Thomas J. Romans, Esq.
Counselor at Law (TR9284)
Landmark Building
27 Warren Street
Hackensack, NJ 07601-5412
Telephone No.: (201) 489-0027
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________________________________________
PETER C. ELLISON, :
on behalf of himself and all others
similarly situated, :
Plaintiff, :
CIVIL ACTION NO.
VS. : 97 CIV. 3608
AMERICAN IMAGE MOTOR CO., INC., :
EDWARD GELB, JOSEPH DEL NEGRO, PAUL J.
COMESKY, ANTHONY VASTANO, ANDREW P. :
DANIELS, VALERIE VASTANO, GLOBAL
FINANCIAL TRADERS, LTD., BGSG HOLDING :
CORP., MICHAEL R. REILLY, JOHN J.
KENNA, MARIA SONNER, MICHAEL JOHN :
TANNERVILLE CHAMBERLAYNE, DAVID
GEORGE ROBERT CARNEGIE, ROBERT :
HARMAN, GORDON ANTHONY YABLON,
HARRIS, LTD., LYBSTER, LTD., TORYL, :
LTD., MINIMUM EFFORT, LTD., THE LAW
FIRM EVERSHEDS, VINCENT J. IOVINE, :
BRIAN M. FOGEL, DAVID S. COLEMAN,
NORTHEAST SECURITIES, INC., WILSON- : JURY TRIAL DEMANDED
DAVIS & CO., and JOHN DOES 1-25.
:
Defendants. :
___________________________________________________________________
CLASS ACTION COMPLAINT FOR
VIOLATIONS OF FEDERAL SECURITIES LAW
AND COMMON LAW
___________________________________________________________________
Plaintiff, Peter C. Ellison, for his Class Action Complaint,
alleges the following:
NATURE OF THE ACTION
SNIPPETS:
Counselor at Law Landmark Building
Attorney for Plaintiff
EDWARD GELB, JOSEPH DEL NEGRO, PAUL J. COMESKY, ANTHONY VASTANO, ANDREW P.: DANIELS, VALERIE
HARMAN, GORDON ANTHONY YABLON, HARRIS, LTD., LYBSTER, LTD., TORYL,: LTD., MINIMUM EFFORT,
DAVIS & CO., and JOHN DOES 1-25.
VIOLATIONS OF FEDERAL SECURITIES LAW
This action arises out of the solicitation, sale and distribution of the common stock of
f the Securities Exchange Act of 1934 and related principles of common-law fraud and negligent
In addition, this action seeks compensation for the failure of defendant Global Financial
Defendants made millions of dollars in profits at the expense of plaintiff and other
As will be more particularly set forth below, Kenna and Reilly obtained a large, undisclosed
The investing public was led to believe that newsletter and telemarketer recommendations were
Iovine and Fogel were at the same time employed by Northeast Securities, Inc., a securities
Wilson Davis and Northeast acted as market makers for the Stock of American Image, as well as
The shares of American Image and other "small cap" stocks in which Reilly and Kenna held
promotional firms to broadcast by telecopier and/or internet E-mail Global promotional
The Liberian Corporations were formed and operated by Eversheds,
The Liberian Corporations opened trading accounts at Northeast and Wilson Davis, and gave to
BGSG Holding Corp., is a Delaware corporation based in Hauppauge, New York, and is under
Wilson Davis, Northeast, Coleman, Fogel and Iovine are collectively referred to as the
Harris, Ltd.; Lybster, Ltd.; Toryl, Ltd.; and Minimum Effort, Ltd. are each Liberian
Michael John Tannerville Chamberlayne, David George Robert Carnegie, Gordon Anthony Yablon,
The Subscriber Class - Plaintiff also brings this action as a class action on behalf of
At such time as a member of the public expressed interest in subscribing to a Global service
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