WEISS & YOURMAN
KEVIN J. YOURMAN (147159)
MICHELLE R. JOHNSON (181789)
10940 Wilshire Blvd.
24th Floor
Los Angeles, CA 90024
Telephone: 310/208-2800

WEISS & YOURMAN
JOSEPH H. WEISS
551 Fifth Avenue, Suite 1600
New York, NY 10176
Telephone: 212/682-3025

Attorneys for Plaintiff


UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA



MIKE DESIDERIO, On behalf of Himself and All Others Similarly situated,

Plaintiff,

vs.


MOTORCAR PARTS & ACCESSORIES, INC., RICHARD MARKS and MEL MARKS,

Defendants.
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CASE NO.

CLASS ACTION

CLASS ACTION COMPLAINT
FOR VIOLATION OF THE
FEDERAL SECURITIES LAWS

JURY TRIAL DEMANDED



Plaintiff individually and on behalf of all others similarly situated, by and through his attorneys, alleges the following upon information and belief, except those allegations concerning himself, which are alleged upon personal knowledge. Plaintiff's information and belief are based on the investigation made by and through plaintiff's counsel.

I. PRELIMINARY STATEMENT


1. For over three years, defendants have concealed from plaintiff, class members, and the investing public the fact that they have continuously been committing gross violations of the federal securities laws, including misleading the public as to the financial and business conditions of defendant Motorcar Parts & Accessories, Incorporated ("Motorcar" or the "Company").

2. Specifically, as stated in greater detail below, defendants concealed from their shareholders accounting irregularities which have caused an extraordinary overstatement of the Company's earnings over the past three years. In addition, throughout the Class Period (as defined below) defendants continuously disseminated materially false and misleading statements regarding the Company's current financial performance and future business prospects.

3. As a result of defendants' deceptive and illegal conduct, plaintiff and other class members purchased their Motorcar shares at grossly inflated prices. Had plaintiff and the other class members been aware of the true condition of Motorcar, they would not have purchased their Motorcar shares, or at least not at the inflated prices at which they purchased those shares.

II. JURISDICTION AND VENUE


4. This court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §1331 and §1337, and Section 27 of the Securities Exchange Act of 1934 (the "Exchange Act") (15 U.S.C. §78aa).

5. This action arises under Sections 10(b) and 20(a) of the Exchange Act and Rule 10b-5 promulgated thereunder (17 C.F.R. §240.10b-5).

6. Venue is proper in this district pursuant to Section 27 of the Exchange Act and 28 U.S.C. §1391(b). Motorcar is headquartered in this district, at 2727 Maricopa Street, Torrance, California, 90503, and the acts charged herein, including the dissemination of materially false and misleading information, occurred in this district.

7. In connection with the acts alleged in this complaint, the defendants, directly or indirectly, used the means and instrumentalities of interstate commerce, including, but not limited to, the mails, interstate telephone communications and the facilities of the national securities markets.

III. PARTIES


8. Plaintiff Mike Desiderio purchased 1000 shares of Motorcar common stock on February 25, 1999 and was damaged thereby.

9. Defendant Motorcar is a leading manufacturer and distributor of replacement alternators and starters for cars and light trucks.

10. Defendant Richard Marks is President and Chief Operating Officer of Motorcar. Defendant Richard Marks sold 150,000 shares of Motorcar stock in the Company's November, 1997 offering, for nearly $2.5 million.

11. Defendant Mel Marks founded Motorcar in 1968. He has served as the Company's Chief Executive Officer and Chairman of the Board of Directors since that time. Defendant Mel Marks sold 100,000 shares of Motorcar stock in the Company's November, 1997 offering, for over $1.6 million.

12. Defendants Richard Marks and Mel Marks (the "Individual Defendants") were at relevant times during the Class Period controlling persons of Motorcar within the meaning of Section 20(a) of the Exchange Act. In addition, the Individual Defendants had the power and influence, and exercised such power and influence, to cause Motorcar to engage in the unlawful practices complained of herein. Because of their executive, managerial and/or directorial positions with Motorcar, the Individual Defendants had access to the adverse, non-public information about the business, finances and future business prospects of Motorcar as particularized herein and acted to misrepresent, misstate or conceal such information from plaintiff, class members and the investing public.

13. The Individual Defendants participated in the wrongdoing complained of herein in order to, among other things, inflate and maintain the price of the common stock of the Company, and conceal the adverse facts concerning the Company's operations, businesses, management, financial condition and future prospects, so that they could, among other things, (i) protect and enhance their positions as officers and/or directors of Motorcar and the substantial compensation and prestige they obtained thereby; (ii) enhance the value of their personal holdings of Motorcar common stock, and.(iii) dispose of millions of dollars worth of Motorcar stock.

