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    John Hancock Life Insurance Company (U.S.A.) et al v. JP Morgan Chase & Co / 850 Securities/Commodities

    • Date
      April 23, 2012
    • City/County
      New York City
    • Type of Case
      850 Securities/Commodities
    • Case Details
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    Title

    John Hancock Life Insurance Company (U.S.A.) et al v. JP Morgan Chase & Co / 850 Securities/Commodities

    Date
    April 23, 2012
    State or Country
    New York
    County/City:
    New York City
    The Court the Case was filed in

    USDC of the Sourthern District of New York (Foley Square)

    Type of Case
    850 Securities/Commodities
    Case Number

    1;12-cv-03184- RJS Case in other court: Supreme Court- New York County, 650195-12 Cause: 28:1441nr Notice of Removal

    Judges

    Judge Richard J. Sullivan

    Plaintiff

    John Hancock Life Insurance Company (U.S.A.)
    John Hancock Life Insurance Company
    (U.S.A.) Separate Account 6A

    John Hancock Life Insurance Company
    (U.S.A.) Separate Account 131

    John Hancock Funds II
    John Hancock Variable Insurance Trust
    John Hancock Sovereign Bond Fund
    John Hancock Bond Trust
    John Hancock Strategic Series
    John Hancock Income Securities Trust

    Defendant

    JP Morgan Chase & Co.
    JPMorgan Chase Bank N.A
    J.P. Morgan Mortgage Acquisitions Corp.

    J.P. Morgan Securities, LLC
    formerly known as
    J.P. Morgan Securities Inc

    J.P. Morgan Acceptance Corporation I
    Chase Mortgage Finance Corporation
    Chase Home Finance LLC

    EMC Mortgage LLC
    formerly known as
    EMC Mortgage Corporation

    Bear Stearns and Co., Inc.
    Bear Stearns Asset Backed Securities I LLC
    Structured Asset Mortgage Investments II Inc.
    WAMU Asset Acceptance Corp.,
    Washington Mutual Mortgage Securities Corp.
    WAMU Capital Corp.,
    Long Beach Securities Corp.
    Banc of America Securities LLC
    CSE Mortgage, LLC
    Deutsche Bank Securities Inc.
    John Barren
    David Beck
    Sara Bonesteel
    Domenic A. Borriello
    Richard Careaga
    Jerome A. Cipponeri
    Christine E. Cole
    Craig S. Davis
    Art Den-Heyer
    Marangal I. Domingo
    David M. Duzyk
    Katherine Garniewski
    Troy A. Gotschall
    Patricia A. Jehle
    Juliana C. Johnson
    Rolland Jurgens
    Joseph T. Jurkowski, Jr.
    Michael D. Katz
    William A. King
    Marc R. Kittner
    Michael J. Kula
    Thomas G. Lehmann
    Stephen Lobo
    Richard D. Lodge
    Kim Lutthans
    Marc K. Malone
    Thomas F. Marano
    Jeffrey Mayer
    Edwin F. McMichael
    Samuel L. Molinaro, Jr.
    Michael B. Nierenberg
    Diane Novak
    Michael L. Parker
    Matthew E. Perkins
    Louis Schioppo, Jr.
    Jeffrey A. Sorense
    Jeffrey L. Verschleiser
    Thomas L. Wind
    David H. Zielke

    Greenwich Capital Markets, Inc.
    also known as
    RBS Greenwich Capital

    Merrill Lynch & Co.

