John Halebian (JH-8005)
Scott A. Kamber (SK-5794)
WECHSLER HARWOOD HALEBIAN
& FEFFER, LLP
488 Madison Avenue, 8th floor
New York, New York 10022
Telephone: (212) 935-7400
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
_______________________________________ X
:
DONALD DONEY and MADELYN J. :
McCABE, on behalf of themselves and all :
others similarly situated, : Civ. No.________
:
Plaintiff, :
:
- v. - : CLASS ACTION COMPLAINT
:
COMMAND SYSTEMS INC., EDWARD :
G. CAPUTO, STEPHEN L. WILLCOX, :
ROBERT B. DIXON, JOHN J.C. :
HERNDON, JAMES M. OATES, :
JOSEPH D. SARGENT, COWEN & :
COMPANY and VOLPE BROWN :
WHELAN & COMPANY, LLC,
:
:
Defendants. :
_______________________________________ X
Plaintiffs, individually and on behalf of all others similarly situated, by
their undersigned attorneys, allege upon personal knowledge as to his own acts and
upon information and belief as to all other matters.
Plaintiffs' information and belief is based on, inter alia, a review of
relevant filings made with the Securities and Exchange Commission ("SEC"), press
releases, news and analyst reports, and an investigation undertaken by plaintiff's
counsel. Plaintiffs believe that further substantial evidentiary support for the
SNIPPETS:
John Halebian
WECHSLER HARWOOD HALEBIAN & FEFFER,
Plaintiffs, individually and on behalf of all others similarly situated, by
relevant filings made with the Securities and Exchange Commission,
releases, news and analyst reports, and an investigation undertaken by plaintiff's
Plaintiffs believe that further substantial evidentiary support for the
allegations set forth below will be shown to exist after a reasonable opportunity for
This is a class action against Command Systems Inc.
In the Prospectus, Defendants detailed a business strategy
providing year 2000 services is one of the most closely followed by investors,
as much interest as possible in its IPO.
common stock at $12.00 per share to plaintiffs and other members of the Class in an
the Registration Statement and Prospectus.
Cowen & Company and Volpe Brown Whelan & Company, LLC
12and 15 of the Securities Act of 1933 [15 U.S.C.
dissemination to the investing public of a false and misleading Form S-1 Prospectus
Chairman of the Board of Command at all relevant times.
The Underwriter Defendants were at all times
shares of Command's common stock pursuant to the Offering.
Class are the defendants herein, members of their immediate families, and any
through appropriate discovery, plaintiff believes that there are hundreds of persons
statements of material fact or omitted and/or misrepresented material facts about
OR OMISSIONS IN THE PROSPECTUS
Offshore Technology Center and that Y2K related services would be the centerpiece
Y2K services and the resulting need for expansion of the Offshore Technology
On April 13, 1998, Hugh Shytle, an analyst with Cowen
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