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1
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COMPLAINT
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EXTRACTED KEY WORDS
WMG COMMON STOCK REPORT PLAINTIFF WELLCARE FACTS CLASS ACTION WELLCARE MANAGEMENT GROUP YORK CLASS PERIOD INDIVIDUAL DEFENDANTS ULLMANN MEMBERS SECURITIES ALLEGATIONS HEALTH CARE MISLEADING UNITED STATES DISTRICT FINANCIAL CONDITION PUBLIC FILINGS CLASS ACTION COMPLAINT NET INCOME EXCHANGE ACT STATES DISTRICT COURT REPRESENTATIONS DISSEMINATION SHAREHOLDERS PARTICIPATION MATERIALLY FALSE |
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
___________________________________
)
GRANT K. WARD, on behalf of )
himself and all others similarly )
situated, ) CASE NO. 96-CV-0521
)
Plaintiff, ) CLASS ACTION COMPLAINT
) FOR VIOLATIONS OF
) FEDERAL SECURITIES LAWS
v. )
)
THE WELLCARE MANAGEMENT GROUP, )
INC.; EDWARD A. ULLMANN; and )
MARYSTEPHANIE CORSONES, ) JURY TRIAL DEMANDED
)
Defendants. )
___________________________________)
Plaintiff makes the following allegations upon
information and belief, except as to allegations specifically
pertaining to the plaintiff and his counsel, based on the facts
alleged below, which are predicated upon a review by forensic
accountants and the investigation undertaken by plaintiff's
counsel, which investigation included analyses of publicly-
available news articles (including reliable investigative
reports), public filings, releases, and other matters of public
record. Plaintiff believes that further substantial evidentiary
_______________________________________________________________________________
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2
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ORDER
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EXTRACTED KEY WORDS
PLAINTIFFS COURT ESQ LAW FIRM DEFENDANT SECURITIES MANAGEMENT AMENDED COMPLAINT FACTS YORK DELOITTE ALLEGE TOUCHE ULLMAN LESLIE WELLCARE MEDICAL MANAGEMENT ALLEGATIONS WELLCARE MANAGEMENT GROUP FINANCIAL STATEMENTS COMPLAINT SUFFICIENTLY ALLEGES MID-HUDSON MEDICAL EXPENSES TRANSACTIONS STOCK PRICE WASHINGTON SECURITIES LITIGATION UNITED STATES DISTRICT RECKLESSNESS INFERENCE |
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
_______________________________________________
In re
THE WELLCARE MANAGEMENT GROUP, INC.
SECURITIES LITIGATION
Case No. 1:96-CV-0521
Filed Apr. 30, 1997
_______________________________________________
Appearances:
Of Counsel:
WHITEMAN, OSTERMAN LAW FIRM
P.O. Box 22016
One Commerce Plaza
Albany NY 12260
NEIL L. LEVINE, ESQ.
LESLIE M. APPLE, ESQ.
for plaintiff Ward and others similarly situated
MILBERG, WEISS LAW FIRM
One Pennsylvania Plaza
New York NY 10119-0165
STEVEN G. SHULMAN, ESQ., et al.
for plaintiff Ward and others similarly situated
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3
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NOTICE
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EXTRACTED KEY WORDS
SHARES DEFENDANTS WELLCARE DISTRICT COURT MEMBER COMMON STOCK YORK PURCHASED SHARES INDIVIDUAL DEFENDANTS PROPOSED SETTLEMENT PLAINTIFFS REPRESENTATIVES UNITED STATES DISTRICT COUNSEL SETTLEMENT HEARING SETTLEMENT FUND AUTHORIZED CLAIMANTS RECOGNIZED LOSS DIRECTORS NORTHERN DISTRICT SUCCESSORS PARTNERS THEREOF CLAIMS ADMINISTRATOR PURCHASE PRICE DISTRIBUTION ATTORNEYS EMPLOYEES SUBSIDIARIES WELLCARE MANAGEMENT |
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------------x
In re THE WELLCARE MANAGEMENT : Civil
Action No.
GROUP, INC. SECURITIES LITIGATION :
96-CV-0521 (TJM/DRH)
---------------------------------------------------------------------x
THIS DOCUMENT RELATES TO: :
:
ALL ACTIONS :
---------------------------------------------------------------------x
NOTICE OF SETTLEMENT OF CLASS
ACTION AND SETTLEMENT HEARING
TO: ALL PERSONS WHO PURCHASED SHARES OF THE WELLCARE MANAGEMENT
GROUP, INC. ("WELLCARE") COMMON STOCK DURING THE PERIOD MARCH 28, 1994
THROUGH AND INCLUDING MAY 14, 1996 (THE "CLASS PERIOD"), AND WERE
DAMAGED THEREBY, EXCEPT WELLCARE, THE INDIVIDUAL DEFENDANTS, MEMBERS
OF THE IMMEDIATE FAMILY OF EACH OF THE INDIVIDUAL DEFENDANTS, ANY
SUBSIDIARY OR AFFILIATE OF ANY DEFENDANT AND THE DIRECTORS, OFFICERS,
EMPLOYEES AND PARTNERS THEREOF, ANY ENTITY IN WHICH ANY EXCLUDED
PERSON HAS A CONTROLLING INTEREST, AND THE LEGAL REPRESENTATIVES,
HEIRS, SUCCESSORS AND ASSIGNS OF ANY EXCLUDED PERSON ("THE CLASS").
The purpose of this Notice is to inform you of the proposed settlement
of this class action and the hearing to be held by the United States
District Court for the Northern District of New York (the "Court") on
January 10, 2000 to consider the fairness, reasonableness and adequacy
of the proposed settlement (the "Settlement") set forth in the
Stipulation of Settlement dated May 18, 1999 (the "Settlement
Stipulation").
A. Statement of Plaintiffs Recovery: Pursuant to the Settlement
described herein, a Settlement Fund consisting of $2,500,000 in cash,
plus interest has been established. Plaintiffs estimate that there
were approximately 5.777 million shares of WellCare common stock
traded during the Class Period which may have been damaged as a result
of the alleged wrongdoing described at paragraph 3 below. Plaintiffs
estimate that the average recovery per damaged share of WellCare
common stock under the Settlement is $0.43 per share before deduction
of Court-awarded attorneys' fees and expenses. Depending on the number
of claims filed, when during the Class Period a Class Member purchased
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