Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

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1 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CLIFFORD JAGODZINSKI, Plaintiff, vs. MORGAN STANLEY SMITH BARNEY, LLC, MORGAN STANLEY & CO. INCORPORATED, CITIGROUP INC., Civil Action No. 12-CV-5891 (DLC) ELECTRONICALLY FILED Defendants. DEFENDANTS MORGAN STANLEY SMITH BARNEY LLC S AND MORGAN STANLEY & CO. LLC S ANSWER AND DEFENSES Defendants Morgan Stanley Smith Barney LLC ( MSSB ) and Morgan Stanley & Co. LLC (formerly known and incorrectly sued as Morgan Stanley & Co. Incorporated) (collectively, Defendants ), by and through their attorneys, Morgan, Lewis & Bockius LLP, hereby answer the Complaint of Plaintiff Clifford Jagodzinski by admitting, denying, and averring as follows: GENERAL ALLEGATIONS 1. Defendants admit that Plaintiff s employment with MSSB was terminated on April 13, Defendants deny the remaining allegations in Paragraph 1 of the Complaint. 2. Defendants deny the allegations in Paragraph 2 of the Complaint. PARTIES 3. Defendants admit that MSSB s records reflect a last-known address for Plaintiff in New York. Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining allegations in Paragraph 3 of the Complaint and, on that basis, deny such allegations. 4. Defendants admit that Morgan Stanley & Co. LLC is a Delaware limited liability company with its headquarters in New York, New York. The allegation in Paragraph 4 as to the

2 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 2 of 9 principal place of business of Morgan Stanley & Co. LLC calls for a legal conclusion to which no response is necessary. 5. Defendants admit that MSSB is a Delaware limited liability company. The allegation in Paragraph 5 as to the principal place of business of MSSB calls for a legal conclusion to which no response is necessary. Defendants deny the remaining allegations in Paragraph 5 of the Complaint. JURISDICTION AND VENUE 6. Defendants admit that Plaintiff purports to bring this case as an action for unlawful retaliation under the Dodd-Frank Act, but deny that they have engaged in any wrongdoing towards Plaintiff, deny that he may recover any relief in this action, and deny the remaining allegations in Paragraph 6 of the Complaint. 7. The allegations in Paragraph 7 of the Complaint call for legal conclusions to which no response is necessary. 8. The allegations in Paragraph 8 of the Complaint call for legal conclusions to which no response is necessary. GENERAL ALLEGATIONS 9. Defendants admit that Plaintiff worked first at Morgan Stanley & Co. LLC (then known as Morgan Stanley & Co. Incorporated), and then worked at MSSB, and that, at certain times, he held the title of Complex Risk Officer. Defendants deny the remaining allegations in Paragraph 9 of the Complaint. 10. Defendants admit that Mr. Jagodzinski s job duties included identifying compliance risk issues and potential securities law violations. Defendants deny the remaining allegations in Paragraph 10 of the Complaint. 2

3 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 3 of Defendants deny the allegations in Paragraph 11 of the Complaint. 12. Defendants deny the allegations in Paragraph 12 of the Complaint. 13. Defendants deny the allegations in Paragraph 13 of the Complaint. 14. Defendants deny the allegations in Paragraph 14 of the Complaint. 15. Defendants admit that in December 2011, Plaintiff was asked to investigate certain trades executed in the accounts of clients serviced by members of Harvey Kadden s team and that he discussed these trades with Mr. Turetzky and Mr. Firestein. Both Mr. Turetzky and Mr. Firestein fully supported the investigation of these trades by Plaintiff and others who were also asked to investigate and provide guidance concerning these trades. Defendants deny the remaining allegations in Paragraph 15 of the Complaint. 16. Defendants deny the allegations in Paragraph 16 of the Complaint. 17. Defendants deny the allegations in Paragraph 17 of the Complaint. 18. Defendants admit that in or about September 2011, Plaintiff investigated a client complaint against Bill Siegel, and that Mr. Siegel acknowledged that he had placed trades in certain accounts without speaking to the clients first. Defendants deny the remaining allegations in Paragraph 18 of the Complaint. 19. Defendants deny the allegations in Paragraph 19 of the Complaint. 20. Defendants deny the allegations in Paragraph 20 of the Complaint. 21. Defendants admit that Mr. Turetzky told Plaintiff that he did not want to see Mr. Siegel lose his job because he was a stand-up guy, and that MSSB has not paid restitution to any clients serviced by Mr. Siegel. Defendants deny the remaining allegations in Paragraph 21 of the Complaint. 22. Defendants deny the allegations in Paragraph 22 of the Complaint. 3

4 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 4 of Defendants admit that Plaintiff previously reported that he had called one of Mr. Paesano s clients and asked about his account and certain trades in his account, and that the client had told him that the account was a discretionary account. Defendants deny the remaining allegations in Paragraph 23 of the Complaint. 24. The allegations in Paragraph 24 of the Complaint call for legal conclusions to which no response is necessary. 25. Defendants deny the allegations in Paragraph 25 of the Complaint. 26. The allegations in Paragraph 26 of the Complaint call for legal conclusions to which no response is necessary. 27. Defendants deny the allegations in Paragraph 27 of the Complaint. 28. Defendants admit that Plaintiff s employment with MSSB was terminated on April 13, 2012, and that he was offered a severance package conditioned upon his execution of a standard separation agreement, which would have included a standard release and standard provisions relating to confidentiality and non-disparagement. Defendants deny the remaining allegations in Paragraph 28 of the Complaint. 29. Defendants deny the allegations in Paragraph 29 of the Complaint. 30. Defendants admit that Plaintiff s Form U-5 truthfully and accurately states that Plaintiff was terminated because of MANAGEMENT DISSATISFACTION WITH EMPLOYEE S PERFORMANCE AS A RISK OFFICER OVER A PERIOD OF TIME, INCLUDING COMMUNICATION AND RESPONSIVENESS. Defendants deny the remaining allegations in Paragraph 30 of the Complaint. 4

