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Stanford University Law School - Securities Class Action Clearinghouse
                  UNITED STATES DISTRICT COURT
              FOR THE WESTERN DISTRICT OF OKLAHOMA

-------------------------------------x
ROBERT MARK, on Behalf               :
of Himself and All Others            :
Similarly Situated,                  :
                                     :
                       Plaintiff,    :  CIVIL ACTION NO. CIV-96-0506-M
                                     :  Filed Apr 4, 1996
                                     :
          v.                         :
                                     :
FLEMING COMPANIES, INC.,             :
ROBERT E. STAUTH, HARRY L.           :
WINN, DONALD W. EYLER, KEVIN J.      :  JURY TRIAL DEMANDED
TWOMEY, MERRILL LYNCH & CO. and      :
J.P. MORGAN SECURITIES, INC.,        :
                                     :
                      Defendants.    :
                                     :
-------------------------------------x


                     CLASS ACTION COMPLAINT

     Plaintiff, by his attorneys, for his Complaint against 

defendants, alleges the claims set forth herein.  Plaintiff's 

claims as to himself and his own actions, as set forth in ¶ 12, 

are based upon personal knowledge.  All other allegations are 

based upon the investigation of counsel, which investigation 

included a review of the public filings with the Securities and 

Exchange Commission (the "SEC") made by Fleming Companies, Inc. 

("Fleming" or the "Company"), press releases issued by the 

Company, and various pleadings filed in the David's Supermarkets, 

Inc. litigation described below.  Based on the foregoing, 

plaintiff believes that substantial evidentiary support exists 

for those allegations.  Each paragraph sets forth with 

particularity the basis for the allegations contained therein.



                          CERTIFICATION


     ROBERT MARK, ("Plaintiff") declares that:

     1.   Plaintiff has reviewed the foregoing complaint and 

authorized its filing.  Plaintiff did not purchase the security 

that is the subject of this action at the direction of counsel or 

in order to participate in this action.

     2.   Plaintiff's transactions in the security that is the 

subject of this action are as follows:  on February 27, 1996, 

plaintiff purchased $11,000 face amount 10 5/8% Senior Notes due 

12-15-2001 at a price of $102/100.

     3.   During the three years prior to the date hereof, 

Plaintiff has not sought to serve or served as a representative 

party for a class in any action filed under the federal securities 

laws.  Plaintiff is willing to serve as a representative party on 

behalf of the class and, if necessary, will provide testimony at 

deposition and/or trial.

     4.   Plaintiff will not accept any payment for serving as a 

representative party on behalf of the class beyond his pro rata 

share of any recovery, except such reasonable costs and expenses 

(including lost wages) directly relating to the representation of 

the class as ordered or approved by the Court.

     I declare under penalty of perjury that the foregoing is true 

and correct.  Executed this 2nd day of April, 1996, at New York, 

New York.

                                                  /s/
                                        _________________________
                                               ROBERT MARK



                       NATURE OF THE CASE

     1.   This is a securities class action on behalf of persons 

who purchased Fleming 10 5/8% Senior Notes (the "Fixed Notes"), and 

Fleming Floating Rate Senior Notes (the "Floating Notes") 

(collectively the "Notes") during the period December 8, 1994 

through and including March 15, 1996 (the "Class Period").

     2.   During the Class Period, defendants, as more 

specifically alleged herein, caused to be filed with the SEC a 

Registration Statement (the "Registration Statement"), which 

incorporated a prospectus ("Prospectus") (hereinafter, the 

Registration Statement and the Prospectus are referred to 

collectively as the "Registration Statement") in connection with 

the Company's December 8, 1994 debt offering (the "Debt 

Offering") for $300,000,000 of Fixed Notes and $200,000,000 of 

Floating Notes.  The Registration Statement was materially false 

and misleading respecting Fleming's exposure to contingent 

liabilities, because the Registration Statement failed to 

disclose the existence of a material loss contingency, that is, a 

lawsuit filed in a Texas state court in August, 1993 denominated 

David's Supermarkets, Inc. v. Fleming Companies, Inc. (the 

"David's Litigation").

     3.   In addition, during the Class Period, as hereinafter 

alleged, defendants Fleming, one of the largest food wholesalers 

and distributors in the United States, Robert E. Stauth, 

Fleming's Chief Executive Officer and the Chairman of its Board 

of Directors, Harry L. Winn, Jr., the Company's Executive Vice 

                                2

President and Chief Financial Officer, Donald W. Eyler, until his 

retirement in 1995 a Senior Vice President of Fleming and its 

Controller-Chief Accounting Officer, and Kevin J. Twomey, a Vice 

President who, in early 1995, succeeded to the position of 

Controller-Chief Accounting Officer, repeatedly misrepresented 

and failed to disclose the existence of the David's Litigation, 

and to accrue an appropriate reserve for the probable loss in 

that lawsuit.

     4.   In the David's Litigation, Fleming was charged with 

fraud, breach of contract, conspiracy, and a violation of the 

Texas Deceptive Trade Practices Act, a statute that provides for, 

among other things, the recovery of treble damages and attorneys' 

fees.  On March 14 and 15, 1996, the jury found that Fleming 

breached its contract with David's Supermarkets, Inc. 

("David's"), and that the Company had committed fraud, deceptive 

trade practices, and breach of contract in its dealings with 

David's, and awarded David's as much as $207.5 million in damages 

and legal fees.  This verdict was approximately five times 

Fleming's previously announced 1995 annual net income and more 

than three times its average net income over the past ten years.  

The announcement of the jury's verdict was the first time that 

the existence of the lawsuit was disclosed to investors.

     5.   Since no later than the commencement of the Class 

Period, it was at least reasonably possible, if not probable, 

that the David's Litigation would have a material adverse effect 

on the Company's financial condition and its results of 

                                3

operations.  Under SEC regulations, therefore, as well as under 

generally accepted accounting principles ("GAAP"), the 

Registration Statement, as well as the Form 10-K and each 

Form 10-Q filed by Fleming during the Class Period, were required 

to disclose the David's Litigation.  Specifically, among other 

things, defendants were required to state in the Registration 

Statement and in Fleming's subsequent SEC filings and press 

releases, that the plaintiff in the David's Litigation was 

seeking in excess of $100 million in damages, which, in the event 

of an outcome unfavorable to Fleming, would have a material 

adverse impact on the Company.  In addition, Fleming was required 

under GAAP to accrue in its financial statements filed in its 

Form 10-K for the fiscal year ended December 31, 1994 (the "1994 

10-K"), and in its Forms 10-Q for the fiscal quarters ended April 

22, July 15, and October 7, 1995 (collectively, the "1995 

10-Qs"), a loss contingency for this litigation.

     6.   Fleming's non-disclosure of the existence of, and facts 

regarding, the David's Litigation was particularly misleading in 

view of the Company's other disclosures concerning the threat, 

commencement and existence of other pending litigation against 

the Company.

     7.   The market's reaction to Fleming's belated disclosure 

was swift.  The price of Company's Fixed Notes plummeted to $820 

per $1,000 face amount of the notes; and its Floating Notes 

dropped to $793.70 per $1,000 face amount of the notes.  As a 

result of Fleming's misrepresentations and omissions and its 

                                4

failure to accrue a loss contingency, the market prices of the 

Notes were artificially inflated as initially offered and 

throughout the Class Period.



                     JURISDICTION AND VENUE

     8.   The claims asserted herein arise under and pursuant to 

Section 11 of the Securities Act of 1933 (the "Securities Act"), 

15 U.S.C. § 77k, and under and pursuant to Sections 10(b) and 

20(a) of the Securities Exchange Act of 1934 (the "Exchange 

Act"), 15 U.S.C. §§ 78j(b) and 78t(a), and Rule 10b-5, 17 C.F.R. 

§ 240.10b-5, promulgated thereunder by the SEC.

     9.   This Court has jurisdiction of this litigation pursuant 

to Section 22 of the Securities Act, 15 U.S.C. § 77v; pursuant to 

Section 27 of the Exchange Act, 15 U.S.C. § 78aa; and pursuant to 

28 U.S.C. §§ 1331 and 1337.

     10.  Venue is proper in this District pursuant to Section 22 

of the Securities Act and Section 27 of the Exchange Act, and to 

28 U.S.C. §1391(b).  Many of the acts and transactions giving 

rise to the violations of law complained of herein occurred in 

this District.  In addition, defendant Fleming maintains its 

principal United States office in this District at 6301 Waterford 

Boulevard, Oklahoma City, Oklahoma 73126.

     11.  In connection with the acts, conduct and other wrongs 

complained of herein, defendants, directly or indirectly, used 

the means and instrumentalities of interstate commerce and the 

United States mails.

                                5

                           THE PARTIES

     12.  Plaintiff Robert Mark purchased $11,000 principal 

amount of Fixed Notes on February 26, 1996, at a price of $1020 

per $1,000 face amount of the Fixed Notes, and suffered damages 

as a result of the violations of the federal securities laws 

alleged herein.

     13.  Defendant Fleming is an Oklahoma corporation with its 

principal place of business in Oklahoma City, Oklahoma.  Fleming 

is a wholesale food distributor and marketer that services food 

stores of various sizes that operate in a wide variety of 

formats, including conventional full-service stores, 

supercenters, price impact stores, combination stores and 

convenience stores.  The Company files annual, quarterly and 

other reports with the SEC in accordance with the Exchange Act.

