UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
)
)
BRIAN BARRY, on behalf of himself and all )
others similarly situated, )
Plaintiff CLASS ACTION COMPLAINT
)
)
v. )
)
WORLDCOM, INC., BERNARD J. )
EBBERS, JAMES C. ALLEN, MAX E. JURY TRIAL DEMANDED
)
BOBBITT, FRANCESCO GALESI, and )
ARTHUR ANDERSEN, LLP )
Plaintiff, by his undersigned attorneys, individually and on behalf of the Class described
below, upon information and belief, based upon, inter alia, the investigation of counsel, which
includes, among other things, a review of public announcements made by defendants, Securities and
Exchange Commission ("SEC") filings made by defendants, press releases, reports of securities
analysts, and media reports, except as to the paragraph applicable to the named plaintiff which is
alleged upon personal knowledge, brings this complaint (the "Complaint") against defendants named
herein, and alleges as follows:
SUMMARY OF ALLEGATIONS
1. This is a securities class action alleging violations of the federal securities
connection with the preparation and dissemination of false and misleading financial statements for
WorldCom, Inc. ("WorldCom" or the "Company") by the defendants named herein. In particular,
during the class period hereinafter defined, defendants made misrepresentations and/or omissions
of material fact, including:
SNIPPETS:
Plaintiff, by his undersigned attorneys, individually and on behalf of the Class described
Exchange Commission filings made by defendants, press releases, reports of securities
alleged upon personal knowledge, brings this complaint against defendants named
WorldCom, Inc. by the defendants named herein.
during the class period hereinafter defined, defendants made misrepresentations and/or
Affirmatively misstating the value of goodwill and other intangible assets
LLP violated the federal securities laws
by certifying WorldCom's financial statements as incorporated in WorldCom's Annual Report for
incorporated by reference into, inter alia, WorldCom's quarterly filings with the SEC after
the truth regarding the foregoing misstatements and omissions gradually became known to the
of the Securities Exchange Act of 1934 and 28 U.S.C.
misleading financial statements during the Class Period, issued materially false and
Plaintiff brings this action as a class action pursuant to Rule 23and of the
converted, exchanged or otherwise acquired the common stock of WorldCom between January 3,
Dissemination of False and Misleading Financial Information
are unaudited and have been prepared in accordance with accounting principles generally
other intangible assets that the Company had obtained in connection with is
continued to announce and report its earnings based on the artificially high carrying
Andersen provided unqualified audit opinions relating to the abovereferenced financial
because they omitted material facts regarding WorldCom's goodwill and intangibles and stated
|
