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Name of Document:Respondents' Answer
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Name of Document:Respondents' Motion for a More Definite Statement
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Name of Document:Respondents' Memorandum of Points of Authorities in Support of Respondents' Motion for a More Definite Statement
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Name of Document:Division's Brief in Opposition to Respondents' Motion for a More Definite Statement
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Name of Document:Respondents' Reply Memorandum in Further Support of Respondents' Motion for a More Definite Statement
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Name of Document:Respondents' Memorandum of Points of Authorities in Support of Motion to Halt the Division's Search for a Substitute Case for Trial
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Name of Document:Respondents' Motion to Halt the Division's Search for a Substitute Case for Trial
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Name of Document:Declaration of Christopher J. Gunther in Support of Respondents' Motion to Halt the Division's Search for a Substitute Case for Trial
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Name of Document:Responden's Motion for Summary Disposition
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Name of Document:Respondents' Memorandum and Points of Authority in Support of Respondents' Motion for Summary Disposition
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Name of Document:Division's Brief in Opposition to Respondents' Motion to Halt the Division's Search for a Substitute Case for Trial
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Name of Document:Reply Brief in Support of Respondents' Motion to Halt the Division's Search for a Substitute Case for Trial
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Name of Document:Non-Party Rabobank International, New York Branch's Motion On Consent of Respondents for Issuance of a Protective Order, with a Draft Proposed Protective Order
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Name of Document:Reply Memorandum and Points of Authorities in Support of Respondents' Motion for Summary Disposition
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Name of Document:Division's Brief in Opposition to Respondents' Motion for Summary Disposition
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Name of Document:Division's Brief in Opposition to Respondents' Motion to Adjourn the Trial
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Name of Document:Respondents' Motion to Adjourn the Trial
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Name of Document:Respondent's Reply in Further Support of Their Motion to Adjourn the Trial
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Name of Document:Division's Witness List
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Name of Document:Respondents' Witness List
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Name of Document:Unopposed Motion of Non-Party Varde Partners, Inc. for Extension of Time to Apply to Quash or Limited Subpoena Served by Respondents and Request for Expedited Consideration
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Name of Document:Non-Party Natixis North America LLP's Motion On Consent for Issuance of a Protective Order, with a Draft of the Proposed Order
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Name of Document:Letter from Division to ALJ Foelak notifying her that the Court of Appeals, 2nd Circuit, vacated stay by order of 6/1/16
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Name of Document:Letter from Division to ALJ Foelak in Response to Respondent's Letter in Opposition
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Name of Document:Respondents' Motion for Reconsideration & Adjourn or, in the Alternative, for Certification for Interlocutory Review, Memorandum of Law and Declaration of Lisa H. Rubin
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Name of Document:Respondents' Motion Requesting that Hearing Officer Ask the Chief Administrative Law Judge to Submit a Motion to the Commission Requesting An Extension of Time Period for Filing the Initial Decision and Memo of Law
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Name of Document:Respondents' Expedited Petition to Commission for (A) an Order Extending the 300-Day Rule & Setting a 12/16 Hearing Date, (B) Interlocutory Review of Hearing Officer Determinations & (C) Order Applying the SEC's Amended Rules of Practice to Proceeding
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Name of Document:Memorandum of Law in Support of Respondents' Expedited Petition to Commission for (A) Order Extend the 300-Day Rule & Setting 12/16 Hearing Date, (B) Interlocutory Review of Hearing Officer Determinations & (C) Order Applying SEC's Amended Rules of Pra...
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Name of Document:Declaration of Lisa H. Rubin Support of Respondents' Expedited Petition to Commission for ((A) Order Extend the 300-Day Rule & Setting 12/16 Hearing Date, (B) Interlocutory Review of Hearing Officer Determinations & (C) Order Applying SEC's Amended Rul...
