Class Action Suit Filed Against Salomon Smith Barney, Citigroup and Travelers Group

June 19, 2001

The law firm of Dwyer & Collora LLP announced that on Friday, June 8, 2001, Federal Judge Robert E. Keeton of the U.S. District Court of Massachusetts certified state classes for four states, including Massachusetts and Connecticut, in a suit filed against Salomon Smith Barney Inc., Citigroup Inc. and Travelers Group Inc.

The lawsuits allege that the defendant companies have illegally required employees to forfeit wages when they leave their employment, under the terms of a compensation program termed the “Capital Accumulation Plan” or “CAP Plan.”

The Massachusetts and Connecticut lawsuits seek to enforce state wage statutes that give employees a non-waivable right to be paid their full wages upon departure. These statutes impose treble damages (in Massachusetts) or double damages (in Connecticut) and attorneys’ fees against employers who violate the law.

Based on information provided by the defendants, more than 100 employees can currently claim approximately $12 million dollars in damages under the Massachusetts wage statute. Approximately 100 Connecticut employees can currently claim an estimated $6 million dollars under their state statute. The law firm stated that it expects the number of employees in each class and the total amount of damages due to increase over time.

Similar suits have been filed in New Jersey and California, and representatives in other states have yet to step forward.

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