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The Regents - University of California | Office of The President

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administer <strong>of</strong> WorldCom’s employee stock option plan generating fees and<br />

brokerage clients for Salomon. Both companies depended upon each other’s<br />

success to drive their businesses.<br />

B. Salomon Provided WorldCom Executives With Stock in IPOs and<br />

Favorable Analyst Reports in Exchange for WorldCom’s<br />

Investment Banking Business<br />

188. In order to make sure that it received WorldCom’s investment<br />

banking business, Salomon engaged in a quid pro quo with WorldCom executives<br />

whereby Salomon provided IPO shares to Ebbers and Sullivan, in return for<br />

WorldCom’s investment banking business. As part <strong>of</strong> the deal, Salomon’s top<br />

telecommunications securities analyst, Jack Grubman, provided favorable ratings<br />

<strong>of</strong> the company which benefitted both Salomon and WorldCom.<br />

189. On September 30, 2002, the Attorney General <strong>of</strong> New York, Elliott<br />

Spitzer, filed a complaint against Ebbers, Sullivan and others alleging that Salmon<br />

and its predecessors engaged in a practice called “spinning” which involved<br />

Salomon providing favored executives with nearly risk-free shares <strong>of</strong> stock in<br />

companies which were about to go public. In a quid pro quo, the executives<br />

reaped enormous pr<strong>of</strong>its from the selling <strong>of</strong> the IPO stock and the executives<br />

selected Salomon as their company’s investment banking for their public<br />

<strong>of</strong>ferings.<br />

190. On August 26 and 30, 2002, Citibank produced documents in<br />

response to a subpoena by the House Committee on Financial Services which<br />

disclosed the executives who received this favorable treatment. Exhibits “F” and<br />

“G. ” <strong>The</strong> documents, and Citibank’s testimony, demonstrate that these<br />

executives earned over $18 million pr<strong>of</strong>its due to these IPO deals. Ebbers and<br />

Sullivan <strong>of</strong> WorldCom both received IPO stock. Ebbers and Sullivan made<br />

substantial pr<strong>of</strong>its from the IPO stock.<br />

191. As a part <strong>of</strong> the deal, Salmon made sure that its analysts gave<br />

favorable reports about the company. Research analysts are supposed to be<br />

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COMPLAINT

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