"" Plaintiffs Barbara J. Fried and B. Mark Fried, Altitude Partners LLC, Richard D. Maltzman as trustee for the Richard D. & Charlene Maltzman Family Trust U/A/D, 3/23/88, Jefforeed Partners, L.P. by its General Partner Jefforeed Management Company, Inc., and Zelfam, LLC, each as limited partners of two Delaware limited partnerships, Lehman Brothers Real Estate Partners III, L.P. (“Partners III”) and Lehman Brothers Real Estate Fund III, L.P.
(“Fund III”) (together the “Partnerships”), sue on behalf of themselves and the limited partners
named on Annex A. Said Plaintiffs allege for their First Amended Complaint (allegations identical with original) against defendants Lehman Brothers Real Estate Associates III, L.P. (“General Partner”), Lehman Brothers Private Equity Advisers, LLC (“Investment Advisor”), and Real Estate Private Equity, Inc. (“REPE”), each an affiliate of bankrupt Lehman Brothers Holdings, Inc. (“Lehman”); and individuals Mark A. Walsh, Brett Bossung, Mark H. Newman, Michael J. Odrich, Christopher M. O’Meara, Richard S. Fuld, Jr., Joseph M. Gregory, Erin Callan, Ian Lowitt and Thomas Russo (collectively, “Insider Defendants”) and DOES 1 through 50, (all defendants, collectively, “Defendants”) upon personal knowledge as to themselves and information and belief as to the knowledge and actions of others. Plaintiffs’ information and beliefs are based on the continuing investigation of their counsel.
Many facts related to Plaintiffs’ allegations are known only to Defendants or are exclusively within their control. Substantial evidentiary support herefor will be developed after reasonable discovery.
SUMMARY OF THE CASE
1. Plaintiffs sue for over 60 Class members (Annex A) that collectively have committed to invest at least $53,750,000 as limited partners of the Partnerships, and have joined in the Agency Agreement (form attached as Annex B) to seek damages for losses incurred due to Defendants‟ misrepresentations and failures to disclose their scheme to use Plaintiffs‟ funds to acquire real estate from Lehman, during its financial crisis, at prices far above Fair Value, without adequate disclosure or informed consent.
Said misrepresentations and omissions were made in very similar Private Placement Memoranda (“PPMs”) related to sales of limited partnership interests in several Lehman real estate limited partnerships. ..""
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