5 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 5 of Defendants admit that Plaintiff received periodic performance reviews during his employment with each Defendant. Defendants deny the remaining allegations in Paragraph 31 of the Complaint. 32. Defendants deny the allegations in Paragraph 32 of the Complaint. 33. The allegations in Paragraph 33 relating to Section 922 of the Dodd-Frank Act call for legal conclusions to which no response is necessary. Defendants deny the remaining allegations in Paragraph 33 of the Complaint. FIRST CAUSE OF ACTION (Alleged Violation of Dodd-Frank Whistleblower Statute) 34. Defendants incorporate by reference and reallege each of the responses set forth above. 35. The allegations in Paragraph 35 call for legal conclusions to which no response is necessary. 36. The allegations in Paragraph 36 call for legal conclusions to which no response is necessary. 37. The allegations in Paragraph 37 call for legal conclusions to which no response is necessary. 38. Defendants deny the allegations in Paragraph 38 of the Complaint. 39. Defendants deny the allegations in Paragraph 39 of the Complaint. 40. Defendants admit that on April 13, 2012, Plaintiff s employment with MSSB was terminated. Defendants deny the remaining allegations in Paragraph 40 of the Complaint. 41. Defendants deny the allegations in Paragraph 41 of the Complaint. 42. Defendants deny the allegations in Paragraph 42 of the Complaint. 5

6 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 6 of 9 PRAYER FOR RELIEF Defendants deny that Plaintiff is entitled to any relief in this action, including that which is sought in the Prayer for Relief in the Complaint (subparagraphs (A)-(G)). GENERAL DENIAL Defendants deny each and every allegation in the Complaint that has not otherwise been specifically admitted or denied herein. DEFENSES 1. The Complaint fails, in whole or in part, to state a claim upon which relief can be granted. 2. The Complaint fails to allege any basis for liability against Morgan Stanley & Co. LLC, and there is no basis for any such liability. 3. The conduct alleged by Plaintiff is not protected by Section 922 of the Dodd- Frank Act. 4. Plaintiff s claims are barred, in whole or in part, by his failure to exhaust administrative remedies. 5. The relief sought by Plaintiff is barred to the extent it exceeds the relief available under Section 922 of the Dodd-Frank Act. 6. Each and every action taken by Defendants with regard to Plaintiff was based on legitimate, non-discriminatory, non-retaliatory reasons. 7. Plaintiff s claims are barred, in whole or in part, because each and every alleged action of Defendants was protected by a privilege and was justified. 8. Defendants, at all relevant times, made a good faith effort to comply with all applicable statutes and laws, and Plaintiff therefore cannot recover punitive damages. 6

7 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 7 of 9 9. Damages, if any, sustained by Plaintiff were solely and proximately caused by Plaintiff s own negligent, reckless, or intentional conduct. 10. Plaintiff s claimed damages are barred to the extent that he has mitigated, or failed to mitigate, his alleged damages. 11. The Complaint is barred, in whole or in part, by the doctrines of res judicata and/or collateral estoppel. 12. Plaintiff s claims are barred, in whole or in part, by the applicable statute of limitations. 13. Plaintiff s claims are barred, in whole or in part, by laches, estoppel, unclean hands, offset, set off, and other equitable defenses. 14. Plaintiff s claims are barred, in whole or in part, by the after-acquired evidence doctrine. 15. Plaintiff s claims are barred, in whole or in part, because Defendants took reasonable steps to prevent the conduct alleged in the Complaint, Plaintiff unreasonably failed to use the preventive and corrective measures that Defendants provided, and reasonable use of Defendants procedures would have prevented at least some of the harm that Plaintiffs allegedly suffered, if any. RESERVATION OF RIGHTS Defendants reserve the right to assert additional defenses as Plaintiff s claims are clarified in the course of this litigation. WHEREFORE, Defendants demand judgment as follows: A. Dismissing the Complaint in its entirety. 7

8 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 8 of 9 B. Granting Defendants their costs, disbursements, and attorneys fees incurred in this action; and C. Granting such other and further relief as the Court deems just and proper. Dated: September 7, 2012 New York, New York Respectfully submitted, /s/ Andrew J. Schaffran Andrew J. Schaffran Thomas A. Linthorst Amir J. Vonsover Morgan, Lewis & Bockius LLP 101 Park Avenue. New York, NY (facsimile) Attorneys for Defendants Morgan Stanley Smith Barney LLC and Morgan Stanley & Co. LLC 8

9 Case 1:12-cv DLC Document 11 Filed 09/07/12 Page 9 of 9 CERTIFICATE OF SERVICE I hereby certify that on this 7th day of September, 2012, a copy of Defendants Answer and Defenses to Plaintiff s Complaint was served via the electronic case filing (CM/ECF) system and first-class mail, postage pre-paid, as follows: Rishi Bhandari Evan Mandel Benjamin R. Delson Mandel Bhandari LLP 11 Broadway Suite 615 New York, NY /s/ Amir J. Vonsover Amir J. Vonsover

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