UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROL1
MEAD ANN KRIM, on her
own behalf and on behalf of all
others similarly situated,
Plaintiff,
VS. > CLASS ACTION
> COMPLAINT
>
COASTAL PHYSICIAN GROUP, INC., > JURY TRIAL DEMANDED
STEVEN M. SCOTT, STEPHEN D. >
CORMAN, and JONATHAN E. KENNEDY, )
Defendants. ;1:97cv()ni26
Plaintiff Mead Ann Krim, complaining of the defendants,. alleges and says,
upon knowledge as to herself and upon information and belief as to all other matters, based
on the facts alleged below, which are predicated upon the investigation undertaken by plain-
tiff's counsel, which investigation inch&d analyses of publicly available news articles,
public filings, releases and other matters of pubbc record- Plaintiff Wieves that further
substantial evidentiary support will exisr for the allegations set for& below after a
opportunity for discovery.
-,.
1. This case involves the peqx$ration on plaintiff and the other
I
of the stock of Coastal Physician Group, Inc. ("6Xastal Phytician Group" or the "Company")
by defendants, which included present z& fo- ofi=n of m Physician
.I -/
- violations of the federal securities laws by participating in the wrongful conduct
herein.
JURISDICTION
2. This Court has jurisdiction over the subject matter of this
SNIPPETS:
Plaintiff Mead Ann Krim, complaining of the defendants,.
on the facts alleged below, which are predicated upon the investigation undertaken by
substantial evidentiary support will exisr for the allegations set for& below after a
violations of the federal securities laws by participating in the wrongful conduct alleged
This Court has jurisdiction over the subject matter of this action
This action arises under Sections 10and 20of the Exchange Act
Venue is proper in this district pursuant to Section 27 of the Exchange
dissemination of materially false and misleading information to the investing public,
Defendant Coastal Physician Group is a DelamTz corporation with its
Plaintiff Mead AM Krim, on November 1, 1995, purchased 250 shares of the common stock of
Class Period, as defined below, the Vice &Adenf and Corporate Controller of Coastal
The members of the Class are so numerous that joinder of all members
24,412,334 shares of common stock of Coastal Physician Grq issu& and outstanding,
i operating revenue, net for the second quarter of 1995 was!QBB,342,CKlO.
The Second Quarter 1995 Form 10-Q also made representations about
Company's fee-for-service billing operations but in no way indicated that the billing system
Higher contract attrition and lower new business development
of 1996 in the hospital-based contract management division,
Plaintiff repeats anal realleges each and every allegation contained in
Each of the Individual Defendants, by virrue of their direct and
collective participation in the preparation and/or dissemination of the false and misleading
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