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Oberhofer v Macco Complaint

Oberhofer v Macco Complaint

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Published by Cory Liebmann

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Published by: Cory Liebmann on Sep 27, 2012
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10/21/2013

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(
( 
STATE OF WISCONSINCIRCUIT COURTMILWAUKEE COUNTY SARAH M. OBERHOFER610 EAST DEAN ROAD Case No.: 09-CV-014613MILWAUKEE, WI 53217Classification: 30106Plaintiff,vs. 30303MACCO FINANCIAL GROUP, INC.1138 MAIN STREETGREEN BAY, WI 54301;and
-
JOHNMACCO
1874 OLD VALLEY ROAD
FILEO
C\VIL
OlV'SIO!1,...
,
DE PERE, WI 54115-3370
26
.lK
",'
l
zmo
26
\
Defendants.
-JOHNBARRE1T
Clerk
of
Cifcuit
COUrt....J
AMENDED COMPLAINT 
Plaintiff, Sarah
M.
Oberhofer, by her attorneys, Whyte Hirschboeck Dudek S.C.,complains as follows:
THE
PARTIES
1.
Plaintiff, Sarah M. Oberhofer, is an adult individual who resides inMilwaukee County, Wisconsin, at 610 East Dean Road, Milwaukee, Wisconsin 53217.2. Defendant Maceo Financial Group, Inc. ("MFG") is a Wisconsincorporation with its principal place
of
business located at 1138 Main Street, Green Bay,Wisconsin 54301. James J. Maceo, Sr., 1138 Main Street, Green Bay, Wisconsin 54301,is
MFG's
registered agent for service
of
process. MFG engages in substantial and notisolated business in Milwaukee County, Wisconsin.
WH017089663.1
 
.
(
3.
Defendant John Macco
is
an adult individual who resides in BrownCounty, Wisconsin, at 1874 Old Valley Road, De Pere, Wisconsin 54115-3370.Defendant Macco engages in substantial and not isolated business activity in MilwaukeeCounty, Wisconsin.
JURISDICTION
AND VENUE
4.
Defendant MFG is subject to this Court's jurisdiction pursuant to Wis.Stat.
§
801.05(1)(c) and (1)(d).
5.
Defendant Macco
is
subject to this Court's jurisdiction pursuant to Wis.Stat.
§
801.05(1)(a), (1)(b) and (l)(d).
6.
Venue is proper in Milwaukee County Circuit Court pursuant to Wis. Stat.
§
801.50(2)(a) and (c) in that the claim arose in Milwaukee County and Defendant doessubstantial business in Milwaukee County.
GENERAL
ALLEGATIONS
7.
Defendant MFG is a wealth management company offering financial andinvestment guidance to individuals and businesses
.
8.
Defendant John Macco
is
owner, president and manager
of
DefendantMFG.
9.
Plaintiff is a licensed financial advisor specializing in financial planning.asset management, and investments for individuals and businesses.
10.In
2008, Plaintiff was employed by RBC Wealth Management as afinancial advisor.
11.
While at RBC Wealth Management, Plaintiff enjoyed businessrelationships with her clients that were established through years
of
hard work andcommitment to her clients' financial wellbeing.
2
WHD/7089663 I
 
12.
In order to entice Plaintiff to end her employment relationship with RBCWealth Management, Defendant John Macco, as president and owner
of
MFG, offeredPlaintiff the following terms
of
employment with his company:,a. a 5% equity stake in MFG;
b.
responsibility for a book
of
business containing $25 million in assets;
c.
a quarterly $5,000 bonus; and
d.
a salary
of
$60,000 per year.
13
. Additionally, in connection with Plaintiff s transfer
of
client accountsfrom RBC Wealth Management to MFG, Defendant Macco further committed to ensurepayment
of
contract buyout, IRA and account closing fees.
14.
In reliance on Defendant Macco's promises, Plaintiff terminated heremployment with RBC Wealth Management and began working at MFG on or aboutDecember
8,
2008.
15.
Less than two months later, Plaintiffs employment with MFG wasterminated without cause on February 3, 2009.
16.
As a result, Plaintiff lost clients due to the sudden change
of
events.
COUNT ONE: BREACH OF CONTRACT -MFG
17.
Plaintiff reincorporates by reference the allegations
of
paragraphs 1through
16
as
if
set forth fully herein.
18.
At all relevant times, the promises made by Defendant Macco were fullyenforceable contractual obligations, as the relationship entered into between Plaintiff andDefendant MFG was marked by offer, acceptance and consideration. The engagementconstituted an enforceable contract between the parties under which MFG is obligated
to
perfonn.
3
WHD17089663
I

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