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clients as instructed by LTD. During each of the years in issue,
one or more employees or officers of INC had signatory authority
for LTD’s bank accounts.
INC maintained in San Antonio two types of files. The first
type was the client statement file, or client file, which
contained documents relating to client account activity. The
client statement file contained copies of LTD Statements of
Account, which identified only the client's LTD account number
and, if applicable, the client's third party institution account
number (e.g., the client's Shearson account number).
Additionally, if applicable, the client statement files contained
copies of: (1) Third party institution statements of account,
which identified the client's name and the third party
institution client number; (2) LTD Cash Receipt forms, which
identified the client's name and LTD account number; (3) LTD
Check Requisition forms, which identified the client's name and
LTD account number; and (4) LTD Debit/Credit Memorandum forms,
which identified the client's name and LTD account number.
The second type of file maintained by INC in San Antonio was
the client legal file, which contained documents relating to the
establishment of the client account itself. The client legal
file contained copies of: (1) The discretionary authorization
between LTD and the client, which included the client's
investment instructions and identified the client's name and LTD
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