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1
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS STOCK ISSUANCE PLAINTIFF SPIN-OFF REGISTRATION STATEMENT SECURITIES EXCHANGE ANALYST AETNA SHARES REPORTS HEALTHCARE ALLEGATIONS MATERIAL FACT MEMBERS MEDICAL COSTS MISLEADING INDIVIDUAL DEFENDANTS SHAREHOLDERS DEFENDANT ROWE MANAGEMENT DISCLOSURES UNITED STATES DEFENDANT DONALDSON CLASS ACTION EXCHANGE ACT CLASS PERIOD SUBSIDIARIES HEALTH CARE AETNA COMMON |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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HANFORD
QUOCK,
:
on behalf of himself :
and all others similarly situated, :
: CASE NO. 01 CV 9796 (GBD)
Plaintiff, :
: CLASS ACTION COMPLAINT
v. :
: JURY TRIAL DEMANDED
AETNA,
INC.,
:
WILLIAM H. DONALDSON and :
JOHN W. ROWE, M.D., :
:
Defendants. :
-----------------------------------x
Plaintiff complains1 of defendants as follows:
I. SUMMARY OF ALLEGATIONS
1. In order to spin-off Aetna U.S. Healthcare, Inc.(ANew
Aetna@ or the ACompany@), a then wholly owned subsidiary of Aetna,
Inc. (AOld Aetna@), a Connecticut incorporated financial services
company, to its public shareholders, defendants filed a
registration statement with amendments (the ARegistration
Statement@) with the Securities and Exchange Commission (the ASEC@).
Thereafter, on December 13, 2000, Old Aetna shareholders received
a share of New Aetna for each share of Old Aetna (along with cash.)
1 Plaintiff's allegations pertaining to plaintiff and his
counsel are made on knowledge. All other allegations are made
upon information (including that derived from analysis of
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