Missoula, Montana 59808
Telephone: (406) 728-8282 `. , : : .
i
-q CLEF?!
MarcA. Topaz; Esq ,-.. (_.. `,, .
Darren J. Check, Esq.
SCH$RIFFIN & ~BARROWAY, ,LLP .,. .' `.
,: . ,..
Three Bala Plaza, Su!te 400
3a:la Cynwyd:, PA. I;9004
j -:,.`/ ":,.'
.`I .
Telephone: (610) 667-7706
i s;torneys f&`Plaintiffs ;. ..:,. I ,.
!
II
. -.- _. ,. ~. ", .._ :
1' IN THE Ii&Till STATES
FOR THE DISTRICT OF'MONTANA
1: hfLSSOUL,A DMSION
1:
1L DONNIE SANDERS, Individually And On
Behalf of All Others Similarly Situated
IL .
IE
17
TOUCH AMERICA HOLDINGS,, INC. f/k/a
IE MONTANA POWER COMPANY and
ROBERT GANNON,
II
ANDED
2c Defendants.
21 Plaintiff has alleged the following based upon the investigation of
22 ounsel, which included a review of United States Securities and Exchange
23 :ommission ("SEC") filings by Touch America Holdings, Inc. f/k/a Montana Power
24 Lompany ("Montana Power" or the `Company"), as well as regulatory filings and
25 sports, securities analysts' reports and advisories about the Company, press releases
26 nd other public statements issued by the Company, and media reports about the
27
28 omplaint for Violations of Federal Securities Laws
Page 7
SNIPPETS:
ROBERT GANNON,
which included a review of United States Securities and Exchange
23:ommission filings by Touch America Holdings, Inc. f/k/a Montana Power
25 sports, securities analysts' reports and advisories about the Company, press releases
and plaintiff believes that substantial additional evidentiary support will exist
for the allegations set forth herein after a reasonable opponunity for discovery.
This is a federal class action on behalf of purchasers of the common stock 5 of Montana Power
seeking to pursue remedies under the Securities Exchange Act of 1934
In connection with the acts alleged in this complaint, defendants, directly
artificially inflated prices during the Class Period and has been damaged thereby.
providing customized voice, data and viden transport, as wtill as Internet services, to L
the market price of the Company's publicly-traded securities would be based upon
IO business prospects and financial condition and performance as particularized herein
13 by the Company materially false and misleading.
value of Montana Power stock; and.caused plaintiff and other members of the Class
Company, at all relevant times, members of their immediate families and their legal
20:OS& to Montana Power, As a result, M0nl:an.a Power lost revenues;
22 billed Montana Power for more than $10 million for local access facilities;
75 and misleading statements and failing to disclose material facts necessary to make
Plaintiff repeats and realleges each and every allegation contained above 22 as if fully set
he Company's management team or had
13 Jefendants was aware of the Company's dissemination of information to the investing
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