WECHSLER HARWOOD
1 HALEBIAN & FEFFER LLP
488 Madison Avenue
2 New York, New York 10022
(212) 935-7400
3 Robert I. Harwood
4 Law Offices of
BONNETT, FAIRBOURN, FRIEDMAN
5 & BALINT, P.C.
4041 North Central Avenue
6 Suite 1100
Phoenix, Arizona 85012
7 (602) 274-1100
Andrew S. Friedman (#005425)
8
Attorneys for Plaintiffs
9
10 IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF ARIZONA
11
12 CHARLES MILLER, on behalf of )
himself and all others similarly )
13 situated, ) NO. CV. 98-0020 PHX ROS
) Jan. 6, 1998
14 )
Plaintiff, ) CLASS ACTION COMPLAINT
15 )
-against- ) JURY TRIAL DEMANDED
16 )
SAMUEL J. PARKER, MARK S. )
17 HANSEN, C. DONALD DORSEY, SUSAN )
C. SCHNABEL, and PETSMART, INC., )
18
19 Defendants.
20 _____________________________________________
)
21 Plaintiff, by his attorneys, for his class action complaint,
22
23 alleges upon personal knowledge as to himself and his own acts, and
24 upon information and belief as to all other matters, based upon, inter
25
SNIPPETS:
27 investigation included, inter alia, a review of the public filings by
PETsMART, Inc. with the Securities and
Exchange Commission, articles in the financial news media,
Plaintiff believes that further substantial evidentiary
11 of himself and all others who purchased shares of PETsMART common stock
14 defendants' violations of the Federal securities laws.
15 Class Period, PETsMART and certain of its senior officers and directors
17 tick product inventory, financial condition, and results of operations.
defendants caused these materially false and
19 misleading statements to be made in order to:
flea and tick control products sold by PETsMART.
over-the-counter flea and tick remedies
accounted for approximately 10-15% of PETsMART's annual sales.
its principal place of business in this District and many of the acts
dissemination of materially false and misleading financial statements,
24 March 1989 as President and Chief Executive Officer,
owned 1,089,544 shares of PETsMART common stock.
Parker attended management and Board of
21 conversations with securities analysts.
each of the individual defendants had a
16 August 3, 1997, the Company operated 373 "superstores" in North America
veterinary clinics were owned by Medical Management International,
The Company reported net income of $11.2
The statements in the November 19, 1996 press release 1 and 1996 Third Quarter 10-Q
Related Party Disclosures:
party transactions to be arranged to obtain
allegation contained above,
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