IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
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ALLAN GENUT,Individually And On) )
Behalf Of All Others Similarly )
Situated, )
Plaintiff, )
) SECURITIES CLASS ACTION
vs. )
) JURY TRIAL DEMANDED
CARNEGIE INTERNATIONAL CORP- )
ORATION, E. DAVID GABLE, )
LOWELL FARKAS, B. CHRIS )
SCHWARTZ and BENNETT H. GOLD- )
STEIN, )
Defendants )
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COMPLAINT
INTRODUCTION
Plaintiff, for his class action complaint (the "Complaint") alleges,
(based, in part, upon the investigation conducted by and through his
undersigned attorneys), the following:
JURISDICTION AND VENUE
1. This Court has jurisdiction over the subject matter of this action
pursuant to Section 27 of the Securities Exchange Act of 1934 (the
"Exchange Act"), 15 U.S.C. ß 78aa.
2. The claims asserted herein arise under Sections 10(b) and 20(a) of
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
CARNEGIE INTERNATIONAL CORP-)
Plaintiff, for his class action complaint alleges,, the following:
This Court has jurisdiction over the subject matter of this action pursuant to Section 27 of
The claims asserted herein arise under Sections 10and 20of the Exchange Act, 15 U.S.C. ßß
Venue is proper in this district pursuant to Section 27 of the Exchange Act because defendant
In connection with the acts alleged in this Complaint, defendants, directly and indirectly,
This action is brought as a class action on behalf of all persons or entities who purchased
During the Class Period, defendants engaged in a course of conduct that was designed to, and
members of the Class to purchase Carnegie's securities at inflated prices.
Plaintiff Allan Genut purchased 1,000 shares of Carnegie common stock on March 30, 1999 at
Defendant Lowell Farkas was, at all relevant times, President, Chief Executive Officer and a
whether documents, releases, reports and statements disseminated to the investing public
defendants made public misrepresentations during the Class Period,
Subsequently, Carnegie engaged in a series of acquisitions, and certain sales, of
The average price of Carnegie stock in 1997 was $0.74 per share.
On April 30, 1999, the first day of trading in Carnegie stock on the AMEX, as discussed
The statements above were false and misleading when made since, as disclosed subsequently,
SEC Regulation S-X ) states that financial statements filed with the SEC which are not
The above transactions have been recorded under the purchase method of accounting and,
The Individual Defendants were motivated to make the misrepresentations discussed herein
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