Evidence

Evidence

DocumentDescription

Expert Reports of Richard Knight

Expert Reports of Richard Knight

Richard Knight is an expert in foreign exchange (FX) markets and FX trading. Mr Knight’s report will assist the Tribunal with expert evidence relating to, inter alia, the structure and operation of FX markets and the relevant FX instruments.

Copies of Mr Knight’s reports are available on request by emailing enquiries@fxclaimuk.com.

Expert Reports of Professor Dagfinn Rime

Expert Reports of Professor Dagfinn Rime

Dagfinn Rime is a Professor of Finance at the BI Norwegian Business School in Oslo. Professor Rime’s report considers, inter alia, the impact of the FX cartels identified in the Commission’s decisions.

Copies of Mr Rime’s reports are available on request by emailing enquiries@fxclaimuk.com.

Expert Reports of John Ramirez

Expert Reports of John Ramirez

John Ramirez is an economist and a Managing Director of Econ One Research Inc, an economic consulting firm. Mr Ramirez is an expert competition economist and will assist the Tribunal with expert evidence covering, inter alia, the quantification of damages suffered by members of the proposed classes.

Copies of Mr Ramirez’s reports are available on request by emailing enquiries@fxclaimuk.com.

First Witness Statement of Phillip Gwyn James Evans and Exhibits

First Witness Statement of Phillip Gwyn James Evans (PGE)

Mr Evans’ witness statement explains the reasons he wishes to act as class representative in this proposed claim. It also explains the reasons why Mr Evans considers that he has the skills and resources necessary to take on the role of class representative and to act fairly and adequately in the interests of class members.

It includes information about the steps that Mr Evans proposes to take to manage the claim, which are further set out in the detailed Litigation Plan (available to download below). Mr Evans’ witness statement also provides further detail regarding the funding and insurance arrangements put in place to fund the claim.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Exhibit PGE1 – CV of Phillip Gwyn James Evans

Mr Evans’ CV contains details of his background and experience.

Exhibit PGE2 – Consultative Panel Terms of Reference

This document provides further information regarding the Consultative Panel that Mr Evans has appointed to assist him in managing the claim. The current members of the consultative panel are Lord Carlile of Berriew CBE QC, Professor Philip Marsden and David Woolcock.

Exhibit PGE3 – Litigation Plan

The Litigation Plan sets out how Mr Evans and his legal advisers will ensure that the proposed claim will be effectively and efficiently pursued in the interests of the proposed classes, including how Mr Evans will ensure that he communicates effectively with members of the proposed classes.

Annex 1 to Litigation Plan – Notice and Administration Plan

The Notice and Administration plan has been prepared by Angeion Group, an experienced class action and administration company which has been engaged by Mr Evans. The Angeion Plan is focused on explaining how those persons within the proposed classes will be made aware of the proposed claim and appropriately targeted with any relevant notices.

Annex 2 to Litigation Plan – Proposed Timetable

The Proposed Timetable contains an estimated timeframe for the progress of the proposed claim.

Annex 3 to Litigation Plan – Costs Budget

The Costs Budget sets out estimates of the costs involved in bringing the proposed claim and administering the claim on behalf of the classes.

Second Witness Statement of Phillip Gwyn James Evans and Exhibits

Second Witness Statement of Phillip Gwyn James Evans

Mr Evans’ second witness statement explains why, from his experience, it would be neither practicable nor desirable to bring the claim on an opt-in basis.

Mr Evans also addresses why he is suitable to act as class representative, including his relevant experience and the steps he has taken to put in place adequate funding and insurance arrangements.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Exhibit PGE11 – Consultative Panel Terms of Reference

This document provides updated information regarding the Consultative Panel that Mr Evans has appointed to assist him in managing the claim. As well as Lord Carlile of Berriew CBE QC, Professor Philip Marsden and David Woolcock, the panel also now includes Professor Joseph Stiglitz, a Nobel Prize-winning economist, public policy analyst and professor at Columbia University.

First Witness Statement of Anthony John Maton and Exhibit

First Witness Statement of Anthony John Maton (AJM)

The Tribunal’s assessment of Mr Evans’ application for a CPO may include consideration of the experience of Mr Evans’ legal representatives. Anthony Maton is the managing partner of Hausfeld & Co LLP, the law firm that Mr Evans has instructed to represent him in his application for a CPO. Mr Maton provides information about his and Hausfeld’s experience and expertise.

