UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH CAROLINA
-----------------------------------x
:
PRISCILLA NEELY, Individually and : CIVIL ACTION
on Behalf Of All Others : NO. [99-CV-00088]
Similarly Situated, : [filed Jan. 11, 1999]
:
Plaintiff, :
v. :
:
DATASTREAM SYSTEMS, INC., LARRY :
BLACKWELL, and DANIEL CHRISTIE, :
:
Defendants. :
:
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COMPLAINT FOR VIOLATIONS OF
THE SECURITIES EXCHANGE ACT OF 1934
Plaintiff on her own behalf and on behalf of all others
similarly situated, for her complaint against defendants, alleges
as follows:
NATURE OF THE ACTION
1. This action is brought on behalf of plaintiff and
all other persons, other than defendants and their affiliates, who
purchased common stock of defendant Datastream Systems, Inc.
("Datastream" or the "Company") during the period from April 1,
1998 through October 20, 1998, inclusive (the "Class Period"), and
who sustained damage in connection with those transactions. During
the Class Period, in violation of the federal securities laws, the
defendants knowingly or recklessly made, caused or permitted to be
made misrepresentations of material fact and/or omitted material
facts necessary to make statements that were made not misleading
with regard to the Company's financial position and operating
performance. This conduct operated to artificially inflate the
market price of Datastream stock during the Class Period, thereby
damaging plaintiff and the Class, who purchased the Company's stock
relying on the market price thereof to accurately reflect its true
value. As a result of defendants' misconduct, the market price of
Datastream stock traded for as much as $27 per share during the
Class Period. On October 20, on revelation of some of the truth,
the price fell to below $11 per share.
2. In the beginning of 1998, Datastream was
experiencing declining sales growth and rising expenses.
Defendants covered up these adverse facts, and reported inflated
earnings so that defendants could (1) continue to tout Datastream
as a growing company, and (2) carry out a $71 million public
offering in which defendant Larry Blackwell personally tried to
sell over $10 million worth of Datastream stock (that offering
ultimately failed to go forward).
3. Defendants' scheme to conceal declining sales growth
and inflate materially Datastream's earnings was twofold. First,
defendants began an acquisition spree, and then improperly took
huge "one-time" charges in violation of generally accepted
accounting procedures. Second, beginning not later than the
quarter ended June 30, 1998, defendants materially understated
operating costs by improperly capitalizing some expenses, rather
than properly expensing them in the period in which they were
incurred, in violation of generally accepted accounting principles
("GAAP"). For example, defendants improperly capitalized
approximately $850,000 in marketing/advertising expenses incurred
in the June 30, 1998 quarter, resulting in a 42% boost to
Datastream's reported operating income that quarter. Defendants
thus artificially inflated operating income by at least $850,000,
from $1.984 million to $2.834 million.
JURISDICTION AND VENUE
4. Jurisdiction exists pursuant to §27 of the
Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. §78aa,
and 28 U.S.C. §1331. The claims asserted arise under §§10(b) and
20(a) of the Exchange Act, 15 U.S.C. §§78j(b), 78t(a) and Rule 10b-
5.
5. Venue is proper in this District pursuant to §27 of
the Exchange Act and 28 U.S.C. §1391(b). Many of the acts giving
rise to the violations complained of occurred in this District.
THE PARTIES
6. Plaintiff Priscilla Neely purchased shares of
Datastream common stock during the Class Period as follows:
Number
Date of Shares Price
06/28/98 1,000 $ 20.375
06/29/98 2,300 20.250
06/29/98 (IRA Acct.) 1,000 20.250
06/30/98 1,000 19.874
07/23/98 500 14.000
7. Defendant Datastream has its executive offices at 50
Datastream Plaza, Greenville, South Carolina. Datastream stock
trades in an efficient market on the NASDAQ National Market System.
Datastream describes itself as a leading provider of computerized
maintenance management systems and enterprise asset management
systems, which are intended to improve factory efficiency. It has
offices or distributors in twenty-two nations and sells software
products in fifteen languages.
8. Defendant Larry Blackwell ("Blackwell") is, and at
all relevant times has been, Chief Executive Officer and Chairman
of the Board of Directors of Datastream.
9. Defendant Daniel Christie is, and all relevant times
has been, Chief Financial Officer of Datastream.