     14.  At all times relevant hereto, defendant Robert E. 

Stauth ("Stauth") was Chairman of Fleming's Board of Directors 

(the "Board") and its Chief Executive Officer.  In 1995, as 

reported in the Company's Proxy Statement accompanying the notice 

of Fleming's annual meeting of shareholders to be held on May 1, 

1996 (the "1995 Proxy Statement"), Stauth's annual salary was 

$588,462, and he beneficially owned 72,374 shares of Fleming 

common stock.  The 1995 Proxy Statement also disclosed that, in 

1994, the Company granted Stauth 24,000 shares of Fleming 

restricted common stock, then valued at $598,500, as well as 

options to purchase 90,000 shares of Fleming common stock, 60,000 

                                6

of which were performance-related.  Stauth signed the 

Registration Statement, as well as the 1994 10-K.

     15.  Defendant Harry L. Winn, Jr. ("Winn") has been 

Fleming's Executive Vice President and Chief Financial Officer 

since he joined the Company in May, 1994.  In 1995, as reported 

in the Proxy Statement, Winn's annual salary was $291,846, and he 

beneficially owned 14,050 shares of Fleming common stock.  Winn 

signed the Registration Statement.

     16.  Until 1995, defendant Donald W. Eyler ("Eyler") was a 

Senior Vice President, Controller and Chief Accounting Officer of 

the Company.  Eyler, who signed the Registration Statement, is 

liable only for the Company's misrepresentations and omissions 

made during the period of his employment.

     17.  Beginning no later than June 5, 1995, defendant 

Kevin J. Twomey ("Twomey") was a Vice President-Controller and

Chief Accounting Officer of the Company.  Twomey, who signed the 

1995 10-Qs, is liable only for the Company's misrepresentations 

and omissions made during the period of his employment.

     18.  Defendants Stauth, Winn, Eyler and Twomey sometimes are 

collectively referred to herein as the "Individual Defendants".

     19.  Defendant Merrill Lynch & Co. ("Merrill Lynch"), is a 

national brokerage and investment banking firm that regularly 

transacts business in this District.  Merrill Lynch was one of 

the co-lead underwriters for the Debt Offering and underwrote 

$270 million principal amount of the Fixed Notes and $180 million 

principal amount of the Floating Notes.  As underwriter, Merrill 

                                7

Lynch sold and distributed to the public the Company's Notes on 

or after December 8, 1994, pursuant to the Registration Statement 

issued in connection with the Debt Offering.  As part of its 

duties as an underwriter, Merrill Lynch conducted, prior to the 

Debt Offering, a due diligence investigation of Fleming.  Merrill 

Lynch received substantial fees, expenses and discounts in 

connection with the Debt Offering, and acted as a market-maker 

for the Notes.  In these various capacities, Merrill Lynch had 

access to material non-public proprietary information about 

Fleming's business, finances, and prospects.

     20.  Defendant J.P. Morgan Securities, Inc. ("J.P. Morgan"), 

is a national brokerage and investment banking firm that 

regularly transacts business in this District.  J.P. Morgan was 

one of the co-lead underwriters for the Debt Offering and 

underwrote $30 million of principal amount of the Fixed Notes and 

$20 million principal amount of the Floating Notes.  As 

underwriter, J.P. Morgan sold and distributed to the public the 

Company's Notes on or after December 8, 1994, pursuant to the 

Registration Statement issued in connection with the Debt 

Offering.  As part of its duties as an underwriter, J.P. Morgan 

conducted, prior to the Debt Offering, a due diligence 

investigation of Fleming.  J.P. Morgan received substantial fees, 

expenses and discounts in connection with the Debt Offering, and 

acted as a market-maker for the Notes.  In these various 

capacities, J.P. Morgan had access to material non-public 

                                8

proprietary information about Fleming's business, finances, and 

prospects.

     21.  Defendants Merrill Lynch and J.P. Morgan are 

collectively referred to herein as the "Underwriter Defendants".  

The Underwriter Defendants participated in the preparation of the 

Registration Statement, which was prepared for the purpose, and 

with knowledge, that it would be used by the Underwriter 

Defendants to solicit purchases of the Notes.  The Underwriter 

Defendants are liable only for the misrepresentations contained 

in, and the omissions from, the Registration Statement.

     22.  Each of the Individual Defendants and the Underwriter 

Defendants, as signatories of the Registration Statement, 

directors and/or officers of Fleming, and as underwriters of the 

Debt Offering, owed to the purchasers of the Notes, including 

plaintiff and the members of the Class, the duty to make a 

reasonable and diligent investigation of the statements contained 

in the Registration Statement at the time it became effective.  

This duty including ensuring that the statements contained 

therein were true, and that there were no omissions of material 

fact required to be stated in order to make the statements 

contained in the Registration Statement not misleading.  As 

hereinafter alleged, each Individual Defendant and Underwriter 

Defendant violated these specific duties and obligations.

                                9

                 PLAINTIFF'S CLASS ALLEGATIONS

     23.  Plaintiff brings this action on his own behalf and as a 

class action pursuant to Rule 23(a) and Rule 23(b)(3) of the 

Federal Rules of Civil Procedure on behalf of a class (the 

"Class") of all persons who purchased the Notes during the Class 

Period, that is, during the period from December 8, 1994 -- the 

date the Company filed its Registration Statement and 

Registration Statement with the SEC -- through March 15, 1996, 

the last trading day before it was publicly revealed that a Texas 

jury awarded David's as much as $207.5 million in its lawsuit 

against Fleming.  Excluded from the Class are the named 

defendants, members of the immediate families of the Individual 

Defendants, any entity in which any defendant has a controlling 

interest, and the legal representatives, heirs, successors, 

predecessors in interest, or assigns of any of the defendants.

     24.  The members of the Class, as purchasers of the Notes on 

their initial offering and on the open market, are so numerous 

that joinder of all members is impracticable.  While the precise 

number of class members cannot be ascertained without the benefit 

of records in the possession or control of Fleming, based upon 

the size of the Debt Offering and upon the distribution of the 

Notes, plaintiff believes that there are at least hundreds of 

members of the Class.

     25.  Plaintiff's claims are typical of the claims of the 

members of the Class.  Plaintiff and all members of the Class 

purchased the Notes during the Class Period at artificially 

                                10

inflated prices, and sustained damages as a result of the same 

wrongful course of conduct.

     26.  Plaintiff will fairly and adequately protect the 

interests of the members of the Class, and has retained counsel 

competent and experienced in class and securities litigation, and 

intends to prosecute this action vigorously.  The claims asserted 

on behalf of the Class are typical of the claims of all members 

of the Class.  Plaintiff is a member of the Class, and does not 

have any interests that are antagonistic to, or in conflict with, 

the interests of the other members of the Class.

     27.  A class action is superior to other available methods 

for the fair and efficient adjudication of this controversy, 

because, among other things, it would be impracticable and 

undesirable for all members of the Class to bring separate 

actions in various parts of the country.  In addition, because 

the damages suffered by many individual Class members may be 

relatively small, the expense and burden of individual litigation 

make it virtually impossible to redress the wrongful conduct 

alleged.

     28.  The prosecution of separate actions by individual Class 

members also would create the risk of inconsistent and varying 

adjudications concerning the subject of this action, which 

adjudications could establish incompatible standards of conduct 

for defendants under the laws cited herein.  Further, common 

questions of law and fact exist as to all members of the Class 

and predominate over any questions affecting solely individual 

                                11

members of the Class in that, at least by use of publicly filed 

reports, defendants have acted on grounds generally applicable to 

the entire Class.  Among the questions of law and fact common to 

the Class are:

          a.   whether defendants filed and issued a false 
     and misleading Registration Statement in connection 
     with the Debt Offering;

          b.   whether the federal securities laws were 
     violated by defendants' acts as alleged herein;

          c.   whether the documents, releases and public 
     statements made by defendants omitted to state and 
     misrepresented material facts concerning the Company's 
     true financial results and liability exposure in 
     connection with the David's Litigation;

          d.   whether defendants acted with the requisite 
     state of mind in omitting and/or misrepresenting 
     material facts respecting the David's Litigation;

          e.   whether the market price of Fleming's Notes 
     during the Class Period was artificially inflated due 
     to the non-disclosures and/or misrepresentations 
     respecting the David's Litigation complained of herein; 
     and

          f.   whether the members of the Class have 
     sustained damages and, if so, the appropriate measure 
     thereof.

     29.  Plaintiffs know of no difficulty that will be 

encountered in the management of this litigation that would 

preclude its maintenance as a class action.  The names and 

addresses of the record owners of the Notes purchased during the 

Class Period are available from the Company or its transfer 

agent(s).  Notice may be provided to such record owners via first 

class mail using techniques and a form of notice similar to those 

customarily used in class actions.

                                12

              ADDITIONAL SUBSTANTIVE ALLEGATIONS

The History and Business of Fleming

     30.  As disclosed in, among other places, the Registration 

Statement and the 1994 10-K, the Company is a wholesale and 

retail food distributor and marketer that services more than 

10,000 retail food stores in 43 states, including 3,700 

supermarkets, representing approximately 13 percent of all 

supermarkets in the United States.  The Company serves food 

stores of various sizes, according to the Registration Statement 

and the 1994 10-K, operating in a wide variety of formats, 

including conventional full-service stores, supercenters, price 

impact stores, combination stores and convenience stores.