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Name of Document:Reply Memorandum of Law in Further Support of Respondents' Expedited Petition to the Commission
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Name of Document:Letter Dated 8/18/16 From Respondents' Counsel to Chair White, Commissioner Stein, and Commissioner Piwowar Requesting Ruling on Expedited Petition
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Name of Document:Respondents' Motion to Compel the Production of Brady Materials
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Name of Document:Respondents' Memorandum of Law in Support of Motion to Compel the Production of Brady Materials
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Name of Document:Declaration of Mary Kay Dunning in Support of Respondents' Motion to Compel the Production of Brady Materials
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Name of Document:Respondents' Reply in Further Support of their Motion to Compel the Produdction of Witness Statements Under The Jencks Act
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Name of Document:Respondents' Motion In Limine To Exclude Transcripts of Investigative Testimony
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Name of Document:Reply In Support Of Respondents' Motion For Limited Modification of May 7, 2015 Order
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Name of Document:Reply Memorandum of Law in Further Support of Respondents' Motion in Limine to Preclude Testimony and Evidence Regarding the Subjective States of Mind of Zohar Fund Investors
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Name of Document:Motion for Limited Modification of May 7, 2015 Order, with Memorandum of Law
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Name of Document:Respondents' Motion in Limine to Preclude Testimony and Evidence Regarding the Subjective States of Mind of Zohar Fund Investors, with Memorandum of Law
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Name of Document:Motion to Compel the Production of Witness Statements Under the Jencks Act
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Name of Document:Respondents' Motion in Limine to Strike Entirety of Report of Division's Expert Mayer And To Preclude Testimony
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Name of Document:Respondents' Motion in Limine to Strike Entirety of Rebuttal Report of Division's Expert Wagner, Portions of Wagner's Opening Report, And To Preclude Testimony on Stricken Matters And Related Topics
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Name of Document:Respondents' Memorandum of Law in Support of Motions in Limine to Strike parts or all of Division's Expert Reports and to Preclude Testimony on the Stricken Subjects
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Name of Document:Respondents' Motion In Limine to Preclude Evidence Concerning Recklessness and Negligence and to Require the Division to Prove Intentional Misconduct
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Name of Document:Respondents' Memorandum of Law in Support of Motion In Limine to Preclude Evidence Concerning Recklessness and Negligence and to Require the Division to Prove Intentional Misconduct
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Name of Document:Division's Opposition to Respondents' Motion to Compel the Production of Witness Statements under the Jencks Act
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Name of Document:Division's Opposition to Respondents' Motion for Limited Modification of May 7, 2015 Order
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Preclude Testimony and Evidence Regarding the Subjection States of Mind of Zahar Fund Investors
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Name of Document:Respondents' Motion in Limine to Exclude the Expert Testimony of Steven L. Henning
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Name of Document:Respondents' Memorandum of Law in Support of Motion in Limine to Exclude the Expert Testimony of Steven Henning
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Name of Document:Declaration of Akiva Shapiro in Support of Respondents' Motion in Limine to Exclude the Expert Testimony of Steven Henning
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Name of Document:Respondents' Motion in Limine to Preclude the Division of Enforcement from Seeking Disgorgement
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Name of Document:Respondents' Memorandum of Law in Support of Motions in Limine to Exclude the Expert Testimony of Michael G. Mayer and Ira Wagner, and to Preclude the Division of Enforcement from Seeking Disgorgement
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Preclude Evidence concerning Recklessness and Negligence and to Require the Division to Prove Intentional Misconduct
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Name of Document:Respondents' Motion in Limine to Exclude the Zohar COO 2003-1, LLC, et al. v. Patriarch Partners, LLC, et al., Case No. 12247-VCS (DEL. CH. Aug. 9 and 10, 2016) Trial Transcripts Marked Division Exhibits 207 and 208
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Name of Document:Respondents' Memo in Support of Motion in Limine to Exclude the Zahar COO 2003-1, LLC, et al. v. Patriarch Partners, LLC, et al., Case No. 12247-VCS (DEL. CH. Aug. 9 and 10, 2016) Trial Transcripts Marked Division Exhibits 207 and 208
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Name of Document:Reply Memorandum of Law in Further Support of Respondents' motion in Limine to Preclude Evidence Concerning Recklessness and Negligence and to Require Division to Prove Intentional Misconduct
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Name of Document:Division's Opposition to Respondents' Motion to Compel the Production of Brady Materials
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Name of Document:Division's Opposition to Respondent's Motion in Limine to Exclude Transcripts of Investigative Testimony Including Division Exhibits 194-206
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Exclude the Zahar COO 2003-1 LLC, et al. v. Patriarch Partners LLC, et al. Case No. 12247-VCS (Del. Ch. Aug. 9 and 10, 2016) Trial Transcripts Marked Division Exhibits 207 and 208
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Name of Document:Respondents' Motion in Limine to Exclude Division Exhibits 71-73
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Name of Document:Respondents' Memorandum of Law in Support of Motion in Limine to Exclude Division Exhibits 71-73
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Name of Document:Respondents' Motion in Limine to Preclude the Introduction of Division Exhibits 118-123
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Name of Document:Respondents' Memorandum of Law in Support of Motion in Limine to Preclude Division Exhibits 118-123
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Name of Document:Respondents' Motion in Limine to Preclude the Division from Introducing into Evidence Exhibits or Portions of Exhibits Containing Unreliable Hearsay, Including but Not Limited to Exhibits 129, 140, 142, 174, 184 and 190.
