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1
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CONSOLIDATED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
COMMON STOCK MARKET MTEL COMMON STOCK CLASS PERIOD1 JONES NEWS EXCHANAE ACT JAI JOHN DEFENDANTS DECLINE GROWTH INDUSTRY COST COMPARES ARCH SAYING SENDERS DOW JONES NEWS THEREOF PLAINTIFFS UNKNOWN EXACT SHARES PRICE PRINCIPLES SOUTHERN DISTRICT |
IN THE UNITED STATES DISTRICT COITRT
FOR THE SOUTHERN DISTRICT OF MISSI~S~~~'sT"'~oFM'ss'ss'PP~
JACKSON DIVISION
: I
IN RE MOBILE TELECOMMUNICATION : MASTER FILE w.
TECHNOLOGIES CORP. SECURITIES : 3:94-CV-6 i-
LITIGATION : : CONSOLIDATED AMENDED
: COMPLAINT
THIS DOCUMENT RELATES TO :
ALL ACTIONS : (JURY TRIAL DEMANDED)
:
Plaintiffs, by their attorneys, allege
upon information and belief (based on, inter alia,
investigation made by plaintiffs by and through
except as to the allegations which pertain to the named
plaintiffs and their counsel. Such allegations
information and belief because many of the material
peculiarly within the knowledge of the defendants.
INTRODUCTION
1. This is an open-market securities
action against Mobile Telecommunication Technologies
("Mtel" or the "Company") and'certain of the Company's
and directors, brought on behalf of purchasers
stock during the period March 31, 1993, through
January 5, 1994 (the "Class" and the "Class Period").
through SkyTel Corp. and other subsidiary operating
provides nationwide paging services and engages in other
communications-related businesses.
2. As alleged below, defendants during
Period affirmatively knew (or, at a minimum,
disregarded) adverse material information regarding
operations, competitive position and future
Thus, for example, defendants knew from internal
other non-public sources that: (i) increasing
eroding Mtel's profits and operating margins and would
Company to radically alter its pricing structure;
experiencing substantial cost over-runs in the
construction of new products; and (iii) Mtel was
substantial losses in joint ventures in the
Alone or in combination, these adverse conditions
Mtel's business and operations, undermining the
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2
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
PROPER MTT LEONARD BARRACK MSB SMITH CRAIG JELLIFFE MGZINCO BIGGS EDMONSON EXCHANGE ACT CLASS PERIOD SUSTAINED DAMAGES MEMBERS FACT COMMON CLASS ACTION MENT DEFENDANTS ATTORNEYS ROBERT FUGATE PALMER CONN EUGENE SOUTHERN DISTRICT |
IN THE UNITED STATES DISTRICT
FOR THE SOUTHERN DISTRICT OF
JACKSON DIVISION
CIVIL ACTION
EUGENE S. CONN, on
behal? of himself and all NO.
others similarly situated, : .
Plaintiff,
V* :
MOBILE TELECOMMUNICATION : JURY TRIAL DEMANDED
TECHNOLOGIES CORP., JOHN N. :
PALMER, AND J. ROBERT FUGATE, :
Defendants, :
CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, submits this
Complaint (l'Complaintlt) against the defendants
allegations made in this Complaint are based on
belief, except those allegations that pertain to
tiff and his counsel. Plaintiff's information and
based, inter alia, on the investigation made by
attorneys.
NATURE OF ACTION AND S-Y OF
1. This is a shareholder class action
of a plaintiff class (the l'ClasslV) consisting of
of the common stock of Mobile Telecommunication
or the l'CompanylV) from March 31, 1993 through and
January 4, 1994 (the "Class Period").
