UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT GEORGIA
CHARLIE MONAHAN, on behalf of himself
and all others similarly situated,
Civil Action No. _____________
Plaintiff,
v.
COMPUCREDIT CORPORATION and
DAVID G. HANNA,
JURY TRIAL DEMANDED
Defendants.
Plaintiff, individually and on behalf of all other persons similarly situated, by his
undersigned attorneys, alleges upon personal knowledge as to himself and his own acts, and
information and belief as to all other matters, based upon, inter alia, the investigation conducted
by and through his attorneys, which included, among other things, a review of the public
documents and announcements made by the defendants, Securities and Exchange Commission
("SEC") filings, and press releases regarding CompuCredit Corporation. ("CCRT" or the
"Company"), as follows:
NATURE OF THE ACTION
1. This is a class action on behalf of all persons who purchased the common stock
of CCRT during the period September 12, 2000 through and including October 24, 2000 (the
"Class Period"), to recover damages caused by defendants' violations of the federal securities
laws. During the Class Period, defendants made false and misleading statements to the investing
public concerning the Company's charge off rate for bad loans.
2. On September 12, 2000, a mere two and a half weeks before the close of the
Company's fiscal third quarter, Defendant Hanna appeared on Bloomberg News to discuss
the recent increase in the Company's stock price and the impact of the slowing economy on
SNIPPETS:
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT GEORGIA
Plaintiff, individually and on behalf of all other persons similarly situated, by his
by and through his attorneys, which included, among other things, a review of the public
documents and announcements made by the defendants, Securities and Exchange Commission
and press releases regarding CompuCredit Corporation.
of CCRT during the period September 12, 2000 through and including October 24, 2000 (the
to recover damages caused by defendants' violations of the federal securities
defendants made false and misleading statements to the investing
Defendant Hanna appeared on Bloomberg News to discuss
When asked about the credit quality of the Company's customers,
We had assumed that the net charge off rate would plateau at the $10.5 rate during the second
In response to this revelation, the price of CCRT common stock fell over 43%, from about $51
20of the Exchange Act, 15 U.S.C. §§78j, 78tand the rules and regulations
law alleged herein, including the preparation and dissemination to the investing public of
Plaintiff Charlie Monahan purchased shares of CCRT common stock as set
CCRT's common stock was, during the Class Period, actively traded on the NASDAQ
overlooked by traditional credit card providers.
Directors' and management meetings and committees thereof and via reports and other
manner as to constitute a fraud and deceit upon plaintiff and the other members of the Class.
Plaintiff brings this action as a class action pursuant to Federal Rules of Civil
officers, directors, employees, affiliates, legal representatives, heirs, predecessors,
disclose material facts during the Class Period;
Each of the defendants is liable as a primary violator, for making materially false
On September 27, 2000, Gary Gordon of PaineWebber Inc. raised his 12month price target price
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