UNITED STATES kXXKT 6OURT
SouTHEmDIsTRIcT
~F:N&WYI~
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HOWARD ROSEN, OFI Bchzrlf of Himself and : Civil Action No.
All Others Similarly Situet.ed, f
: CLASS ACTION
Plaintiff, :
: COMPLAINT FOR
VS. : FEDERAL SECURlTlES
,
MARTHA STEWART LIVR\JCi OM-NIMEDIA, :
INC., MLRTHA STEWART, hEGORY R, :
BLATT, DORA BRASCHI CAkDINALE, L. :
JOHN DOERR, SHAltON'L. PATRICK, :
K.LEl%R PERKINS CALJFIELD & BYERS,, :
MA.RGARET ROACH, SUZh'NE SC)BEL, :
LAUREN PODLACH STANK% and GAEL :
TOWEY, ,' ,
Defendants. :
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DEMAND FOR JURY
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INTRODUC'X1J~jN AND OVERVIEW
SNIPPETS:
This writing/publication is a creative work fu11~ protected by all applicable copyright laws,
No copyright is dtaimed in4he text af sktutes, regulations, and any excerpts from analysts'
All rights reservid -`including the right to rcprodpcc in whole or in pan;
This is's securities class action on behalf of all purchasers of the common stock of
Mafiha Stewart Living, Omnimedia,, Inc. against the Company and
certain of its officers and directors (the "lndikidual Defendants") for violations of the
Exchange Act of 1934.
lnciuding SfeGar& sales; approximatiely 5.3 million shares ofMSL0 stock were sold by
MSLO executives during,the Class Period at p$ices as,high as $20 per share, allowing insiders
the "Martha Stewart I..ivingY and Wartha.
primarily through r;al&s of "Martha Stewart Living" magazine which.
The diminution or loss of i:he services of Martha Stewart, and slny negative market or
by defendants that MSLO's value as a going sonccttnY and thus its stock price,
been accused of irisider stock trading in the scc$tities of h&lone.
sold;100% pf her ImClonr shwes.
a beneficial owner oF,,more than 5% o.f the shares /of ImClone, she was nor required to
argue she was not liable For insider trading even i&she had material,
all, `MSLO insiders obtained il,licit insider trading proceeds of over $79 inillion, and
and course of business that operated as a I?aud or deceit on purchasers of MSLO stock by
The individual Defendants also have had substantial and continuous contacts with
Plainti fF,HowatdRoscri Purchased MISDO common stock as described in the attached
Defendant Gael Towey 1s Senior Executive Vice President and Creative
The Indivictuai Defendants' irtsiderlseiling was in violation of the abstain or disclose
The chal,lenge, in our view,~ is to differentiate the ongoing business fundamentals ofMartha
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