UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

PHILIP RALPH BELPASSO .. HONORABLE DICKLNSON R. DEBEVOIS

Plainti~f. :: CIVIL ACTION

NO.83-2268D

vs.

SMITH BARMEY, HARRIS UPHAM 6~ CO. ~--~ F~ILED OR\QINAL

OCT Defendant. ~c~N-4.

PLAINTIFF'S STATEMENT OPPOSING DEFENDANT'S

MOTION FOR DISMISSAL AND INFORMATION THEKE IN

Philip R. Belpasso 40-09 Kuiken Terrace Fair Lawn, New Jersey

-------- In reply to Smith Barney's memorandum of law in support of motion for dismissal T wish to state that I have presented my case in the original filing.

In my certification of particularities and exhibits which I have presented the statements show clearly the irregularities to which I have called the courts attention.

It is unlikely that any addistional facts can

or should be produced at this point in time.

I have honestly presented the intenable situations

which Smith Barney put me into and wish to draw

the court's attention to the dates on Exhibit (D)

this statement shows that after withholding my account

in a series of ruses they made the adjustments on

the 9 GEO International options and on that date

finally released my account.

It is suspect that in the cases in which I

feel Smith Barney abused my trust, which a customer

should have in their broker, they rationalize it

by explaining that both concern "inadvertent" credits

which were therafter corrected.

Should a concern of the stature of Smith Barney make two "inadvertent" errors on the same account?

------

All these statenents I have made in the honest belief that the service extended to me by Smith Barney was dishonest and faulty resulting in a financial loss to me of $20,000.00 dollars.

ii i 10/6/83 Philip R. Belpasso

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