Citigroup Entities in Successful Dismissal of HealthSouth Securities Law Claims

March 31, 2006

Cleary Gottlieb successfully obtained a dismissal for its clients, Smith Barney Inc., Salomon Brothers Inc. and Salomon Smith Barney Inc. in a class action filed in the United States District Court for the Northern District of Alabama. The plaintiffs, HealthSouth stockholders, alleged that the named Citigroup entities had violated sections of the Exchange Act by participating in several private placements of HealthSouth notes totaling approximately $2 billion, advising HealthSouth on various mergers, and issuing equity analysts research reports about HealthSouth. Judge Karon Owen Bowdre granted Cleary’s motion to dismiss all claims for failure to state a claim.