In another high profile matter tied to the subprime mortgage crisis, the Firm represented the Public Employees Retirement Association of Colorado and the Tennessee Consolidated Retirement System, as representative parties in a class action alleging federal securities law violations against Citigroup Inc. and certain officers and directors for failure to report and/or disclose exposure to tens of billions of dollars in collateralized debt obligations and other subprime mortgage-backed derivative instruments.  As discovery efforts would ultimately prove, the values of these assets were seriously overstated due to mortgage defaults and other impairments, and rendered untrue Citigroup’s representation that it had “limited continuing involvement” with such CDO instruments.  Through direct ownership of tens of billions of CDO’s and undisclosed liquidity puts, Citigroup had also agreed to repurchase much of these positions.  Such exposure required timely write downs so as not to inflate Citigroup’s reported assets, revenues and earnings during the relevant period.  This litigation involved the most complex financial instruments and mortgage secularization products, and implicated difficult valuation and accounting issues respecting one of the largest institutions in our global financial markets.  After a lengthy period of fact and expert discovery and lengthy mediation proceedings led by our institutional clients, Citigroup agreed to settle the class action claims for $590 million in 2012.  This settlement is one of the largest civil action recoveries arising out of the subprime mortgage-related financial crisis.