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Name of Document:Memorandum of Law in Support of Resps' Motion in Limine to Preclude the Division from Introducing into Evidence Exhibits or Portions of Exhibits Containing Unreliable Hearsay, Including but Not Limited to Exhibits 129, 140, 142, 174, 184 and 190
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Name of Document:Respondents' Motion in Limine to Preclude the Admission of Any Portions of Investigative Testimony Transcripts without Introduction of Corresponding Portions of Audio Recordings, and to Exclude Transcripts for which Audio not Preserved and Produced
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Name of Document:Respondents' Memorandum of Law in Support of Motion in Limine to Preclude the Admission of Any Portions of Investigative Testimony Transcripts w/out Introduction of Corresponding Portions of Audio Recordings, and to Exclude Transcript for which Audio n...
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Name of Document:Declaration of Mary Kay Dunning in Support of Respondents' Motion in Limine to Preclude Admission of Any Portions of lnvestigative Testimony Transccript without Intro of Corresponding Portions of Audio Recordings, and to Exclude Transcript for which Au...
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Name of Document:Divison's Opposition to Respondents' Motion in Limine to Strike as Inadmissible, In Whole or In Part, Certain Lay Opinion Testimony
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Name of Document:Respondents' Reply in Further Support of their Motion to Compel the Production of Brady Materials
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Name of Document:Memorandum of Law in Further Support of Respondents' Motion in Limine to Exclude Transcripts of Investigative Testimony, Including Division Exhibits 194 thorugh 206
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Name of Document:Division's Opposition to Respondents' Expedited Petition to the Commission
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Name of Document:Office of Litigation and Administrative Practice's Opposition to Respondents' Requests for the Issuance of Subpoenas to Produce Documents
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Name of Document:Memorandum of Law in Further Support of Motion in Limine to Exclude The Zohair CDO 2003-1, LLC, et al., V. Patriarch Partners, LLC, et al., Case No. 12247-VCS (Del. Ch. Aug 9 and 10, 2016) Trial Transcript marked Division Exhibits 207 and 208
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Name of Document:Respondents' Reply Memorandum of Law in Further Support of Motion in Limine to Strike as Inadmissible, in Whole or in Part, Certain Lay Opinion Testimony
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Precl ude Div from Introducing into Evidence Exhibits or Portions of Exhibits Containing Unreliable Hearsay, Including (but not limited to) Exhibits 129, 140, 142, 174, 184, and 190
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Exclude Division Exhibits 71 Through 73
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Preclude Introduction of Division Exhibits 118-123
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Name of Document:Division's Opposition to Respondents' Motion in Limine to Preclude Admission of Portions of lnvestigative Testimony Transcript Without lntroduction of Corresponding Portions of Audio Recordings of the Testimony, and to Exclude Transcript for which no R...
