UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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:
STUART SEROTA, MARVIN SEROTA,
MARSHA SEROTA and SONDRA :
FORLADER, :
Plaintiffs, 93 Civ.
:
- against - . COMPLAINT-CLASS
.
PNF INDUSTRIES, INC., PLAINTIFFS
OTIS H. HASTINGS, ALFONSO : BY JURY
MARGINO, ROBERT M. MONTAGUE,
JR., JAMES NEVILLE, SAMUEL :
GOTFRIED, WILLIAM FISCHBEIN,
IRA S. SALK, ALFRED P. AVASSO, :
GOLDSTEIN & HALPF, DALESSIO,
THIERMAN & LEBEN, SIDNEY KAPLAN, :
ROBERT J. VAN CANEGHAN, LOUIS
MICELI, JOHN DOE and THE :
AMERICAN STOCK EXCHANGE, INC.,
l .
Defendants. :
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Plaintiffs, complaining of the defendants, by
Joseph M. Weitzman, allege upon knowledge as to
and the transactions alleged in paragraph 7, and
and belief based upon, inter alia, the investigation
through their attorney as to all other matters,
investigation included, among other things, a review
documents, public filings, news releases and news
concerning PNF Industries, Inc., as follows:
JURISDICTION AND VENUE
1. The claims in this action arise under the
Exchange Act of 1934 ("Exchange Act"), the Rules and
of the Securities and Exchange.Commission (BISEC1l)
thereunder, and the common law.
2. (a) The jurisdiction of the court is based on
27 of the Exchange Act, 15 U.S.C. §78aa, and the
pendent jurisdiction.
(b) Venue is proper in this district
Section 27 of the Exchange Act. Many of the acts and
SNIPPETS:
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
STUART SEROTA, MARVIN SEROTA,
ROBERT J. VAN CANEGHAN, LOUIS
AMERICAN STOCK EXCHANGE, INC.,
owners of the common stock of PNF as follows:
the laws of the State of New York and is engaged in the business
to resign.
merged to form PNF.
grounds of its gross incompetence.
(APB Nos.
with the conduct of the PNF audits;
failure.
Fire product.
the fact that the No Fire patent was valued at an incredible
over management decisions.
stock disclosed4.
Amex.
Grayhound.
thereof6.
sheets".
complaint.
thereunder.
deceit.
and Avasso.
sale of the common stock of PNF.
proper.
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