Joseph R. Seidman (JS-9260)
IO East 40'" Street
New York, NY 100 16
Tel: (212) 779-1414
SC%UFFRIii & BARROWAY, LLP
Marc A. Topaz, Esq.
Three Bala Plaza East, Suite 400
Bala Cynvyd, I?,4 19004
Tel: (6 IQ) 667-7706
CAULEY, GELLER BOWMAN & COATES, LLP
Paul J, Geller, Esq.
One Boca Place
2255 Glades Road - Suite 421A
Boca Raton, FL 3343 1
Tel: (561) 750-3000
Attorneys for Plaintiff
UNITED STATES DISTRICT CBURT
SOUTHERN DISTRKT OF NEW YORK
>
CAROL FINGER, on Behalf of Himself and all )
Others Similarly Situated, > CIVIL ACTION NO.
>
Plaintiff, ) CLASS ACTION COMPLAINT
) FOR VIOLATIONS OF
V, ) FEDElRAL SECURITIES
>
SALOMON SMITH BARNEY INC,, JACK ) J-LJRY TRIAL DEM&`?DED
GRU-BMCW and MORGAN STANLEY DEAN )
WlTTER 2% co., INC., 1
>
Defendants. 5
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Carol Pinger, by his attorneys, for his cornpIaint against defendants Salomon
Barney Inc. ("Smith Barney"), Jack Gmbman and Morgan Stanley Dean Wit& & Co. ("Morgan
Stanley"), alleges as follows:
NATURE OF THE ACTXQN
1. This is a securities fraud class action on behalf of all persons and entities who
SNIPPETS:
Three Bala Plaza East, Suite 400
Boca Raton, FL 3343 1 Tel:
Carol Pinger, by his attorneys, for his cornpIaint against defendants Salomon Smith
Barney Inc., Jack Gmbman and Morgan Stanley Dean Wit& & Co. ("Morgan
This is a securities fraud class action on behalf of all persons and entities who
purchased the common stock ofLevel 3 Communications, Inc.
between January 4, 1999 and June 18,2001, inchtsive (the "Class" and the "Class Period,"
issuing positive recommendations about
Level 3 even though there were no rational economic reasons or factual bases to justify such
obtain investment banking business; and concealing significant,
their influence and reputation to tout the Company's stock even though they knew or recklessly
disregarded that there existed no reasonable basis for the positive recommendations.
Level 3 common stock traded as high as $13225 per share.
Plaintiff brings this action on behalf of himself and all others who purchased
Securities Exchange Act of 1934, 15 USC, 5 7Sj, and RuIe lob-5
telephone communications and the facilities of interstate commerce.
business at 388 Greenwich Street, New York, New York 10013.
Defendant Morgan Stanley is a full-service securities firm with its principal place
Plaintiff brings this action as a class action pursuant to Federal Rule of Civil
Procedure 23 on behalf of a CIass consisting of all persons and entities who purchased the
Company, members of their immediate families and their legal representatives, heirs,
Smith Barney's and Morgan Stanley's telecommunications research
total of $917,125 in fees for all the notes sold.
Barney again acred as lead underwriter and defendant Morgan Stanley again acted as an initial
privately placed 3 1.44 billion and Eu800 milhon worth of debt in three separate debt
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