Fiat Chrysler Automobiles N.V. Securities Litigation:

Jung Kyoon Kong, et al. v. Fiat Chrysler Automobiles N.V., et al.

Filing Date: December 02, 2019

Case Summary: CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS

According to the Complaint, Fiat Chrysler Automobiles N.V., with its subsidiaries, designs, engineers, manufactures, distributes, and sells vehicles, components, and production systems. The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) Fiat employed a bribery scheme to obtain favorable terms in its collective bargaining agreement with International Union, United Automobile, Aerospace and Agricultural Implement Workers of America; (2) high-ranking Fiat officials were aware of and authorized the scheme; and (3) due to the foregoing Defendants statements about Fiats receivables, business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Plaintiff, on behalf of himself and the Class, prays for judgment and relief as follows:

(a) declaring this action to be a proper class action, designating plaintiff as Lead Plaintiff and certifying plaintiff as a class representative under Rule 23 of the Federal Rules of Civil Procedure and designating plaintiffs counsel as Lead Counsel;

(b) awarding damages in favor of plaintiff and the other Class members against all defendants, jointly and severally, together with interest thereon;

awarding plaintiff and the Class reasonable costs and expenses incurred in this action, including counsel fees and expert fees; and

(d) awarding plaintiff and other members of the Class such other and further relief as the Court may deem just and proper.

Plaintiff hereby demands a trial by jury.

First Identified Complaint: Jung Kyoon Kong,

COURT: E.D. New York DOCKET #: 19-CV-06770 JUDGE: Hon. Frederic Block

DATE FILED: 12/02/2019 CLASS PERIOD START:02/26/2016 CLASS PERIOD END: 11/20/2019

PLAINTIFF LAW FIRMS NAMED IN COMPLAINT: The Rosen Law Firm, P.A. (NY)

Instructions and Questions (Identify your answers using the numbers and letters of the questions):

1. Parties to the case:
   1. Who is pleading the case?
   2. Who is answering the case?
2. What category of Law does this case fall under (explain), i.e.:
   1. Public Law or private Law or both?
   2. Civil case or criminal case or both?
3. Resolving/Settling the case:
   1. What other options do the parties have for settling this case, apart from the court?
   2. Would you recommend those other options to the parties? Why or why not?
4. State the burden of proof in this case:
   1. What does/do the plaintiffs have to prove and to what level?
   2. What does/do the defendants have to prove and to what level?
5. You have been engaged as a forensic accountant for the plaintiffs. What standards or rules do you have to meet to ensure that you and your opinions are admissible during the case trial?