Printout of the highlights of various items on this website
Under Item 2
  1. Exhibit D - 3 The Lutheran Medical Center notice to employees - stating that CitiStreet is a "Joint Venture between Citigroup and State Street, two of the largest, most well respected financial companies in the country".
  2. Exhibit Z-2 - "About CitiStreet" PR release by CitiStreet explaining size and ownership of CitiStreet as being a 50/50 Joint Venture between State Street Corp and Citigroup
  3. Exhibit Z-3 - Letter date 2/4/03 from Weil Gotshal &Manges to LoPresti's lawyer stating that CitiStreet "is not a legal entity" and that Copeland Associates no longer exists as of August 2000.
  4. Exhibit Z-6 - Check drawn by the allegedly non-existent Copeland Associates, Inc on 10/7/2002 for $108,717.63 - signed by Robert Dughi, 2 years after they no longer existed.
  5. Exhibit Z-7 - Check drawn by allegedly non-existent Copeland Associates, Inc. on 9/10/2002 for $107,566.48 - signed by Robert Dughi - 2 years after they no longer existed.
Under Item 4
  1. Page 1 - Letter from Weil Gotshal & Manges, attorney's for Citigroup, Inc. and State Street, Corp., to James Giokas, Chief Deputy Clerk, dated 3/17/03, reiterating "that Copeland Associates, Inc no longer exists" as of August 2002 and that "?there is not a cognizable legal entity entitled "CitiStreet"".
  2. Page 10 - Press release from CitiStreet dated 3/27/03 stating it has 3,500 employees, 8 million participants, with $170 billion in assets and that CitiStreet is a 50/50 Joint Venture between State Street Corp (NYSE:STT) and Citigroup (NYSE:C).
Under Item 5
  1. Page 3 - Opening comments by Magistrate Judge Viktor V. Pohorelsky, held on 7/7/03 that there is no CitiStreet and that Copeland Associates, Inc. does not exist and that he doesn't understand why LoPresti is "?going through this rigmarole", and statement by the Magistrate Judge regarding the existence of CitiStreet and Copeland that it is a factual dispute which would require discovery.
  2. Page 8 - Line 23 - Statement by Magistrate Judge Pohorelsky that there is no company named CitiStreet.
  3. Page 9 - Line 24 - Statement by Magistrate Judge Pohorelsky that LoPresti is "? just playing games?" in seeking a default judgment against CitiStreet and Copeland.
Under Item 6
  1. Page 42 - Denial by Magistrate Judge Pohorelsky that he recuse himself based on his having worked with Ping Moy, Esq., general counsel for Lutheran Medical Center, when they were both Assistant U.S. State Attorneys in the Southern District of New York.
  2. Page 51 - Letter from Robert Heinemann dated 5/4/2004, refusing to note the defaults of CitiStreet and Copeland Associates, Inc. on the docket of the court.
  3. Page 61 - Order from Magistrate Judge Viktor V. Pohorelsky, dated 6/17/04, stating that he would preside at the hearing to be held on LoPresti's motion to disqualify Magistrate Judge Viktor V. Pohorelsky.
Under Item 9
  1. Page 15 - Bio of Merrill B. Stone, Esq., a partner in Kelley Drye & Warren wherein it is stated that attorney Stone represented State Street in forming the CitiStreet Joint Venture with Citigroup.
  2. Page 26 - Affidavit dated 5/7/03 of David Lender, Esq. of Weil Gotshal & Manges to the court concerning the non-existence of CitiStreet and Copeland.
  3. Page 28 - Weil Gotshal & Manges argues to the court on 5/7/03 that LoPresti's assertions of the existence of CitiStreet are "?based on a meaningless discussion about unauthenticated press releases?"
  4. Page 33 - Affidavit to the court dated 5/1/03 by Robert Dughi stating that "CitiStreet does not exist".
  5. Page 71 - An article dated 5/02 quoting Robert Dughi, stating he is the President of CitiStreet.
  6. Page 73 - Article dated 12/8/99 from CNN Money concerning formation of CitiStreet as a Joint Venture between Citigroup, Inc. and State Street, Corp.
  7. Page 74 - An article in the Boston Business Journal dated 12/8/99 regarding the formation of a Joint Venture called CitiStreet between Citigroup, Inc. and State Street, Corp.
