1 Michael D. Braun (167416)
Timothy J. Burke (181866)
2 STULL, STULL & BRODY
10940 Wilshire Boulevard
3 Suite 2300
Los Angeles, CA 90024
4 Tel: (310) 209-2468
Fax: (310) 209-2087
5 Kevin J. Yourman (147159)
6 WEISS & YOURMAN
10940 Wilshire Boulevard
7 24th Floor
Los Angeles, CA 90024
8 Tel: (310) 208-2800
Fax: (310) 209-2348
9 Attorneys for Plaintiff
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12 UNITED STATES DISTRICT COURT
13 NORTHERN DISTRICT OF CALIFORNIA
14
15 DENNIS PASPARAGE, on Behalf of Himself and ) CASE NO.
All Others Similarly Situated, )
16 ) CLASS ACTION
Plaintiff, )
17 ) COMPLAINT FOR THE VIOLATION
vs. ) OF THE FEDERAL SECURITIES LAWS
18 )
RIVERSTONE NETWORKS, INC., PIYUSH ) DEMAND FOR JURY TRIAL
19 PATEL, ROMULUS PEREIRA, ROBERT )
STANTON, SURESH GOPALAKRISHNAN, )
20 and JOHN KERN, ))
21 Defendants. )
_______________________________________ )
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SNIPPETS:
STULL, STULL & BRODY
Suite 2300 Los Angeles,
Attorneys for Plaintiff
COMPLAINT FOR THE VIOLATION OF THE FEDERAL SECURITIES LAWS CASE NO.
and on personal knowledge as to himself and his activities, and on information and belief as
Inc. ("Riverstone" or the "Company") between August 20, 2001 and June 5, 2002, inclusive (the
seeking remedies under the Securities Exchange Act of 1934.
include Riverstone, Piyush Patel, Romulus Pereira, Robert Stanton, Suresh Gopalakrishnan, and
Specifically, defendants misled the investing
21 1391because the acts charged herein, including the dissemination of materially false and
telecommunications service providers in the metropolitan area network.
and routing solutions in the MAN for carrier customers.
Patel also served as the President and chief executive officer of Cabletron.
16 the President and CEO since March 2000 after serving as Chief Operating Officer of
Stanton held several senior financial management positions at
Gopalakrishnan and Kern had a duty to disseminate truthful
10 Individual Defendants also had a duty to report all trends, demands or uncertainties that
aimed to reduce prices by pitting cable companies against both new and entrenched telecom
owned 92,088,235 shares of common stock, representing approximately 86% of Riverstone's
WORLD'S FIRST METRO MPLS ETHERNET NETWORK
By deploying Riverstone routers to create its metro network,
optimal foundation for the profitable delivery of IP services," said Romulus Pereira,
the creation and delivery of several exciting new services, positioning HGC to increase its
HGC was a joint venture of Hutchison Whampoa
14 Ltd. and Asia Global Crossing.
which expects its equipment to serve nearly one million Hong Kong customers
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