Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
and seek the suspension of the shares of Spencer Pharmaceutical, and request further
justifications, and information fromthe management ofSpencerPharmaceutical andfrom the
saidacquirer AI-Dora. HadtheAMF actedon its mission ofoversight of financial markets, the
Plaintiff's claims would have been non-existent andtherefore we request the court to joined
theAMFasadefendant.
IfjoinderdefendantAutoritedesMarchesFinanciersduQuebecisdenied bythe court, this will
createasignificantprejudiceto the defendants.
b) TheCourt should orderthePlaintifftoamend its civil complaint and or Statementof
claimstoincludethepeopleandentitieslistedasdefendants
The information obtained during the discovery period has provided enough evidence to the
Plaintiff to amend its civil complaint and or Statement of claims to include the people and
entities wehaverequested tobejoinedasdefendants.
The Plaintiff's civil action is not a "vanilla" civil action, as the Securities and Exchange
Commission,the Plaintiffshould not besatisfied to obtain ajudgmentand or partial judgment
from adefendantor defendants, butshould seekthe truth andpursue all possibledefendants
regardlessofcost,timeandor degreeofdifficulties.
The court should not allow the bundling of unrelated defendants to have the effect of
subjecting a defendant to substantial risk of incurring double, multiple or otherwise
inconsistent obligations.
Case 1:12-cv-12334-IT Document 115 Filed 10/01/14 Page 31 of 32
c) The Court should ordera stay ofthe proceedings until such time asthe Plaintiffhas
amendeditscivil complaintand orstatementofclaims
The information obtained during the discovery period has provided enough evidence to the
Plaintiffto amend its civil complaint and or Statement of claims to include the people and
entitieswehaverequestedto bejoinedasdefendants.
It istherefore in the interest ofthis court to order astay ofthe proceedings indefinitely and
provide the necessary time forthe Plaintiffto amend its civil complaint and or statement of
claimsaswell asservetheamendedsummonsto thejoinderdefendants.
d) TheCourtshoulddismissthiscivilactionfordefendantJean-FrancoisAmyot
The information obtained during the discovery period has provided enough evidence to the
Plaintiffto dismissdefendantJean-FrancoisAmyotfromthese proceedings.
Respectfully
September23,2014
Defendant
Case 1:12-cv-12334-IT Document 115 Filed 10/01/14 Page 32 of 32