2. During the Class Period, defendants
its financial condition, prospects, operations,
and liquidity in a materially false and misleading
Defendants did so through a series of materially
leading public statements in press releases and
Securities and Exchange Commission ("SEC").
statements concerning the Company's business,
and capital resources, and prospects were false and
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3
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COMPLAINT
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EXTRACTED KEY WORDS
MEMBERS MTEL COMMON STOCK BRODY STULL ESQ WEISS JOSEPH LAW JULES BRODY LAW OFFICES BALA PLAZA EAST COUNSEL DECLINE VENTURES GARRISON THEREOF FACT COMMON PLAINTIFFS UNKNOWN EXACT PROSPECTS OBLIGATIONS EXCHANGE ACT SHARES PRINCIPLES MOBILE ROBERT FUGATE |
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
ROCHELLE AGRIS AND RICHARD BELADINO, Civil
Plaintiffs, COMPLAINT
-against- ;
JOHN N. PALMER, JAI P. BHAGAT, J. i CLASS ACTION
ROBERT FUGATE AND MOBILE
TELECOMMUNICATION TECHNOLOGIES ;
CORP., ; PLAINTIFFS
TRIAL BY
Defendants.
Plaintiffs, by their attorneys, for their
against the defendants, allege upon information and
except as to paragraph 5, which is alleged on knowledge,
follows:
JURISDICTION AND VENUE
1. This Court has jurisdiction of this
under Section 27 of the Securities Exchange Act of 1934 (the
"Exchange Act") as amended, 15 U.S.C. 5 78aa, and 28 U.S.C.
SS 1331 and 1337, and under the doctrine of pendent
2. The claims herein arise under Section
20(a) of the Exchange Act [15 U.S.C. S 78j(b) and S
Rule lob-5 promulgated thereunder by the Securities
Commission [17 C.F.R. S 240.1023-53 and under common law
principles.
3. Venue is properly laid in this District
to S 27 of the Exchange Act and 28 U.S.C. s 1391(b) and
i
acts, conduct, combination and conspiracy complained
including the preparation, issuance and dissemination
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4
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COMPLAINT
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EXTRACTED KEY WORDS
MEMBERS YORK MTEL COMMON STOCK PURCHASE PLAINTIFF ATTORNEYS FLOOR PENN PLAZA PROPER MISLEADING RCCCNT TOUR COVERAGE LYY3 HDD VTI RICHMULLD MARTIN AQRHCY PRICE-CUTTING THEREOF FACT COMMON ANRL U-5-C TEUCOMMUNICATION TECHNOLOGIES DIIACAT DLMER JOIIN |
DARnAR~ E. CIIELES,
1
Plaineiff,
-against- 1
1 C.&MS
JOIIN N. !DLMER, JU I!. DIIACAT, J.
RORERT FUGATE AND MORItvR ;
TEUCOMMUNICATION TECHNOLOGIES
CORP., :
Defendants.
Plaintiff, by her attozncycr, for her
Lhe &f~n~rrLY, alleye~ upvrl idurtaaliurr arrd
paragraph 5, which ia allegmd on knowledge, as
1. Tbie court hat juriediction of
Ser:Liurl 27 UT Lhr Srcur.iLie!y Exchdnye AcL wl: 2934
Act"1 as amended, 15 U;S.C. § 7&a, and 28 U-5-C. Jf 1331 anrl 1.337,
and under the doctrine of pendent jurkdiction.
2. The claims htrtiu &rise: udar
20(a) ot the Exchange Act [1S U.S.C. 5 78j (bl and Q 78t_(a)l
Rule lob-5 promulgated thereunder by the
Commission (17 C.F.R. 9 24O.lOb-51 and under comman
3, Venue is properly laid in this Distrlcrs
5 3.7 of t.he exchange Act. and 2FL IT-S-C. I 1391 (h) and
3&E, conduct, combination and concpiracy compktincd
the preparation, issuance and dissemination of
-I-
misleading information to the investing public,
substantial part in the District of Mississippi.
Telecommunication Technologies Corp. ("Mtel" or the
maintained its principal place of business in this District
relevam times.
4. In connection with the conduct complained
defendants, directly or indirectly, used the
instrumentalities of interstate commerce, including
interstate telephone communications and the facilities
securities exchanges.
