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Page 1 of 22 THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION KAZENERCOM TOO, a Kazakhstan corporation and YERKIN BEKTAYEV, a Kazakhstan citizen. Plaintiffs. v. Case No.: 1:11-cv-00831 WORLD TRADE FINANCIAL CORPORATION, a California corporation, and PENSON FINANCIAL SERVICES, INC., a Texas corporation. Defendants. ________________________________________/ COMPLAINT Plaintiffs, KAZENERCOM TOO, a Kazakhstan corporation, and Plaintiff, YERKIN BEKTAYEV, a Kazakhstan citizen, by and through undersigned counsel, sue Defendant, WORLD TRADE FINANCIAL CORPORATION, a California corporation, and Defendant, PENSON FINANCIAL SERVICES, INC., a Texas corporation (collectively, “the Defendants”), and allege as follows: PARTIES 1. Plaintiff, KAZENERCOM TOO (“KEC”), a Kazakhstan corporation, is in the oil and gas business. As explained in greater detail infra, KEC owned an interest in a concession allowing it explore and develop oil and gas rich areas of Kazakhstan. In April 2005, and in full reliance upon the publicly-traded share value of TURAN PETROLEUM, INC. (“TPI”), KEC Case 1:11-cv-00831 Document 1 Filed 09/20/11 Page 1 of 22
