SUPREME COURT OF THE STATE OF NEW YORK. COUNTY OF NEW YORK PASHA S. ANWAR and JULIA ANWAR, on behalf of themselves and all other similarly situated investors in the Greenwich Sentry, LP, 68603769 private investment limited partnership, X INDEX NO. 08/ PLAINTIFFS, ~ against ~ CLASS ACTION COMPLAINT JURY TRIAL DEMANDED PAIRFIELD GREENWICH GROUP, FAIRFIELD GREENWICH LIMITED, a i Cayman Islands company, FAIRFIELD GREENWICH (BERMUDA) LTD., Q g FAIRFIELD GREENWICH ADVISORS LLC, & WALTER M. NOEL, JR., ANDRES WW PIEDRAHITA, JEFFREY TUCKER, BRIAN wed a Ss FRANCOUER, and AMIT VIAYVERGIYA, er : § -x Plaintiff, by and through ther attorneys Lovell Stewart Halebian LLP, file this class action Complaint seeking relief as prayed for herein and allege as follows: NATURE OF THE ACTION 1, This is a class action for breaches of fiduciary duty, negligence and unjust ccorichment arising out of defendants’ mismanagement of the investmonts of plaintiffs and other members of the proposed class. Plaintiffs and other class members entrusted defendants with the ‘management and protection of their investment assets, Defendants breached this duty. Defendants owed plaintifis and the Class a fiduciary duty to protect and manage these assets with care, diligence and the highest degree of good faith. As a direct result of defendants’ unlawful conduct alleged herein, plaintiffs and the Class suffered avoidable losses and defendants were unjustly enriched.JURISDICTION AND VENUE 2 This Court has personal jurisdiction over defendants pursuant to CPLR §§ 301 and 302(@). Venue lies in New York County pursuant to CPLR § 503 because, emong other ‘hings, (a) one ot more defendants reside inthis County, () the principal place of business of one or more defendants is inthis County, and (c) parts ofthe unlawful conduct complained of occurred in this County, PARTIES Plaintiffs 3, Plaintifis PASHA S, ANWAR and JULIA ANWAR (*Plaintifis”) are residents of Ulinois and are owners of an equity interest in the Greenwich Sentry, L.P., a Delaware Jimited Patinership operating as 2 private investment limited partnership (“Greenwich Sentry"), which ‘Rey purchased in or about May 2007. Plaintiffs previously owned an equity interest in the Faitfield Sentry Fund (“Fairfield Sentry”), 4 Plaintiffs and each member ofthe Class purchased equity interests in Greenwich Sentry and/or Fairfield Sentry and stil held equity interests in Greenwich Sentry and/or Fairfield Sentry through December 10, 2008, the last day before the revelations regarding the massive ‘Faudalent activities of Bernard L. Madoff and Bemard L. Madoff Investment Securities LLC began to be made public (the “Class Period”), Defendants 5. Defendant FAIRFIELD GREENWICH GROUP was founded in 1983 and has its Principal place of business in New York City (hereafter referred to as “FGG", and together with ‘efendants listed in Paragraphs 6 through 13 herein, the “FG Defendants"), 6. Defendant FAIRFIELD GREENWICH LIMITED (hereinafter referred to as “FGLimited”) is an exempted company organized under the laws of the Cayman Islands and served as the general partner of Greenwich Sentry from its inception until March 1, 2006. FG Limited is an affiliate of FGG. 7. Defendant FAIRFIELD GREENWICH (BERMUDA) LTD. (hereinafter referred, to as “FG Bermuda”) was organized as a corporation under the laws of Bermuda on June 13, 2003 and became the general partner of Greenwich Sentry effective March 1, 2006. FG Bermuda registered as an investment advisor under the Juvestment Advisers Act of 1940, a5 amended, effective April 20, 2006. FG Bermuda’s stated office address is Suite 606, 12 Church Street, Hamilton, Bermuda. 8 Defendant FAIRFIELD GREENWICH ADVISORS LLC (hereinafter referred to as “FG Advisors”) is an affiliate of FGG and FG Bermuda, and has its principal offices at 55 East 52 Street, New York, New York. FG Advisors provides Fairfield Sentry and Greenwich Sentry with certain administrative services and back-office support. 9. Defendant WALTER M. NOEL, JR. (hereinafter referred to as “Noel”), is @ Founding Partner of FGG, and according to FGG’s own description, continues to oversee all of FGG's activities with defendants Piedrahita and Tucker. He is a member of the Board of Directors of FGG and serves as a Director for many FGG funds and management company entities, Upon information and belief, defendant Noel resides on Park Avenue in New York City. 10. Defendant ANDRES PIEDRAHITA (hereinafter referred to as “Piedrahita”) is 2 Founding Partner of FGG. He is a member of the Executive Committee of FGG and serves as a Director for many FGG funds and management company entities. He also serves as President and as a Director of Greenwich Sentry’s General Partner, FG Bermuda.