ALBRIGHT, STODDARD, WARNICK
& ALBRIGHT
G. MARK ALBRIGHT (NV #001394)
WILLIAM H. STODDARD (NV #001477)
801 South Rancho Drive
Quail Park Suite D-4
Las Vegas, NV 89106
Telephone: 702/384-7111
MILBERG WEISS BERSHAD
HYNES & LERACH LLP
WILLIAM S. LERACH
DARREN J. ROBBINS
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/231-1058
WOLF HALDENSTEIN ADLER
FREEMAN & HERZ, LLP
FRANCIS M. GREGOREK
BETSY C. MANIFOLD
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/338-4599
Attorneys for Plaintiffs
(Additional counsel appear on signature page.)
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
K. MITCHELL NAFICY and SAM NAFICY,
On Behalf of Themselves and All
others Similarly Situated,
Plaintiffs,
vs.
DELGRATIA MINING CORPORATION, J.
TERRENCE ALEXANDER, CHARLES A.
AGER, ERIC X. LAVARACK, GEOFF
COURTNALL, PATRICK J. FURLONG and
DAVID R. MANNING,
SNIPPETS:
Attorneys for Plaintiffs
COMPLAINT FOR VIOLATION OF THE SECURITIES EXCHANGE ACT OF 1934
This is a class action on behalf of purchasers of the common stock of Delgratia Mining
This action alleges that defendants made false and misleading statements about Delgratia's
For example, Delgratia falsely reported that its Nevada gold project contained 5 million
The defendants, which include both current and former officers and directors of the Company,
Defendants further agreed to pay $5 million in exploration and development costs for the
During the Class Period, defendants disclosed certain assay results purportedly from the
However, defendants knew but failed to disclose that the assay results were not conducted by
Defendants concealed the truth about the Nevada gold project in order to allow various
Defendants Eric Lavarack and David Manning also sold some 20,000 shares of their Delgratia
Delgratia is a mining company that acquires properties in the United States and Latin America
The Company's value was and is dependent on the successful definition of geological resources
At the same time Alexander was selling large, cheap blocks of Arakis stock to offshore
Therefore, Alexander enlisted the aid of a long-time business associate, defendant Charles
NGC owned all the shares of Valley Gold Corporation,
Furthermore, exploration and development of the Josh Project was to be conducted by Cactus
Plaintiff K. Mitchell Naficy purchased 150 shares of Delgratia common stock on March 17, 1997
Because of defendant Alexander's positions with the Company, he knew the adverse non-public
and committees thereof, and via reports and other information provided to him in connection
When the assay results from drill holes on the Josh Project were received, the Individual
On February 27, 1997, Delgratia filed a Report on Form 6-K with the SEC in which it reported
ALBRIGHT, STODDARD, WARNICK & ALBRIGHT G. MARK ALBRIGHT WILLIAM H. STODDARD
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