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City of Ouro Preto v. Merrill Lynch Pierce Fenner & Smith et al: Class Action Complaint (‘Lender Liability for Brazil Environmental Damages’)

Complaint for "for lender liability against the Defendants arising from loans and financing which directly promoted, and continues to promote, significant environmental degradation in and around the Brazilian State of Minas Gerais" in City of Ouro Preto, in Minas Gerais, Brazil v. Merrill Lynch Pierce Fenner & Smith, Barclays Capital Inc., Citibank Inc., Citigroup Global Markets Inc., JPMorgan, and JPMorgan Securities LLC at the U.S. District Court for the Southern District of New York.