A. BARRY CAPPELLO, SBN 037835
J. PAUL GIGNAC, SBN I25676
CAPPELLO & MCCANN LLP
83 1 State Street
Santa Barbara, CA 93 101
Telephone (805) 564-2444
STEVEN H. HANEY, SBN 121980
RENEE E. JACOBS, SBN 201377
HANEY, BUCHANAN & PATTERSON L.L.P.
707 Wilshire Boulevard
Fifty-Third Floor
Los Angeles, CA 900 17
Telephone (213) 228-6500
GERALD P. CUNNINGHAM, SBN 116762
LAW OFFICES OF GERALD P. CUNNINGHAM
3699 Wilshire Boulevard
Suite 700
Los Angeles, CA 9001 0
Telephone (2 13) 487-4448
Attorneys for Plaintiffs
UNITED STATES DISTRICT
FOR THE CENTRAL DISTRICT OF
DARLENE HANEY, an individual; JAMES ) Civil No.: CV 00-00758 AHM (MANX)
WEINALD, an individual; FRANK )
TAKASHIMA; an individual; and DIANE ) SECOND
WILSON, an individual; and on behalf of ) COMPLAINT
themselves and all others similarly situated, )
and on behalf of THE PACIFIC TELESIS ) (1)
GROUP SUPPLEMENTAL RETIREMENT ) IN
AND SAVINGS PLAN FOR SALARIED ) (2)
EMPLOYEES; THE PACIFIC TELESIS )
GROUP SUPPLEMENTAL RETIREMENT ) TO
ANDSAVINGS PLAN'FOR )
NONSALARIED EMPLOYEES; AND THE ) (3)
SBC SAVINGS AND SECURITY PLAN, )
AND THE SBC SAVINGS PLAN, 1 (4)
1
Plaintiffs, 1 OF
) (5)
V. ) (6)
)
PACIFIC TELESIS GROUP, a Nevada 1 (7)
SNIPPETS:
BARRY CAPPELLO, SBN 037835 J. PAUL GIGNAC, SBN I25676 CAPPELLO & MCCANN LLP
STEVEN H. HANEY, SBN 121980 RENEE E. JACOBS, SBN 201377 HANEY, BUCHANAN & PATTERSON L.L.P.
COMPANY, a California Corporation; SBC)
Corporation; SAVINGS PLAN COMMITTEE)
Supplemental Retirement and Savings Plan for Salaried Employees; the Pacific Telesis Group
Security Plan, and the SBC Savings Plan, by their attorneys, brings this individual and class
Plan Committee of the Pacific Telesis Group Supplemental Retirement
Nonsalaried Employees; Benefit Plan Committee of the SBC Savings Plan and the SBC Savings
19 Defendants are liable for those statements because at the time each of those statements
25 purposes that violated ERISA.
Plaintiffs bring the action in their own right and on behalf of a class
SBC acquired PTG on or about April 1, 1997 in a corporate merger.
Ln addition, through the company stock fund, employees could direct some or all of their own
behalf of the participants consisted of PTG common stock.
In March 1994, PTG "spun-off' its wireless telecommunications subsidiary, PacTel Corporation.
equivalent number of shares of the new entity, renamed AirTouch Communciations, Inc.
AirTouch stock only if they affirmatively elected to do so in writing.
their AirTouch stock would be liquidated and the proceeds of the liquidation "mapped"
AirTouch holdings), the price of AirTouch stock had more than doubled, and analysts agreed
promising investment at the time of the liquidation,
At all relevant times, she was a participant, 29 U.S.C.
of a rollover distribution.
relevant times, PTG has been the plan sponsor, named fiduciary and administrator of the PTG
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