Where facts are alleged that include a misrepresentation or omission of material fact in connection with the purchase or sale of a security,
No. 11 Civ. 5643 (S.D. N.Y., 4/15/14). FRCP (Rule 9b “Particularity,” Rule 12(b)(6) “Claim for Relief”) * PSLRA (Pleading Requirements) * 1934 Act (§10 “Rule 10b-5”) * Misrepresentation/Omission * State Statutes Interpreted (California Corporations Code §25506) * Fiduciary Standards (Broker) * Transaction Causation/Reliance (Justifiable) * Culpability Standards (Scienter) * Self-Directed Accounts * Timeliness Issues (Statutes of Limitations) * Derivative/Vicarious Liability (Conspiracy).