Counsel's Letter to FINRA Requesting Arbitration Panel to Direct Non-Party to Produce Documents - Appendix 5T - Securities Arbitration: Practice and Forms
W. Reece Bader is a Partner in the Frankfurt office of Orrick and is a member of the Securities Litigation/Regulatory Group. Prior to moving to the Frankfurt office in 2008, Mr. Bader was located in the firm's Paris, Washington, D.C, Silicon Valley, New York and San Francisco offices. He has concentrated his practice in the area of securities and futures litigation since 1970. He has extensive experience, including substantial jury and non-jury trial work in broker-dealer litigation including securities, commodities and public finance. He also handles appellate matters and has represented the Securities Industry Association as amicus curiae in broker-dealer litigation. He has acted as lead defense counsel in complex class actions involving initial public offerings and derivative suits, both on behalf of underwriters, companies and officers and directors. He also regularly represents broker-dealers and individuals in both SEC and SRO enforcement actions. Mr. Bader has argued cases before the D.C., Second, Third, Ninth and Federal Circuits. He serves as an arbitrator for FINRA, NYSE and NFA, and the Center for Public Resources (Distinguished Neutrals Panel). He is a former member of the National Arbitration and Mediation Committee of the NASDR, past Co-Chair of the Securities Litigation Committee, and past Co-Chair of the Alternative Dispute Resolution Committee of the ABA's Litigation Section. Mr. Bader is a frequent lecturer and panelist for such organizations as the Practising Law Institute, ALI/ABA, FINRA and the Securities Industry and Financial Markets Association.
Originally from Securities Arbitration: Practice and Forms
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Counsel’s Letter to FINRA Requesting Arbitration Panel to Direct Non-Party to Produce Documents
________________________, 20___
____________________________, Esq.
FINRA Dispute Resolution
One Liberty Plaza, 27th Floor
165 Broadway
New York, NY 10005
Attention: ________________
Re: [Claim Name]
FINRA Dispute Resolution Case No. ____________
Dear _____________________:
On behalf of [Claimant], we hereby respectfully request that Panel to issue an order
pursuant to Section 12512(b) of the NASD Code of Arbitration Procedure directing [_______], a
non-party, to produce to Claimant at the above-noted address, within ___________(___) days
from the date of such Order, the documents described in the subpoena duces tecum dates
_________, ___, a Copy of which is enclosed herewith.
[State reasons justifying issuance of subpoena].