UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
________________________________________________
EDWARD R. BARRON, on behalf of himself X No.
and all others similarly situated, :
: CLASS ACTION
Plaintiff, : COMPLAINT
:
against : JURY TRIAL DEMANDED
:
SALOMON SMITH BARNEY, INC., :
CITIGROUP, INC., SANFORD WEILL :
and JACK GRUBMAN, :
:
Defendants. :
________________________________________________X
Plaintiffs, by his undersigned attorneys, individually and on behalf of the Class described
below, upon information and belief, based upon, inter alia, the investigation of counsel, which
includes, among other things, a review of public announcements made by defendants, Securities and
Exchange Commission ("SEC") filings made by defendants, press releases, and media reports,
except as to the paragraph applicable to the named plaintiffs which is alleged upon personal
knowledge, brings this complaint (the "Complaint") against defendants named herein, and alleges
as follows:
SUMMARY OF ALLEGATIONS
1. This is a securities class action alleging violations of the federal securities laws
connection with misstatements and omissions of material fact regarding AT&T Corp. ("AT&T" or
the "Company") by the defendants named herein. In particular, during the class period hereinafter
SNIPPETS:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Exchange Commission filings made by defendants, press releases, and media reports,
This is a securities class action alleging violations of the federal securities laws in
during the class period hereinafter
defined, defendants Salomon Smith Barney, Inc. and Grubman issued a materially
misleading analyst recommendation regarding AT&T common stock that recommended
that investors buy such stock.
materially misleading by defendants' failure to disclose crucial facts regarding Salomon's
C That defendants Salomon and Grubman had significant, material conflicts of interest,
obtain investment banking business for Salomon, including, inter alia, the AT&T
As the result of the foregoing, the market prices of AT&T common stock and AT&T
Wireless Group tracking stock and the offering price for the initial public offering of AT&T
Plaintiff brings this action pursuant to Section 11 of the Securities Act of 1933,
In connection with the acts alleged in this Complaint, defendants, directly or
Plaintiff Edward R. Barron purchased shares of AT&T Wireless Group
whether the federal securities laws were violated by defendants' acts as
that Salomon could win a role underwriting the initial public offering of AT&T Wireless Group
2002 The Wall Street Journal reported that New York State Attorney
Other investigations on analyst conflicts currently are being conducted by Congress, as well
MISSTATEMENTS AND OMISSIONS OF MATERIAL FACTS
recklessly and for the purpose and effect of artificially inflating the market price of AT&T
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