UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
THE ALBERT FADEM TRUST and LLOYD R. X
FADEM, as Trustee, on behalf of themselves and all : No.
others similarly situated, :
: CLASS ACTION
Plaintiffs, : COMPLAINT
:
against : JURY TRIAL DEMANDED
:
CITIGROUP INC., SANFORD I. WEILL, :
and TODD THOMSON, :
:
Defendants. :
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Plaintiffs, by their undersigned attorneys, individually and on behalf of the Class
upon information and belief, based upon, inter alia, the investigation of counsel, which includes,
other things, a review of public announcements made by defendants, Securities and Exchange
("SEC") filings made by defendants, press releases, reports of securities analysts, and media
except as to the paragraph applicable to the named plaintiffs which is alleged upon personal
bring this complaint (the "Complaint") against defendants named herein, and allege as follows:
SUMMARY OF ALLEGATIONS
1. This is a securities class action alleging violations of the federal securities laws
common law in connection with misstatements and omissions of material fact regarding Citigroup Inc.
("Citigroup" or the "Company") by the defendants named herein. In particular, during
the class period hereinafter defined, defendants made misrepresentations and/or omissions of
including:
C Failing to disclose that Citigroup misrepresented a 1999 transaction with Enron
structured as commodity trade but served the same purpose as a loan to help Enron
$125 million in debt off of its books;
SNIPPETS:
Plaintiffs, by their undersigned attorneys, individually and on behalf of the Class described
other things, a review of public announcements made by defendants, Securities and Exchange
filings made by defendants, press releases, reports of securities analysts, and media reports,
This is a securities class action alleging violations of the federal securities laws and the
common law in connection with misstatements and omissions of material fact regarding
C Failing to disclose that Citigroup misrepresented a 1999 transaction with Enron that was
plummeted $5.04 or 15.73% to close at $27.00, less than half its class period high.
Securities Exchange Act of 1934 and 28 U.S.C. § 1331.
New York Stock Exchange, and certain of the wrongful acts alleged herein took place or
Goes Far Beyond Credit Risk Associated With Loans To Enron
Regulators are examining whether the banks helped to create the intricate and misleading
MISSTATEMENTS AND OMISSIONS OF MATERIAL FACTS
Defendants made misrepresentations and/or omissions of material fact,
Citigroup's common stock was traded on a developed
statements therein were made and distributed with reckless disregard for facts that Citigroup
market prices for Citigroup common stock in violation of Section 10of the Exchange Act and
making of affirmative statements and reports, or participation in the making of affirmative
recklessly and for the purpose and effect of artificially inflating the market price of
the Individual Defendants controlled the public dissemination of
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