     31.  On February 22, 1996, in a press release carried by 

Bloomberg Business News, the Company announced its results for 

its fiscal year ended December 30, 1995 ("fiscal 1995"), 

reporting revenues of $17.5 billion, and net income of 

$42 million.  Fleming's average net income for the past ten 

years, as determined from the Company's annual report for fiscal 

1995 (the "1995 Annual Report"), was approximately $61,996,000.

     32.  As described in the 1994 10-K and in the Registration 

Statement, although in some geographic areas Fleming charges its 

customers based upon a percentage markup over cost, Fleming 

generally charges its customers for products based on an agreed 

price, which price includes the Company's defined "cost".  In 

determining such "cost", as disclosed in the 1994 10-K and in the 

Registration Statement, the Company did not historically pass 

                                13

through to its customers the benefits it obtained from 

promotional fees and allowances from Fleming's vendors.  As part 

of its so-called re-engineering process, however, the Company 

disclosed in the 1994 10-K and in the Registration Statement that 

Fleming will begin to charge actual costs of acquiring certain of 

its food products, including passing through to its customers all 

promotional fees and allowances received from suppliers.  

According to the 1994 10-K and the Registration Statement, the 

net effect of this pricing change and increases in the costs 

charged to customers for handling and transportation, will, among 

other things, lower the cost of products to most of the Company's 

customers.



The Fleming - David's Relationship
and the David's Litigation

     33.  David's, according to Plaintiff's Original Petition in 

the David's Litigation, which was filed in the district court in 

Johnson County, Texas on August 24, 1993 (the "David's 

Complaint"), and to the First through Fifth Amended Original 

Petitions (collectively, the "Amended David's Complaints"; 

together with the David's Complaint, the "David's Complaints") 

had 22 stores, employed approximately 500 people, and provided 

groceries to a variety of communities in Texas.  According the [sic]

David's Complaints, David's, through its predecessor, began using 

Fleming as its primary supplier on or about January 16, 1989, 

pursuant to an agreement the terms of which provided that Fleming 

would charge David's for products "at agreed-upon mark-ups over 

                                14

Fleming's cost for each type of product."  For example, according 

to the Complaints, in the initial form of the agreement between 

David's predecessor and Fleming, Fleming agreed to provide 

grocery products, dairy products, meat and store supplies at 

Fleming's cost plus 3.45%, frozen food and frozen meat at its 

cost plus 6.25%, and produce at its cost plus 7.65%.

     34.  According to the David's Complaints, David's and 

Fleming operated under this or similar agreements until November, 

1991.  For approximately 10 months, between November, 1991 and 

September, 1992, David's purchased its grocery products from 

suppliers other than Fleming.  In September, 1992, David's 

returned to Fleming and received from Fleming, as part of an 

overall financial restructuring, $7.5 million of financing.

     35.  On August 24, 1993, the David's Litigation was filed 

against Fleming and one of its Executive Vice Presidents, James 

E. Stuard ("Stuard"), in the District Court in Johnson County, 

Texas.  The David's Complaint alleged that Fleming systematically 

overcharged David's and ultimately drove David's to the brink of 

insolvency.  Fleming effectuated its scheme, according to the 

David's Complaint, by regularly marking-up its actual costs by 

paper transfers between various Fleming offices, and then 

calculating the agreed upon "cost plus" price on an inflated 

figure, rather than on Fleming's actual cost.  Thus, the "cost" 

upon which Fleming calculated the agreed mark-up was not 

Fleming's true cost, but was instead a phony figure that included 

large, secret mark-ups within Fleming's own corporate structure.

                                15

     36.  As also alleged in the David's Complaints, the "cost" 

of the products Fleming sold to David's prior to November, 1991 

was improperly overstated in other ways, including the failure by 

Fleming to pass along to David's the benefit of Fleming's so-

called "deal" buying and the "rebates" and promotional discounts 

Fleming obtained from its suppliers.

     37.  The David's Complaint alleged that Fleming's conduct 

was intentional, cynical and systematic, and that officers of the 

Company, including Executive Vice President Stuard, were knowing 

participants in this illicit behavior.  Indeed, the David's 

Complaint asserted that Stuard negotiated the agreement and its 

various revisions with David's, and directed Fleming's operations 

in the region with full knowledge and approval of the Company's 

wrongful and illicit behavior.

     38.  The David's Complaints charged Fleming and Stuard with 

breach of contract, fraud, conspiracy, and violation of the Texas 

Deceptive Trade Practices Act (the "DTPA"), which provides for, 

among other things, treble damages and the recovery of attorneys' 

fees, as follows:

          a.   Breach of contract.  David's alleged that Fleming 

     breached its contracts with David's by using improperly 

     inflated costs as the basis for the prices it charged 

     David's for products purchased prior to November, 1992.

          b.   Fraud.  David's alleged that Fleming committed 

     fraud, because Fleming had, at the time the agreements were 

     entered into, already formed its intent to charge David's 

                                16

     based on improperly inflated costs, and even arranged for 

     the Company's suppliers to raise their invoice prices to 

     Fleming in exchange for subsequent secret rebates and 

     kickbacks.  The David's Complaints also allege that fraud 

     was perpetrated by Fleming, because Fleming knew at the time 

     the agreements were entered into that it was not using its 

     buying power to maximize the benefit to David's and, even 

     worse, that Fleming would keep for itself all benefits 

     produced as a result of Fleming's buying power.

          c.   Conspiracy.  David's claimed that Fleming and 

     Stuard schemed, planned, and conspired to systematically 

     overcharge David's for groceries, food and store products.

          d.   Violation of the DTPA.  David's, as a "consumer" 

     under the DTPA, alleged that Fleming violated the DTPA, by, 

     among other things, (i) the advantage the Company took over 

     David's; (ii) engaging in a variety of false, misleading, 

     and deceptive acts, including representing that its goods or 

     services were of a particular standard, quality, or grade, 

     when they were of another; (iii) making false or misleading 

     statements of fact concerning the reasons for, existence of, 

     or amount of price reductions; (iv) by representing that an 

     agreement confers or involves rights, remedies, or 

     obligations which it did not have or involve, or that were 

     prohibited by law; and (v) failing to disclose information 

     concerning goods or services that was known at the time of 

     the transaction and with the intention to induce David's 

                                17

     into a transaction into which David's would not have entered 

     had the information been disclosed.

     39.  The David's Complaint alleged that Fleming's wrongful 

acts were material, were the direct and proximate cause of 

substantial damage to David's, and almost destroyed David's 

ability to compete in the marketplace, because it was unable to 

price its merchandise competitively.  As a result, David's lost 

substantial business and revenue, and was forced to close several 

of its stores.  In the David's Complaint, therefore, David's 

requested, in addition to its costs and attorneys' fees, actual 

damages of $20 million trebled to $60 million, and exemplary 

damages of at least $50 million.  When the First Amended David's 

Complaint was filed on or about February 23, 1995, David's 

request for exemplary damages was raised to $65 million; and by 

the time the Fifth Amended David's Complaint was filed on or 

about February 12, 1996, David's was requesting, in addition to 

attorneys' fees and costs and pre-judgment interest, 

$54.632 million in actual damages for its breach of contract and 

conspiracy claims trebled to $163.896 million, actual damages of 

$38.655 million for its fraud claim, and exemplary damages in the 

amount of 22.5% of Fleming's net worth of $1.078 billion (or 

approximately 1.5% of Fleming's 1994 net sales of 

$15.753 billion).

     40.  On September 19, 1993, the Company filed an answer to 

the David's Complaint rather than seeking its dismissal, thus 

ensuring that the Company would be exposed to costly discovery 

                                18

and, in all likelihood, to protracted litigation, and, if David's 

was successful, to liability in excess of $110 million.

     41.  According to the David's Litigation Docket Book Report 

obtained from the Johnson County, Texas District Court (the 

"Docket Report"), discovery began immediately after the filing of 

Fleming's answer.  The parties exchanged various discovery 

requests, including requests for the production of documents and 

interrogatories, as well as notices for the taking of depositions 

upon oral examination and upon written questions.  Indeed, 

discovery was quite extensive.  David's, throughout 1994, 1995 

and into February, 1996, served at least five requests for the 

production of documents, two requests for admissions, and a set 

of interrogatories; in addition, David's took the depositions of 

at least twenty witnesses, with several lasting over one day, 

including the deposition of Stuard, which lasted over five days 

-- July 6, 1995, August 8, 1995, October 12, 1995, December 12, 

1995 and January 26, 1996 -- producing seven volumes, and of 

defendant Eyler, which lasted over two days.  Fleming, for its 

part, served at least eight requests for the production of 

documents, two sets of interrogatories and a request for 

admissions; in addition, the Company took the deposition of at 

least eleven witnesses, also with several lasting over one day.