    UBS Securities LLC
    formerly known as
    UBS Warbug LLC

    Brian Bernard
    Megan M. Davidson
    Eric Ferren
    Stephen Fortunato
    Donald Wilhem
    Merrill Lynch, Pierce, Fenner & Smith Inc.
    JP Morgan Chase Bank, N.A

    ThirdParty Defendant
    Federal Deposit Insurance Corporation

    Plaintiff Attorney

    Plaintiff
    John Hancock Life Insurance Company
    (U.S.A.)
    represented by Geoffrey Coyle Jarvis
    Grant & Eisenhofer P.A. (NY)
    485 Lexington Avenue
    29th Floor
    New York, NY 10017
    (302-622-7040
    Fax: (302)-622-7100
    Email: gjarvis@gelaw.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    Grant & Eisenhofer P.A. (NY)
    485 Lexington Avenue
    29th Floor
    New York, NY 10017
    (646) 722-8500
    Fax: (646) 722-8501
    Email: delman@gelaw.com
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    Grant & Eisenhofer P.A. (NY)
    485 Lexington Avenue
    29th Floor
    New York, NY 10017
    (646)-722-8532
    Fax: (646)-722-8501
    Email: rgerson@gelaw.com
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Life Insurance Company
    (U.S.A.) Separate Account 6A
    represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Life Insurance Company
    (U.S.A.) Separate Account 131
    represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Funds II represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Variable Insurance Trust represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Sovereign Bond Fund represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Bond Trust represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Strategic Series represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    Plaintiff
    John Hancock Income Securities Trust represented by Geoffrey Coyle Jarvis
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Deborah A. Elman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Daniel Gerson
    (See above for address)
    ATTORNEY TO BE NOTICED

    ThirdParty Plaintiff
    JP Morgan Chase Bank, N.A. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant Attorney

    Defendant
    JP Morgan Chase & Co. represented by Penny Shane , II
    Sullivan and Cromwell, LLP(NYC)
    125 Broad Street
    New York, NY 10004
    212-558-4837
    Email: shanep@sullcrom.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    Sullivan & Cromwell, LLP(NYC)
    125 Broad Street
    New York, NY 10004
    (212) 558-7353
    Fax: (212) 291-9327
    Email: cambriaa@sullcrom.com
    TERMINATED: 05/29/2013
    David Allen Castleman
    Sullivan & Cromwell, LLP(NYC)
    125 Broad Street
    New York, NY 10004
    (212) 558-4191
    Fax: (212) 558-3588
    Email: castlemand@sullcrom.com
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    Sullivan & Cromwell LLP (Los Angeles)
    1888 Century Park East, Suite 2100
    Los Angeles, CA 90067
    (310)-712-6640
    Fax: (310)-712-8800
    Email: sacksr@sullcrom.com
    ATTORNEY TO BE NOTICED

    Defendant
    JPMorgan Chase Bank N.A. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    J.P. Morgan Mortgage Acquisitions Corp. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    J.P. Morgan Securities, LLC
    formerly known as
    J.P. Morgan Securities Inc.
    represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    J.P. Morgan Acceptance Corporation I represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Chase Mortgage Finance Corporation represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Chase Home Finance LLC represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    EMC Mortgage LLC
    formerly known as
    EMC Mortgage Corporation
    represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Bear Stearns and Co., Inc. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Bear Stearns Asset Backed Securities I
    LLC
    represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Structured Asset Mortgage Investments II
    Inc.
    represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    WAMU Asset Acceptance Corp., represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Washington Mutual Mortgage Securities
    Corp.
    represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    WAMU Capital Corp., represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Long Beach Securities Corp. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Banc of America Securities LLC represented by Meredith Eve Kotler
    Cleary Gottlieb Steen & Hamilton,
    LLP(NYC)
    One Liberty Plaza
    New York, NY 10006
    (212) 225-2000
    Fax: (212) 225-3999
    Email: mkotler@cgsh.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED

    Defendant
    CSE Mortgage, LLC represented by John E. Zummo
    Howard and Howard Attorneys PLLC
    200 S. Michigan Ave. Ste, 1100
    Chicago, IL 60604
    (312) 372-3425
    Fax: (312) 939-5617
    Email: jzummo@howardandhoward.com
    PRO HAC VICE
    ATTORNEY TO BE NOTICED
    Michael John Tiffany
    Leader & Berkon LLP
    630 Third Avenue, 17th Floor
    New York, NY 10017
    212-486-2400
    Email: mtiffany@leaderberkon.com
    ATTORNEY TO BE NOTICED
    Michelle Dianne Velasquez
    Vedder Price P.C.
    1633 Broadway
    New York, NY 10019
    (212) 407-7792
    Fax: (212) 407-7799
    Email: mvelasquez@vedderprice.com
    TERMINATED: 05/10/2013

