NOTICE THIS PETITION DOES NOT
CONTAIN A REMOVABLE CAUSE OF ACTION.
REMOVAL WOULD BE IN BAD FAITH.
NO. ________
JAMES H. BROWN, SCOTT COOK, (,) IN THE DISTRICT COURT
OF
CHARLES A. HAYS, CHRISTOPHER (,)
A. LENG, RAY WACHSMANN, AND SID (,)
BOWERS, on behalf of themselves (,)
and others similarly (,)
situated, (,)
(,)
Plaintiffs, (,)
(,)
VS. (,) HARRIS COUNTY, T E X A
S (,)
COOPERS & LYBRAND, (,)
(,)
(,)
Defendant. (,) ____TH JUDICIAL
DISTRICT
PLAINTIFFS' ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Plaintiffs, James H. Brown, Scott Cook, Charles A.
Hays, Christopher A. Leng, Ray Wachsmann, and Sid Bowers on behalf
of themselves and others similarly situated, and file this their
Original Petition against Defendant Coopers & Lybrand, and for
cause of action would show this Honorable Court as follows:
I.
Parties
a.
Plaintiff, James H. Brown is an individual and a resident of
Illinois. Plaintiffs Christopher A. Leng and Ray Wachsmann are
individuals and a residents of California. Plaintiff Charles A.
SNIPPETS:
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Plaintiffs, James H. Brown, Scott Cook, Charles A.
Original Petition against Defendant Coopers & Lybrand,
Hays is a resident of Tennessee.
Cook are individuals and a residents of Texas.
By offering prospectus dated May 13, 1994,
675,000 shares of North American Advanced Materials Corporation
Lybrand consented to the inclusion of its auditors report dated
In this report and the comments in the Prospectus,
Defendant represented that it performed an audit of the balance
in the offering materials was untrue and misleading,
Had Coopers & Lybrand not issued its consent that the
regulations and guidelines required disclosure that North American
Plaintiff class to get Coopers & Lybrand paid past due amounts.
damaged in excess of the minimum jurisdictional amounts of this
That the firm was "independent" and giving its expert opinion based upon its independence;
That the firm conducted an audit in accordance with accepted auditing standards, and that
These representations were false.
damages, exemplary damages, reasonable and necessary attorney fees,
COMMON LAW FRAUD
Coopers & Lybrand knowingly made untrue representations
jurisdictional amounts of this court.
Materials Corporation as a going concern, and that the financials
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