1:13-Cv-07089-UA
Case 1:13-cv-07089-ALC-SN Document 1 Filed 10/04/13 Page 1 of 85 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK KEVIN McDONNELL, ANTHONY INSINGA, ROBERT MICHIELS and JOHN DEVIVO, on behalf of themselves and all Case No.: ___________________ others similarly situated, ECF Case Plaintiffs, CLASS ACTION COMPLAINT v. JURY TRIAL DEMANDED ROYAL DUTCH SHELL PLC, BP PLC, STATOIL ASA, MORGAN STANLEY, TRAFIGURA BEHEER B.V., TRAFIGURA AG, PHIBRO TRADING LLC, VITOL, S.A. and JOHN DOES 1-50, Defendants. Based upon investigation of counsel from publicly available information including information about prices, the North Sea Brent Crude Oil market, the European Commission (―EC‖) and other investigations relating to violations of the Platts Market-On-Close price assessment process, reports published by and on behalf of the International Energy Agency, the International Energy Forum, the Organization of Petroleum Exporting Countries and the International Organization of Securities Commissions (―IOSCO‖), Plaintiffs allege, upon knowledge as to themselves and their own acts, and upon information and belief as to all other matters, as follows: I. NATURE OF THE ACTION 1. This action arises from a manipulation of North Sea Brent Crude Oil (as defined herein) and related markets by Defendants Royal Dutch Shell plc (―Shell‖), BP plc (―BP‖), Statoil ASA (―Statoil‖), Morgan Stanley, Trafigura Beheer B.V., Trafigura AG, Phibro Trading LLC (―Phibro‖), Vitol, S.A. (―Vitol‖) and others during the period of at least 2002 through the present (the ―Class Period‖). Case 1:13-cv-07089-ALC-SN Document 1 Filed 10/04/13 Page 2 of 85 2.
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