    Defendant
    Deutsche Bank Securities Inc. represented by Robert F. Serio
    Gibson, Dunn & Crutcher, LLP (NY)
    200 Park Avenue, 48th Floor
    New York, NY 10166
    212-351-3917
    Fax: 212-351-5246
    Email: rserio@gibsondunn.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Aric Hugo Wu
    Gibson, Dunn & Crutcher, LLP (NY)
    200 Park Avenue, 48th Floor
    New York, NY 10166
    (212) 351-3820
    Fax: (212) 351-5344
    Email: awu@gibsondunn.com
    ATTORNEY TO BE NOTICED
    Jonathan Brian Austin
    Gibson, Dunn & Crutcher, LLP (NY)
    200 Park Avenue, 48th Floor
    New York, NY 10166
    (212) 351-2638
    Fax: (212) 351-6238
    Email: jbaustin@gibsondunn.com
    ATTORNEY TO BE NOTICED
    Lawrence Jay Zweifach
    Gibson, Dunn & Crutcher, LLP (NY)
    200 Park Avenue
    New York, NY 10166
    (212) 351-4000
    Fax: (212) 351-4035
    Email: lzweifach@gibsondunn.com
    ATTORNEY TO BE NOTICED

    Defendant
    John Barren represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    David Beck represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Sara Bonesteel represented by Joel Charles Haims
    Morrison & Foerster LLP (NYC)
    250 West 55th Street
    New York, NY 10019
    212-468-8000
    Fax: 212-468-7900
    Email: jhaims@mofo.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Andreea R Vasiliu
    Morrison & Foerster LLP (NYC)
    250 West 55th Street
    New York, NY 10019
    (212)-468-8000
    Fax: (212)-468-7900
    Email: avasiliu@mofo.com
    ATTORNEY TO BE NOTICED
    James Joseph Beha , II
    Morrison & Foerster LLP (NYC)
    250 West 55th Street
    New York, NY 10019
    (212) 468-8000
    Fax: (212)-469-7900
    Email: jbeha@mofo.com
    ATTORNEY TO BE NOTICED
    Lashann Moutique DeArcy
    Morrison & Foerster LLP (NYC)
    250 West 55th Street
    New York, NY 10019
    (212)-468-8000
    Fax: (212)-468-7900
    Email: ldearcy@mofo.com
    ATTORNEY TO BE NOTICED

    Defendant
    Domenic A. Borriello represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Richard Careaga represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Jerome A. Cipponeri represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Christine E. Cole represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Craig S. Davis represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Art Den-Heyer represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Marangal I. Domingo represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    David M. Duzyk represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Katherine Garniewski represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Troy A. Gotschall represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Patricia A. Jehle represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Juliana C. Johnson represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Rolland Jurgens represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Joseph T. Jurkowski, Jr. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Michael D. Katz represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    William A. King represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Marc R. Kittner represented by Joel Charles Haims
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Andreea R Vasiliu
    (See above for address)
    ATTORNEY TO BE NOTICED
    James Joseph Beha , II
    (See above for address)
    ATTORNEY TO BE NOTICED
    Lashann Moutique DeArcy
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Michael J. Kula represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Thomas G. Lehmann represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Stephen Lobo represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Richard D. Lodge represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Kim Lutthans represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Marc K. Malone represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Thomas F. Marano represented by Joel Charles Haims
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Andreea R Vasiliu
    (See above for address)
    ATTORNEY TO BE NOTICED
    James Joseph Beha , II
    (See above for address)
    ATTORNEY TO BE NOTICED
    Lashann Moutique DeArcy
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Jeffrey Mayer represented by Richard Aframe Edlin
    Greenberg Traurig, LLP
    200 Park Avenue
    New York, NY 10166
    212-801-9200
    Fax: 212-805-5528
    Email: edlinr@gtlaw.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Candace Marie Camarata
    Greenberg Traurig, LLP (NYC)
    200 Park Avenue
    New York, NY 10166
    (212)-801-2141
    Fax: (212)-309-9541
    Email: camaratac@gtlaw.com
    TERMINATED: 11/12/2013
    James Michael Barton
    Greenberg Traurig, LLP (NY)
    Met Life Building, 200 Park Avenue
    New York, NY 10166
    (212)-801-6954
    Fax: (212)-801-6400
    Email: bartonja@gtlaw.com
    ATTORNEY TO BE NOTICED
    Ronald Daniel Lefton
    Greenberg Traurig, LLP (NYC)
    200 Park Avenue
    New York, NY 10166
    2128013159
    Fax: 2122246116
    Email: leftonr@gtlaw.com
    ATTORNEY TO BE NOTICED