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Name of Document:Respondents' Reply Memorandum in Further Support of Motion in Limine to Preclude the Introduction of Division Exhibits 118-123
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Name of Document:Respondents' Reply Memorandum in Further Support of Motion in Limine to Exclude Division Exhibits 71 through 73
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Name of Document:Respondents' Reply Memorandum in Further Support of Motion in Limine to Preclude the Division from Introducing into Evidence Exhibits or Portions of Exhibits Containing Unreliable Hearsay Including but not Limited to Exhibits 129, 140, 142, 174, 184, a...
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Name of Document:Respondents' Reply Memorandum in Further Support of Motion in Limine to Preclude Admission of any Portions of Investigative Testimony Transcripts w/out Introduction of Audio Recordings of the Testimony for which Audio Recordings not Preserved and Produced
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Name of Document:Letter of 10/3/16 from Respondents to Division counsel, with attachments
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Name of Document:Declaration of Dugan Bliss Regarding the Division of Enforcement's Search for Material Exculpatory Evidence
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Name of Document:Respondents' Motion to Compel Disclosure of Identities of the Authors of Division's Handwritten Notes
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Name of Document:Respondents' Memorandum of Law in Support of Motion to Compel Disclosure of Identities of the Authors of Division's Handwritten Notes
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Name of Document:Declaration of Monica Losemen in Support of Respondents' Motion to Compel Disclosure of Identities of the Authors of Division's Handwritten Notes
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Name of Document:Respondents' Motion to Compel MBIA to Produce Documents Responsive to the Subpoenas
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Name of Document:Respondents' Memorandum of Law in Support of Motion to Compel MBIA to Produce Documents Responsive to the Subpoenas
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Name of Document:Declaration of Lisa H. Rubin in Support of Respondents' Motion to Compel MBIA to Produce Documents Responsive to the Subpoenas
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Name of Document:Respondents' Motion to Preclude the Division's Witness, Matthew Mach, from Testifying and for Expedited Briefing
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Name of Document:Memorandum of Law in Support of Respondents' Motion to Preclude the Division's Witness, Matthew Mach, from Testifying and for Expedited Briefing
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Name of Document:Declaration of Mary Beth Maloney in Support of Resps' Motion to Preclude the Division's Witness, Matthew Mach, from Testifying and for Expedited Briefing
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Name of Document:Division's Motion to Partially Strike Respondents' Statements of Messrs. Lundelius, Vinella and Schwarcz
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Name of Document:Division's Motion to Strike Respondents' Further Amended Witness List and Requests for Hearing Subpoenas to Previously Undisclosed Witnesses
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Name of Document:Respondents' Motion to Compel the Produciton of Brady Material and Jencks Act Witness Statements
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Name of Document:Memorandum of Law in Support of Respondents' Motion to Compel the Production of Brady Material and Jencks Act Witness Statements
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Name of Document:Declaration of Monica Loseman in Support of Respondents' Motion to Compel the Produciton of Brady Material and Jencks Act Witness Statements
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Name of Document:Division's Response to Respondents' Motion to Compel Disclosure of the Identities of the Authors of the Division's Handwritten Notes
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Name of Document:Division's Response to Respondents' Motion to Compel MBIA to Produce Documents
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Name of Document:Respondents' Pre-Hearing Memorandum
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Name of Document:Division's Pre-Hearing Brief
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Name of Document:Respondents' Motion for Leave to File a Motion to Compel Barclays to Produce a Document Responsive to a Court-Ordered Subpoena and for Expedited Briefing
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Name of Document:Respondents' Motion to Compel Barclays to Produce a Document Responsive to a Court-Ordered Subpoena and for Expedited Briefing
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Name of Document:Memorandum of Law in Support of Respondents' Motion for Leave to File a Motion to Compel Barclays to Produce a Document Responsive to a Court-Ordered Subpoena and for Expedited Briefing
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Name of Document:Declaration of Susan Brune in Support of Respondents' Motion for Leave to File a Motion to Compel Barclays to Produce a Document Responsive to a Court-Ordered Subpoena and for Expedited Briefing
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Name of Document:Respondents' Motion in Limine to Partially Strike and Preclude
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Name of Document:Respondents' Motion to Stay Proceedings & Compel Division to Make Further Disclosures regarding Two Division Witnesses and for Expedited Briefing & Evidentiary Hearing
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Name of Document:Respondents' Motion for Confidential Treatment of Declaration of Susan Brune in Support of Respondents' Motion to Stay Proceedings & Compel Division to Make Further Disclosures Regarding Two Division Witnesses, for Expedited Briefing, and an Evidentiar...