     42.  The Docket Report also discloses that significant 

discovery was undertaken prior to December 8, 1994 -- the date of 

Fleming's Debt Offering.  In particular, David's served at least 

three requests for the production of documents, a set of 

                                19

interrogatories and a request for admissions, and took the 

depositions of at least five witnesses; Fleming served at least 

four requests for production and a set of interrogatories, and 

took the deposition of at least one witness.  Even more discovery 

was undertaken prior to March 27, 1995, the date on which Fleming 

filed its 1994 10-K.  David's served an additional request for 

the production of documents and an additional request for 

admissions; Fleming served at least two additional requests for 

the production of documents, and took the depositions of at least 

four additional witnesses.

     43.  On November 4, 1994, Fleming moved for partial summary 

judgment, conceding that, at best, at least certain of David's 

claims presented issues of fact that would be tried.  David's 

responded on January 9, 1995.  On January 24, 1995, before 

Fleming filed its 1994 10-K with the SEC, the court denied 

Fleming's motion, ensuring that the case would proceed to trial.  

Nevertheless, neither the Registration Statement nor the 1994 10-

K even disclosed the existence of the David's Litigation.  

Neither did any of Fleming's 1995 10-Qs.

     44.  The David's Litigation proceeded to trial in February, 

1996.  On March 14, 1996, as reported in Bloomberg Business News 

after the close of the market, the jury returned a partial 

verdict against Fleming in the amount of at least $73 million.  

According to the jury verdict sheet, the jury also found against 

Stuard for $100,000.  The jury found the Company and Stuard 

liable for breach of contract, fraud, and violation of the DTPA.  

                                20

The next day, also after the market closed, Bloomberg Business 

News reported that the jury awarded punitive damages, and 

determined that Fleming must pay a total of as much as 

$207.5 million for committing unfair and deceptive trade 

practices.


Defendants' Failure to Disclose the
David's Litigation in the Registration Statement


     45.  On December 8, 1994, Fleming announced the Debt 

Offering, in which it would issue $500 million of senior notes, 

with the transaction expected to close on December 15, 1994.  The 

Notes, it was disclosed, would mature on December 15, 2001.  The 

Fixed Notes -- $300 million of the Debt Offering -- would carry a 

fixed interest coupon of 10 5/8%, and the Floating Notes -- the 

remaining $200 million of the Debt Offering -- were structured to 

carry an interest rate based on a floating three month London 

interbank offered rate, or LIBOR, plus a margin of 2.25%.  

Merrill Lynch and J.P. Morgan were the underwriters for the Debt 

Offering.

     46.  In the Registration Statement, dated December 8, 1994, 

the Company provided investors with unaudited "pro forma" 

financial information for the year ended December 25, 1993, and 

the forty weeks ended October 1, 1994, which pro forma financial 

information gave effect to the Debt Offering and to the Company's 

acquisition of the Scrivner Group, as if each had occurred on the 

first day of the respective periods.  For the year ended 

December 25, 1993, pro forma net sales were approximately $19.11 

                                21

billion, and pro forma net earnings were approximately $18.7 

million.  For the period ended October 1, 1994, pro forma net 

sales were approximately $14.3 billion, and pro forma net 

earnings were approximately $33 million.  The Registration 

Statement was signed by defendants Stauth, Winn and Eyler.

     47.  By December 8, 1994, the parties to the David's 

Litigation served a total of at least seven requests for the 

production of documents, two sets of interrogatories, a request 

for admissions, and took the depositions of at least six 

witnesses prior to the issuance of the Registration Statement; 

indeed, as disclosed in an April 1, 1996 report by Bloomberg 

Business News, one memo shown to the jury in the David's 

Litigation referred to "artificially inflating costs to build in 

margin."  In addition Fleming had already undertaken an 

investigation sufficient to form the basis of its motion for 

partial summary judgment.  Nevertheless, the Registration 

Statement made no disclosure of the David's Litigation, a lawsuit 

in which the Company and one of its senior executives were 

charged with systematic and pervasive fraudulent conduct, and 

which sought damages -- claimed at that time to be in excess of 

$110 million -- that were almost six times the pro forma 1993 net 

earnings, and in excess of three times the pro forma 1994 net 

earnings, each as presented in the Registration Statement.

     48.  Instead, defendants disclosed two other legal matters 

in the Registration Statement.  One such matter was represented 

in the Registration Statement as being in its "preliminary 

                                22

stages"; the other matter was represented as not likely to have a 

material impact on the Company.  Neither legal matter related to 

the claims asserted in the David's Litigation.

          a.   The first legal matter involved two lawsuits that 

     were filed in federal court in Florida (the "Florida 

     Litigation") after the filing of the David's Litigation.  As 

     specifically disclosed in the Registration Statement, the 

     Florida Litigation concerns allegations that former 

     employees of a Fleming subsidiary, while acting within the 

     scope of their employment, participated in a fraudulent 

     scheme by taking money for certain "diverting" transactions 

     that had not actually occurred; as a result, the 

     Registration Statement discloses, the plaintiffs in the 

     Florida Litigation alleged, among other causes of action, 

     common law fraud, breach of contract, negligence, conversion 

     and civil theft, and violations of the federal Racketeer 

     Influenced and Corrupt Organizations Act and comparable 

     state law.  The Registration Statement then states, even 

     though the Florida Litigation is in its "preliminary 

     stages," and, therefore, that "the Company is unable to 

     predict a potential range of monetary exposure to the 

     Company," that "[b]ased on the recovery sought, an 

     unfavorable judgment could have a material adverse effect on 

     the Company."

          b.   The Registration Statement also specifically 

     discloses that "[t]he Company has been designated by the 

                                23

     U.S. Environmental Protection Agency as a potentially 

     responsible party under the Comprehensive Environmental 

     Response, Compensation and Liability Act (the "CERCLA 

     Matter").  With respect to the CERCLA Matter, the 

     Registration Statement states that "[w]hile liability under 

     CERCLA . . . is joint and several, the Company believes 

     that, to the extent it is ultimately determined to be liable 

     . . ., such liability will not result in a material adverse 

     effect on its consolidated financial position or results of 

     operations."

          c.   The only other Registration Statement disclosure 

     respecting litigation is a general catch-all for a variety 

     of ordinary, run-of-the-mill lawsuits against the Company 

     arising "in the ordinary course of business."  As to these 

     cases, the Registration Statement discloses that, "[w]hile 

     the ultimate effect of such actions cannot be predicted with 

     certainty, the Company expects that the outcome of these 

     matters will not result in a material adverse effect on its 

     consolidated financial position or results of operations."  

In sum, even though discovery in the David's Litigation was well 

underway, the Registration Statement explicitly disclosed only 

the Florida Litigation, actions that were filed after the David's 

Litigation in which discovery had not yet even begun, and the 

CERCLA Matter, for which the Company, named only as a potentially 

responsible party, believed it would not have material liability.  

As such, defendants led the investing public to believe that the 

                                24

Florida Litigation and the CERCLA Matter were the only 

significant legal matters facing the Company.

     49.  The Registration Statement did contain a disclosure 

relating to the subject matter of the David's Litigation without 

as much as a reference to that lawsuit.  Under "Sales Terms" in 

the "Management's Discussion and Analysis" section of the 

Registration Statement, Fleming described the manner in which the 

Company calculates its charges to customers -- an issue at the 

very heart of the David's Litigation -- and stated that it 

intends to change its practices by passing through to customers 

"all promotional fees and allowances received from vendors."  

Specifically, the Registration Statement stated:

          The Company currently charges customers for 
          products based generally on an agreed price 
          which includes the Company's defined "cost" 
          (which does not give effect to promotional 
          fees and allowances from vendors), to which 
          is added a fee determined by the volume of 
          the customer's purchase.  In some 
          geographical areas, product charges are upon 
          a percentage markup over cost.  A delivery 
          charge is usually added based on order size 
          and mileage from the distribution center to 
          the customer's store. . . . As part of the 
          reengineering process, the Company will begin 
          to charge the actual costs of acquiring its 
          grocery, frozen food and dairy products while 
          passing through to its customers all 
          promotional fees and allowances received from 
          vendors."

(Emphasis added)  This disclosure in the Registration Statement, 

without any accompanying reference to the pending David's 

Litigation in which the central point of the disclosure -- the 

definition of "cost" and the passing along of "rebates" and 

promotional fees to Fleming's customers -- was being litigated, 

                                25

and which could have had a material adverse impact on the 

Company, also was materially misleading.

     50.  Under "Liquidity and Capital Resources" in the 

"Management's Discussion and Analysis" section of the 

Registration Statement, Fleming disclosed that the Company's two 

principal sources of liquidity were cash flows from operations 

and bank borrowings.  In fact, as of October 1, 1994, Fleming's 

total indebtedness was 66% of total capital, an increase of 16% 

from December 25, 1993.  Under "Liquidity and Capital Resources," 

the Company also described, among other things, certain 

restrictive covenants contained in its "Credit Agreement," the 

Company's only committed line of credit.  Those restrictive 

covenants included, among other things, the maintenance of 

certain financial ratios, as well as restrictions on the 

Company's ability to incur additional debt, to create liens and 

encumbrances, and to make certain payments, investments, loans 

and guarantees.  Defendants' disclosed that "[t]he Company is 

currently in compliance with all financial covenants under the 

Credit Agreement," and that "[t]he Company believes that cash 

flows from operating activities and its ability to borrow under 

the Credit Agreement will be adequate to meet the Company's 

working capital needs, planned capital expenditures and debt 

service obligations for the foreseeable future."  No mention was 

made, however, of the potential effect of the David's Litigation 

on the Company's liquidity, on its ability to make capital 

expenditures, or on compliance with its debt covenants, even 

                                26

though the plaintiffs in that case were seeking over $110 million 

the payment of which could have materially impacted the 

maintenance of the debt covenants, the Company's ability to 

obtain additional financing, and the Company's ability to make 

future capital expenditures.