    Defendant
    Edwin F. McMichael represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Samuel L. Molinaro, Jr. represented by Pamela Rogers Chepiga
    Allen & Overy
    1221 Avenue of Americas
    New York, NY 10020
    (212) 610-6300
    Fax: (212) 610-6399
    Email: pamela.chepiga@allenovery.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Josephine Alice Cheatham
    Allen & Overy LLP
    1221 Avenue of The Americas
    New York, NY 10020
    (212)-756-1102
    Fax: (212)-610-6399
    Email: allie.cheatham@allenovery.com
    ATTORNEY TO BE NOTICED

    Defendant
    Michael B. Nierenberg represented by Joel Charles Haims
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Andreea R Vasiliu
    (See above for address)
    ATTORNEY TO BE NOTICED
    James Joseph Beha , II
    (See above for address)
    ATTORNEY TO BE NOTICED
    Lashann Moutique DeArcy
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Diane Novak represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Michael L. Parker represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Matthew E. Perkins represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Louis Schioppo, Jr. represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Jeffrey A. Sorense represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Jeffrey L. Verschleiser represented by Dani R. James
    Kramer Levin Naftalis & Frankel, LLP
    1177 Avenue of the Americas
    New York, NY 10036
    (212)-715-9363
    Fax: (212)-715-8000
    Email: djames@kramerlevin.com
    ATTORNEY TO BE NOTICED
    Jade Anne Burns
    Kramer Levin Naftalis & Frankel, LLP
    1177 Avenue of the Americas
    New York, NY 10036
    (212)-715-9209
    Fax: (212)-715-8084
    Email: jburns@kramerlevin.com
    ATTORNEY TO BE NOTICED

    Defendant
    Thomas L. Wind represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    David H. Zielke represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Greenwich Capital Markets, Inc.
    also known as
    RBS Greenwich Capital
    represented by Robert F. Serio
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Aric Hugo Wu
    (See above for address)
    ATTORNEY TO BE NOTICED
    Jonathan Brian Austin
    (See above for address)
    ATTORNEY TO BE NOTICED
    Lawrence Jay Zweifach
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Merrill Lynch & Co

    Defendant
    UBS Securities LLC
    formerly known as
    UBS Warbug LLC
    represented by Lawrence Jay Zweifach
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Aric Hugo Wu
    (See above for address)
    ATTORNEY TO BE NOTICED
    Jonathan Brian Austin
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert F. Serio
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Brian Bernard represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Megan M. Davidson represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Eric Ferren represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Stephen Fortunato represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Donald Wilhem represented by Penny Shane , II
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Allison Joan Cambria
    (See above for address)
    TERMINATED: 05/29/2013
    David Allen Castleman
    (See above for address)
    ATTORNEY TO BE NOTICED
    Robert Andrew Sacks
    (See above for address)
    ATTORNEY TO BE NOTICED

