GOLDSTEIN LITE & DEPALMA
Allyn Z. Lite (AL-6774)
Joseph J. DePalma (JD-7697)
Robert J. Berg (RB-8542)
Two Gateway Center, 12th Floor
Newark, NJ 07102-5003
(973) 623-3000
WOLF POPPER LLP
Marian P. Rosner
Wallace A. Showman
845 Third Avenue
New York, NY 10022
(212) 759-4600
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
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:
ALBERT ORAN, individually and on behalf : [Case No. 97-CV-4313]
of a class of others similarly situated, :
: CLASS ACTION COMPLAINT
Plaintiff, : [filed Sep. 18, 1997]
:
-vs- : JURY TRIAL DEMANDED
:
JOHN R. STAFFORD, ROBERT G. BLOUNT, :
JOSEPH J. CARR, LOUIS L. HOYNES, JR., :
WILLIAM J. MURRAY, DAVID M. OLIVIER, :
JOHN R. CONSIDINE, PAUL J. JONES, :
FRED HASSAN, and AMERICAN HOME :
PRODUCTS CORPORATION, :
:
Defendants. :
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Plaintiff, individually and on behalf of all others similarly situated, by his attorneys, alleges
upon information and belief, based upon the investigation of their counsel, which included, among
things, a review of various public filings by the corporate defendant with the Securities and
Commission ("SEC"), and various news and journal articles (except for those allegations which
plaintiff, which are based upon personal knowledge):
NATURE OF THE ACTION
SNIPPETS:
Attorneys for Plaintiff
Plaintiff brings this action as a class action on behalf of himself and a class consisting of
Defendants engaged in a scheme and course of conduct to defraud or deceive purchasers of the
This action arises under Sections 10and 20of the Securities Exchange Act of 1934, 15 U.S.C.
This Court has jurisdiction of this action under Section 27 of the Exchange Act, 15 U.S.C. §
Many of the acts alleged herein, including the dissemination to the investing public of
He purchased common stock of American Home Products Corporation during the Class Period as
Defendant John R. Stafford is, and was at all relevant times, Chief Executive Officer and
Defendant Robert G. Blount is, and was at all relevant times, Senior Executive Vice President
is, and was at all relevant times, General Counsel and a Senior Vice President of AHP.
AHP common stock was actively traded on the New York Stock Exchange.
The Individual Defendants, because of their positions with the Company, had access to the
gs and committees thereof and reports and other information provided to them in connection
so that the market price of the Company's stock would be based upon truthful and accurate
Each of the defendants is liable as a participant in a fraudulent scheme and course of
The scheme deceived the investing public regarding AHP, artificially inflated the price of
CLASS ACTION ALLEGATIONS
whether documents, filings, releases and statements disseminated to the investing public,
AHP was followed by several securities analysts employed by major brokerage firms who wrote
Redux, a newer version of Pondimin, was approved by the FDA in early 1996 for sale for the
Before and during the Class Period, defendants knew that Redux had a record of adverse
On September 16, 1997, it was first disclosed in The Wall Street Journal and The New York
In addition to the duties of full disclosure imposed on defendants as a result of their
ccurate and truthful information with respect to the Company's operations and performance so that
The Individual Defendants' primary liability and controlling person liability arise from the
about AHP, and/or signed the Company's public filings with the SEC, which public filings contained
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