CONTROLLING PERSON ALLEGATIONS
10. Defendants Blackwell and Christie (the "Individual
Defendants"), by reason of their executive and Board positions,
were controlling persons of Datastream during the Class Period and
had the power and influence, which they exercised, to cause
Datastream to engage in the conduct complained of.
11. During the Class Period, each Individual Defendant
occupied a position that made him privy to non-public information
concerning Datastream. Because of this access, each of these
defendants knew the adverse material facts specified herein and
that those facts were being concealed or misrepresented.
12. Each of the defendants is liable for making false
and misleading statements and for willfully or recklessly
participating in a fraudulent scheme and course of business that
operated as a fraud on purchasers of Datastream stock and damaged
Class members in violation of the federal securities laws. All of
the defendants pursued a common goal, i.e., inflating the price of
Datastream stock by making false and misleading statements and
concealing material adverse information. The scheme and course of
business was designed to and did: (i) deceive the investing
public, including plaintiff and other Class members; (ii)
artificially inflate the price of Datastream stock during the Class
Period; and (iii) cause plaintiff and the other members of the
Class to purchase Datastream stock at inflated prices.
13. Each defendant had the opportunity to commit and
participate in the violations of law described herein. The
Individual Defendants were top officers and directors of Datastream
and they controlled its press releases, corporate reports, SEC
filings, and communications with analysts. Thus, the defendants
controlled the public dissemination of, and could conceal and
misrepresent, the information about Datastream's business and
finances that reached the public and inflated the price of
Datastream's stock.
CLASS ACTION ALLEGATIONS
14. Plaintiff brings this action as a class action
pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil
Procedure on behalf of a class (the "Class") consisting of all
persons who purchased Datastream common stock during the period
April 1 through October 20, 1998, inclusive. Excluded from the
Class are the defendants herein, members of the immediate families
of the Individual Defendants, any entity in which any defendant has
a controlling interest, and the legal affiliates, representatives,
heirs, controlling persons, successors, and predecessors in
interest or assigns of any such excluded party.
15. Because more than 19 million shares of the Company's
common stock were outstanding and because the Company's common
stock was actively traded on the NASDAQ during the Class Period,
the members of the Class are so numerous that joinder of all
members is impracticable. While the exact number of Class members
can only be determined by appropriate discovery, plaintiff believes
that Class members number at least in the hundreds and that they
are geographically dispersed.
16. Plaintiff's claims are typical of the claims of the
members of the Class because plaintiff and all of the Class members
sustained damages arising out of the defendants' wrongful conduct
complained of herein.
17. Plaintiff will fairly and adequately protect the
interests of the Class members and has retained counsel who are
experienced and competent in class and securities litigation.
Plaintiff has no interest which is contrary to or in conflict with
those of the members of the Class plaintiff seeks to represent.
18. A class action is superior to all other available
methods for the fair and efficient adjudication of this controversy
since joinder of all members is impracticable. Furthermore, as the
damages suffered by individual members of the Class may be
relatively small, the expense and burden of individual litigation
make it impossible for the members of the Class individually to
redress the wrongs done to them. There will be no difficulty in
the management of this action as a class action.
19. Questions of law and fact common to the members of
the Class predominate over any questions which may affect only
individual members in that 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 the federal securities laws were
violated by defendants' acts as alleged herein;
(b) Whether the Company's publicly disseminated
releases and statements during the Class Period omitted and/or
misrepresented material facts and whether defendants breached any
duty to convey material facts or to correct material facts
previously disseminated;
(c) Whether defendants participated in and pursued
the common course of conduct complained of;
(d) Whether the defendants acted willfully and/or
recklessly in omitting and/or misrepresenting material facts;
(e) Whether the market price of Datastream common
stock during the Class Period was artificially inflated due to the
material nondisclosures and/or misrepresentations complained of
herein; and
(f) Whether the members of the Class have sustained
damages and, if so, what is the appropriate measure of damages.
Generally Accepted Accounting Principles
20. "Generally accepted accounting principles," or GAAP,
is a term of art used to refer to financial statements prepared
through application of financial principles published by the
American Institute of Certified Public Accountants (AICPA). See 1
AICPA Professional Standards, AU §411. Regulations S-X of the SEC
state, "Financial statements filed with the Commission which are
not prepared in accordance with generally accepted accounting
principles will be presumed to be misleading or inaccurate, despite
footnote or other disclosures, unless the Commission has otherwise
provided." 17 C.F.R. §210.4-01(a)(1).