Fleming's Continued Failure
to Disclose the David's Litigation

     51.  On or about March 27, 1995, the Company filed with the 

SEC its 1994 10-K, signed by defendant Stauth.  Fleming reported 

net sales of approximately $15.76 billion, net earnings of 

approximately $56.2 million, current assets of $1.82 billion and 

current liabilities of approximately $1.32 billion.

     52.  As of March 27, 1995, significant discovery in the 

David's Litigation had been completed; for example, the parties 

combined served at least ten requests for the production of 

documents, two sets of interrogatories, two requests for 

admissions, and took the depositions of at least ten witnesses.  

In addition, approximately two months earlier, on January 24, 

1995, Fleming's motion for partial summary judgment was denied.  

Nevertheless, the David's Litigation remained undisclosed, and no 

accrual for the probable loss had been made even though Fleming 

must already have performed an investigation sufficient to 

respond to David's discovery requests and to file its motion for 

partial summary judgment.

     53.  Instead of disclosing the David's Litigation and its 

potential material adverse consequences, Fleming and the 

                                27

Individual Defendants chose expressly to describe in the notes to 

the consolidated financial statements only the Florida Litigation 

and the CERCLA Matter in addition to the Company's catch-all, "in 

the ordinary course of business" disclosure.  With respect to the 

Florida Litigation, the Company expressly stated that

               The litigation is complex, discovery has 
          not commenced and the ultimate outcome cannot 
          presently be determined.  Furthermore, 
          management is unable to predict a potential 
          range of monetary exposure, if any, to the 
          company.  Based on the large recovery sought, 
          an unfavorable judgment could have a material 
          adverse effect on the company.  Management 
          believes, however, that a material adverse 
          effect on the company's consolidated
          financial position is not likely.  The 
          company intends to vigorously defend the 
          actions.

(Emphasis added)  Thus, even though discovery had not yet 

commenced, even though management was not able to predict a 

potential impact of the Company, and even though management 

believed that a material adverse effect on the Company's 

consolidated financial position was unlikely, Fleming and the 

Individual Defendants chose to make a full disclosure of the 

Florida Litigation.  In contrast, the David's Litigation, which 

was past the summary judgment stage with significant discovery 

completed, remained undisclosed.

     54.  In addition to the above disclosure, the 1994 10-K 

included disclosures respecting liquidity and pricing that were 

similar to those included in the Registration Statement, each 

without reference to the David's Litigation.

                                28

     55.  On or about May 3, 1995, in a press release carried by 

PR Newswire, the Company announced its results for its first 

fiscal quarter ended April 22, 1995.  Sales for the quarter were 

approximately $5.5 billion, a 36% increase over the prior-year 

period, and net earnings were $19.5 million, a 19.9% decrease 

over the prior-year period.  In its 1995 first quarter Form 10-Q 

filed with the SEC on or about June 5, 1995, the Company reported 

total current assets of approximately $1.6 billion and total 

current liabilities of approximately $1.2 billion.  The 10-Q was 

signed by defendant Twomey.

     56.  The first quarter 10-Q also failed to disclose or 

accrue for the David's Litigation.  Instead, in note 5 to the 

Consolidated Condensed Financial Statements, Fleming specifically 

described only the Florida Litigation, and in note 3, stated that 

"[t]hese consolidated financial statements should be read in 

conjunction with the consolidated financial statements and 

related notes" included in the 1994 10-K.  Meanwhile, in the 

David's Litigation, discovery continued, including the deposition 

of defendant Eyler and the noticing of the deposition of 

defendant Stauth.  Still, no disclosure was made.  In addition, 

note 1 to the Consolidated Condensed Financial Statements in the 

first quarter 10-Q contained management's false representation 

that the financial statements included therein reflect "all 

adjustments necessary to present fairly the company's financial 

position at April 22, 1995."

                                29

     57.  On or about August 2, 1995, in a press release carried 

by PR Newswire, the Company announced its results for its second 

fiscal quarter ended July 15, 1995.  Sales for the quarter were 

approximately $4.0 billion, an increase of 39% over the prior-

year period, and net earnings were $14.7 million, a decrease of 

21% over the prior-year period.  In its 1995 second quarter Form 

10-Q filed with the SEC on or about August 29, 1995 and signed by 

defendant Twomey, the Company reported total current assets of 

approximately $1.57 billion and total current liabilities of 

approximately $1.22 billion.  Even though substantial additional 

discovery had been completed by then, including the depositions 

of defendant Eyler, of Gerald G. Austin, Fleming's Executive Vice 

President of Marketing, and two days of depositions of James E. 

Stuard, the Fleming Executive Vice President named as a party 

defendant in the David's Litigation, the second quarter 10-Q 

failed to disclose or to accrue for the David's Litigation.  Once 

again, in note 5 to the Consolidated Condensed Financial 

Statements, the 10-Q specifically described only the Florida 

Litigation, and in note 3, stated that "[t]hese consolidated 

financial statements should be read in conjunction with the 

consolidated financial statements and related notes" included in 

the 1994 10-K.  The Consolidated Condensed Financial Statements, 

in note 1 thereto, also contained management's false 

representation that the financial statements included therein 

reflect "all adjustments necessary to present fairly the 

company's financial position at July 15, 1995."

                                30

     58.  On or about October 25, 1995, in a press release 

carried by PR Newswire, the Company announced its results for 

third fiscal quarter ended October 7, 1995.  Sales for the 

quarter were $3.9 billion, a 6% decrease from the prior-year 

period, and net earnings were $3.7 million, a 35% increase over 

the prior-year period.  In its 1995 third quarter Form 10-Q filed 

with the SEC on or about November 20, 1995 and signed by 

defendant Twomey, the Company reported total current assets of 

approximately $1.6 billion and total current liabilities of 

approximately $1.3 billion.  The third quarter Form 10-Q also 

failed to disclose or to accrue for the David's Litigation; 

instead, in note 5 to the Consolidated Condensed Financial 

Statements, the 10-Q specifically described only the Florida 

Litigation, and in note 3, stated that "[t]hese consolidated 

financial statements should be read in conjunction with the 

consolidated financial statements and related notes" included in 

the 1994 10-K.  The notes in the Consolidated Condensed Financial 

Statements included in the third quarter 10-Q, like those in the 

10-Qs for the first two fiscal quarters, also contained 

management's representation that the financial statements 

included therein reflect "all adjustments necessary to present 

fairly the company's financial position at October 7, 1995."

     59.  On or about February 22, 1996, in a press release 

carried by PR Newswire, the Company announced the results for its 

fourth quarter ended December 25, 1995.  Sales for the quarter 

were $4.05 billion, a decrease of 12% compared with the prior-

                                31

year period, and net earnings were $4.05 million, a 61% decrease 

compared with the prior-year period.  For the year, sales were 

$17.5 billion, an increase of 11% compared with the prior-year 

period, and net earnings were $42 million, a decrease of 26% over 

the prior-year period.  Fleming and the Individual Defendants 

continued to conceal the David's Litigation from the investing 

public, despite the fact that the trial was then underway in a 

Texas courtroom and David's had amended its complaint to seek 

over $445 million in actual and exemplary damages.

     60.  Each of the disclosures and announcements described 

above, including those contained in the Registration Statement, 

in the 1994 10-K, in the 1995 10-Qs, and in the Company's 

February 22, 1996 fourth quarter and 1995 year-end earnings 

announcement, were materially false and misleading, because of 

their failure to disclose the David's Litigation.  Such 

disclosure was required so that the statements concerning 

litigation against Fleming, the nature of Fleming's contractual 

relationships with its customers, and Fleming's liquidity 

described above would not be materially false and misleading.  In 

addition, under GAAP, as set forth below, a lawsuit that charged 

senior management with systematic and pervasive fraudulent 

conduct in its dealing with a customer, that sought damages that 

could eliminate several years of a company's net earnings, and 

that could have a material adverse impact on a company's 

financial condition is required to be disclosed to investors in 

the notes accompanying a company's financial statements.  In 

                                32

addition, as described below, SEC regulations require that the 

potential exposure of a public company to such litigation be 

described in the "Management's Discussion and Analysis" section 

of a registrant's SEC filings.

     61.  Additionally, the Company's 1994 10-K and 1995 10-Qs, 

as well as its earnings announcements that were publicly 

disseminated during the Class Period, were materially false and 

misleading, because the reported net income and reported current 

assets were materially overstated, while the Company's reported 

current liabilities were materially understated.  Under GAAP, the 

company was required, as early as the dissemination of the 1994 

10-K, to accrue for the contingent liability resulting from the 

lawsuit, because such an adverse outcome was probable.  The 

Company's failure to reflect such an accrual rendered its 

reported financial condition and results of operations during the 

Class Period materially overstated.

     62.  Finally, the Company's representations in the notes to 

the Consolidated Condensed Financial Statements included in its 

1995 10-Qs that the financial statements contained therein 

"present fairly the Company's financial position," were false and 

misleading, because the Company's net income and current assets 

were materially overstated, and its current liabilities were 

materially understated, each as a result of the Company failure 

to accrue for the probable loss to be realized from the David's 

Litigation.

