Selected Court Filings

April 30, 2010
Plaintiff's Reply Brief. (PDF, 2MB)
Plantiffs reply to Bank of Nova Scotia's response brief.

April 21, 2010
Bank of Nova Scotia's Response Brief. (PDF, 193KB)
Bank of Nova Scotia's response to Plaintiffs appeal brief.

March 19, 2010
Plaintiff's Opening Brief. (PDF, 421KB)
Appeal filed by the Plaintiffs in the Supreme Court of New York.

September 21, 2009
Plaintiff's Motion to Reconsider. (PDF, 72KB)
Memorandum In Support of Plaintiff's Motion for Leave to Reargue the Motion for Summary Judgement filed in the Supreme Court of New York.

August 4, 2009
Court's ruling on Third Dispositive Motion(PDF, 936KB)
Ruling filed in the Supreme Court of New York.

November 3, 2008
Court's Hearing on Show Cause (PDF, 416KB)
Transcript of the show cause hearing in the Supreme Court of New York.

October 22, 2008
Plaintiff's 4th Amended Complaint (PDF, 1.3MB)
Complaint filed in the Supreme Court of New York.

October 9, 2008
Status Conference Transcript (PDF, 1.1MB)
Transcript of Status Conference in the Supreme Court of New York.

August 8, 20078
Court Denies Second Motion to Dismiss (PDF, 1.5 MB)
Court Order denying Second Motion to Dismiss.

November 15, 2007
Court's Hearing on Motion to Dismiss (PDF, 2.3 MB)
Transcript of court's hearing of arguments from Plaintiffs and Defendants on the issue of whether Act of State and International Comity apply. At one point the judge tells Scotiabank's lawyer that his arguments do not pass the "smell test."

September 21, 2007
Plaintiff's Opposition to Motion to Dismiss (PDF, 2.2 MB)
Plaintiffs argue that the doctrines of Act of State and International Comity do not apply in this case.

August 3, 2007
Bank of Novia Scotia's Motion to Dismiss the Second Amended Complaint (PDF, 2.2 MB)
Bank of Novia Scotia argues that the doctrines of Act of State and International Comity bar the court from considering the Plaintiffs' claims.

March 23, 2007
Court Denies First Motion to Dismiss (PDF, 592 KB)
The court rules that while three causes of action against the Bank of Novia Scotia are time-barred, three others are not, and that the case can continue.

December 15, 2006
Second Amended Complaint (PDF, 1.4 MB)
Rita Maria Sanchez de Hernandez, Et Al V. Bank of Novia Scotia, a complaint for money damages and equitable relief, amended with additional plaintiffs and additional information.

October 31, 2006
Plaintiffs' Opposition to Motion to Dismiss Claims as Time-Barred (PDF, 3.3 MB)
Plaintiffs argue that the statute of limitations has not, in fact, run out on it's complaints against the Bank of Novia Scotia.

September 8, 2006
Motion to Dismiss Claims as Time-Barred (PDF, 1.1 MB)
The Bank of Novia Scotia argues that the statute of limitations has run out on the complaints filed against it by Rita Maria Sanchez de Hernandez, Et Al.

August 4, 2006
First Amended Complaint (PDF, 1.5 MB)
Rita Maria Sanchez de Hernandez, Et Al V. Bank of Novia Scotia, a complaint for money damages and equitable relief.