21. In Datastream's 1997 Report on Form 10-K filed with
the SEC on March 31, 1998, Datastream and its auditor stated that
Datastream's financial statements were in conformity with GAAP.
The Company never updated this statement, so investors were led to
believe that all of Datastream's subsequent financial statements
also were prepared in conformity with generally accepted accounting
principles.
22. GAAP mandates that "the costs of intangibles
purchased from others for use in research and development
activities and that have alternative future uses (in research and
development projects or otherwise) shall be capitalized and
amortized as intangible assets." Financial Accounting Standards
Board Statement 2, §11(c). There is a narrow exception to this
statement, applicable only where assets are acquired, and where
costs are properly assigned to a particular research and
development project that is being abandoned. "[C]osts assigned to
assets to be used in a particular research and development project
and that have no alternative future use should be charged to
expense at the date of consummation of the combination." As
explained below, defendants caused Datastream to improperly write
off acquisition costs, especially research and development costs,
that were substantially greater than could plausibly be attributed
to the fair market value of the assets that were determined to be
worthless to Datastream.
23. In addition, Datastream changed its accounting
practice with respect to marketing costs in the middle of the Class
Period. Prior to the second quarter of 1998, Datastream accounted
for marketing costs as an expense in the quarter in which the
expenses were incurred. Beginning in the second quarter,
defendants caused Datastream to capitalize some of these costs,
thereby reducing quarterly reported expenses and increasing
quarterly reported income. This practice violated GAAP and
deceived investors.
BACKGROUND FACTS
24. Datastream first offered common stock to the public
in July 1995. Datastream was able to report a consistent upward
trend in total revenue earnings through the four quarters of 1997,
as follows:
1 9 9 7
Q1 Q2 Q3 Q4
Total Revenue $14,682 $16,814 $17,400 $20,872
Net Income 1,978 2,601 2,976 3,883
Income Per Share .11 .14 .15 .19
25. On January 27, 1998, defendants caused Datastream to
issue a press release touting the fourth quarter results as marking
"the 22nd consecutive quarter of record revenues."
26. However, the level of total revenue and net income
achieved in 1997 was not sustainable. Defendants were aware that
a decrease in reported earnings, and especially in reported income
excluding one-time charges, would cause a decline in Datastream's
stock price.
27. To avoid a decline in stock price, defendants caused
Datastream to embark on a costly program of acquisition, coupled
with excessive writeoffs, so that expenses that should properly
have been reported as operating costs could be hidden within one-
time charges.
The Class Period Begins
28. On April 1, 1998, defendants caused Datastream to
issue the following in a press release:
GREENVILLE, SC (April 1, 1998) - Datastream
Systems, Inc. (Nasdaq: DSTM) a leading provider of
computerized maintenance management systems (CMMS),
announced today that it has acquired Insta
Instandhaltung Technischer Anlagen GmbH (Insta), a
leading European provider of CMMS headquartered in
Munich, Germany, effective March 31, 1998.
Under the terms of the agreement, Datastream has
acquired all of the outstanding shares of capital
stock of Insta for approximately $7 million of
consideration, 62.5% of which will be paid in cash
and 37.5% in stock. The transaction will be
accounted for as a purchase. Datastream will incur
a one time write-off of approximately $4 million to
$6 million in its fiscal first quarter for
acquisition related costs, in-process R&D write
off, and other restructuring costs. Insta had
annual revenues and profits for the year ended
December 31, 1997 of approximately USD $5.3 million
and $475,000, respectively.
"We continue to view the European market as an
attractive market for growth given the broad-based
European migration to client/server platforms,
pervasive Year 2000 issues, and increased demand
for mission critical software products in Europe,"
stated Larry Blackwell, president and CEO of
Datastream Systems, Inc. "This acquisition
continues our strategy, initiated with the purchase
of SQL Systems Group at the end of 1996, of
acquiring distribution, products, and skilled
personnel in key European markets. As the leading
provider of maintenance software in Germany with
over 1400 installations, Insta establishes
Datastream as the clear European market leader, a
position which represents a solid foundation for
sales of our low- and mid-tier Germanic-based
products."