    Defendant
    Merrill Lynch, Pierce, Fenner & Smith
    Inc.
    represented by Meredith Eve Kotler
    (See above for address)
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED

    ThirdParty Defendant
    Federal Deposit Insurance Corporation represented by Scott Hu Christensen
    Hughes Hubbard & Reed LLP (DC)
    1775 I Street, N.W., Suite 600
    Washington, DC 20006
    (202)-721-4644
    Fax: (202)-721-4646
    Email:
    scott.christensen@hugheshubbard.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    William Robert Stein
    Hughes Hubbard & Reed LLP (NY)
    One Battery Park Plaza
    New York, NY 10004
    (202)721-4650
    Fax: 2027214646
    Email: stein@hugheshubbard.com
    LEAD ATTORNEY
    ATTORNEY TO BE NOTICED
    Andrew J. Dober
    Federal Deposit Insurance Corporation
    3501 Fairfax Drive
    Arlington, VA 22226
    703-562-2545
    Fax: 703-562-2481
    PRO HAC VICE
    ATTORNEY TO BE NOTICED
    Thomas M. Clark
    Federal Deposit Insurance Corporation
    New York Legal Services Office
    350 Fifth Avenue, Suite 1200
    New York, NY 10118
    (917)-320-2855
    Fax: (917)-320-2917
    Email: thclark@fdic.gov
    ATTORNEY TO BE NOTICED

    Judges Comments

    Did the Judge harm many of the American public by not having a criminal investigation? The Judiciary is self policing and must turn in crimes that are brought to there attention.

    Comments

    INTRODUCTION

    Plaintiffs John Hancock Life Insurance Company (U.S.A.), John Hancock Life Insurance
    Company (U.S.A.) Separate Account 6a; John Hancock Life Insurance Company (U.S.A.)
    Separate Account 131; John Hancock Funds II; John Hancock Variable Insurance Trust; John
    Hancock Sovereign Bond Fund; John Hancock Bond Trust; John Hancock Strategic Series; and
    John Hancock Income Securities Trust (“Plaintiffs”), by their attorneys, Grant & Eisenhofer
    P.A., bring this action pursuant to Sections 11, 12(a)(2) and 15 of the Securities Act of 1933 (the
    “Securities Act”), 15 U.S.C. §§77k, 771(a)(2), and 77o; and the common law. This action is
    brought against Defendants JPMorgan Chase & Co. (“JPMorgan Chase”); J.P. Morgan Chase
    Bank, N.A. (“JPMorgan Bank”); J.P. Morgan Mortgage Acquisition Corp. (“JPMM
    Acquisition”); J.P. Morgan Securities, LLC (“JPMS”); J.P. Morgan Acceptance Corporation I
    (“JPM Acceptance”); Chase Home Finance LLC (“Chase Home Finance”); Chase Mortgage
    Finance Corporation (“Chase Mortgage Finance”)” EMC Mortgage LLC (“EMC”); Bear Stearns
    & Co. Inc (“Bear Stearns”); Bear Stearns Asset Backed Securities I LLC (“BSABS”); Structured
    Asset Mortgage Investments II Inc. (“SAMI”); WaMu Asset Acceptance Corp. (“WAAC”);
