WEISS & YOURMAN
Kevin J. Yourman, Esq. (147159)
10940 Wilshire Blvd.
Los Angeles, CA 90024
(310) 208-2800
BERNSTEIN LIEBHARD & LIFSHITZ, LLP
Stanley D. Bernstein, Esq.
Michael S. Egan, Esq.
10 East 40th Street, 22nd Floor
New York, New York 10016
(212) 779-1414
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
ANDREW SAMET, on behalf of himself and ) Case No. 99-0124DDP (ANx)
all others similarly situated, ) ) CLASS ACTION COMPLAINT FOR
Plaintiff, ) VIOLATION OF FEDERAL SECURITIES
) LAWS
v. ) [filed Jan. 7, 1999]
)
AIRTOUCH COMMUNICATIONS, INC. ) JURY TRIAL DEMANDED
)
Defendant. )
_____________________________________ )
1. Plaintiff, Andrew Samet, by his undersigned attorneys, for his class action complaint, alleges
the claims set forth herein. Plaintiff's claims as to himself and his own actions, as set forth in
paragraph 5 below, are based upon personal knowledge. All other allegations are based upon the
investigation of counsel, which investigation included a review of public filings with the
Securities and Exchange Commission (the "SEC") made by AirTouch Communications, Inc.
("AirTouch" or the "Company"), securities analysts' reports about the Company, press releases
issued by the Company, and media reports about the Company, and media reports about Bell
Atlantic Corp. ("Bell Atlantic") and Vodafone Group Plc. ("Vodafone"). Based upon such
investigation, plaintiff believes that substantial evidentiary support exists for the allegations
forth herein.
JURISDICTION AND VENUE
2. Plaintiff brings this action pursuant Sections 10(b) and 20(a) of the Securities Exchange Act of
1934 (the "Exchange Act"), 15 U.S.C. 78j and 78t, Rule 10b-5, 10b-5, 17 C.F.R. § 240.10b-5,
promulgated thereunder by the SEC.
SNIPPETS:
BERNSTEIN LIEBHARD & LIFSHITZ, LLP
New York, New York 10016
Plaintiff, Andrew Samet, by his undersigned attorneys, for his class action complaint,
Plaintiff's claims as to himself and his own actions, as set forth in paragraph 5 below, are
All other allegations are based upon the investigation of counsel, which investigation
plaintiff believes that substantial evidentiary support exists for the allegations set forth
This Court has jurisdiction in this action pursuant to Section 27 of the Exchange Act, 15
Defendant AirTouch is and was, at all times relevant hereto, a corporation duly incorporated
As of October 31, 1998, there were 572,061,921 shares of AirTouch common stock outstanding
Defendant owed to the purchasers and sellers of AirTouch stock, including plaintiff and
This duty included ensuring that the statements contained therein were true, and that there
Plaintiff brings this case as a class action pursuant to Rule 23 of the Federal Rules of
Throughout the Class Period, the common stock of AirTouch was actively traded on the New York
Plaintiff has retained competent counsel experienced in class action litigation under the
Whether the documents, filings, releases, and statements disseminated to the investing public
AirTouch was followed by and regularly communicated with securities analysts employed by
the New York Times reported that "executives close to the deal said representatives for
As a result of the foregoing, the market price of AirTouch stock was artificially depressed
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