LINTED STATES DIST'RXT COURT
SOUTHEKN DISTRIUT OP `INDMA
~~NU'OLlS ~DIVISION
CAROLE PATAl, individually and on behalf of : NoI
all others similarly situated,
PlaintiB, .
CLASS ACTKB4' COMPLUT
VS.
DENIW W. l3AKKE4 ROGER W, SANT,
BARRY J. SHARI? and AES CORE .
JURY TRJ& PEMANDED
Defendants. : .
Plaintiff, by her attorneys, for her coinplaint against the defendants, alleges
follows:
JURJSDICT~ON Am VENUE
1, The claims asserted herein arise under and pwguant to Sections 11,
12(a)(2) and 15 of the Securitks Act of 1933, as amended (the FJecu.riti.es
Act") [ 15 U.S
$4 77k, 771(a)(2) and 774.
2. This Court has jurisdiction of this action pursuant to Section 22 of
Securities Act [lS USC, 0 77~1,
3: Venue is properly laid in this judicial district pursuant to Section
Securities Act. The acts and conduct complained df, including the preparation, issuance and
dissemination of materially false and misleading information to the investing public, OCGUSI~
substantial part in this judicial district.
PARTIB,S
Plaintiffs
SNIPPETS:
Plaintiff, by her attorneys, for her coinplaint against the defendants, alleges as
This Court has jurisdiction of this action pursuant to Section 22 of thhe
Securities Act [lS USC, 0 77~1,
Venue is properly laid in this judicial district pursuant to Section 22 of tbs
common stock in connkction with the tender offer, pursuant to the Registration Statement
hereto and incorporated herein by reference,
IpALCO and Al% stock is as follows:
27,200 1, A.ES engaged in an exchange offering of AES common stock for IPALCO common
shares pursuant to a Registration Statement &ted and filed with the SEC on August 16, 2000,
These defendants are referred to herein as the "Individual Defendants," Bach of the h-&Mual
Plaintiff brings this action as a class action pursuant to Federal Rules of Civil
the Proxy Statement/Prospectus dated September 8,2ObO, and who suffered damages as a result
the date of the transaction at issue, and the legal representatives, agents, affiliates,
The members of the Class are so numerous that joinder of all members i.s
Whether the federal securities laws were violated by defendants' acts as
price for the acquisition was reported by AES to be approximately $2,1 billion based on the
The Materially False And Misleading Registtiation Statement
Loans That Increased AES Stack Volatility and DSlutioa
the impact of SELLS could have a imaterially negative effect on the value of AE%
United Kingdom Operations an4 tJle Financial Deterioration at its Fifoots
incorporated by reference in the IRegistration Statement and Prospectus,
operations to IPALCO shareholders, among otiersl and all of these factors resulted from
facilities which do not have long-term contracts to sell their power have come under severe
and in that they failed to disclose the following material, adverSe facts about AES'S
contained un?xue statements of material facts, omitted to state other facts necessary to make
upon which this complaint is based to the time that plaintiff filed her Complaint.
preparation of the false and misleading Prospectus.
|