                                33

     63.  The safe harbor for forward-looking statements 

contained in Section 27A(a) of the Exchange Act is inapplicable 

here, because the statements at issue are historical, not 

forward-looking:  Defendants failed to disclose facts existing at 

the time the statements were made respecting litigation pending 

against the Company.  Even if those statements are deemed to be 

"forward-looking", they are exempt from the safe harbor by 

paragraph (b)(2)(A), which provides that "this section shall not 

apply to a forward looking statement included in a financial 

statement prepared in accordance with generally accepted 

accounting principles," and by paragraph (b)(2)(D), which exempts 

statements made in connection with an initial public offering, 

such as the Debt Offering.



The Truth is Finally Revealed

     64.  With the reports on March 14 and 15, 1996 of the jury's 

verdicts, investors learned for the first time that a potentially 

devastating litigation had shadowed the Company for the past two 

and one-half years.  On March 15, the Company filed a Current 

Report on Form 8-K in which, pursuant to Item 5 thereto, it 

disclosed the jury's verdicts.  In addition, Fleming stated in 

the Form 8-K that "[t]he company believes that this is an 

isolated verdict specifically related to David's Supermarkets.  

Fleming will continue to service retailers and deal with them 

honestly and professionally as it has always done."

                                34

     65.  Investors were left holding notes in a Company that 

could be rendered insolvent as a result of a material contingency 

that went undisclosed for 2 1/2 years.  The market's reaction to 

this startling news was swift and severe.  By March 18, as a 

result of heavy trading, the price of the Company's Floating 

Notes dropped to $793.70 per $100 [sic] face amount of notes, and the 

Fixed Notes dropped to $820 per $1000 face amount of notes.  On 

March 18, 1996, Moody's Investors Service placed the Company's 

Bal rating for its senior unsecured debt (which includes the 

Notes in this action) under review for possible downgrade, citing 

the "significant damages" awarded against the Company in the 

David's Litigation.  Standard & Poor's has placed the Notes on 

its CreditWatch for a possible downgrade.

     66.  The fallout from the David's Litigation has continued.  

On March 28, 1996, Bloomberg Business News reported that Fleming 

had cut its quarterly dividend 98% from $.30 per share, which it 

had paid since the fourth quarter of 1991, to $.02 per share.  

The Company was reported to have said that the cut would, among 

other things, help it meet its bank's requirements for an appeal 

bond in the David's Litigation.

     67.  On March 29, 1996, not surprisingly, Bloomberg reported 

that Fleming was delaying the filing of certain sections of its 

Form 10-K for fiscal 1995 until certain matters regarding the 

David's Litigation were resolved; in particular, the company said 

it would delay filing information respecting its "legal 

proceedings, financial data, and management's discussion and 

                                35

analysis of financial condition and results of operations."  In 

addition, Bloomberg reported that, to post the necessary appeal 

bond for the David's Litigation, the Company must seek an 

amendment to its Credit Agreement.

     68.  On April 1, 1996, Bloomberg Business News reported that 

other Fleming customers, notwithstanding the statements made by 

the Company in its Form 8-K, were investigating their 

relationships with the Company in the wake of the David's 

Litigation verdict.  It was reported that Red Apple Group, 

operator of Gristede's and some Sloan's supermarkets in New York, 

expressed dissatisfaction and was "looking at it."  And the U.S. 

Army, Navy and Air Force, all of which use the Company as one of 

the top suppliers to their retail outlets, are investigating 

Fleming.



                              COUNT I

                   Against All Defendants for
       Violations of Section 11 of the Securities Act

     69.  Plaintiff repeats and realleges all preceding 

allegations as if fully set forth herein, except any allegations 

of fraud, scienter, scheme to defraud and wrongful conduct that 

operated as a fraud and deceit upon plaintiff and the members of 

the Class.  This Count is asserted against all defendants for 

violations of Section 11 of the Securities Act, 15 U.S.C. § 77k.

     70.  The Registration Statement was materially false and 

misleading; contained untrue statements of material facts; 

omitted to state material facts necessary to make the statements 

                                36

made in the Registration Statement, under the circumstances in 

which they were made, not misleading; and failed to disclose 

adequately material facts.  As detailed herein, the 

misrepresentations contained in, or the material facts omitted 

from, the Registration Statement included the following:

          a.   Defendants' failure to disclose in the 

     Registration Statement the existence of the David's 

     Litigation, that the Company and one of its former Senior 

     Executive Officers were named as parties defendant in that 

     lawsuit, and that an outcome unfavorable to Fleming would 

     have a material adverse effect on the Company.

          b.   Defendant's representation in the Registration 

     Statement that, in addition to certain disclosed litigation, 

     it was a party to various other litigation that "will not 

     result in a material adverse effect on its consolidated 

     financial statements or results of operations," falsely led 

     investors to believe that Fleming was not a party to any 

     litigation that could have a material adverse effect on the 

     Company.

          c.   The defendants' disclosure in the Registration 

     Statement respecting Fleming's current pricing policy and 

     its plans to change that policy -- without any reference to 

     the David's Litigation in which that policy was being 

     litigated -- falsely led investors to believe that there was 

     no material litigation concerning Fleming's pricing 

     policies.

                                37

          d.   The defendants' liquidity and capital expenditures 

     disclosure in the Registration Statement was materially 

     misleading, because that disclosure never mentioned the 

     potential effect that a material adverse judgment would have 

     on Fleming's ability to maintain compliance with it debt 

     covenants, its ability to make future capital expenditures, 

     or its ability to obtain additional borrowing.

     71.  The Company is the registrant for the Debt Offering and 

filed the Registration Statement as the issuer of the Notes sold 

in the Debt Offering, as defined in §11(a)(5) of the Securities 

Act.  The Company, the Individual Defendants, and the Underwriter 

Defendants named herein were responsible for the contents of the 

Registration Statement and caused its filing with the SEC.

     72.  Fleming is the issuer of the Notes sold via the Debt 

Offering.  As issuer of the Notes, Fleming is liable to plaintiff 

and the members of the Class for the misstatements in, and the 

omissions from, the Registration Statement.

     73.  The Company and the Individual Defendants signed the 

Registration Statement or otherwise caused it to be prepared, 

filed with SEC and circulated to the public, including plaintiff 

and the other members of the Class.

     74.  The Underwriter Defendants were underwriters and 

sellers with respect to the Notes sold in the Debt Offering 

within the meaning of the Securities Act.  Those underwriters 

owned and sold all of the Notes issued in the Debt Offering under 

a firm underwriting agreement.

                                38

     75.  None of defendants named herein made a reasonable 

investigation or possessed reasonable grounds for the belief that 

the statements described above, which were contained in the 

Registration Statement, were true, were without omissions of any 

material facts, and were not misleading.

     76.  At the time they purchased the Notes, neither plaintiff 

nor any member of the Class knew or by the exercise of reasonable 

care could have known of the facts concerning the inaccurate and 

misleading statements and omissions alleged herein.

     77.  Plaintiff and members of the Class each purchased the 

Notes prior to the date the Company made generally available to 

its securities holders an earnings statement covering a period of 

at least twelve months beginning after the effective date of the 

Registration Statement.

     78.  In connection with the Debt Offering and sale of the 

Notes, the defendants, directly or indirectly, used the means and 

instrumentalities of interstate commerce and/or the U.S. mails.

     79.  This action was brought within one year after the 

discovery of the untrue statements and omissions and within three 

years after the Notes were sold to the public in the Debt 

Offering.

     80.  By reason of the foregoing, defendants have violated 

Section 11 of the Securities Act and are liable to plaintiff and 

the members of the Class, each of whom has been damaged by reason 

of such violations, in a total amount in excess of $80 million.

                                39

                             COUNT II

              Against Fleming and the Individual
                  Defendants for Violations of
                 Section 10(b) of the Exchange
          Act and Rule 10b-5 Promulgated Thereunder

     81.  Plaintiff repeats and realleges all preceding 

allegations as if fully set forth herein.

     82.  During the Class Period, defendants, directly and 

indirectly, by use of means and instrumentalities of interstate 

commerce and/or the mails, engaged in a plan and course of 

conduct, pursuant to which each of them knowingly or recklessly 

engaged in acts, transactions, practices, and courses of business 

that operated as a fraud and deceit upon plaintiff and the other 

members of the Class; made various untrue statements of material 

facts and omitted to state material facts necessary in order to 

make the statements made, in light of the circumstances under 

which they were made, not misleading; and employed devices and 

artifices to defraud in connection with the purchase and sale of 

securities, which were intended to, and, throughout the Class 

Period, did:  (i) deceive the investing public, including 

plaintiff and the other Class members, regarding, among other 

things, the existence of, and the consequences of a probable 

adverse outcome of, the David's Litigation; (ii) artificially 

inflate and maintain the market price of the Notes; and 

(iii) cause plaintiff and other members of the Class to purchase 

the Notes at artificially inflated prices.

