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1
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COMPLAINT
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EXTRACTED KEY WORDS
ENERGY SECURITIES REPORTS PLAINTIFF TRADING UNITED STATES EXCHANGE ACT INDIVIDUAL DEFENDANTS MARKETING GAS BUSINESS REVENUES PRETAX OPERATING INCOME TRADES POWER EXCHANGE COMMISSION SECURITIES ANALYSTS MISLEADING WHOLESALE GAS MATERIALLY FALSE ENERGY MANAGEMENT SERVICES ALLEGATIONS NATURAL GAS TRANSACTIONS COMMON STOCK MATERIAL FACTS DISCLOSURE ACCOUNTING REPRESENTATIONS |
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
CRAIG DRIMEL, Individually and on Behalf of )
all Others Similarly Situated, )
) Civ. No. ________________
Plaintiff, )
) CLASS ACTION
vs. ) COMPLAINT FOR
) VIOLATIONS OF FEDERAL
CMS ENERGY CORPORATION, CONSUMERS ) SECURITIES LAWS
ENERGY COMPANY, WILLIAM T. McCORMICK, )
JR., DAVID W. JOOS and ALAN M. WRIGHT, ) JURY TRIAL DEMANDED
)
Defendants. )
)
Plaintiff has alleged the following based upon the investigation of
included a review of United States Securities and Exchange Commission ("SEC") filings by CMS Energy
Corporation ("CMS") and Consumers Energy Company ("Consumers") (together CMS and Consumers
shall hereinafter be referred to as "CMS" or the "Company"), as well as regulatory filings and
securities analysts reports and advisories about the Company, press releases and other public
issued by the Company, and media reports about the Company, and Plaintiff believes that substantial
additional evidentiary support will exist for the allegations set forth herein after a reasonable
for discovery.
NATURE OF THE ACTION
1. This is a federal class action on behalf of purchasers of the
between August 3, 2000 to May 10, 2002, inclusive (the "Class Period"), seeking to pursue remedies
under the Securities Exchange Act of 1934 (the "Exchange Act").
JURISDICTION AND VENUE
2. The claims asserted herein arise under and pursuant to Sections 10(b)
SNIPPETS:
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