Federal Court Holds that Trader’s Role as Hedge Fund Manager Does Not, by Itself, Create Fiduciary Duty to Fund's Investors

  • Hedge fund trader’s motion to dismiss manager’s breach of fiduciary duty claim denied, since state law requires that parties to a joint venture owe one another such a duty, and allegations that trader recklessly acted to shut the fund down would constitute a breach of such duty.
  • Trader’s motion to dismiss manager’s breach of contract claim also denied, since complaint adequately alleged that trader caused two unsatisfied “day trade calls” that remained unsatisfied during the relevant period.
  • Investor’s claim that trader breached fiduciary duty dismissed because investor failed to show he placed his “trust and confidence” in trader.
  • Investor’s claim that trader tortiously interfered with contract dismissed for failure to allege that trader intended to harm investor.

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