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Chronology of FINRA Arbitration Against TD Ameritrade

Chronology of Court Case Against TD Ameritrade

  1. We take TD Ameritrade to court.

  2. TD Ameritrade's Memorandum to Compel Arbitration

  3. Memorandum of No Objection to the Stay

  4. District Court of Maryland in Towson grants my motion!

  5. After the 60 day stay, I send my Motion to Reschedule the Trial

  6. District Court of Maryland in Towson grants my motion to reschedule!

  7. TD Ameritrade objects to the rescheduling of my case.

  8. Response to the belated attempt to change a court decision by Donald English of Miles & Stockbridge, P.C., Ameritrade's lawyer.

  9. TD Ameritrade responds to my memorandum in support of rescheduling case.

  10. Memorandum in Support of Rescheduling Case for Trial.

  11. Subpoena for our telephone recordings.

  12. Discovery Request.

  13. TD Ameritrade motions to quash my subpoena of telephone recordings.

  14. My Motion for Order to Compel the Production of Subpoenaed Evidence and the Responses to Interrogatories.

  15. Memorandum in Support of District Court's Granting of Motion to Continue Proceeding. Running logical circles around this lawfirm.

  16. Post Hearing Memorandum: the Plaintiff's presentation at the 3/11/11 Hearing.

  17. Maryland District Court delays sending ruling to parties.

  18. What is he hiding? Judge Robert Steinberg gives no legal basis for ruling.

  19. Court denies Plaintiff his Rule 3-534 right to contest and correct ruling.

  20. Judge Steinberg enters illegible response 30 days late.

  21. Plaintiff exposes mysterious court practices.

  22. Plaintiff submits recording of conversation where TDA gave false information about investment.

  23. TD Ameritrade violates Maryland Code Section 10-402

  24. FINRA falsely claims that the SEC is researching issue.


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Laurent J. LaBrie v. TDAmeritrade

Laurent J. La Brie     In the District Court of Maryland
v.
Toronto Dominion Ameritrade    Case No. 0804-0021814-2010

MEMORANDUM IN SUPPORT OF MOTION TO RESCHEDULE CASE FOR TRIAL

1.Defendant, in its Memorandum in Support of Defendant's Opposition to Plaintiff's Motion to Reschedule Case for Trial, filed on or about December 3, 2010 represents to the Court that Defendant was unaware that the Court had conditioned its stay on TDA's beginning arbitration by November 1, 2010 and that Defendant was not able to comply with the Court's ruling. In that Memorandum, Defendant states, "On August 27, 2010, this Court granted TDA's Motion to Compel Arbitration."

2.The Court ruling clearly stated that the motion that was granted was that of the Plaintiff.

3.Mr. La Brie is the named Plaintiff in this case. Defendant had been sent a copy of the clearly referenced Motion which stated "Laurent J. La Brie, hereby submits this statement of his non objection to allowing arbitration to proceed and to resolution of this matter by arbitration rather than by lawsuit and to stay this litigation for a 60 day period ending November 1, 2010 but this non objection is conditioned on Defendant, within said 60 days, presenting to Plaintiff a confirmation from FINRA that FINRA has received the Claim for the $15,173.94 (and any further financial claims the Defendant has against the Plaintiff) which Plaintiff asserts is due to Plaintiff from the described transactions Defendant executed on behalf of Plaintiff."

4.On or about September 1, 2010, Hollie Mason, Associate Counsel for the Defendant, understood the ruling of the Court and called the Plaintiff to cite her disagreement with said ruling. Plaintiff explained that Defendant should address her issue to the Court directly as is provided by Maryland Rules 3-534 and 3-535.

5.In Defendant's letter to Plaintiff dated September 2, 2010, Ms. Mason stated, "We are in receipt of the Court Order granting your request to stay this matter and proceed to arbitration." She also wrote, "TD Ameritrade cannot initiate the arbitration." (See Exhibit A) Since representatives of both parties understood the Court's Order and the condition under which the Plaintiff's motion was made, it is unlikely that Defendant's professional legal counsel did not understand said ruling.

6.Defendant, in its Memorandum to the Court dated December 3, 2010, claims "TDA cannot file an arbitration claim against itself." Since the Defendant failed to bring this objection to the court within the time period allotted by Rules 3-534 and 3-535, Plaintiff requests that the Court disallow Defendant's objection as being untimely.

7.If Defendant believes itself unable to bring disputes to FINRA for arbitration, Defendant should not have written in their Account Agreement that Defendant would do so. It is a further demonstration of lack of good faith that the Defendant wrote and electronically signed an Agreement with the Plaintiff while having full knowledge that Defendant could not fulfill said Agreement.

8.NOW, THEREFORE Plaintiff respectfully repeats its request that the Court lift the stay and grant the Plaintiff a new trial date.

________________________________
Laurent J. La Brie
5 Pleasant Ridge Drive #205
Owings Mills, MD 21117

Attachment: Exhibit A: Memorandum from TD Ameritrade dated September 2, 2010 (See last page of this memorandum.)

I HEREBY CERTIFY that on this 7th day of December, 2010, a copy of the foregoing MEMORANDUM IN SUPPORT OF MOTION TO RESCHEDULE CASE FOR TRIAL was mailed, first class, postage prepaid to:
TD Ameritrade
Resident Agent: CSC-Lawyers Incorporating Service Company
7 St. Paul Street, Suite 1660
Baltimore, MD 21202

________________________________
Laurent J. La Brie

Chronology of Court Case Against TD Ameritrade





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