IRA M. PRESS (IP 5313)
KIRBY MCINERNEY & SQUIRE, LLP
830 Third Avenue, 10th Floor
New York, New York 10022
Telephone: (212) 371-6600
Facsimile: (212) 751-2540
LIONEL Z. GLANCY
GLANCY & BINKOW LLP
1801 Avenue of the Stars Suite 311
Los Angeles, California 90067
Telephone: (310) 201-9150
Facsimile: (310) 201-9160
Attorneys for Plaintiff Brian Barry and
The Barry Family LP
Additional Counsel listed on signature page
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
BRIAN BARRY, On Behalf of the Barry Case No.
Family LP, individually, and on behalf of all
others similarly situated, CLASS ACTION COMPLAINT FOR
VIOLATIONS OF THE FEDERAL
SECURITIES LAWS
Plaintiff,
v. JURY TRIAL DEMANDED
EDISON SCHOOLS INC.,
PRICEWATERHOUSECOOPERS LLP;
ADAM FEILD, and CHRISTOPHER
WHITTLE,
Defendants.
Plaintiff, by plaintiff's undersigned attorneys, alleges, upon information and
belief (said information and belief being based, in part, upon the investigation conducted
1
SNIPPETS:
New York, New York 10022 Telephone:
LIONEL Z. GLANCY GLANCY & BINKOW LLP
Attorneys for Plaintiff Brian Barry and
EDISON SCHOOLS INC., PRICEWATERHOUSECOOPERS LLP;
ADAM FEILD, and CHRISTOPHER
Plaintiff, by plaintiff's undersigned attorneys, alleges, upon information and
by and through plaintiff's attorney), except with respect to paragraph 5, which is alleged
upon personal knowledge, as follows:
This is a securities fraud class action brought on behalf of investigators
of the Securities and Exchange Act of 1934, 15 U.S.C. Section 78j,
This Court has personal jurisdiction over defendants pursuant to Section
Plaintiff purchased shares of Edison common stock during the Class
Edison develops medium and large school districts.
PWC audited Edison's financial statements for fiscal1999 that were
Defendant Adam Feild is the Company's executive vice
As a result, and according to the SEC Order,"the review of accounting
materially false and misleading, as Edison's restatement acknowledges.
The Company reported approximately $376 million of revenue.
would learn at the end of the Class Period, approximately half of the reported revenues were
report by the Bloomberg News Service.
The Bloomberg report quoted Walter Schuetze,
The members of the Class are so numerous that joinder of all members
Whether the federal securities laws were violated by defendants' acts
FRAUD ON THE MARKET DOCTRINE
failed to disclose material facts,
entitled to a presumption of reliance upon the integrity of the market price for the Company's
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