     83.  Pursuant to the aforesaid plan and course of conduct, 

defendants participated, directly and indirectly, in the 

                                40

preparation and/or issuance of the statements and documents 

referred to above.  Each of the Individual Defendants 

participated directly in the wrongs complained of herein.  By 

reason of his senior position as an executive officer and/or 

director, as well as their close personal working relationships, 

each of the Individual Defendants was a "controlling person" of 

Fleming, within the meaning of Section 20(a) of the Exchange Act, 

and had the power and influence, and exercised the same, to cause 

Fleming to engage in the unlawful conduct complained of herein.  

The Individual Defendants were able to, and did, directly or 

indirectly, in whole or material part, control the content of the 

Company's public financial reports, filings with the SEC, and 

public statements.  Each Individual Defendant was provided, for 

his approval or otherwise, with copies of Fleming's reports, 

filings, releases, and statements herein alleged to have been 

materially false and misleading prior to or shortly after their 

issuance by the Company, and had the ability and opportunity to 

prevent their issuance or to cause them to be corrected.

     84.  As an officer and/or director of a publicly-held 

company the Notes of which were, and are, registered pursuant to 

the Exchange Act, each Individual Defendant had a duty to 

disseminate timely, accurate, truthful, and complete information, 

as set forth below, with respect to the outcome of the David's 

Litigation, as well as the probable or reasonably possible 

adverse consequences that this litigation would have on the 

Company's financial condition and its results of operations so 

                                41

that the market price of the Notes would be based on truthful, 

accurate and complete information.  As hereinafter alleged, each 

Individual Defendant violated these specific duties and 

obligations.

     85.  Said statements and documents were materially false and 

misleading in that, among other things, they misrepresented the 

nature of litigation pending against the Company, and failed to 

disclose the existence and the consequences of a probable adverse 

outcome of the David's Litigation.  The documents and statements 

referred to above were materially false and/or misleading in 

that, among other things:

          a.   The Company's disclosures in the Registration 

     Statement and in the 1994 10-K (repeated and referenced in 

     the 1995 10-Qs) respecting the existence and status of the 

     Florida Litigation, the CERCLA Matter and other litigation 

     "in the ordinary course of business," falsely led investors 

     to believe that the only significant litigation against or 

     contemplated against the Company were the Florida Litigation 

     and the CERCLA Matter.


          b.   All of defendant's statements during the Class 

     Period failed to disclose that Fleming was a party defendant 

     in the David's Litigation.  Given that there was more than a 

     reasonable possibility that the outcome of the David's 

     Litigation would be unfavorable, defendants reported 

     financial results during the Class Period violated GAAP by 

                                42

     failing to disclose the nature and amount of the loss 

     contingency.

          c.   The Company's disclosures in the Registration 

     Statement and in the 1994 10-K (repeated and referenced in 

     the 1995 10-Qs) respecting Fleming's current pricing policy 

     and its plans to change that policy -- without any reference 

     to the David's Litigation in which that policy was being 

     litigated -- falsely led investors to believe that there was 

     no material litigation concerning Fleming's pricing 

     policies.

          d.   Fleming and the Individual Defendants failed to 

     accrue a loss for the probable material adverse outcome in 

     the David's Litigation in the 1994 10-K and the 1995 10-Qs.  

     As detailed above, given Fleming's culpability with respect 

     to the conduct underlying the allegations in the David's 

     Complaint, as well as the completion of substantial 

     discovery and the preparation of a motion for partial 

     summary judgment, Fleming and the Individual Defendants 

     knew, or, but for its recklessness, should have known, by 

     the time the Company issued the 1994 10-K, that it was 

     probable that the lawsuit would result in an unfavorable 

     outcome with material adverse consequences for the Company.

          e.   Fleming and the Individual Defendants falsely 

     represented in the notes to the Consolidated Condensed 

     Financial Statements included in its 1995 10-Qs that "[i]n 

     the opinion of management, all adjustments necessary to 

                                43

     present fairly the company's financial position . . . and 

     the results of operations and cash flows for the periods 

     presented have been made."

          f.   In all of its SEC disclosures respecting liquidity 

     and capital expenditures, the Company never mentioned the 

     potential effect that a material adverse judgment would have 

     on Fleming's ability to maintain compliance with its debt 

     covenants, its ability to make future capital expenditures, 

     and its ability to obtain additional borrowing.

     86.  Disclosure of these facts was required so that the 

statements detailed above would not be materially misleading.  In 

addition, it is management's responsibility, under SEC 

regulations and under GAAP, to disclose fully all material loss 

contingencies, such as lawsuits seeking significant damages 

against a registrant.  Under Rule 303(a)(1) of Regulation S-K, 

which governs "Management's Discussion and Analysis of Financial 

Condition and Results of operations," management must

          [i]dentify any known trends or any known 
          demands, commitments, events or uncertainties 
          that will result in or that are reasonably 
          likely to result in the registrant's 
          liquidity increasing or decreasing in any 
          material way.  If a material deficiency is 
          identified, indicate the course of action 
          that the registrant has taken or proposes to 
          take to remedy the deficiency.

The purpose of Rule 303, as set forth therein, is to provide 

readers of the financial statements with meaningful information 

relevant to the assessment of the registrant's financial 

condition and results of operations as determined through the 

                                44

evaluation of the amounts and certainty of cash flows.  The Rule 

specifies that the disclosures are intended to focus on material 

events and uncertainties that would cause reported financial 

information not to be necessarily indicative of future operating 

results or of future financial condition, including matters that 

would have an impact on future operations that have not had an 

impact in the past.  Disclosures, which are intended to be 

forward-looking, are required for information presently known to 

the registrant that will impact upon future operating results.

     87.  Under GAAP, particularly Statement of Financial 

Accounting Standards No. 5, Accounting for Contingencies 

("SFAS 5"), disclosure is required for all loss contingencies, 

expressly including pending or threatened litigation, which are 

"reasonably possible" to occur, that is, whenever the chance of 

the loss occurring is more than "remote", or slight.

     88.  In addition, SFAS 5 requires that an accrual be 

recorded whenever (i) it is "probable" that the loss contingency 

will occur, that is, whenever the loss is likely to occur; and 

(ii) the amount of the loss may be reasonably estimated.  In the 

event that the first element is established but only a range of 

loss is reasonably estimable, SFAS 5 requires that, unless a 

particular amount within the range is determined to be a better 

estimate (in which case such amount should be accrued), the 

minimum amount of the range should be accrued.  SFAS No. 5 also 

provides that:

          [i]f no accrual is made for a loss 
          contingency because one or both of the 

                                45

          conditions in paragraph 8 are not met . . . 
          disclosure of the contingency shall be made 
          when there is at least a reasonable 
          possibility that a loss or an additional loss 
          may have been incurred.  The disclosure shall 
          indicate the nature of the contingency and 
          shall give an estimate of the possible loss 
          or range of loss or state that such an 
          estimate cannot be made.

Thus, even if no amount is reasonably estimable, disclosure is 

still required.

     89.  SFAS 5 provides guidance for the determination of 

whether or not a pending lawsuit should be disclosed, whether or 

not it should be accrued for, or both:

               If the underlying cause of the 
          litigation . . . is an event occurring before 
          the date of an enterprise's financial 
          statements, the probability of an outcome 
          unfavorable to the enterprise must be 
          assessed to determine whether [it is probable 
          and reasonably estimable].  Among the factors 
          that should be considered are the nature of 
          the litigation . . .; the progress of the 
          case (including progress after the date of 
          the financial statements but before those 
          statements are issued); the opinions or views 
          of legal counsel and other advisers; the 
          experience of the enterprise in similar 
          cases; the experience of other enterprises; 
          and any decision of the enterprise's 
          management as to how the enterprise intends 
          to respond to the lawsuit . . . (for example, 
          a decision to contest the case vigorously or 
          a decision to seek an out-of-court 
          settlement).

     90.  At all relevant times, Fleming and the Individual 

Defendants had actual knowledge that the statements and documents 

complained of herein were materially false and misleading as set 

forth herein and intended to deceive plaintiff and the other 

members of the Class.  In the alternative, these defendants acted 

                                46

in reckless disregard for the truth in that they failed or 

refused to ascertain and disclose such facts as would have 

revealed the materially false and misleading nature of the 

statements and documents complained of herein although such facts 

were readily available to defendants from, among other sources, 

the record in pending litigation.  Said facts and omissions of 

defendants were committed willfully or with reckless disregard 

for the truth.  In addition, Fleming and the Individual 

Defendants knew or recklessly disregarded that material facts 

were being misrepresented or omitted as alleged herein.

     91.  Information showing that these defendants acted 

knowingly or with reckless disregard for the truth is peculiarly 

within defendants' knowledge and control.  As senior corporate 

officers of Fleming, the Individual Defendants had knowledge of 

the details of the Company's financial affairs and results, 

including litigation in which Fleming was named as a party 

defendant; indeed, defendants Stauth and Eyler were deposed in 

the David's Litigation and it was disclosed in an April 11, 1996 

Bloomberg Business News report that Stauth's deposition testimony 

"hurt the company's stand."  Plaintiff, who purchased the Notes 

on the open market, does not have knowledge of the details of the 

Company's internal corporate affairs.  However, the following 

facts, among others, indicate a strong inference that Fleming and 

the Individual Defendants acted with scienter:

          a.   Fleming and the Individual Defendants knew that 

     the fact that a lawsuit seeking more than $110 million in 

                                47

     damages was filed against Fleming is the type of information 

     that, under Rule 303(a)(1) of Regulation S-K, promulgated 

     under the Exchange Act, must be, and is expected by 

     investors and securities analysts to be, disclosed.  

