Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
2Activity
0 of .
Results for:
No results containing your search query
P. 1
SNB v Geithner Complaint1

SNB v Geithner Complaint1

Ratings: (0)|Views: 1,028 |Likes:
Published by Foreclosure Fraud
4closureFraud.org
4closureFraud.org

More info:

Categories:Types, Research, Law
Published by: Foreclosure Fraud on Jun 23, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

12/21/2012

pdf

text

original

 
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIASTME NATIONAL BANK OF BIG SPRING
901 South Main StreetBig Spring, TX 79720;
THE 60 PLUS ASSOCIATION, INC
515 King Street
Suite 315
Alexandria, VA 22314;
and
THE COMPETITIVE ENTERPRISE INSTITUTE
1899 L StreetFloor 12
Washington, DC 20036,
Plaintiffs,
V.
TIMOTHY GEITHNER, in his official capacity as
United States Secretary of the Treasury and
ex officio
Chairman of the Financial Stability Oversight Council
1500 Pennsylvania Avenue, NWWashington, DC 20220;
U.S. DEPARTMENT OF THE TREASURY;
RICHARD CORDRAY, in his official capacity asDirector of the Consumer Financial Protection Bureau, inhis official capacity as
ex officio
Director of the FederalDeposit Insurance Corporation, and in his official
capacity as
ex officio
member of the Financial Stability
Oversight Council
1700 G Street NW
Washington, DC 20552;THE CONSUMER FINANCIAL PRO1 ECTION
BUREAU;
BENJAMIN BERNANKE, in his official capacity as
Case No.
 
Chairman of the Board of Governors of the FederalReserve System, and in his official capacity as ex
officio
Member of the Financial Stability Oversight Council
20
th
Street and Constitution Avenue NW
Washington, DC 20551;
MARTIN GRUENBERG, in his official capacity asVice Chairman and Acting Chah
an of the Board of
Directors of the Federal Deposit Insurance Corporation,and in his official capacity as
ex officio
Member of the
Financial Stability Oversight Council
550 17th Street NWWashington, DC 20429;
THOMAS CURRY, in his official capacity as U.S.Comptroller of the Currency, and
ex officio
member ofthe Financial Stability Oversight Council
Comptroller of the CurrencyWashington, DC 20219;
MARY SCHAPIRO, in her official capacity as Chairmanof the U.S. Securities and Exchange Commission and
exofficio
member of the Financial Stability Oversight
Council100 F Street NE
Washington, DC 20549;
GARY GENSLER, in his official capacity as Chairmanof the U.S. Commodity Futures Trading Commission and
ex officio
member of the Financial Stability Oversight
Council
Three Lafayette Center
1155 21
g
Street
Washington, DC 20581;
DEBBIE MATZ, in her official capacity as Chairman of
the National Credit Union Administration Board and
ex
officio
Member of the Financial Stability Oversight
Council1775 Duke Street
Alexandria, VA 22314;S. ROY WOODALL, in his official capacity as Memberof the Financial Stability Oversight Council;
and
2
 
THE FINANCIAL STABILITY OVERSIGHT
COUNCIL1500 Pennsylvania Avenue, NWWashington, DC 20220,
Defendants.
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
The above-captioned plaintiffs, by and through their undersigned attorneys, allege as
follows:
INTRODUCTION
This action challenges the unconstitutional formation and operation of theConsumer Financial Protection Bureau ("CFPB"), an agency created by Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203 (July 21, 2010)
("Dodd-Frank Act").
2.This action challenges the unconstitutional appointment of CFPB DirectorRichard Cordray, appointed to office neither with the Senate's advice and consent, nor during a
Senate recess.
3.
Finally, this action challenges the unconstitutional creation and operation of the
Financial Stability Oversight Council ("FSOC"), an inter-agency "council" created by Title I of
the Dodd-Frank Act.
4.
Titles I and X of the Dodd-Frank Act comprise unprecedented violations of "thebasic concept of separation of powers and the checks and balances that flow from the scheme ofa tripartite government,"
United States v. Nixon,
418 U.S. 683, 704 (1974), in several ways:
3

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->