UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
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AVROM GART, Individually and On Behalf
of All Others Similarly Situated,
Plaintiff,
- against -
ELECTROSCOPE, INC., ROBERT C.
ODELL, DAVID W. NEWTON, VERN D.
KORNELSEN, ROBERT D. TUCKER,
JOE W. TIPPETT, DONALD R.
TEMPLE, C. RANDLE VOYLES, and
JOHN G. KINNARD AND COMPANY,
INC.,
Defendants.
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UNITED STATES DISTRICT COURT
AVROM GART, Individually and On Behalf of All Others Similarly Situated,
Plaintiff Demands a
Plaintiff, by his attorneys, for his Class Action complaint, alleges:
This is a securities class action on behalf of purchasers of the common stock of
That Offering was for 1,200,000 shares of common stock at $10.50 per share.
In its 1996 fiscal year ended March 31, 1996, less than three months before the Company's
The Prospectus was full of optimism about continued growth, especially for fiscal 1997,
On February 7, 1997, Electroscope filed its 1997 third fiscal quarter Form 10-Q with the SEC,
This Court has jurisdiction over the subject matter of this action pursuant to section 22 of
The wrongs alleged in this Complaint occurred, in substantial part, in this District,
In connection with the acts, conduct, and other wrongs complained of herein, defendants,
Defendant Roger C. Odell, a co-founder of Electroscope, was, at an times relevant hereto,
Defendants Robert D. Tucker, Joe W. Tippett, Donald R. Temple, and C. Randle Voyles were, at
Defendant John G. Kinnard and Company, Inc. was the lead underwriter of the Offering.
Because 1,200,000 shares of Electroscope's common stock were issued pursuant to the Offering
The names and addresses of the purchasers of Electroscope common stock on the (Offering and
The Registration Statement and Prospectus contained materially false and misleading
Electroscope designs, manufactures, and sells medical devices used in electrostatic surgery,
At the heart of Electroscope's sales strategy is its "Distribution Agreement" with Valleylab.
The Registration Statement of which the Prospectus was a part and which became effective on
I am seeking to serve as a representative party on behalf of a class in one other action
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