1. Not Clearly Explaining the Claim
The defendant is involved in a fraud and you provide a complicated explanation that the Court does not fully understand. Your claim is likely to be dismissed (probably with leave to re-file once). See www.ricolawyer.org
2. Assuming that justice will be done
Many scheme continue with skilled counsel, until the collapse finds limited funds and unpaid claims. The skilled SEC believed Madoff and not his accuser. Simply because a wrong has been committed do not assume that the Court will address it; you need to prove your claim clearly and convincingly.
3. Lumping the defendants together
Saying the defendant willfully and deliberately conspired to defraud the plaintiff making multiple false statements resulting in the substantial losses set forth above- is not going to do it. In a fraud case, you need to identify what each defendant did. Each will pretend not to understand what it is alleged to have done wrong and a vague complaint will again be subject to dismissal.
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