Securities America, Inc., et al, No. 3:09-cv-01568-F (N.D. Tex.) and In re: Medical Capital Securities Litigation, No. ML10-2145 DOC (RNBx) (C.D. Cal.), two related cases, the Firm raised unique issues regarding whether broker-dealer sellers of securities could be held liable for misrepresentations made in offering documents. As co-lead counsel in actions against defendants that sold stock or partnership interests in Provident Energy or Shale Royalties, and/or notes issued by special purpose corporation affiliated with Medical Capital Holdings, Inc., Zwerling Schachter obtained a settlement of $80,000,000 against defendants Securities America, Inc., Securities America Financial Corporation and Ameriprise Financial, Inc., representing approximately 37% of investors’ estimated losses. The Firm obtained additional settlements in the Billitteri action of $1,520,000 against defendant Capital Financial Services, Inc., and $5,400,000 against defendants NEXT Financial Group, Inc. and NEXT Financial Holdings, Inc.