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PATRICIA
.
GLASER
State
Bar
No.
5668
pglaser~~
laserweil
om
G.
JILL
BASINGER
State
Bax
No.
195739
j
asinger@glaserweil.
com
RORY
.
MILLER
State
Bar
No.
23
780
rmiller~~ laserweil
om
GLASER
WEIL
FINK
HOWARD
AVCHEN
HAPIRO
LLP
10250
onstellation
Boulevard,
9th Floor
Los
Angeles,
alifornia
90067
Telephone:
310)
53-3000
Facsimile:
310)
56-2920
Attorneys
for
Plaintiff
William
H.
Gross
SUPERIOR
COURT OF
THE
STATE
OF
CALIFORNIA
FOR
THE
COUNTY
OF
ORANGE
WILLIAM
H.
GROSS
n
ndividual
Plaintiff
v.
PACIFIC
INVESTMENT
MANAGEMENTCOMPANY
LLC
Delaware
limited
liability
company,
ALLIANZ ASSET
MANAGEMENT
OF AMERICA
.P.
a
Delaware
limitedpartnership
and
DOES
-100
nclusive
Defendants.
Case
No.
Unlimited
Jurisdiction
COMPLAINT
FOR:
1)
CONSTRUCTIVE TERMINATION
2)
BREACH
OF
CONTRACT
3)
BREACH
OF
COVENANT
OF
GOOD
FAITH
AND
FAIR
DEALINGJURY
TRIAL
DEMANDED
1044676
COMPLAINT
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INTRODUCTION
1.
Driven
by
a
ust
for
power,
reed,
and
a
desire
to
improve
their
own
inancial
position
and
reputation at
the
expense
of
nvestors
and
decency,
a
abal
of
acific
Investment
Management
Company
LLC
PIMCO )
anaging
directors plotted
to
drive
founder
Bill
Gross
out
of
PIMCO
n
order
to
take,
without compensation,
ross's percentage
ownership
in the
profitability
of
PIMCO.
heir
improper,
ishonest,
and
unethical
behavior
must
now
be
exposed.
2.
Plaintiff Bill
Gross founded
defendant
PIMCO
ver
40
ears
ago and
has
been
intimately
connected
with
its
investment
ctivities
since
that
time.
As
a
founder
and
senior
executive,
as
well as
aworld-renowned
investor,
Mr.
Gross
eceived
substantial
income
as
PIMCO
grew
and
established
itself
as
one of
he
leading fixed
income
security
investment
irms
in
the
world.
3.
Mr.
ross's
ongoing
success
at
PIMCO
roved
to
be
his
undoing. In
the
minds of
certain
younger
executives
at
PIMCO,
r.
ross's
ongoing
presence
at
the
company
checked
their
ovum
financial
and
career
ambitions.
Under
PIMCO's
profit-sharing
plan
Mr.
Gross
was
ntitled
toreceive
20
f
he
entire
profit
shaxing
bonus
pool
each
year.
By
orcing
him
out
of
PIMCO,
he
younger
executives
would
split
Mr.
ross's
share
of
he
bonus
pool
amongst
hemselves.4.
In
addition
to receiving
compensation
consistent
with
his
skill
and
reputation,
Mr.
Gross
was
lso
well-known
as
an
advocate
for
PIMCO's
nvestors.
He
hampioned
reasonable
feesfor
PIMCO's
ervices
and
was
vocally
skeptical inside
the firm
of
a
elect
group
of
he
younger
executives'
desire
to
transform
PIMCO
nto
ahigh-risk,
high
-fee asset
-management
company
hat
invested
in
riskier
equities
and
leveraged
real
estate
investments, as
opposed
to
the
stable
bonds
hat
built
the firm's
reputation.
5.
As
ong
as
Mr.
Gross remained
at
the
company
he
founded,
hese
younger
executives
were
unable
to
transform
PIMCO,
ncreasing
client
risk
and
heir
own
ompensation.
As
consequence,
Mr.
Gross
became
he
taxget
of
a power
truggle
within
PIMCO
a
truggle that
eventually
led
to
his
wrongful
and
illegal
ouster
from
the
company
he
founded and
a
truggle
where
PIMCO
v~rongly
and
illegally
denied
Mr.
Gross hundreds
of
illions
of
ollaxs
in
earned
compensation.
1044676
1
COMPLAINT
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THE
ARTIES
6.
Plaintiff
William
H.
Gross
s
aworld-renowned
investment
manager
ocusing
on
bonds and
other
fixed
income
securities.
Over
his nearly
50
years
in
the
industry,
Mr.
Gross has
developed
a
towering
reputation that
has,
among
other
things,
ed
to
him
being
called
the
Bond
King by
he
financial
media.
At
ll
relevant
times,
Mr.
Gross
was
a
esident
of Orange
County,
California.
7.
Defendant
PIMCO
s
a
Delaware
imited
liability
company
with
a
rincipal
place
of
business
at
650
Newport
enter Drive,
Nevv~port
Beach,
alifornia.
8.
Defendant
Allianz
Asset
Management
of America
L.P.
is
a
Delaware
limitedpartnership
with
a
principal
place
of
usiness
at
6$0
Newport
enter
Drive,
Newport
Beach,
California.
9.
Defendants
Does
1
through
100,
nclusive,
are
sued
herein
under
ictitious
names.
Their
true
names
and
capacities
axe
unknov~m
to
Plaintiff.
When
heir
true
names
and
capacities
areascertained,
Plaintiff
will
amend
his
complaint
by
nserting their true
names
and
capacities herein.
Plaintiff
s
informed
and
believes,
and
on
hat basis
alleges,
that
each
of
he
fictitiously
named
defendants
is
the
agent,
servant,
employee,
epresentative, partner,
and
j
int-venturer
of
heir
co-
defendants,
and
in
doing
the things herein
alleged
was
cting
within the
course
and
scope
of
uchagency,
employment,
epresentation, partnership,
and
j
int
venture with the
knowledge,
ermission
and
consent
of
heir
co-defendants,
and
so
ratified
ll
of
heir
acts
and
conduct. Therefore,
each
Doe
Defendant
s
responsible
in
some
manner
or the
occurrences
herein
alleged,
and
Plaintiff
amages
as
herein
alleged
were
proximately
caused
by
aid
defendants.
10.
At
ll
relevant
times,
each
Defendant
was
he
agent
of
he other
Defendants
and
was
at
ll
times
acting
within
the
purpose
and
scope
of
such agency.
Moreover,
n
committing
the
acts
and
omissions
asserted herein,
Defendants,
and
each
of hem, were
acting
in concert
together,
n the
course
and
scope
of
heir
respective
relationship
with
each
other,
whether as
employees,
gents,
representatives,
independent
contractors,
providers,
service
providers,
as agents
or
representatives
of
each
other, respectively,
or as
oint venturers, co-conspirators
or
otherwise.
1044676
COMPLAINT
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