UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
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FRAIZER INVESTMENTS, individually and on
behalf of all others similarly situated,
Plaintiff,
§ Case No.
- against -
RELIANT RESOURCES INC.; DELOITTE &
TOUCHE LLP; GOLDMAN, SACHS & CO.;
CREDIT SUISSE FIRST BOSTON CORP.; ABN§ JURY TRIAL
AMRO ROTHSCHILD LLC; BANC OF§ DEMANDED
AMERICA SECURITIES LLC; DEUTSCHE
BANC ALEX. BROWN INC.; MERRILL
LYNCH, PIERCE, FENNER & SMITH, INC.;
UBS WARBURG LLC; R. STEVE LETBETTER;
STEPHEN W. NAEVE; MARY P.
RICCIARDELLO, and RELIANT ENERGY INC.,
Defendants.
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ORIGINAL COMPLAINT - CLASS ACTION
Plaintiff, by undersigned counsel, alleges the following upon personal knowledge as to
its acts and as to all other matters upon information and belief upon, inter alia, the
and through their attorneys, including a review of the public filings of Reliant Resources, Inc.
the "Company") with the Securities and Exchange Commission ("SEC"), and public statements made by
or reasonably attributable to defendants or their agents.
INTRODUCTION AND DESCRIPTION OF THE CASE
ORIGINAL COMPLAINT - CLASS ACTION
SNIPPETS:
RELIANT RESOURCES INC.; DELOITTE &§ TOUCHE LLP; GOLDMAN,
AMERICA SECURITIES LLC; DEUTSCHE§ BANC ALEX.
Plaintiff, by undersigned counsel, alleges the following upon personal knowledge as to
15 of the Securities Act of 1933 and under sections 10and 20of the Securities Exchange Act of
2001 initial public offering of Reliant common stock and /or at all times
During the class period, Reliant stock was issued and traded at artificially inflated prices
This inflation of reported revenues was achieved through "round-trip" energy trading in which
Defendants included these inflated revenue and trading volume figures in a Registration
Such transactions involved co-operating counterparties including: CMS Energy Corp.; EnCana
Statement and Prospectus for an initial public offering of Reliant common stock.
The price of Reliant's common stock during this period was artificially inflated by the
An additional 7.8 million shares were subsequently issued and sold when the underwriters of
preparation and dissemination to plaintiffs and other investors of false and misleading
Defendant Reliant Energy, Inc. spun off Reliant Resources in Reliant's
and Chief Executive Officer, and a director of the Company.
President and Chief Accounting Officer of the Company.
The Individual Defendants each signed the Registration Statement for Reliant's IPO.
Rothschild LLC, Banc of America Securities LLC, Deutsche Banc Alex.
Pierce, Fenner & Smith, Inc., and UBS Warburg LLC (the "Lead Underwriter Defendants") served
which specialize, inter alia, in underwriting public offerings of securities.
Defendant Deloitte & Touche LLP is an accounting an consulting
Deloitte & Touche audited Reliant's financial statements for 1999 and 2000
Statement for the Reliant IPO, and reproduced at ¶¶__-__ above, were materially false and
misleading, contained untrue statements of material facts, omitted to state other facts
Reliant, and/or signed the Company's public filings with the SEC, which public filings
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