BERNSTEIN LIEBHARD & LPFSHITZ, LLP
Mel E. Lifshitz (ML-2616)
Michael S. Bigin (m-0037)
10 East 40" Str
New York, NY ()2CV
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Tel: (212) 779- `,,'
SCNIFFRIN & &iRROWAY, LLP
Marc A. Topaz, Esq.
Three Bala Plaza East, Suite 400
Bala Cynwyd, PA 19004
Tel: (610) 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
UNlTED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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DELBERT CURRENS, On Behalf of Himself and )
all Others Similarly Situated, ) CIVIL ACTION
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Plaintiff, ) CLASS ACTION
) FOR VIOLATIONS
V. ) FEDERAL
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SALOMON SMlTIl BARNEY, MC., CITIGROUP, ) JWRY TRIAL DEMANDEQ
l-NC., SANFORD WEILL, and JACK GRUBMAN, )
>
Defendants. 1
* )
Plaintiff, by his undersigned attorneys, individually and on behalf of tie Class
below, upon actual knowledge with respect to the allegations relaf:d to Plaintiffs purchase of
.' . .? , ; , J_
the common stock of AT&T Corp. ("AT&T" or the "Company"), and ofAT&T Wireless
stock, and upon information and belief with respect to the remaining allegations, based
SNIPPETS:
Plaintiff, by his undersigned attorneys, individually and on behalf of tie Class described
the common stock of AT&T Corp., and ofAT&T Wireless
stock, and upon information and belief with respect to the remaining allegations, based upon,
of public statements made by Defendants and their employees, Securities and Exchange
This is a federal securities class action brought by tplaintiff against Defendants
Salomon who purchased the common stock of AT&T between November 29,1999 and August
purchased AT&T Wireless tracking stock pursuant or traceable to the April 27,200O registration
Exchange Act of 1934 and Rule lob-5 promulgated thereunder,
Grubman of an analyst report regarding Salomon, which recommended the purchase of AT&T
Furthermore, when issuing the AT&T recommendation, Defendants Salomon and Grubman
and support lucrative financial deals for Salomon, and specifically the AT&T Wireless
The Class Period begins on November 29,
day The Wall Street Journal revealed that the New York State Attorney General,
underwriting a lucrative spin-off.
AT&T Wireless tracking stock pursuant or traceable to the April 27,2000, registration
Defendant Citigroup is the parent corporation of Salomon,
tracking stock pursuant or traceable to an April 27,200O registration statement, have
among others, as part of a broad investigation into whether Wall Street firms violated New
investment banking profits for both Salomon and Grubman.
banking client telecommunication companies such as X0 Communications,
were based more on Salomon's investment banking fees than objective analysis,
not influenced by the firm's interest in attracting and retaining investment banking business.
Grubman made materially false and misleading
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