Additionally, Insta's Enterprise Resource Planning
(ERP) integration capabilities represent an
important knowledge base for us to leverage as we
increase our focus on ERP integration," continued
Mr. Blackwell. "Given these factors and the proven
success of the similar SQL Systems acquisition, we
believe that this transaction represents a value
enhancing event for shareholders."
"The merger of Insta with Datastream will enable
Insta to focus on expanding its customer base
within Germany, Austria and Switzerland," said
Michael Hartmann, founder and president of Insta.
"Many of our customers in Germany have plants or
facilities located in other countries. Aligning
ourselves with a multinational company such as
Datastream gives us a mechanism to service the
worldwide operations of the large, prominent German
firms that typify our customer base," continued
Hartmann.
29. This press release was false and misleading because:
(a) it failed to disclose that the announced write-
off would be greater than that permitted by GAAP; and
(b) it failed to disclose that the transaction was
intended to artificially inflate Datastream's earnings by
permitting costs of operations to be hidden inside the one-time
writeoff.
30. On April 23, 1998, defendants caused Datastream to
issue the following press release, purporting to describe first
quarter results:
Total revenues for the quarter ended March 31, 1998
were $20.1 million, a 37 percent increase from
$14.7 million in the first quarter of 1997.
Software sales rose 20 percent to $7.4 million,
consulting services rose 55 percent to $9.0
million, and technical support rose 38 percent to
$3.8 million from the same quarter a year ago.
Net income in the first quarter was $3.4 million
before the one-time charges related to the
acquisition of Insta, GmbH on March 31, 1998.
Excluding the charges, first quarter net income
increased 70 percent from $2.0 million in the same
quarter of 1997.
Diluted earnings per share for the quarter, before
the acquisition-related charges, were $.17 based on
20.25 million weighted average shares, a gain of 55
percent from $.11 per share based on 18.77 million
weighted average shares in the first quarter of
1997.
One-time charges associated with the acquisition of
Insta, GmbH include write-offs of $2.5 million for
in-process research and development and $598,000
for certain assets rendered obsolete through the
acquisition of software technology. Accounting for
the charges, Datastream reported net income of
$237,000 or $.01 per diluted share in the first
quarter of 1998.
Our results were in line with expectations," said
Larry Blackwell, Datastream's President and CEO.
"Client/server sales showed strong annual growth,
MP2 Professional for Microsoft Access was released
ahead of schedule, and we completed the acquisition
of Insta, the market leader in Germany."
* * *
"On April 1, 1998 we announced the acquisition of
Insta, GmbH, located in Munich, Germany," continued
Blackwell. "This addition continues the strategy
initiated with the acquisition of SQL Group to
build a presence in key markets through combination
with established companies that have quality
products and skilled personnel."
31. This press release was materially misleading for the
following reasons:
(a) It failed to disclose that the one-time
writeoff was greater than GAAP permits, and included costs that
should not properly be accounted for as "in process research and
development;" and
(b) It failed to disclose that one purpose of the
announced merger was to increase Datastream's reported earnings
from operations in the current and immediate future quarters,
through the mechanism of improper allocation of expenses to a one-
time charge.
32. On May 13, 1998, Datastream filed a report on Form
10-Q with the SEC, signed by defendant Christie, which contained
the same financial disclosures as in the April 23 press release.
This Form 10-Q was materially misleading for the reasons stated in
¶33 above.
33. In addition, the Form 10-Q stated with respect to
accounting for the Insta purchase, "The purchase price has been
allocated to the tangible and intangible assets purchased and the
liabilities assumed based on the fair values on the date of
acquisition." This statement was materially misleading. In fact,
defendants caused Datastream to allocate a larger portion of the
purchase price to "in-process research and development" than the
fair value of such assets.
34. On June 16, 1998, defendants caused Datastream to
issue a press release announcing a new acquisition:
GREENVILLE, SC (June 16, 1998) - Datastream
Systems, Inc. (Nasdaq: DSTM) a leading developer of
computerized maintenance management systems (CMMS),
announced today that it has acquired Strategic
Information Systems Pte. Ltd, ("SIS"), a prominent
developer of CMMS headquartered in Singapore. In a
separate action, Datastream signed a letter of
intent to acquire its largest regional distributor,
Australia-based Datastream (Pacific) Pty Ltd.
