The Regents - University of California | Office of The President

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General of New York, between October 1997 and February 2002, Salomon
advised WorldCom on about 23 investment banking deals for which it earned over
$100 million. Its chief telecommunications analyst, Jack Grubman, had a close
and improper relationship with WorldCom, including attending Board of
Directors’ meetings where he provided investment advice and obtained
confidential, non-public information. At the times of the acts and omissions
alleged herein, Grubman was an agent and/or employee of Salomon and acting
within the course of scope of his agency/employment.
16. Defendant CitiGroup, Inc. (“Citigroup”) is an international financial
services company offering asset management, banking, investment services and
investment banking. It is the parent of Salomon and does business in California.
There is a unity of interest and ownership between CitiGroup and Salomon such
that the acts of the one are for the benefit and can be imputed as the acts of the
other. Citigroup through its division, CitiBank, loaned millions of dollar to
WorldCom.
2. The Accounting Defendant
17. Defendant Arthur Andersen, LLP (“Arthur Andersen”) is a multiinternational
accounting, auditing and consulting firm which does business in
California. Until 2002, Andersen was one of the largest accounting firms in the
world, also formerly known as one of the “Big 5" accounting firms.
18. Andersen operates as an integrated entity throughout the world, and is
including Defendant Andersen Worldwide Organization (“AWO”); the AWO
member firms; the partners of the firms. AWO and Arthur Andersen set the
policies and procedures governing all member firms and offices worldwide.
19. Except where otherwise indicated, these entities are referred to in this
Complaint as “Andersen.”
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COMPLAINT