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1
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PLAINTIFF MATERIAL FACTS EXCHANGE SECURITIES COMMON CLASS PERIOD OMISSIONS POWER REPORTS FEDERAL SECURITIES LAWS CALIFORNIA VIOLATION COMMON STOCK BUSINESS INTER ALIA CRUCIAL FACTS POWER GRID CONNECTION WEAKNESSES SALES PRESENTATION EXCHANGE ACT BUSINESS PRACTICES PROPRIETARY INFORMATION STATES DISTRICT COURT COMMISSION CONSULTING BUSINESS MISLEADING MISREPRESENTATIONS |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
HERBERT CONDELL, on behalf of himself X No.
and all others similarly situated, :
: CLASS ACTION
Plaintiffs, : COMPLAINT
:
against : JURY TRIAL DEMANDED
:
PEROT SYSTEMS CORP., :
ROSS PEROT and ROSS PEROT, JR., :
:
Defendants. :
________________________________________________X
Plaintiffs, by their undersigned attorneys, individually and on behalf of the Class
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 plaintiffs which is
alleged upon personal knowledge, bring this complaint (the "Complaint") against defendants named
herein, and allege as follows:
SUMMARY OF ALLEGATIONS
1. This is a securities class action alleging violations of the federal securities laws
the common law in connection with misstatements and omissions of material fact regarding Perot
Systems Corp. ("Perot Systems" or the "Company") by the defendants named herein. In particular,
SNIPPETS:
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