emotional injury inflicted upon plaintiff by Defendants (Defendants engaged in a deliberate course
of
action to cause Plaintiff emotional and financial harm in an effort to, among other things, (a)force Plaintiff into a settlement agreement to insulate the corporation and individuals from furtherlegal liability, (b) retaliate against Plaintiff for raising concerns about various unethical and possiblyillegal practices at the firm, and (c) to force Plaintiff into a confidentiality agreement that wouldpreclude Plaintiff from exercising rights to publicly discuss past unethical and possibly illegal be-havior by the Corporate Officers), and (8) the tortious interference with business advantage (theintentional impeding
of
business relationships by Defendants, Defendants, under fraudulentpretenses, intentionally impeded the communication and relationship
of
Plaintiff with otherassociates with full knowledge that such contacts are vital in the financial industry for, among otherthings, the search for future employment).
THE
PARTIES
2. A resident
of
New
York City (Brooklyn), Plaintiff worked for Defendants as an Analystfrom on or about March 1997 until on or about December 2000, and as a Trader and Portfolio Man-ager from on or about January 2001 until December 14, 2007. As a Trader and Portfolio Manager,the Plaintiff managed the Fixed Income futures portfolio in the
firm's
family
of
investment funds.
3.
Upon information and belief, Defendant International Foreign Exchange Concepts Incor-porated (a.k.a. FX-Concepts, hereafter
"IFEC,"
but also known as "FX-Concepts," and
"FXC")
wasand is a corporation organized and existing under the laws
of
the State
of
New
York, with an officeand headquarters and its principal place
of
business located at 225 West 34
th
Street, Suite 710,
New
York,
NY
10122. Defendant
"IFEC"
is a hedge fi.md-type entity that engages in the investment
of
funds for mostly institutional clients in primarily the foreign exchange and interest rate markets.4. Upon information and belief, Defendant John
R.
Taylor, an individual, was and is the
Chief
Executive Officer ("CEO")
of
"IFEC," with his principal place
of
residence located
in
Man-hattan,
New
York. Taylor is also, on information and belief, the majority shareholder
of"IFEC,"
and his principal place
of
employment is 225 West 34
th
Street, Suite
71
0,
New
York,
New
York10122.
5.
Given the refusal
of"IFEC"
and Defendant corporate officers to pay Plaintiff back paythat was earned by Plaintiff and owed to
Plaintiff
by
"IFEC,"
Plaintiff
is
unfortunately
unable
toafford the expensive
of
an investigation into more
detailed
background information on Defendantsat this time. Plaintiff anticipates curing any defects to this background information following dis-covery.
JURISDICTION AND VENUE
6.
This court has personal and subject matter jurisdiction over this case because (a) Plaintiffresides in the City and State
of
New
York, and in the County
of
Kings County, (b) upon informationand belief, Defendant
"IFEC's"
principal
place
of
business is located in the City and State
of
New
York, (c) upon information and belief, Defendant John
R.
Taylor's
principal
place
of
business, andhis residence,
is
located
in the City and State
of
New
York, and (d) the disputes raised hereby in-volve (i) Defendants' breach
of
an employment contract for the performance
of
services that wasprimarily negotiated and
entirely
performed in the City and State
of
New
York; (ii) the Breach
of
2
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