     Specifically, because David's was seeking in excess of $110 

     million dollars in damages in its lawsuit filed in August 

     1993 -- an amount that was nearly 10% of Fleming's 1993 

     current assets, and because the allegations in the David's 

     Litigation concerned the integrity of Fleming's management, 

     the Company was required to describe in its filings with the 

     SEC "any material pending legal proceedings."  Given these 

     defendants' knowledge of Regulation S-K and the fact that it 

     disclosed other pending litigation in its SEC filings, its 

     failure to disclose the David's Litigation was necessarily 

     the result of a conscious and deliberate decision to conceal 

     these facts from the public.

          b.   In the 1995 Annual Report, which was filed with 

     the SEC on March 18, 1996 but apparently was prepared prior 

     to the verdict in the David's Litigation, Fleming disclosed 

     the David's Litigation.  In the "Litigation and 

     contingencies" footnote to its fiscal 1995 consolidated 

     financial statements, the Company described the relevant 

     facts, and that the case went to trial in February, 1996.  

     Fleming then made the following disclosure:

               Management is unable to predict a 
          potential range of monetary exposure, if any, 
          to the company, but believes the claims 
          asserted are without merit and that a 

                                48

          material adverse effect on the company's 
          consolidated financial position is less than 
          probable.  However, based on the large 
          recovery sought, an unfavorable result could 
          have a material adverse effect on the 
          company.  The company is vigorously defending 
          the litigation.

     Obviously, these defendants believed that an adverse outcome 

     from the David's Litigation was at least reasonably possible 

     as of February 22, 1996 -- prior to the verdict -- the date 

     of the accountants' report on the fiscal 1995 consolidated 

     financial statements.  Whatever facts Fleming and the 

     Individual Defendants were privy to on February 22, 1996, 

     those facts clearly were available to them throughout the 

     Class Period.  No explanation was provided, however, for the 

     change in the Company's belated disclosure, over 2 1/2 years 

     after the David's Litigation was filed.

          c.   Fleming and the Individual Defendants failed to 

     disclose the David's Litigation in order to conceal its 

     fraudulent and deceptive practices from its other customers, 

     thereby protecting its goodwill and reducing the possibility 

     that other customers would file lawsuits as a result of 

     similar conduct.  Indeed, as described above, the belated 

     disclosure of the verdict in the David's Litigation has 

     caused several of Fleming's customers to perform their own 

     investigation of the Company's practices.

     92.  In addition, certain of the Individual Defendants had 

personal motives for failing to disclose and accrue for the 

David's Litigation and thereby artificially create and inflate 

                                49

the market for the Notes and artificially enhance the value of 

Fleming:

          a.   Defendant Stauth beneficially owned 72,374 shares 

     of Fleming common stock, was granted 24,000 shares of 

     Fleming restricted common stock, and was granted options to 

     purchase 90,000 more shares (60,000 of which were 

     performance related) of the Company's common stock.

          b.   Defendant Winn beneficially owned 14,050 shares of 

     Fleming common stock.

          c.   The Individual Defendants participated in the 

     wrongdoing complained of herein in order to inflate and 

     maintain the price of Fleming's common stock so that they 

     could protect and enhance their positions as senior officers 

     of the Company, as well as the substantial compensation, 

     prestige and other benefits they obtained thereby.

     93.  As a result of Fleming's and the Individual Defendants' 

fraudulent conduct as alleged herein, the prices at which the 

Notes were initially sold and purchased on the secondary market 

were artificially inflated throughout the Class Period.  At the 

time that plaintiff and the other members of the Class purchased 

the Notes, the true value of such Notes was substantially lower 

than the prices paid by plaintiff and the other members of the 

Class.  The market price of the Notes declined sharply 

immediately following the public disclosures on March 14 and 

15, 1996 of the material adverse impact of the David's 

Litigation.  In ignorance of the materially false and misleading 

                                50

nature of the statements and documents complained of herein, as 

well as of the adverse, undisclosed information known to 

defendants, plaintiff and the other members of the Class relied, 

to their damage, on such statements and documents, and/or on the 

integrity of the offering and market prices of the Notes in 

purchasing such Notes at artificially inflated prices during the 

Class Period.  Had plaintiff and the other members of the Class 

known the truth, they would not have taken such action.

     94.  At all relevant times, the misrepresentations and 

omissions particularized in this Complaint directly or 

proximately caused or were a substantial contributing cause of 

the damages sustained by plaintiff and the other members of the 

Class.  The misstatements and omissions complained of herein had 

the effect of creating in the market an unrealistically positive 

assessment of Fleming, as well as of its litigation exposure, 

thereby causing the Notes to be overvalued and artificially 

inflated at all relevant times.  Defendants' false portrayal, 

during the Class Period, of Fleming's exposure to materially 

adverse judgments resulted in purchases of the Notes by plaintiff 

and by the other members of the Class at artificially inflated 

prices measured by the difference between the market prices and 

the actual value of such Notes at the time of purchase, thus 

causing the damages complained of herein.

     95.  The Underwriter Defendants, Merrill Lynch and J.P. 

Morgan, made a market for the Notes and, as a result, there was a 

ready market for the Notes throughout the Class Period.  In 

                                51

addition, their price reflected sensitivity to new market 

conditions, as evidenced by the sharp and immediate drop in price 

upon the disclosure by Fleming of the verdict in the David's 

Litigation.

     96.  In addition, at the time the Notes were issued, Fleming 

common stock was listed and actively traded on the New York, 

Pacific and Chicago Stock Exchanges, and the Company had twelve 

different issues of debt outstanding, including debentures that 

were registered pursuant to Section 12(b) of the Exchange Act and 

listed and traded on the New York Stock Exchange.  Because 

Fleming securities, including its debt securities, had been 

trading prior to the Debt Offering, the pricing of the Notes on 

the offering and thereafter was made in relation to the prices 

the market as a whole was willing to pay for Fleming securities.

     97.  As a result, the market for Fleming securities, 

including the Notes, was well-developed, and the price at which 

the Notes were initially offered, and at which the Notes traded 

thereafter, necessarily reflected the material misrepresentations 

and omissions complained of herein.

     98.  As a direct and proximate result of defendants' 

aforesaid wrongful conduct during the Class Period, plaintiff and 

the other members of the Class have suffered substantial damages 

in connection with their purchases of the Notes.

     99.  By virtue of the foregoing, each defendant has violated 

Section 10(b) of the Exchange Act, and Rule 10b-5 promulgated 

thereunder.

                                52

                            COUNT III

               Against the Individual Defendants
                        for Violations of
               Section 20(a) Of The Exchange Act

     100. Plaintiff repeats and realleges each of the foregoing 

allegations as if fully set forth herein.

     101. Throughout the Class Period, each of the Individual 

Defendants, by reason of his position as a senior executive 

officer or and/director of Fleming, had the power and influence, 

and exercised the same, to cause the Company to engage in the 

unlawful acts, conduct, and practices complained of herein.  As a 

result, at the time of the wrongs alleged herein, the Individual 

Defendants were "controlling persons" of the Company within the 

meaning of Section 20(a) of the Exchange Act.

     102. Pursuant to Section 20(a) of the Exchange Act, by 

reason of the foregoing, each of the Individual Defendants is 

liable to the same extent as is Fleming for the Company's 

aforesaid violations of Section 10(b) of the Exchange Act and 

Rule 10b-5 promulgated thereunder.  As a direct and proximate 

result of said defendants' wrongful conduct during the Class 

Period, plaintiff and the other members of the Class have 

suffered substantial damages in connection with their purchases 

of the Notes.



                        PRAYER FOR RELIEF

          WHEREFORE, plaintiff, on behalf of himself and the 

Class, prays for judgment against defendants, as follows:

                                53

     A.   Declaring this action to be a class action properly 

maintainable pursuant to Rule 23(a) and Rule 23(b)(3) of the 

Federal Rules of Civil Procedure on behalf of the Class, and 

declaring plaintiff to be a proper Class representative;

     B.   Awarding plaintiff and the other members of the Class 

damages as a result of the wrongs complained of herein in an 

amount to be determined at trial;

     C.   Awarding plaintiff and other members of the Class their 

costs and expenses of this litigation, including, without 

limitation, reasonable attorneys' and experts' fees, and other 

costs and disbursements; and

     D.   Awarding plaintiff and the other members of the Class 

such other and further relief as the Court may deem just and 

proper.





                                54

                       JURY TRIAL DEMANDED

     Plaintiff hereby demands a trial by jury.

Dated:  April 3, 1996

                                   JONES, GIVENS, GOTCHER
                                     & BOGAN, P.C.

                                                 /s/
                                   By____________________________
                                     Jack L. Brown (OBA # 10742)
                                   15 East Fifth Street
                                   Suite 3800
                                   Tulsa, OK  74103-4309
                                   (918) 581-8200

                                   BERNSTEIN LITOWITZ BERGER &
                                     GROSSMANN LLP
                                   Jeffrey A. Klafter
                                   Jeffrey N. Leibell
                                   1285 Avenue of the Americas
                                   New York, New York  10019
                                   (212) 554-1400





                                55


3 Aug 1997