    Washington Mutual Mortgage Securities Corp. (“WMMSC”); WaMu Capital Corp. (“WaMu
    Capital”); Long Beach Securities Corp. (“LBSC”); Banc of America Securities LLC (“Banc of
    America”); CSE Mortgage, LLC (“CSE Mortgage”); Deutsche Bank Securities Inc. (“Deutsche
    Bank”); Greenwich Capital Markets, Inc. a.k.a. RBS Greenwich Capital (“GCM”); Merrill
    Lynch & Co. “Merrill”); UBS Securities LLC f.k.a. UBS Warburg LLC (“UBS”); John Barren;
    David Beck; Sara Bonesteel; Domenic A. Borriello; Richard Careaga; Jerome A. Cipponeri;
    Christine E. Cole; Craig S. Davis; Art Den-Heyer; Marangal I. Domingo; David M. Duzyk;
    Katherine Garniewski; Troy A. Gotschall; Patricia A. Jehle; Juliana C. Johnson; Rolland
    Jurgens; Joseph T. Jurkowski, Jr.; Michael D. Katz; William A. King; Marc R. Kittner; Michael J. Kula; Thomas G. Lehmann; Stephen Lobo; Richard D. Lodge; Kim Lutthans; Marc K.
    Malone; Thomas F. Marano; Jeffrey Mayer; Edwin F. McMichael; Samuel L. Molinaro, Jr.;
    Michael B. Nierenberg; Diane Novak; Michael L. Parker; Matthew E. Perkins; Louis Schioppo,
    Jr.; Jeffrey A. Sorensen; Jeffrey L. Verschleiser; Thomas L. Wind; David H. Zielke; Brian
    Bernard; Megan M. Davidson; Eric Ferren; Stephen Fortunato; and Donald Wilhelm
    (collectively, the “Defendants”).
    Plaintiffs make the allegations in this Complaint based upon personal knowledge as to
    matters concerning Plaintiffs and their own acts, and upon information and belief as to all other
    matters. This information is derived from the investigation by Plaintiffs’ counsel, which has
    included a review and analysis of annual reports and publicly filed documents, reports of
    governmental investigations by the United States Securities and Exchange Commission (the
    “SEC”), the Financial Crisis Inquiry Commission (the “FCIC”), the United States Department of
    Justice (the “DOJ”), the United States Senate Permanent Subcommittee on Investigations (the
    “PSI”), and numerous investigations by other federal and state governmental units, as well as
    press releases, news articles, analysts’ statements, conference call transcripts and presentations,
    and transcripts from speeches and remarks given by Defendants. In addition, Plaintiffs’ counsel
    conferred with counsel for other Plaintiffs who have filed other complaints against these
    Defendants based on the same or similar activities. Based on the foregoing, Plaintiffs believe
    that substantial additional evidentiary support exists for the allegations herein, which Plaintiffs
    will find after a reasonable opportunity for discovery.

