UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
PELICAN EQUITY, LLC, Plaintiff,

-against-

ROBERT V. BRAZELL, STEPHEN L. NORRIS, TALOS PARTNERS, LLC, RAMARAMACHANDRAN, DARL McBRIDE, and BRYAN CAVE LLP, Defendants.
........
AIP's Proprietary Stock Loan Business

18. During the period 2004 through early 2009, AIP developed a novel and potentially immensely profitable program through which it would arrange for persons who own marketable securities to pledge those assets as security for loans in amounts constituting substantial percentages of their market value under circumstances in which they could not obtain financing in comparable amounts from traditional lenders. Under AIP's stock loan program, borrowers would have the benefit of certain unique and innovative insurance coverage. From 2005 to 2008, AIP made numerous loans using its novel stock loan program.
.......

23. On or about November 8,2008, Brazell contacted Robbins and told him that he believed that the AIP stock loan product was "the best opportunity he has seen in his lifetime." Brazell told Robbins that he "wants to become partners with him" and open offices in New York as soon as possible. He implored Robbins to stay in New York for a month to get the partnership going and asked Robbins to give him extensive due diligence materials on AIP, including but not limited to its organizational documents. Rama, who was an AIP employee at the time, sent that confidential information to Brazell. Brazell almost immediately started introducing potential borrowers to AIP, including (1) Sandie Tillotson, the co-founder ofNu Skin Enterprises, for whom Brazell claimed to act as a financial advisor, and (2) Sheldon Adelson, the founder of the Las Vegas Sands Corp., with whom Brazell claimed to have a seat on the board of directors of another company. Brazell also claimed to be able to introduce AIP to many other very high net worth and influential people with whom he purportedly had significant personal relationships.
....
44. Talos is today conducting business from the same offices at 540 Madison Avenue Brazell purported to secure for AIP a few months previously. Talos hired or engaged numerous individuals who previously were AIP employees or whom AIP recruited to work in or consult on the AIP stock loan business, including Peter Densen (formerly of AON and who is currently listed on Talos' website as its Chief Risk Officer and Chairman of its Underwriting Committee), Senator Robert W. Kasten, Brian Nord, Larry Russell Jr., Todd Bergeron, Derek Cornaby, Douglas Anderson and Robert M. Daughtry. On information and belief, the defendants (other than Bryan Cave) closed or sought to close loans with Sandie Tillotson and Sheldon Adelson. On information and belief, they also consummated an arrangement with AON on terms substantially similar to those negotiated by Brazell and Norris for AIP in January 2009. According to a current employee, Talos has closed more than $500 million in loans in the last 90 days using the stolen Confidential Business Information.