Anwar et al v. Fairfield Greenwich Limited et al

Filing 331

DECLARATION of Amanda M. McGovern in Support re: #329 MOTION to Dismiss Second Consolidated Amended Complaint.. Document filed by CITCO Fund Services (Europe) B.V., Citco Canada Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Mcgovern, Amanda)

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Anwar et al v. Fairfield Greenwich Limited et al Doc. 331 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x ANWAR, et al., Plaintiffs, -againstFAIRFIELD GREENWICH LIMITED, et al., Defendants. This Document Relates To: All Actions --------------------------------------------------------------x DECLARATION OF AMANDA M. MCGOVERN IN SUPPORT OF DEFENDANTS CITCO FUND SERVICES (EUROPE) B.V. AND CITCO (CANADA) INC.'S MOTION TO DISMISS THE SECOND CONSOLIDATED AMENDED COMPLAINT GILBRIDE, HELLER & BROWN, P.A. Lewis N. Brown Amanda M. McGovern One Biscayne Tower, 15th Floor 2 South Biscayne Boulevard Miami, FL 33131 T: 305.358.3580 F: 305.374.1756 lbrown@ghblaw.com amcgovern@ghblaw.com CURTIS, MALLET-PREVOST, COLT & MOSLE, LLP Eliot Lauer (EL 5590) Michael Moscato (MM 6321) 101 Park Avenue New York, NY 10178 T: 212.696.6000 F: 212.697.1559 elauer@curtis.com mmoscato@curtis.com Attorneys for Citco Fund Services (Europe) B.V. and Citco (Canada) Inc. MASTER FILE NO. 09-CV-0118 (VM) Dockets.Justia.com Pursuant to 28 U.S.C. § 1746, AMANDA M. MCGOVERN deposes and states: I am a member of the bar of the State of Florida and have been admitted to practice pro hac vice before the United States District Court for the Southern District of New York in this matter. I am a partner of the firm of Gilbride, Heller & Brown, P.A., counsel for Defendants Citco Fund Services (Europe) B.V. and Citco (Canada) Inc., in this action. I submit this Declaration in support of Citco Fund Services (Europe) B.V. and Citco (Canada) Inc.'s Memorandum of Law in Support of Their Motion to Dismiss the Second Consolidated Amended Complaint. 1. Attached hereto as Exhibit A is a true and correct copy of Fairfield Sentry Limited's Administration Agreement, dated February 20, 2003. 2. Attached hereto as Exhibit B is a true and correct copy of Fairfield Sigma Limited's Administration Agreement, dated February 20, 2003. 3. Attached hereto as Exhibit C is a true and correct copy of Greenwich Sentry L.P.'s Administration Agreement, dated August 10, 2006. 4. Attached hereto as Exhibit D is a true and correct copy of Greenwich Sentry Partners L.P.'s Administration Agreement, dated August 10, 2006. 5. Attached hereto as Composite Exhibit E is a true and correct copy of the relevant portions of the Private Placement Memoranda and Confidential Offering Memoranda for Fairfield Sentry Limited, Fairfield Sigma Limited, Greenwich Sentry, L.P., and Greenwich Sentry Partners, L.P. 6. Attached hereto as Exhibit F is a true and correct copy of the Declaration of 2 Elizabeth Anne Weaver, dated December 21, 2009. Dated: December 22, 2009 /s/ Amanda M. McGovern Amanda M. McGovern 3

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