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.
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APPENDIX 5S
AAA Form - Respondents’ Responses to Request for Documents
AMERICAN ARBITRATION ASSOCIATION
________________, ) Case No.: ________________
)
Claimant, ) Respondents Response to Claimant’s Request for
) Documents
vs. )
)
________________, )
)
Respondents. )
_________________)
TO CLAIMANT ________________:
Respondents ______________________________ (“Respondents”) hereby respond to
Claimant’s Request for Production of Documents as follows:
PRELIMINARY NOTES AND GENERAL OBJECTIONS
A. Respondents object generally to any definition and/or Request for Production of
Documents to the extent it seeks information subject to a claim of privilege, and hereby asserts
such privilege.
B. Respondents object generally to any Request for Production of Documents to the
extent it calls for information which constitutes or contains trade secrets or proprietary or
confidential information, the disclosure of which may competitively injure _____________.
C. Respondents respond to the Requests for Production of Documents with the
reservation of the right to augment the response based upon information which may subsequently
be discovered.
