Anwar et al v. Fairfield Greenwich Limited et al

Filing 346

DECLARATION of Amanda M. McGovern in Support re: #344 MOTION to Dismiss Second Consolidated Amended Complaint.. Document filed by Citco Group Limited. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Mcgovern, Amanda)

Anwar et al v. Fairfield Greenwich Limited et al

Doc. 346

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 DEFENDANT THE CITCO GROUP LIMITED'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 Blvd. Miami, FL 33131 T: 305.358.3580 F: 305.374.1756 [e-mail] [e-mail] 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 [e-mail] [e-mail] Attorneys for The Citco Group Limited MASTER FILE NO. 09-CV-0118 (VM)

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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 Defendant, The Citco Group Limited, in this action. I submit this Declaration in support of The Citco Group Limited's Memorandum of Law in Support of Its Motion to Dismiss the Second Consolidated Amended Complaint. 1. Attached hereto as Exhibit A is a true and correct copy of the Declaration of

Melanie Crinis, dated December 22, 2009. 2. Attached hereto as Exhibit B is a chart summarizing certain of Plaintiffs' section

10(b), Rule 10b-5, and section 20(a) claims that are time-barred by the 28 U.S.C. § 1658 FiveYear Statute of Repose. For ease of reference, Plaintiffs are identified in the chart in the order in which they appear in the Second Consolidated Amended Complaint. 3. Attached hereto as Exhibit C is a chart summarizing certain of Plaintiffs'

negligence-based tort claims that are time-barred by the CPLR § 214(4) Three-Year Statute of Limitations. For ease of reference, Plaintiffs are identified in the chart in the order in which they appear in the Second Consolidated Amended Complaint. Dated: December 22, 2009. /s/ Amanda M. McGovern Amanda M. McGovern

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