IRA M. PRESS (IP 5313)
PAMELA E. KULSRUD (PK 4310)
KIRBY MCINERNEY & SQUIRE, LLP
830 Third Avenue, 10th Floor
New York, New York 10022
Telephone: (212) 371-6600
Facsimile: (212) 751-2540
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
PAUL WRIGHT, individually, and on behalf of all Case No.
others similarly situated,
CLASS ACTION COMPLAINT FOR
Plaintiff, VIOLATIONS OF THE FEDERAL
LAWS
v.
MERRILL LYNCH & CO., INC., MERRILL JURY TRIAL DEMANDED
LYNCH, PIERCE, FENNER & SMITH, INC.,
DAVID H. KOMANSKY and HENRY BLODGET
Defendants.
Plaintiff, by his attorneys, for his Class Action Complaint, alleges the following upon personal
as to himself and his own acts, and upon information and belief based upon the investigation of
attorneys as to all other matters. The investigation includes the thorough review and analysis of
statements, publicly-filed documents of defendants, press releases and news articles. Plaintiff
that further substantial evidentiary support will exist for the allegations set forth below after a
opportunity for discovery.
SUMMARY OF ACTION
1. This is a securities class action on behalf of public investors who purchased the common stock
Merrill Lynch & Co., Inc. during the period from July 5 of 1999 through April 8, 2002 (the "Class
Plaintiff complains of a fraudulent scheme and deceptive course of business that injured purchasers
Merrill Lynch & Co., Inc. stock during the Class Period.
SNIPPETS:
New York, New York 10022
PAUL WRIGHT, individually, and on behalf of all Case No.
Plaintiff, by his attorneys, for his Class Action Complaint, alleges the following upon
statements, publicly-filed documents of defendants, press releases and news articles.
that further substantial evidentiary support will exist for the allegations set forth below
Merrill Lynch & Co., Inc. during the period from July 5 of 1999 through April 8, 2002.
Inc. stock during the Class Period.
During the Class Period, defendant Merrill Lynch & Co., Inc. and its wholly-owned subsidiary,
objectivity and integrity of Merrill Lynch's securities analysts.
Merrill Lynch -- establishing that the technology stock recommendations of Merrill Lynch
In some instances, the New York State Attorney General obtained evidence,
Henry Blodget, privately disparaged the very stocks they publicly touted.
dozens of putative class action lawsuits were filed by investors in the
rather than based on their ability to generate investment banking
1934 (the "1934 Act"), 15 U.S.C. §78aa, as well as pursuant to 28 U.S.C. §§ 1331 and 1337.
Plaintiff Paul Wright purchased shares of Merrill Lynch & Co., Inc. common stock during the
Defendant David H. Komansky was Chairman and Chief Executive Officer of Merrill Lynch & Co.,
The Merrill Lynch Rating System:
This simply was not the case with respect to ratings published by the Internet group.
false ratings, reports, price objectives, and recommendations to advance Merrill Lynch's
These publications and organizations
Plaintiff repeats and realleges each and every allegation contained in the above paragraphs,
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