SIS specializes in high-end asset management
systems for vertical markets that are asset-
sensitive, such as utilities and petrochemical
industries. SIS annual revenues for the fiscal
year ended February 29, 1998 were U.S. $4.61
million and earnings were U.S. $271,000. Under the
terms of the agreement, Datastream has acquired all
of the outstanding shares of capital stock of SIS
for approximately $6.5 million, 70% of which will
be paid in cash and 30% in stock.
35. On July 15, 1998, defendants caused Datastream to
issue the following press release, purporting to describe second
quarter results:
GREENVILLE, SC (July 15, 1998) - Datastream
Systems, Inc. (Nasdaq: DSTM) today announced record
revenue for the second quarter of 1998.
Total revenue for the quarter ended June 30, 1998
was $23.4 million, a 39 percent increase from $16.8
million in the second quarter of 1997. Software
sales rose 36 percent to $9.3 million, consulting
services rose 42 percent to $9.8 million, and
technical support rose 40 percent to $4.3 million
from the same quarter a year ago.
Net income in the second quarter was $3.6 million
before the one-time charges related to the
acquisition of Strategic Information Systems Pte,
Ltd., ("SIS") on June 16, 1998. Excluding the
charges, second quarter net income increased 39
percent from $2.6 million in the same quarter of
1997.
Diluted earnings per share for the quarter, before
the acquisition-related charges, were $.18 based on
20.5 million weighted average shares in the second
quarter of 1997.
One-time charges associated with the acquisition of
SIS include a write-off of $2.7 million for in-
process research and development. Accounting for
the charges, Datastream reported net income of
$672,330 or $.03 per diluted share in the second
quarter of 1998.
"We have completed a very active quarter," said
Larry Blackwell, Datastream's President and CEO."
New product releases of MP2 and a 100% web centric
MP5 have been well-received. The acquisition of
SIS in Singapore and the recent acquisition of our
Australian distributor, plus the opening of our
Shanghai office, give us a substantive presence in
Asia." Sales of Microsoft Access based MP2
increased 85 percent sequentially to $1.4 million
and sales of MP5, the Company's high-end asset
management system, gained 88 percent sequentially
to $3.1.
36. This press release was materially misleading
(a) for the reasons described in ¶29 above;
(b) because it failed to disclose that Datastream
had artificially reduced reported operating costs by improperly
capitalizing marketing expense, which represented an undisclosed
change of Datastream's prior accounting practice of accounting for
marketing costs as expenses in the quarter incurred. This
undisclosed accounting change had a material effect on the
Company's earnings, as it reduced reported expenses by about
$850,000; and
(c) because the defendants caused Datastream to
report a $200,000 reduction in general and administrative cost
(despite the new acquisition), and did not disclose that this
reported cost savings was caused by reallocation of actual costs
incurred from the general and administrative category, which GAAP
required to be accounted for as a regular operating expense, to
other cost categories which could be either included within one-
time writeoffs, or capitalized.
37. Defendants were motivated to artificially inflate
the price of Datastream common stock, because the Company and
defendant Blackwell were planning to sell enormous amounts of
stock. On June 26, 1998, Datastream filed a draft prospectus with
the SEC, proposing sales of 500,000 shares by Blackwell and 3.5
million shares by Datastream, at a price of up to $20.47 per share.
The proposed stock sale would go forward only if Datastream's stock
price remained at its then-current level.
38. Despite the accounting manipulations, Datastream's
stock declined in price during the month of July. If not for the
materially misleading earnings report on July 15, the decline would
have been greater. On July 23, the Company announced that the
proposed stock sale had been cancelled.
39. On August 6, 1998, Datastream filed a report on Form
10-Q with the SEC, signed by defendant Christie, that contained the
same financial information, including misrepresentations and
omissions, as the July 15 press release. This Form 10-Q was
materially misleading for the reasons stated in ¶37 above.
40. In addition, the Form 10-Q stated with respect to
accounting for both the Insta and the SIS purchases: "The purchase
price has been allocated to the tangible and intangible assets
purchased and the liabilities assumed based on the fair values on
the date of acquisition." This statement was materially
misleading. In fact, defendants caused Datastream to allocate a
larger portion of the purchase price to "in-process research and
development" than the fair value of such assets.
