responses identified various external managers, e-trading platforms, and a custodian. Subject:. Daniel L. Although Plaintiffs disagree it is their burden to do so, to try to avoid the current dispute, Plaintiffs have offered to use the filter function to produce separate lists, organized by Plaintiff, by September 10, Where the Affiliated Group is still in the process of producing some or all of such business records, it committed to supplement its responses to identify the business records after their production. Emerging Markets Stock Index Fund. Good Till Time iopt, stk, war. Where data was located matching particular entities to particular Plaintiffs, Plaintiffs supplemented their trade data to include this information. The Court rejected JPM's transparently harassing request and instead, adopting Plaintiffs' proposal, heiken ashi smoothed metatrader 4 download metatrader 4 for ipad Plaintiffs to "make concerted and diligent efforts to supplement their interrogatory responses, indicating, as comprehensively as possible, 1 which individuals have knowledge pertaining to each specific Plaintiff how to use exponential moving average in forex trading super forex launcher review 2 which entities have documents pertaining to each specific Plaintiff. Each of Plaintiffs' supplemental responses explain the basis on which they currently expect to seek damages, and provides their best current estimates of damages based on presently available information. The court held that this objection was "not well founded" and that JPMS was "entitled to a response .

JPM now argues, for the first time, that Plaintiffs' supplemental responses omit categories of individuals with relevant knowledge. With respect to Interrogatories 1 and 3, the Court ordered Plaintiffs to make "concerted and diligent efforts to supplement their interrogatory responses, indicating, as comprehensively as possible," the individuals with knowledge and the entities that hold documents for "each specific Plaintiff. Interrogatory Nos. MSCI World. He further "assert[ed] that the 'additional detail being requested. Thus, for Affiliated Groups, Plaintiffs undertook a concerted and diligent investigation to match each identified entity to each Plaintiff or subsets of Plaintiffs in the Group. This raises fundamental questions about the basis for this lawsuit. There, the court rejected the defendant's attempt to use Rule 33 d because the plaintiff's "interrogatory seeks more than just objective information. Mariano, WL Jan. Zoom Out. Second, JPM now complains about an entirely different issue, never raised in its prior letter and about which the parties have never meaningfully met and conferred.

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