Join the mailing list Printer-friendly version

COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP FILES CLASS ACTION SUIT AGAINST FALCON STRATEGIES TWO LLC

New York – May 22, 2008 – Coughlin Stoia Geller Rudman & Robbins LLP (“Coughlin Stoia”) (http://www.csgrr.com/cases/falcon/) today announced that a class action has been commenced in the United States District Court for the Southern District of New York on behalf of all persons or entities who have tendered or are being asked to tender their shares of Falcon Strategies Two LLC (“Falcon” or the “Company”), a fund affiliated with defendant Citigroup, Inc.(“Citigroup”) (NYSE:C), in connection with a tender and exchange offer (the “Tender Offer”), on the basis of a Confidential Tender and Exchange Offer Memorandum, dated May 8, 2008 (the “Tender Memorandum”), that contains materially misleading statements and omissions. The Complaint alleges claims under Sections 10(b) and 14(e) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Delaware law.

If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from today. If you wish to discuss this action or have any questions concerning this notice or your rights or interests, please contact plaintiff’s counsel, Samuel H. Rudman or David A. Rosenfeld of Coughlin Stoia at 800/449-4900 or 619/231-1058, or via e-mail at djr@csgrr.com. If you are a member of this class, you can view a copy of the complaint as filed or join this class action online at http://www.csgrr.com/cases/falcon/. Any member of the purported class may move the Court to serve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent class member.

Defendant Falcon is a Delaware limited liability company that was purportedly formed on April 27, 2004 to serve as a multi-strategy fixed income alternative seeking to provide investors with absolute returns, current income and portfolio diversification. The Company, which commenced operations on October 29, 2004, claimed to invest in a select combination of fixed income strategies to achieve attractive risk-adjusted, and in some cases “absolute,” returns.

The Complaint alleges that, unbeknownst to investors, Falcon’s investment approach was not conservative but was instead highly leveraged on the condition of the credit markets and liquidity in the bond markets. In this regard, Falcon’s investments were more akin to derivatives.

According to the Complaint, in fact, Falcon employed municipal bond arbitrage, carried commercial debt obligations and held asset-backed mortgage instruments that were intrinsically tied to the condition of the credit and bond markets. Moreover, Falcon heavily invested in funds under the Citigroup umbrella that employed these investment strategies. When these markets failed, the underlying investments declined in value.

In connection with the filing of the Complaint, Plaintiff also filed a motion for a preliminary injunction seeking to enjoin the Tender Offer until Falcon and other named defendants (collectively, “Defendants”) correct the allegedly false and misleading Tender Memorandum to enable investors to make an informed decision about whether to tender their shares. In particular, Plaintiff alleges that the Tender Memorandum is materially false and misleading because it fails to disclose the following material facts: the present and potential value of the Company’s assets and shares, as well as the makeup of those assets and the Company’s individual investments; the nature of any claims that Defendants are requiring investors to release as a condition to the acceptance of any tendered shares; the nature, scope and subject matter of the U.S. regulatory inquiry to which Citigroup is responding as well as any related civil litigation; and the events leading up to the investors’ massive losses, the Tender Offer and the wind-up and liquidation of the Company’s assets and operations. The Court has not yet set a date for Plaintiff’s preliminary injunction motion and there can be no assurance that the Court will set a date for the injunction hearing. If the Tender Offer is not enjoined by the Court (or voluntarily extended by Defendants), it will expire according to its terms on June 30, 2008.

The plaintiff is represented by Coughlin Stoia, which has expertise in prosecuting investor class actions and extensive experience in actions involving financial fraud.

Coughlin Stoia, a 190-lawyer firm with offices in San Diego, San Francisco, Los Angeles, New York, Boca Raton, Washington, D.C., Philadelphia and Atlanta, is active in major litigations pending in federal and state courts throughout the United States and has taken a leading role in many important actions on behalf of defrauded investors, consumers, and companies, as well as victims of human rights violations. The Coughlin Stoia Web site (http://www.csgrr.com) has more information about the firm. Contact: Coughlin Stoia Geller Rudman & Robbins LLP Samuel H. Rudman, 800-449-4900 David A. Rosenfeld djr@csgrr.com