    SUMMARY OF ALLEGATIONS

    1. This action arises out of Plaintiffs’ purchases of certain residential mortgagebacked securities (“RMBS”), as evidenced in the form of “Certificates”, in reliance on the false
    and misleading statements that were made by Defendants. Based on these material misrepresentations and omissions, Plaintiffs purchased securities that were far riskier than had
    been represented, backed by mortgage loans worth significantly less than had been represented,
    and that had been made to borrowers who were much less creditworthy than had been
    represented.
    2. The securities purchased by Plaintiffs were collateralized against mortgages
    originated and/or acquired by Defendants JPMorgan Bank, EMC, and non-defendants such as
    Bear Stearns Residential Mortgage Corporation (“BSRMC”); Performance Credit Corp. f/k/a
    Encore Credit Corp. (“Encore”); Long Beach Mortgage (“Long Beach”); and Washington
    Mutual Bank (“WaMu Bank”), as well as various other third-party originators defined in ¶107
    below (collectively the “Originators”).
    3. These Originators did not, however, hold the mortgage loans they originated
    and/or acquired. Rather, taking advantage of an unprecedented boom in the securitization
    industry, these Originators flipped their mortgage loans to investment banks, which then
    repackaged the loans and sold the loans as RMBS to investors seeking safe investments, such as
    Plaintiffs. In the case of the loans underlying Plaintiffs’ Certificates, the entities that sold the
    RMBS were JPMorgan Chase, Bear Stearns, WaMu and Long Beach. Specifically, each of these
    entities pooled the mortgage loans made by the Originators; deposited the loans into special
    purpose entities or “trusts”; and then repackaged the loans for sale to investors in the form of
    RMBS. In nearly every case, an affiliate of JPMorgan Chase, Bear Stearns or WaMu was one of
    the underwriters that prepared the Offering Documents and sold the RMBS to investors such as
    Plaintiffs.
    4. The Certificates entitled investors to receive monthly distributions of interest and
    principal on cash flows from the mortgages held by the trusts. The Certificates issued by each
    trust were divided into several classes (or “tranches”) that had different seniority, priorities of payment, exposure to default, and interest payment provisions. Rating agencies, such as DBRS,
    Inc. (“DBRS”), Fitch, Inc. (“Fitch”), Moody’s Investors Service, Inc. (“Moody’s”), and Standard
    & Poor’s Corporation (“S&P”),1
    and/or rated the investment quality of all tranches of
    Certificates based upon information provided by the Defendants about the quality of the
    mortgages in each mortgage pool and the seniority of the Certificate among the various
    Certificates issued by each trust. These ratings, in part, determined the price at which these
    Certificates were offered to investors.
    5. In selling the Certificates, the Defendants prepared and filed with the SEC certain
    registration statements (the “Registration Statements”), prospectuses (the “Prospectuses”),
    prospectus supplements (the “Prospectus Supplements”, and free writing prospectuses (the “Free
    Writing Prospectuses”, and together with the Registration Statements, Prospectuses, and
    Prospectus Supplements, the “Offering Documents”). In these Offering Documents, Defendants
    repeatedly touted the strength of the Originators’ underwriting guidelines and standards; the fact
    that the underwriting guidelines and standards were designed to ensure the ability of the
    borrowers to repay the principal and interest on the underlying loans and the adequacy of the
    collateral; and that the mortgages underlying the Certificates were originated in accordance with
    those stated underwriting guidelines and standards. In addition, in the Offering Documents,
    Defendants repeatedly assured investors as to the soundness of the appraisals used to arrive at the
    value of the underlying properties and specifically represented that the real estate collateralizing
    the loans had been subjected to objective and independent real estate appraisals that complied
    with the Uniform Standards of Professional Appraisal Practice (“USPAP”) and, in some cases,
    that they met the even more rigorous appraisal requirements of the Federal National Mortgage Association (“Fannie Mae) and the Federal Home Loan Mortgage Corporation (“Freddie Mac”).
    Defendants emphasized their quality control procedures such as re-underwriting of a random
    selection of mortgage loans, conducting post-funding audits of origination files, and/or reverifying information to assure asset quality.
    6. Defendants JPMorgan, Bear Stearns, WaMu, and Long Beach (as defined in ¶¶
    33, 49, 71) were obligated to perform due diligence on the mortgage loans they acquired from
    third parties. Defendants represented in the Offering Documents, which Plaintiffs relied on, that
    they performed such due diligence and undertook certain quality control measures to ensure that
    shoddily underwritten mortgages were not included in the Certificates they underwrote and sold.
    See, e.g., Prospectus Supplement for WMALT Series 2006-9 Trust (Form 424B5), at S-29 (Oct.
    27, 2006): “The sponsor’s credit risk oversight department conducts a credit, appraisal, and
    compliance review of adverse samplings (and, in some cases, statistical samplings) of mortgage
    loans prior to purchase from unaffiliated mortgage loan sellers.”
    7. As set forth below, the Offering Documents contained material misstatements and
