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ED
ON
312512009
I
UBS
AG
and
UBS
SECURITIES LLC,
Plaintiffs,
-
gainst
-
JATIN
SURYAWANSHI,
PARTHA
SARKAR,
and
SANJAY
GIRDHAR,
Defendants.
0’
UMMONS
Index
No.
Date purchased: March
24,2009
Plaintiffs designate New YorkCounty as the place of trial.The basis
of
venue is, inter alia,plaintiffs’ place of business in NewYork County.
TO THE ABOVE-NAMED DEFENDANTS:
YOU
AREHEREBYSUMMONED
to answer the complaint in this action andto serve a copy of your answer, or, if the complaint is not served with the summons, to serve anotice of appearance, on plaintiffs’ attorneys within twenty
(20)
days after service
of
this
summons,
exclusive of the day of service, if this summons is personally delivered to you withinthe State
of
New York,
or
within thirty
(30)
days after service is complete,ifthis summons is ntpersonally delivered to
you
within the State
of
New
York.
Your time to appear may be extendelas provided
in
subdivision
(b)
of CPLR
3012.
In the event of your failure to appear
or
answer,judgment may be taken against you by default for the relief demanded in thewmplaint.Dated: March
24,2009
B
-
Adam J. Safer
LCeG;
Claire
L.
Huene
250
Park AvenueNew York, New York 10177
Attorneys
for
Plaintifs
(212)
336-3500
Supreme Court Records OnLine Library - page 1 of 18
TO:
Jatin Suryawanshi
25
Bracchi DriveStamford,
CT
06903Partha Sarkar57 Acre View DriveStamford, CT
06903
Sanj
ay Girdhar25 Church Street
Pleasantville,
NY
10570
2
Supreme Court Records OnLine Library - page 2 of 18
SUPREME
COURT
OF
THE STATE
OF
NEW
YORKCOUNTY
OF
NEW
YORK
UBS
AG and
UBS
SECURITIES LLC,
Plaintiffs,
-
gainst
-
JATIN
SURYAWANSHI,
PARTHA
SARKAR,
and
SANJAY
GIRDHAR,
Index
No.
COMPLAINT
Q9
Defendants.Plaintiffs
UBS
AG
and UBS Securities LLC (collectively,
“UBS”),
y theirundersigned attorneys, as their complaint against defendants Jatin Suryawanshi (“Suryawanshi”),Partha Sarkar (“Sarkar”), and Sanjay Girdhar (“Girdhar”), allege as follows:
Preliminarv
Statement
1.
This emergency action for injunctive relief arises outofthemisappropriation of trade secrets, breach
of
contract, breach of fiduciary duty, unfair competitionand other wrongdoing by three
of
its employees, Suryawanshi,
Sarkar
and
Girdhar. Defendantshave collectively coordinated and planned together to move to
a
UBS
ompetitor, taken
UBS
trade secrets
-
ncluding more than
25,000
physical lines
of
source code for
UBS’
rade secretalgorithmic trading programs
-
deleted documents from
UBS
omputers to hide their acdand commenced performing services for their new employer, Jefferies
&
Cornpany$&f!.
R
e
eo
+
“Jefferies”) while still
UBS
mployees.
m
%-~s*.o
*r
From defendants’ actions, it is clear that they intend to disclose,
%
wy
-
.
i
‘et
have already disclosed, vital
UBS
rade secrets, confidential and proprietary information
to
Jefferies. They
are
also in flagrant violation
of
the notice periods (the “Notice Periods”)
in
theircontracts with
UBS,
ursuant to which they remain
UBS
mployees until April
5,2009
for
Supreme Court Records OnLine Library - page 3 of 18
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