BERNSTEIN LIEBHARD & LIFSHITZ, LLP
Sandy A. Liebhard (SL-0835)
Michael S. Bigin (MB-0037)
10 East 40th Street
New York, NY 10016
Tel: (212) 779-1414
SCHIFFRIN & BARROWAY, LLP
Marc A. Topaz, Esq.
Three Bala Plaza East, Suite 400
Bala Cynwyd, PA 19004
Tel: (6 10) 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) 750-3000t
Attorneys for Plaintiff
UNITED STATES DIS'lRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CHRISTOPHER DEMMITT, on Behalf of Himself i
and all Others Similarly Situated, j CIVIL ACTION NO.
>
Plaintiff, ) CLASS ACTION COMPLAINT
) FOR VIOLATIONS OF THE
V. ) FEDERAL SECURITIES LAWS
)
MORGAN STANLEY DEAN WITTER & CO., ) JURY TRIAL DEMANDED
MORGAN STANLEY TECHNOLOGY FUND >
(f/k/a MORGAN STANLEY DEAN WITTER )
TECHNOLOGY FUND), MORGAN STANLEY )
DEAN WITTER DISTRIBUTORS INC., MORGAN )
STANLEY DEAN WITTER ADVISORS INC., >
AND MORGAN STANLEY DEAN WITTER >
INVESTMENT MANAGEMENT INC., >
>
Defendants. >
1
Plaintiff, by his undersigned attorneys, individually and on behalf of the Class
SNIPPETS:
Plaintiff, by his undersigned attorneys, individually and on behalf of the Class described
included, among other things, a review of public statements made by Defendants and their
reports, and allege as follows:
This is a federal securities class action brought by Plaintiffs against Defendants
Morgan Stanley Dean Witter & Co. ("MSDW" or the `ICompany"),
Fund ("Technology Fund" or the "Fund"), Morgan Stabley Dean Witter Distributors Inc.
Dean Witter Investment Management Inc. (all collectively,
clients of MSDW) who purchased shares of any and/or every class of the Fund's shares from the
corporate finance (collectively "investment banking") dusiness from these present and former
recommendations on many of the companies whose shares were in the Fund's portfolio;
Plaintiffs and the Class in their decisions to purchase oq' sell shares of the Fund.
Section 22 of the Securities Act, 15 U.S.C. 5 80a-43 of the Investment Company Act of 1940,
York County, New York.
Plaintiff purchased shares of the Fund during the Class Period,
Information incorporated into the respective, relevant prospectuses herein, "a preeminent
influenced by the firm's interest in attracting and retaining investment banking business.
In recent years, however, the Chinese wiall has crumbled, with research analysts
York State Attorney General, Eliot Spitzer filed a Genbral Business Law Article 23-A action
NASD, New York Stock Exchange, and New York State Attorney General into research analyst
MSDW filed a Registration Statement with the SEC on June 16,
The SOAIs also state that Distributors "has entered into a selected dealer
The total cost of its common stock portfolio, as stated in its first semi-annual
disclose, inter nlia, certain material facts, as set forth herein.
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