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NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

IN THE MATTER OF THE ARBITRATION BETWEEN

Jane Dough,
CLAIMANT,

v.

Joe Broker and XYZ Brokerage, Inc.,

RESPONDENTS.

Case No.

STATEMENT OF CLAIM

Claimant states her claim against the Respondents, jointly and severally, as follows:

INTRODUCTION

ISSUES TO BE DETERMINED

a) Whether RESPONDENTS, based upon their knowledge of the CLAIMANT's objectives, recommended transactions and executed transactions for the CLAIMANT in unsuitable investments, thereby breaching their contract with the CLAIMANT by violating the rules and regulations of the various Exchanges, the customs and usages of the marketplace and/or Texas law and/or Federal law;

b) Whether RESPONDENTS intentionally or negligently failed to supervise the CLAIMANT's account, violating the rules and regulations of the NASD and/or Texas laws, rules or regulations;

c) Whether RESPONDENTS used the CLAIMANT's funds in an improper manner;

d) Whether RESPONDENTS breached their fiduciary duties owed to the CLAIMANT;

e) Whether RESPONDENTS perpetrated fraud upon the CLAIMANT under the provisions of Texas common law and/or the provisions of the Texas corporate securities laws, rules and regulations, and/or Federal laws, rules and regulations, including, without limitation, Rule 10b-5;

f) Whether RESPONDENTS' actions were in any way negligent which negligence caused the losses sustained by the CLAIMANT;

g) Whether RESPONDENTS induced the CLAIMANT by fraud to justifiably rely upon RESPONDENTS all to the CLAIMANT's detriment;

h) Whether RESPONDENTS in any other respect violated the rules and/or regulations and/or the customs and usages of the various exchanges to which they belong, which conduct caused damage to the CLAIMANT.

THE PARTIES

1. CLAIMANT, Jane Dough ("CLAIMANT") is a 68 year old woman who lives in Fort Worth, Texas.

2. RESPONDENT, Joe Broker ("Broker"), is/was employed by and under the control of RESPONDENT XYZ Brokerage, INC., as a registered representative.

3. RESPONDENT, XYZ Brokerage, INC., ("XYZ") is qualified and licensed to do business in the State of Texas and is a registered securities broker-dealer.

FACTUAL BACKGROUND ESTABLISHING THE CLAIM

4. Jane Dough is a 68 year old woman whose investment experience is limited to the purchase, over thirty years ago, of Dow chemical stock.