  8. Page 75 - Article dated 12/9/99 from the New York Times regarding the formation of a Joint Venture called CitiStreet between Citigroup, Inc. and State Street, Corp.
  9. Page 82 - Article from Newsday dated 2/2/01 concerning award by Nassau County and the criticisms for the County appointing CitiStreet as a vendor for pensions to Nassau County employees.
  10. Page 139 - Check dated 9/18/02 written by Copeland Associates, Inc. signed by Robert Dughi for the sum $107,586.48. Mr. Dughi had previously sworn that Copeland Associates, Inc. did not exist because it went out of business in a merger in the year 2000.
  11. Page 140 - Page 139 - Check dated 10/7/02 written by Copeland Associates, Inc. signed by Robert Dughi for the sum $108,717.63. Mr. Dughi had previously sworn that Copeland Associates, Inc. did not exist because it went out of business in a merger in the year 2000.
  12. Page 141 - Check dated 1/8/03 written by Copeland Associates, Inc. signed by Robert Dughi for the sum $107,826.13. Mr. Dughi had previously sworn that Copeland Associates, Inc. did not exist because it went out of business in a merger in the year 2000.
Under Item 11
  1. Page 5 - Weil Gotshal & Manges argues to the court in papers dated 7/7/04 that "?"CitiStreet" and "Copeland Associates, Inc" are not cognizable legal entities".
  2. Page 7 - Weil Gotshal & Manges argues on 7/7/04 that plaintiffs "evidence does not refute that neither "CitiStreet" nor "Copeland Associates, Inc." are cognizable legal entities".
    3. Under Item 14
  3. Page 38 - Line 15 - Magistrate Judge Pohorelsky refuses to recuse himself at hearing dated 7/16/04.
    4. Under Item 16
  4. Page 1 - Letter from LoPresti's lawyer to Weil Gotshal & Manges dated 8/25/04 regarding his statement at the 7/16/04 hearing that he represents CitiStreet.
    5. Under Item 17
  5. Page 1 - November 3, 2004 Letter from LoPresti's lawyer to Weil Gotshal & Manges containing excerpts from 56 pension providers indicating that CitiStreet is the broker for their pension plans.
    6. Under Item 22
  6. Page 4-20 - Affidavit dated 12/26/04 by LoPresti's attorney regarding objections to the orders made by Magistrate Judge Pohorelsky, and his having convened what was analogous to a kangaroo court.
    7. Under Item 23
  7. Page 1 - Letter dated 1/3/05 from LoPresti's attorney to Judge Johnson regarding Citibank owning the mortgage on the home of Magistrate Judge Pohorelsky.
    8. Under Item 25
  8. Page 7 - Line 6 - Magistrate Judge Pohorelsky denies having a mortgage with Citibank.
  9. Page 7 - Line 19 - Magistrate Judge Pohorelsky states he has his checking account with Citibank and his IRA with Citibank.
  10. Page 72 - Line 22 - Mr. Dughi asks "Can we agree that we are a joint venture."
  11. Page 72 - Line 24 - Magistrate Judge Pohorelsky states "Let's not agree on anything just yet?"
  12. Page 73 - Lines 1-6 - Mr. Dughi states that he agrees that CitiStreet is a joint venture owned 50/50 by Citigroup and State Street.
Under Item 33
  1. Page 1-14 - LoPresti's objections to the findings made at the 1/5/05 hearing, including recital to the court of the entries in the Kings County clerk's office stating that on 6/11/99 Chase Manhattan, Manhattan Mortgage Corp assigned Magistrate Judge Pohorelsky's mortgage to Citibank that was recorded on 3/29/01 at Liber 5119 page 1316.
  1. Pages 5-14 - LoPresti's objections to the hearing conducted by Magistrate Judge Pohorelsky on 1/5/05.
Under Item 46
  1. Page 60 - Citigroup lawyers reiterate and argue to the U.S. Second Circuit Court of Appeals, that "CitiStreet" and "Copeland are non-existent entities.
Under Item 47
  1. Page 19 - Lutheran Medical Center reiterates to the U.S. Second Circuit Court of Appeals that its employees were told that CitiStreet is a joint venture between Citigroup and State Street, Corp.
Under Item 57
  1. Page 1-7 - LoPresti's reasons for petitioning U.S. Second Circuit Court of Appeals for a rehearing.

Don't have Adobe Acrobat?
Click Here for Free Download