UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
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MICHAEL E. GLASS On Behalf of Himself and All Others Similarly
Situated,
Plaintiff,
v.
CAREMATRIX CORP., ABRAHAM D. GOSMAN, ANDREW GOSMAN, ROBERT KAUFMAN,
FREDERICK LEATHERS and MICHAEL GOSMAN,
Defendants.
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No.
CLASS ACTION
COMPLAINT FOR VIOLATION OF THE SECURITIES EXCHANGE ACT OF 1934
Plaintiff Demands A
Trial By Jury
Plaintiff, individually and on behalf of all persons similarly
SNIPPETS:
CAREMATRIX CORP., ABRAHAM D. GOSMAN, ANDREW GOSMAN, ROBERT KAUFMAN,
FREDERICK LEATHERS and MICHAEL GOSMAN,
COMPLAINT FOR VIOLATION OF THE SECURITIES EXCHANGE ACT OF 1934
Plaintiff Demands A
Plaintiff, individually and on behalf of all persons similarly situated, by his undersigned
Plaintiff believes that further substantial evidentiary support will exist for the
Plaintiff brings this action as a class action on behalf of himself and all persons or
During the Class Period, defendants engaged in a scheme and course of conduct, in violation
Plaintiff Michael E. Glass purchased CareMatrix common stock during the Class Period, as set
CareMatrix develops, manages, and operates assisted living facilities and various other
Gosman") has served as the Company's Chairman of the Board of Directors since October 1996,
A. Gosman and certain members of the Company's senior management are the primary owners of
A. Gosman is the father of Andrew Gosman and Michael Gosman.
Defendant Robert Kaufman was, until April 15, 1999, when he resigned from the Company, Chief
The Individual Defendants participated in the drafting, preparation, and/or approval of the
the market prices of CareMatrix common stock during the Class Period were artificially
The Company's operations, revenues, growth, and earnings were inexorably intertwined with the
Thereafter, CareMatrix and Chancellor would enter into a development contract, which
defendants artificially inflated and manipulated the Company's earnings through the improper
The revenues recognized from the related party "development fees" were material to the
In the research report, the analysts supported the rating and earnings estimates by
The balance of the related party receivable relates to amounts due from Chancellor for
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