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1
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COMPLAINT
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EXTRACTED KEY WORDS
CLASS PERIOD MEMBERS SQUARE EXCHANGE ACT BUSINESS DAMAGES PURCHASE FASB STATEMENT NOS KENDALL CON-UNON STOCK CONGLETON EXCHANGE COMMISSION IISECII OMISSIONS BUSINESS PROSPECTS COMUNON STOCK LAW FACT COMNON RECORD OWNERS SHARES REPORTS FMB MARKET PRAY JUDGEMENT CEDURE PROPER |
IN - m1- sTAms D1Sm1CT
FOR THE DISTRICT OF ?vIASSACHUSETIS uNITED STATES DISTRICT COURT
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>
ALVIN SLATER and SHIRLEY SLATER, 1 No.
Plaintiffs, j > --
-against-
KENDALL SQUARE RESEARCH CORP.;
HENRYBURKHARZYT III; PETERAPPLETON
JONES; KARL G. WASSMAN III; and
WILLIAM H. CONGLETON,
Defendants.
-- X
Plaintiffs, by their attorneys, allege
and belief (based on, inter alia, the investigation
plaintiffs by and through their attorneys),
allegations which pertain to the named plaintiffs
counsel, as follows:
JUFtISDICTION AND VENUE
1. The claims asserted herein arise under and
pursuant to Sections IO(b) and 20(a) of the Securities
Act of 1934 (the "Exchange Act") [15 U.S.C. §§ 78j(b)
and Rule lob-5 promulgated thereunder by the Securities
Exchange Commission (IISECII) [17 C.F.R. § 24O.lOb-51,
principles of corm-non law.
2. This Court has jurisdiction of
pursuant to § 27 of the Exchange Act, as amended [15 U.S.C.
78aa], and 28 U.S.C. §§ 1331, 1337 and 1367.
3. Venue is properly laid in this District
to § 27 of the Exchange Act and 28 U.S.C. § 1391 (b) and (c$>,:
acts, conduct, combination and conspiracy
including the preparation, issuance and dissemination
materially false and misleading information to the
public, occurred in substantial part in the District
Massachusetts. Defendant Kendall Square Research Corp.
Square11 or the llCorrpanyll) has maintained its principal
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2
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CIVIL COVER SHEET
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EXTRACTED KEY WORDS
COURT PARTIES TBE LOCAL RULE PLAINTIFF GOVERNMENT DISTRICT DEMAND UNITED STATES SHEET COUNTY ATTORNEYS SQUARE CLTLZENSHLP PARTY DEFENDANTS KENDALL-SQUARE ESQ BERMAN DEVALERIO PEASE LIBERTY BOSTON ILL PTF DEF INCORPOR6TD FOREIGN PURSUANT ACT |
JS 44
(Rev. 07199)
The Jsd4 Ciw CO'@~ sheet and the lnformarlon contalc.,rd hewn
the filing and ~ewce of pleadi*& or orhlr
xcept as 0 R vld bv local
rules of court. This form, approved bv the Judicial Conference
1974. 1s requwed for the use of rha Clerk of Coun br the purpose of
sheet. ISEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
1 (a) P~I~FFS Alvin J. Slater and Shirley
DEFENDANTS Kendall-Square
Corp.,
Slater
Henry Burkhardt III,
Jones,
Karl G. Wassman III,
H. Congleton
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
COUNTY OF RESIDENCE OF FIRST
Middlesex
(EXCEPT IN US PLAINTIFF CASES)
(IN U.S.
NOTE: IN LAN0 CONDEMNATION
OF THE
TRACT OF LAND INVOLVED
(c) ATTORNEYS (FIRM NAME. AOORESS, AND TELEPHONE
ATTORNEYS (IF KNOWN)
-Norman ISerman, Esq.
Berman, DeValerio & Pease
One Liberty Square
Boston, MA 02109 542-8300
II. BASIS OF JURlSDlCTlON ,PLACE
OF PRINCIPAL
(PUCE
AN I IN ONE
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