UNITEDSTATESDIST'RICTCOURT
FORTBEDISTRKT OFMNNESOTA
Janis Dolan,.on behalf of herself and all others
similarly situated, Civil Action No.
Plaintiff,
vs. . CLASSACTXONCOMPLAINT
SU.PEl?.VALU, MC., MICHAJZ W. WRIGHT, i
JEFFREY NqDDLE and PAMELA I(. KNOUS. :
JlJRYTRIALDEhNDED
Defendants.
Plaintiff, Janis Dolan, individually and on behalf of all other persons similarly
her undersigned attorneys, alleges the following based upon personal knowledge as to herself and
her own acts, and information and belief as to all other matters, based upon, her da, the
investigation conducted by and through her attorneys, which included, among other things, a review
of the public documents and announcements made by the defendants, Securities and &change
Commission ("SEC") filings, and press releases regarding Supervalu, Inc. ("Supervalu" or the,
"Company"), and plaintiff believes that substantial evidentiaty support will exist for the
set forth herein after a reasonable opportunity for discovery.
NATLJREQFT~EACTION
1. This is a class action, brought by plaintiff on behalf of herself and a Class
of all other persona who purchased Supervalu common stock during the period from April 4,200l
through and including June 26, 2002 (the "Class Period"), to recover damages caused by the
SNIPPETS:
Plaintiff, Janis Dolan, individually and on behalf of all other persons similarly situated, by
Commission filings, and press releases regarding Supervalu, Inc. ("Supervalu" or the,
and plaintiff believes that substantial evidentiaty support will exist for the allegations
This is a class action, brought by plaintiff on behalf of herself and a Class consisting
of all other persona who purchased Supervalu common stock during the period from April 4,200l
through and including June 26, 2002, to recover damages caused by the
' defendants' violation of federal securities laws.
and/or failed to correct false and misleading financial statements and press releases
Exchange Act of 1934, 15 U.S.C. $3 78jand 7&, and Rule lob-5, 17
and dissemination to the investing public offalse and,misleading information, occurred in
Chief Executive Officer and was a member of the Board o.f Directors during the Class Period
replacing Defendant Wright in that position:
for the truthfulness and accuracy ofthe Company's public filings and press releases described
Each of the defendants knew or recklessly disregarded tit the false and/or misleading
constitute a fraud and deceit upon plaintiff and the other members of the Class.
defendants made public misrepresentations or failed to disclose
misrepresented material facts and the time the true facts were
financial results were presented in conformity with Generally Accepted .Accounting Principles
The statements referenced above in paragraphs 25-29 were each materially false
The impact of these announcements was immediately felt in the market.
the principle that the financial information presented should be
&APB No. 4,1128,35, 88, 171);
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