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1
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CIVIL COVER SHEET
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EXTRACTED KEY WORDS
HARTMAN ENTRY CAMBRIDGE BIOTECH PATRICK LEONARD PETER DELOITTE TOUCHE SUMMONS COMPLAINT CIVIL DOCKET TZVI SHAFER PLAINTIFF N-K |
U.S. District Court
U.S. District Court - Massachusetts
CIVIL DOCKET FOR CASE #: 94-CV-12351
Shafer v. Cambridge Biotech, et al
Assigned to: Judge William G. Young
Demand: $0,000
Lead Docket: 93-CV-12486
Dkt # in So. Dist. N.Y. : is 94cv4438
Cause: 15:78m(a) Securities Exchange Act
I TZVI SHAFER Avrom S. Fischer
Plaintiff [COR LD NTC]
786 East 19th
New York, NY
718-434-7696
V.
CAMBRIDGE BIOTECH CORP.
I Defendant
PATRICK J. LEONARD
I Defendant
PETER P. HARTMAN
Defendant
DELOITTE & TOUCHE
Defendant
I Docket as of November 29, 1994 11:08 am
Proceedings include all events.
1:94cv12351 Shafer v. Cambridge Biotech, et al
n/29/94 1 Original file, certified copy of transfer
sheet received from the District of
Docket # in other court:94cv4438 (bdb)
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2
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COMPLAINT
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EXTRACTED KEY WORDS
COMMON STOCK DEFENDANTS DELOITTE PLAINTIFF MEMBERS FINANCIAL STATEMENTS HARTMAN SECURITIES TOUCHE REPORT MISREPRESENTATIONS REVENUE ACCEPTED AUDITING STANDARDS UNITED STATES MANAGEMENT RELEVANT DETAIL PUBLIC FILINGS ACCEPTED ACCOUNTING PRINCIPLES EXCHANGE ACT MISLEADING DEFENDANTS LEONARD CLASS ACTION FINANCIAL POSITION PERIOD ENDING UNITED STATES DISTRICT STATES DISTRICT COURT ANNOUNCEMENTS PURCHASERS PARTICIPANT |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YOdK IA
-against
CAMBRIDGE BIOTECH CORP., PATRICK J. LEONA
PETER P. HARTMAN, and DELOITTE & TOUCHE;
Defendants.
---------*------------------------------x
CLASS ACTION COMPLAINT WITH JURY DEMAND
NATURE OF THE CASE
1. This is a Class Action brought by Tzvi Shafer on his own behalf and
other persons or entities, except for Defendants, who bought Cambridge Biotech Corp.
Biotech" or the "Company") common stock (the "Class") during the period November 5, 1992
October 29, 1993, inclusive (the "Class Period"). Based upon announcements by Cambridge
which at the moment are devoid of the relevant detail, it, appears that purchasers of the
x g$.d-
of Cambridge Biotech in 1991 were also ha&&l by the conduct complained of herein. Neither
or any member of the class was a participant in the management of Cambridge Biotech and
except for the circumstances of plaintiffs own purchases the allegations of the complaint
misrepresentations by defendants are on information and belief and the source of that
public filings by Cambridge Biotech with the United States Securities & Exchange Commission
and press release.
2. This action, based on a violation of Section 10(h) of the
SEC Rule lob-5 promulgated thereunder, arises out of a course of business and conduct
which the price of Cambridge Biotech's common stock was inflated by Cambridge Biotech's
overstatement in November 1992 of its net income for the third fiscal quarter 1992
,: -. --- -
-- 1 -*
-- 2 -
30, 1992) and the resulting overstatement of its full year 1992 financial results issued
in March 1993 and by the issuance and dissemination of a misleading auditor's report
Financial Statements of Cambridge Biotech for the period ending December 31, 1992
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