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1
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CONSOLIDATED AMENDED COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT ACT FINANCE PLAINTIFFS SECURITIES REPORTS SERVICING EXCHANGE ACT LOANS REVIEW LOSSES OMNI CLASS PERIOD COMMON STOCK INCOME MISLEADING UNITED STATES PUBLIC FILINGS ACCOUNTING DELINQUENCIES SECURITIZATION NON-PRIME RESPONSIBILITY CONSUMERS DEFICIENCIES AUTOMOBILE DEFENDANT TIPTON DISCLOSURE CONNECTION |
pertaining to plaintiffs, which nre. based on personal knowledge), after due investig;ltion
counsel. The investigation included a review and analysis oF public statements and corporate
documents of defendants, including various public filings by National Auto Finance Company,
Inc. ("National Auto" or the "Clompany'") with the United States Securirics and Exchange
Commission ("SIX"), and analysts reports, and other review and analysis cd mtierirlls
concerning the dcfendanrs named hercin and Iha allegattions .set forth below, including
articles and articles in Enancial publications. Plaintiffs believe that these allcgtions and
contentions will have further evidentiury support after a reasonable opputtunity for
invtlstigation and discovery.
JURISD~~TXON AND VENUE
1. This Court has jurisdiction over the subjet matter of this action
to 1522 of the Securities Exchnge Act of 1933 (the "1933 Act") and $27 of the
Exchange Act af 1934 (the "Fxhang Act").
2, The claims ass&cd below arise under Scctiaas 11, 12(a)(2) and 15 of
Securities Act of 1933 (the "Securititi Act"), 15 U.S.C. Ej77k, 771(a)(2) and 770 and
lo(b) of the $CCUI~L~CS Exchange Act of lY34 (tb~ "Exchange Act"), 15 U.S.C. §78j(b],
KG-5 yromulgatcd thcreuader by the SEC, 17 C,F.R. 5240.10b-5, and Section 20(u) of fhe
Exchange Act, IS USC. g?&(a).
3. Venue is proper in this District pwsmnt b $22 of the 1933 Act
the Exchange Act. Many of the acts and transactions constituting the violations of the
alleged herein, including the prepr&m, issuance, and dissemination of marcrially
misleading inCumratiun to the invesling public, have occurred in this District. In
principhl execwive offices of the corporate defendant are siluati in this Disttic~
4. In connection with the acts, conduct and other wrongs alleged
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2
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COMPLAINT
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EXTRACTED KEY WORDS
RESERVES O-K PROSPECTUS CONSUMER STOCK FACTS JUNA TOTAL REVENUES PAR EXCESS OMNI CUSTOMERS PAYMENTS DEALERS INCOME RISE FILINGS FOLKWING INSTITUTIONS CONSUMER FINANCE COMPANY SPECIALIZED CONSUMER FINANCE NATIONAL AUTO COMPLAINT RETRIEVAL SERVICES REPORTS CHSS REMOTE SEPARATE CLAIMS CLASS MEMBERS |
98-8767
PEARL PECKERMAN, I.R.A., an behalf of herself
and all others similarly situated,
Plaintiff,
V.
NATIONAL AUTO FINANCE COMPANY, INC.,
GARY L. SHAPIRO, KEITH 6. STEIN, ROY E.
TIPTON, KEVIN G. ADAMS, EDGAR A, OTTO,
PETER OFFERMAN, MORGAN M. SCHUSSLER,
STEVEN L. GURBA, CRUT-TENDEN ROTH, INC. and
RAYMOND JAMES & ASSOCIATES, INC.,
atbrneys, alleges the following, upon information and
allegations pertaining to plaintiff, which are based on personal
investigation by her counsel. The investigation included
public statements and corporate documents of defendants,
filings by National Auto Finance Company, Inc. {"National
with the United States Securities and Exchange Commission
reports, and other review and analysis of materials
herein and the atlegations set forth below, including
in financial publications. Plaintiff believes that these
contentions will have further evidentiary support after a
for
futd-er investigation and discovery.
JURlSDlCTlON AND VENUE
1. This Court has jurisdiction over the
pursuant ta §Z! of the Securities Exchange Act of 1933 (the
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