Mr Maton’s statement also explains some of the steps that Hausfeld took to obtain the non-confidential versions of the European Commission’s decisions on Mr Evans’ behalf.

Exhibit AJM3 – Hausfeld & Co LLP profile and Counsel CVs

This includes a profile of Hausfeld’s relevant experience and professional biographies of each member of the team of barristers that Mr Evans has instructed. The barristers representing Mr Evans are Aidan Robertson QC, Victoria Wakefield QC, Joanne Box and Aaron Khan, all of Brick Court Chambers.

Second Witness Statement of Anthony John Maton

Second Witness Statement of Anthony John Maton (AJM)

Mr Maton’s second witness statement describes the amendments that were made to this proposed claim after Mr Evans received copies of the confidential versions of the European Commission’s decisions from the banks. Mr Maton also provides further information regarding Mr Evans’ funding arrangements, and explains that Mr Evans has obtained additional ATE insurance.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Third Witness Statement of Anthony John Maton

Third Witness Statement of Anthony John Maton

Mr Maton’s third witness statement provides updated information about Mr Evans’ funding arrangements, including the additional ATE insurance that Mr Evans has put in place in respect of the claim.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Fourth Witness Statement of Anthony John Maton and Exhibits

Fourth Witness Statement of Anthony John Maton

Mr Maton’s fourth witness statement explains why he considers that, from his experience, opt-in proceedings would be impracticable.

Mr Maton also: (a) describes the funding structure of the claim, which provides that payment of unrecovered costs (including funding fees) is to be made out of undistributed damages; (b) updates on the status of other FX collective actions; and (c) provides an overview of the additional relevant experience Hausfeld has obtained since his first witness statement.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Exhibit AJM15 – Updated Hausfeld & Co LLP profile

Updated profile of Hausfeld’s relevant experience.

Fifth Witness Statement of Anthony John Maton

Fifth Witness Statement of Anthony John Maton

Mr Maton’s fifth witness statement provides responsive evidence in relation to various factual matters, including the timing of Mr Evans’ application, Mr Evans’ funding and insurance arrangements, Hausfeld & Co LLP’s role in monitoring wider developments that impact the proposed proceedings, sources of data that will be relied upon by Mr Evans’ experts and economic challenges that would arise if the proposed proceedings were brought on an opt-in basis.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Sixth Witness Statement of Anthony John Maton and Exhibit

Sixth Witness Statement of Anthony John Maton

Mr Maton’s sixth witness statement addresses updates to Mr Evans’ funding, budget and insurance arrangements.

Copies of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Exhibit AJM 24 – Amended LFA

This is an extract from Exhibit AJM 24 containing Mr Evans’ updated costs budget.

First Witness Statement of Adrian Mark Chopin

First Witness Statement of Adrian Mark Chopin

Adrian Chopin is a Managing Director of Bench Walk Advisors, a specialist litigation funder with whom Mr Evans is working to bring the claim.

Mr Chopin’s statement provides information about the experience and expertise of Bench Walk Advisors together with details of the funding structure for the claim.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Second Witness Statement of Adrian Mark Chopin

Second Witness Statement of Adrian Mark Chopin

Mr Chopin’s second statement provides additional information about Mr Evans’ funding arrangements.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Third Witness Statement of Adrian Mark Chopin

Third Witness Statement of Adrian Mark Chopin

Mr Chopin’s third witness statement addresses the impracticability of funding opt-in proceedings and provides additional information about Mr Evans’ funding arrangements.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Fourth Witness Statement of Adrian Mark Chopin

Fourth Witness Statement of Adrian Mark Chopin

Mr Chopin’s fourth witness statement further addresses the impracticality of opt-in proceedings from the perspective of a commercial litigation funder. It also responds to commentary from the other potential class representative regarding Mr Evans’ funding and insurance arrangements.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

Fifth Witness Statement of Adrian Mark Chopin

Fifth Witness Statement of Adrian Mark Chopin

Mr Chopin’s fifth witness statement addresses the costs of litigation funding and changes to Mr Evans’ litigation funding budget.

Copies of certain of Mr Evans’ funding and ATE insurance documents are available on request by emailing enquiries@fxclaimuk.com.

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