    omitted material information. Contrary to Defendants’ assurances, the Originators of the
    underlying loans had not followed their touted underwriting guidelines and standards when
    originating and/or acquiring the mortgage loans. To the contrary, the Originators had engaged in
    a wholesale and systematic abandonment of their underwriting guidelines, thereby granting
    mortgage loans to borrowers who did not satisfy the eligibility criteria as described in the
    Offering Documents. In addition, the mortgages underlying the Certificates had been extended
    based on collateral appraisals that were not performed in accordance with USPAP or Fannie Mae
    or Freddie Mac, so that the value of the underlying properties had been overstated, thereby
    exposing investors such as Plaintiffs to additional losses in the event of foreclosure. Defendants did not apply rigorous quality control procedures to uncover these lapses, and when they learned
    of such lapses, they deliberately overlooked them.
    8. Defendants’ conduct with respect to mortgage-backed securities has also been
    detailed in both the January 27, 2011, Final Report of the National Commission on the Causes of
    the Financial and Economic Crisis in the United States (the “FCIC Report”) and the April 13,
    2011, report issued by the PSI, chaired by Senator Carl Levin, entitled WALL STREET AND THE
    FINANCIAL CRISIS: ANATOMY OF A FINANCIAL COLLAPSE (the “Levin Report”). Both reports and
    their supporting testimony and exhibits have shed significant light on the extent to which
    Defendants intentionally securitized bad mortgage loans and sold them to investors like
    Plaintiffs. Numerous other investigations have been launched by the DOJ, the SEC, and various
    state Attorneys General.
    9. The practices of financial institutions such as JPMorgan, Bear Stearns, WaMu,
    and Long Beach and their role in inflating the housing bubble have been and continue to be the
    subject of intense regulatory scrutiny. On May 21, 2011, the WALL STREET JOURNAL reported
    that New York State Attorney General Eric Schneiderman had requested informal meetings with
    executives from several financial firms, including JPMorgan, as part of an investigation by his
    office into mortgage practices and the packaging and sale of loans to investors.
    10. On October 2, 2011, the NEW YORK TIMES reported that the New York Attorney
    General rejected a proposed nationwide settlement worth more than $20 billion that would also
    grant full immunity, from future prosecution, to financial institutions such as JPMorgan, Bear
    Stearns, WaMu, and Long Beach, and their control persons. Attorney General Schneiderman
    stated he believes that the losses caused by investment banks are far greater than the proposed
    settlement amount and he is unwilling to release these financial institutions from liability
    resulting from future investigations. The New York Attorney General’s office has since joined forces with Delaware Attorney General Beau Biden to “pursue a wider-ranging probe into Wall
    Street's role in the mortgage meltdown,” and the attorneys general of Kentucky, Minnesota and
    Nevada have expressed criticism of the proposed settlement—calling it weak and inappropriately
    favorable to the banks.
    11. On February 29, 2012, JPMorgan Chase announced that it is under investigation
    and may face a civil suit by the SEC regarding whether the firm misled investors in offerings of
    mortgage-backed securities. Specifically, the SEC has requested information relating to JP
    Morgan’s due diligence and disclosures for certain mortgage-backed securities transactions, and
    settlements of claims against the originators of loans that JPMorgan unit Bear Stearns Cos. Inc.
    packaged into securities.
    12. As a result of the untrue statements and omissions in the Offering Documents,
    Plaintiffs purchased Certificates that were far riskier than represented and that were not
    equivalent to other investments with the same credit ratings. As the truth regarding Defendants'
    misrepresentations and omissions has come to light, the rating agencies have responded by
    significantly downgrading the Certificates purchased by Plaintiffs. The Certificates, therefore,
    are no longer marketable at anywhere near the purchase prices paid by Plaintiffs. As a
    consequence, Plaintiffs have suffered losses on their purchases of the Certificates.
    13. Defendants JPMorgan, Bear Stearns, WaMu, and Long Beach knew about the
    poor quality of the loans they securitized and sold to investors like Plaintiffs, because in order to
    continue to keep their scheme running, they completely vertically integrated their RMBS
    operations by having affiliated entities at every stage of the process. In addition, Defendants
    JPMorgan, Bear Stearns, WaMu, and Long Beach were aware of lending abuses on the part of
    the third party originators they purchased loans from due to, inter alia, their financial ties to the
    third party originators and their reviews of loan documentation and performance.

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    https://www.scribd.com/document/471816775/Exhibit-a-Case-1-12-Cv-03184-RJ-1-1%20

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    https://www.scribd.com/document/471816780/Exhibit-B-Complaint-Case-1-12-Cv-03184-RJ-1-2

    Document Link 4

    https://www.scribd.com/document/471816778/Exhibit-C-Case-1-12-Cv-03184-RJ-1-3%20

    Document Link 5

    https://www.scribd.com/document/471816783/Exhibit-D-Case-1-12-Cv-03184-RJ-1-4%20

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