The Class Period Ends
41. The Class Period ends on October 20, 1998, when
Datastream released its Third Quarter financial results. Although
defendants once again sought to hide operating costs of yet another
acquisition inside yet another writeoff for "in process R&D," this
time for $1.1 million, and were able to report record operating net
income, the price of Datastream stock declined by 29%, from $14-1/8
to $10 per share. Absent the third quarter acquisition, reported
software revenue actually declined from the previous quarter. One
stock analyst reduced the rating of Datastream stock, due to lower-
than-expected software application sales, and the Company's warning
of increased competition. Datastream stock has not yet recovered.
CLAIM FOR RELIEF I
For Violation of Section 10(b) Of The
Exchange Act And Rule 10b-5 Against All Defendants
42. Plaintiff incorporates by reference ¶¶1-41.
43. Each of the defendants: (a) knew or had access to
the material adverse non-public information about Datastream's
financial results and then existing business conditions, which was
not disclosed; and (b) participated in drafting, reviewing and/or
approving the misleading statements, releases, reports and other
public representations of and about Datastream.
44. During the Class Period, defendants, with knowledge
of or reckless disregard for the truth, disseminated or approved
the false statements specified above, which were misleading in that
they contained material misrepresentations and failed to disclose
material facts necessary in order to make the statements made, in
light of the circumstances under which they were made, not
misleading.
45. Defendants violated §10(b) of the Exchange Act and
Rule 10b-5 in that they:
(a) Employed devices, schemes and artifices to
defraud;
(b) Made untrue statements of material facts or
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; or
(c) Engaged in acts, practices and a course of
business that operated as a fraud or deceit upon plaintiff and
others similarly situated in connection wit 0(a) of the Exchange Act. By reasons of their positions as
officers and directors of Datastream, defendants Blackwell and
Christie had the power and authority to cause Datastream to engage
in the wrongful conduct complained of herein.
49. By reason of such wrongful conduct, Blackwell and
Christie are liable pursuant to §20(a) of the Exchange Act. As a
direct and proximate result of these defendants' wrongful conduct,
plaintiff and the other members of the Class suffered damages in
connection with their purchases of Datastream common stock during
the Class Period.
BASIS FOR THE ALLEGATIONS
50. Plaintiff has alleged the foregoing based upon the
investigation of his counsel, which included a review of
Datastream's SEC filings, securities analysts' reports and
advisories about the Company, press releases issued by the Company
and media reports about the Company. It is believed that
substantial evidentiary support will exist for the allegations set
forth herein after a reasonable opportunity for discovery.
PRAYER FOR RELIEF
WHEREFORE, plaintiff prays for judgment as follows:
1. Declaring this action to be a proper class action
pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil
Procedure on behalf of the Class defined herein;
2. Awarding plaintiff and the members of the Class
compensatory damages;
3. Awarding plaintiff and the members of the Class pre-
judgment and post-judgment interest, as well as reasonable
attorneys' fees, expert witness fees and other costs;
4. Awarding extraordinary, equitable and/or injunctive
relief as permitted by law, equity and the federal statutory
provisions sued hereunder and any appropriate state law remedies;
and
5. Awarding such other relief as this Court may deem
just and proper.
JURY DEMAND
Plaintiff demands a trial by jury.
NESS MOTLEY LOADHOLT
RICHARDSON & POOLE
_____________________________
Terry E. Richardson, Jr.
William Cook
2202 Jackson Street
P.O. Box 365
Barnwell, SC 29812
(803) 259-9900
BERGER & MONTAGUE, P.C.
____________________________
Todd S. Collins
Arthur Stock
1622 Locust Street
Philadelphia, PA 19103
(215) 875-3000
THE OLSEN LAW FIRM
______________________________
Kurt Olsen
2121 K Street, N.W.
Suite 800
Washington, DC 20037
(202) 261-3553
LEVY and LEVY
_____________________________
Morris J. Levy
Stephen G. Levy
445 Northern Boulevard
Great Neck, NY 11021
Attorneys for Plaintiff and
the Class
Source: File to epost from Berger & Montague, P.C.