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1
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COMPLAINT
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EXTRACTED KEY WORDS
LOANS KOZLOWSKI SWARTZ SECURITIES TRANSACTIONS INVESTORS DISCLOSE SHAREHOLDERS COMPENSATION EXCHANGE ACT BELNICK FEDERAL SECURITIES LAWS FUNDS RELOCATION LOAN PROXY STATEMENTS PRACTICES PERQUISITES ANNUAL REPORTS KELP RELOCATION LOAN PROGRAM EXECUTIVES EXCHANGE ACT RULES APARTMENT VIOLATIONS DISCLOSURE CAUSING TYCO UNAUTHORIMI EMPLOYEES PARK CITY |
-- ..-.
.lJNIT'ED STATES DISTFtICT COURT
SOUTHERN DISTRICT OP NEW YORK 02
I :
SE(fLTRITIIES AI'@ EXCHANGE COMMISSION,
:
PlainlIft, :
and MARK A. BELNICK,
D&lldantS.
.'
1. This is a lootir~g cse. It involves egregious,
misconduct by the fhree most &or executives at Tyco
1996 until June of 2002, L. Dennis I&low&i (Xozlowski'~
and Mark H. SW&Z (,,SwzW) (then Tyco's Chief Financial OfBcer) took
dollars in secref unauthorimi a.nd improper low interest 6r interest-&e
horn Tyco. Kozlowski and Swartz con&led these transactions from Tyco's
Kozlowski and Swab later pocketed tens of millions of dollars by
repayment of many of their improper loans. They also concealed these
.
shareholders. Moreover, Kozlowski and Swartz engaged in num=ous highly
party transactions with Typo and awarded tb~el~~~ lavish
the tmnsa~tions or perquisites ta Tyco shareholders. At the sane time
engaged in their massive covert defilcation of corporate funds,
investors that at Tyco "nothing was hidden behind the scenes," that Tyco's disclosures
"exceptional" and that Tyco's management "ptided itself on having sharp focus with
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