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Name of Document:Memorandum of Law in Support of Respondents' Motion to Stay Proceedings and Compel Division to Make Further Disclosures regarding Two Division Witnesses and for Expedited Briefing and Evidentiary Hearing
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Name of Document:Respondents' Motion for Leave to File a Motion for a Protective Order
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Name of Document:Respondents' Motion for a Protective Order
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Name of Document:Memorandum of Law in Support of Respondents' Motion for a Protective Order
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Name of Document:Respondents' Motion for Leave to File a Motion to Compel the Office of Litigation and Administrative Practice to Produce Documents Responsive to Respondents' Subpoenas
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Name of Document:Respondents' Motion to Compel the Office of Litigation and Administrative Practice to Produce Documents Responsive to Respondents' Subpoenas
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Name of Document:Memorandum of Law in Support of Respondents' Motion to Compel the Office of Litigation and Administrative Practice to Produce Documents Responsive to Respondents' Subpoenas
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Name of Document:Declaration of Mary Beth Maloney in Support of Respondents' Motion to Compel the Office of Litigation and Administrative Practice to Produce Documents Responsive to Respondents' Subpoenas
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Name of Document:Division's Opposition to Respondents' Motion to Compel the Production of Brady Material and Jencks Act Witness Statements
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Name of Document:Division's Response to Respondents' Motion to Preclude Division's Witness, Matthew Mach, from Testifying
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Name of Document:Respondents' Reply Memorandum in Further Support of Respondents' Motion to Compel MBIA to Produce Documents Responsive to Respondents' Subpoena
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Name of Document:Division's Motion for Confidential Treatment of Opposition to Respondents' Motion to Stay Proceedings and Compel Division to Make Further Disclosures Regarding Two Division Witnesses
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Name of Document:Respondents' Opposition to Division's Motion to Partially Strike Respondents' Statements of Messrs. Lundelius, Vinella, and Schwarcz
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Name of Document:Declaration of Goutam U. Jois in Support of Respondents' Opposition to Division's Motion to Partially Strike Respondents' Statements of Messrs. Lundelius, Vinella, and Schwarcz, with Ex. A-D.
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Name of Document:Memorandum of Law in Support of Respondents' Motion in Limine to Partially Strike and Preclude
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Name of Document:Declaration of Gautam U. Jois in Support of Respondents' Motion in Limine to Partially Strike and Preclude, with Ex. A-B.
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Name of Document:Respondents' Memorandum of Law in Opposition to the Division's Motion to Strike Respondents' Further Amended Witness List and Requests for Hearing Subpoenas to Previously Undisclosed Witnesses, with Ex. 1-4.
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Name of Document:Letter dated 10/20/16 to ALJ Foelak from Counsel for Non-Party MBIA regarding service of Respondent's Motion to Compel MBIA to Produce Documents Responsive to Subpoenas
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Name of Document:Letter dated 10/21/16 from Resps' counsel to ALJ regarding Subpoenas to three Division employees (A Lee, N. Kelly, and B. Mitchell)
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Name of Document:Letter dated 10/30/16 from Division to ALJ and Respondents regarding witness Peter Berlant
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Name of Document:Non-Party MBIA Insurance Corp's Memorandum of Law in Opposition to Respondents' Motion to Compel MBIA to Produce Documents Responsive to Respondents' Subpoena
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Name of Document:Declaration of Jonathan M. Hoff in Support of Non-Party MBIA Insurance Corp's Opposition to Respondents' Motion to Compel MBIA to Produce Documents Responsive to Respondents' Subpoena
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Name of Document:Letter dated 10/31/16 from Respondents to ALJ regarding alleged Brady violation involving witness Peter Berlant.
