global clearing services to other firms and institutions, which include the services described in moredetail below.
Defendant, Lockwood Advisors, Inc. (“Lockwood”) is a corpora
tion doing business inthe state of Pennsylvania. Lockwood may be served with service of process by serving the Secretaryof State by certified mail, return receipt requested, pursuant to Rules 106 and 108a of the TexasRules of Civil Procedure. Lockwood may be served by serving its President, Leonard A. Reinhart,One Wall Street, 32
, New York, New York 10286.
II. JURISDICTION & VENUE
This Court has original jurisdiction over this proceeding pursuant to 28 U.S.C.§1332(d)(2)(A) because this is a class action in which the amount in controversy exceeds$5,000,000.00 and is a class in which some members of the Plaintiff class are citizens and residentsof states different from Defendants.
III. FACTUAL BACKGROUND
A. The Stanford Financial Empire7.
From the mid-
1980s through February 2009, R. Allen Stanford (“Stanford”), a former
gym owner from Mexia Texas, built a financial service empire that at its height boasted 30,000customers in 130 countries managing billions of dollars in investment funds. The empire wascomprised of over 140 companies from across the globe, all of which were ultimately owned byStanford himself, that
operated under the brand name “Stanford Financial” with its worldwide
headquarters located in Houston, Texas. The conglomeration of Stanford companies (hereinafterc
ollectively referred to as “Stanford Financial”)
included the main operating companies: theHouston, Texas-based registered broker/dealer and investment adviser company Stanford GroupCompany ("SGC"); Antiguan based offshore bank Stanford International Bank Ltd.