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5
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COMPLAINT 2
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EXTRACTED KEY WORDS
DEFENDANTS PLAINTIFF STOCK COMMON FUGATE UNITED STATES PALMER EXCHANGE ACT SECURITIES PAGING SERVICE NATIONWIDE PAGING LAW MARKET COMPETITION OMISSIONS FEDERAL SECURITIES MOBILE TELECOMMUNICATIONS TELECOMMUNICATION TECHNOLOGIES VIOLATIONS DELAWARE CORPORATION UNDERSIGNED ATTORNEYS ANNUAL REPORT PROFITABILITY CLASS PERIOD INDIVIDUAL CLASS MEMBERS MARKET ANALYSTS JURISDICTION WADE JACKSON NET INCOME |
S(IUTHERN
l-N THE UNITED STATES DISTRICT CO&T
FOR THE SOUTHERN DISTRICT OF MIssIs IPPI JAN "
JACKSON DIVISION J.
WADE JACKSON,
Plaintiff,
VS. CML ACTION NO. 3 I'?+
MOBILE TELECOMMUNICATIONS
TECHNOLOG&S CORJ?OR4TION,
a Delaware corporation,
JOHN N. PALMER, J. ROBERT
FUGATE and DAVID W. GARRISON,
Defendants.
CLASS ACTION COMPLAINT
Plaintiff, Wade Jackson, by and through his undersigned attorneys, alleges the following
upon information and belief, based on publicly available information, and the investigation of
counsel:
1. This is an action alleging violations by the Defendants of the federal securities
laws arising from false statements and omissions regarding the &an&l condition of Mobile
TelecommuniCation Technologies Corp. ("MTEL" or the "Company"). PlaintifY brings this
action on his Own behalf and on behalf of all persons or entities that acquired the common
stock of MTEL between October 28, 1993 and January 4, 1994. Plaintiff seeks, on behalf of
himself and the Class, damages, expenses of suit, and other relief.
JURISDICTION AND VENUE
2. This Court has jurisdiction of this action under Section 27 of the
Exchange Act of 1934 (the "Exchange Act"), 15 U.S.C. §78(aa), and 28 U.S.C. $133 1, by
reason of the federal questions alleged herein and principles of supplemental
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6
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
STOCK PRICE MTT COMMON STOCK CLASS PERIOD REPORT PALMER SIMON SAMUEL LEONARD BARRACK BACINE RODOS MSB SMITH CRAIG JELLIFFE MOZINGO BIGGS EDMONSON PROPER FEES TXB EXCEWGE ACT ENORMOUS PRICE TERIAL FACTS ADVERSE PUBLIC DISCFTOSURB COMMERCIAL SERVICE LLAIF SOLD |
IN THE WITED STATES DISTRICT
FOR THE SOUTHERN DISTRIff OF
JACKSON DIVISION
: CIVIL ACTION
ALVIN LEVIN, Tmstee for :
Winslow's Pharmacy, Inc. :
Profit Sharing Plan, on .
behalf of himself and a11 :
others similarly situated, :
Plaintiff, :
v. : :
MOBILE TELECCMMUNICATION : my TRI.A& DEMANDED
TECHNOLOGIES CORP., JOKN N. :
PALMER, AND J. ROBERT FUGATE, : i
Defendants. :
CLASS ACTION CWPLAIFT
Plaintiff, by its attorneye, submits this Class
Complaint (11Complaiett4) 'against the defendants
allegations made in this Complaint are based on
belief, except those allegations that pertain to
Liff and his counsel. Plaintiff's information
based, inter alia, on the investigation made by and
attorneys.
1. This fs a shareholder class action
of a plaintiff class (the MClasall) consisting of
of the common stock of Mobile Telecommunication
or the llCompanylf) from March 31, 1993 through and including
January 4; 1994 (the "Class Period").
2. During the Class 'Period, defendants
its financial condition, prospects, operations,
and liquidity in a materially false and misleading
Defendants did so through a series of materially
misleading public statements in press releases and filings
the Securities and Exchange Commission (flSEC~~). Defendants'
public statements concerning the Ccmpany'a business,
liquidity and capital resources, and prospects were
misleading and misrepresented and failed to disclose
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