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Name of Document:Respondents' Redacted Reply Memorandum of Law in Support of Motion to Compel MBIA to Produce Documents Responsive to Respondents' Subpoenas
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Name of Document:Division's Response to Respondents' Request for Issuance of a Subpoena Duces Tecum Directed at Anchin, Block & Anchin
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Name of Document:Letter dated 11/4/16 (with Exhibits A-B) from Respondents to Administrative Law Judge requesting Administrative Law Judge to order Division to produce documents listed on its Amended Privilege Log
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Name of Document:Declaration of Richard M. Humes
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Name of Document:Declaration of Brent S. Mitchell
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Name of Document:Non-Party Varde Partners, lnc.'s Memorandum in Support of its Motion to Quash
Subpoena served by Respondents
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Name of Document:Respondents' Memorandum of Law in Opposition to the Motion of Non-Party Varde
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Name of Document:Non-Party Varde Partners, Inc. 's Reply to Respondents' Opposition to Motion to
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Name of Document:Respondent's Post-Hearing Brief
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Name of Document:Division's Post-Hearing Brief
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Name of Document:Division's Proposed Findings of Fact and Conclusions of Law
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Name of Document:Respondent's Proposed Conclusions of Law
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Name of Document:Respondents' Post-Hearing Opposition Brief
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Name of Document:Division's Response in Opposition to Resps' Post-Hearing Brief
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Name of Document:Division's Request for Official notice of Complaint Filed by the Zahar Funds Against Respondents
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Name of Document:Respondents' Opposition to Division's Request for Official notice of Complaint filed by the Zahar Funds against Respondents or in the Alternative, Respondents' Motion to Strike Improperly Noticed Allegations
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Name of Document:Respondents' Motion to Stay Proceedings Pending Resolution of their Constitutionality, or, in the Alternative, for Permission to Seek a Stay from the Commission
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Name of Document:Respondents' Memorandum of Law in Support of Motion to Stay Proceedings Pending
Resolution of their Constitutionality, or, in the Alternative, for Permission to Seek a
Stay from the Commission
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Name of Document:Division's Opposition to Resps' Motion to Stay these Proceedings Pending Resolution
of their Constitutionality, or, in the Alternative, for Permission to Seek a Stay from
Commission
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Name of Document:Petition For Interlocutory Review of the Hearing Officer's Denial of a Stay of This Proceeding, And For a Stay; Respondents' Memorandum of Law in Support; and Declaration of Akiva Shapiro In Support; with Exs. 1-5
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Name of Document:Letter dated 10/24/16 from Division to Respondents enclosing revised rebuttal report of Ira
Wagner 8/31/2015.
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Name of Document:Letter dated 06/09/17 to ALJ from Division notifying the Court of supplemental authority in light of the US Supreme Court's decision in Kokesh v. SEC, No. 16-529
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Name of Document:Letter dated 6/27 /17 from Resps to Commissioners with supplemental authority for stay of proceedings, Ex. 1-3.
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Name of Document:Letter Dated 7 /18/16 from Respondents to ALJ in Response to ALJ Order Rejecting Parties’ Joint Request for December 2016 Trial Date
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Name of Document:Letter Dated 10/27 /16 from Respondents to ALJ Stating Their Position in Requiring Varde Partners to Produce Documents
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Name of Document:Letter Dated 10/28/16 from Respondents to ALJ Notifying Her that MBIA has Failed to Produce Documents Responsive to the 5/27/15 Subpoena
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Name of Document:Respondents' Unopposed Motion to Correct Record Index
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Name of Document:Initial Decision
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Name of Document:Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Sections 203(e), 203(f) and 203(k) of the Investment Advisers Act of 1940, and Section 9(b) of the Investment Company Act of 1940, and Notice of Hearing
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Name of Document:Notice That Initial Decision Has Become Final
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Name of Document:Order Scheduling Hearing and Designating Presiding Judge
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Name of Document:Scheduling Order
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Name of Document:Prehearing Order
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Name of Document:Order
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Name of Document:Notice
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Name of Document:Protective Order
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Name of Document:Order
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Name of Document:Order Denying Petition for Interlocutory Review and Petition to Apply the Commission's Amended Rules of Practice
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Name of Document:Order Denying Motion to Stay Administrative Proceeding
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