FILED: NEW YORK COUNTY CLERK 05/23/ :18 PM INDEX NO /2013 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 05/23/2017. Exhibit B
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3 Name of Case: State of New York ex rel. Eric Rasmusen v. Citigroup Inc., Index No /2013 (Sup. Ct. N.Y. Cty.) (Ramos, J.) Date of Hearing: May 17, 2017 ERRATA SHEET 2 4 York, has York. Has Typographical Error 2 7 Ed Polubinski. Ted Polubinski Ed Polubinski, Ted Polubinski from Citigroup. for Citigroup business business and public policy professor 2 20 his taxes its taxes transactions, the creditor transactions that he engaged in 3 7 I.R.S., which Citi relied on, expressly says that they were not to. Citigroup engaged in I.R.S. Notices, which Citi relied on, expressly say that they were not changes in control tax recording is correct. tax reporting was correct. 4 7 New York Law New York False Claims Act 4 10 until the relator is an unless the relator is an original source original source paper, itself based paper, itself based entirely on public facts entirely on public facts, that alleges that alleges Typographical Error 4 26 alone suggests that he alone alleges that Citi s alone alleges the Citi s 5 5 a relator should take a relator could take 5 11 in is , the quoted The quote 5 13 the fraud is already in a fraud are already in the public public 5 16 doubt, substantially, doubt that substantially 5 22 state operating losses state net operating loss deductions. deductions the Citi Citi 6 4 complaint. policy paper the public disclosure the public disclosure bar would would 6 16 own paper. own policy paper wrongfully wrongly
4 6 22 Jamaica The Jamaica 7 24 and some bedrock under bedrock that; reported that; it reported (k)(1) 1453(k-1) Typographical Error 8 18 imply apply 8 23 claim of accuracy claimed inaccuracy 8 23 it s its Typographical Error 8 24 claim of accuracy claimed inaccuracy 9 9 Michaelson Michaelsen Typographical Error 9 10 that New that New Typographical Error 9 12 possible, and possible, and Typographical Error 9 24 from for rules the rules Citigroup, Citigroup Typographical Error it s its Typographical Error Court to dismiss Court dismiss Hodgson Hodgson Russ adhere hew it its Typographical Error 12 2 adduced deduced 12 6 adduced deduced findings filings , 1453, 13 3 was attached to my was not attached to my affirmation as affirmation as was k not satisfactory 10-K not satisfy 15 7 Providing such provided that such information information Or any Or under any satisfactory satisfy K s 10-K satisfactory satisfy 16 6 the action a qui tam action 16 7 state the state the Typographical Error 16 8 position or position or Typographical Error 16 9 the plaintiff the qui tam plaintiff information. They re information. He s not. not there is s there s this (b)(2) 190(9)(b)(ii) SEC rules. SEC reports receives requests qualify for qualify as Congressional report Congressional reports 2
5 17 24 we re the provider there s a provided that reckless recklessness you your your 22 5 What other, What, other Typographical Error (k)(1) 1453(k-1) Typographical Error what and Maybe not. If they are not, Your Honor can cut me off the Citi s Citi s Bosch Bosh Typographical Error states state 3
26 DENISE M. PATERNOSTER, RPR Senior Court Reporter Denise M. Paternoster, RPR - Senior Court Reporter
1 1 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK - CIVIL TERM - 53 3 ------------------------------------------------x THE STATE OF NEW YORK ex rel. 4 ERIC RASMUSEN, 5 Plaintiff, 6 -against-
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