14. Defendants are liable, jointly and severally, as direct participants in the wrongs complained of herein. Defendants had a duty to promptly disseminate accurate and truthful information with respect to Motorcar's business, operations, financial condition and future prospects or to cause and direct that such information be disseminated so that the market price of Motorcar stock would be based on truthful and accurate information.

15. Each of the defendants knew of the fact that the illegal acts and practices and misleading financial statements and omissions described herein would adversely affect the integrity of the market for Motorcar common stock and would artificially inflate or maintain the price of those securities. Each of the defendants, by acting as herein described, did so knowingly and thereby constituted a fraud and deceit upon plaintiff and members of the Class plaintiff seeks to represent.

IV. PLAINTIFF'S CLASS ACTION ALLEGATIONS


16. Plaintiff brings this action as a class action pursuant to Rule 23(a) and (b)(3) of the Federal Rules of Civil Procedure on behalf of a Class consisting of all persons and entities who purchased or otherwise acquired Motorcar common stock from August 4, 1996 through August 1, 1999, inclusive (the "Class Period"), and who were damaged thereby. Excluded from the Class are the defendants, officers and directors of the Company, members of their immediate families, and their legal representatives, heirs, successors or assigns and any entity in which defendants have or had a controlling interest.

17. During the Class Period, thousands of shares of common stock of Motorcar were traded on an efficient and developed securities market. Thousands of brokers nationwide have access to trading information about Motorcar through the system. Within minutes of any transaction taking place, this system displays the most recent trades and prices.

18. The members of the Class are so numerous that joinder of all members is impracticable. While the exact number of Class members is unknown to plaintiff at this time and can only be ascertained through appropriate discovery, plaintiff believes that there are hundreds, if not thousands, of members of the Class. As of February 9, 1999, there were approximately 6.5 million shares of Motorcar common stock outstanding and actively traded on the NASDAQ, an efficient market.

19. Plaintiff's claims are typical of the claims of the members of the Class as all members of the Class are similarly affected by defendants' wrongful conduct in violation of federal law that is complained of herein.

20. 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. Plaintiff has no interests that are adverse or antagonistic to those of the Class.

21. A class action is superior to other available methods for the fair and efficient adjudication of this controversy. Because the damages suffered by many individual Class members may be relatively small, the expense and burden of individual litigation make it virtually impossible for the Class members to individually seek redress for the wrongful conduct alleged herein.

22. Common questions of law and fact exist as to all members of the Class and predominate over any questions affecting solely individual members of the Class. Among the questions of law and fact common to the Class are:

(i ) whether the federal securities laws were violated by defendants' acts as alleged herein;

(ii) whether defendants participated in and pursued the common course of conduct complained of herein;

(iii) whether documents, press releases and other statements disseminated to the investing public and the Company's shareholders during the Class Period misrepresented material facts about the business, management, products, markets, financial condition, and business prospects of Motorcar;

(v) whether defendants failed to correct prior statements when subsequent events rendered those prior statements untrue or inaccurate;

(vi) whether defendants acted willfully and knowingly in misrepresenting and/or omitting to state material facts;

(vii) whether the market price of Motorcar's common stock during the Class Period was artificially inflated due to the misrepresentations and/or non-disclosures complained of herein; and

(viii) whether the members of the Class have sustained damages, and, if so, what is the proper measure thereof.

23. Plaintiff will rely, in part, upon the presumption of reliance established by the fraud-on-the-market doctrine in that:

a. defendants made public misrepresentations or omitted material facts during the Class Period, as alleged herein;

b. the misrepresentations and/or omissions were material;

c. Motorcar's common stock was traded in an efficient market;

d. The misrepresentations and/or omissions alleged tended to induce reasonable investors to misjudge the value of Motorcar shares; and

e. Plaintiff and members of the Class acquired their shares between the time defendants made the misrepresentations and/or omissions and the time the truth was revealed, without knowledge of the falsity of the misrepresentations.

24. Based upon the foregoing, plaintiff and members of the Class are entitled to a presumption of reliance upon the integrity of the market for, at least, the purposes of class certification, as well as for ultimate proof of the claims on their merit. Similarly, plaintiff and members of the Class are entitled to a presumption of reliance with respect to the omissions alleged herein.

25. Plaintiff envisions no difficulty in the management of this litigation as a class action.

BACKGROUND AND ALLEGATIONS OF FRAUD


Motorcar, a New York corporation, was founded in 1968 by Defendant Mel Marks, who has served as CEO and Chairman of the Board since that time. Defendant Richard Marks, Mel Marks' son, joined Motorcar in 1979 and has served as the Company's President and Chief Operating Officer since 1987. Both Individual Defendants are major shareholders in the Company, and both of them are eligible for bonuses under the Executive and Key Employee Incentive Bonus Plan, under which no bonuses will be awarded unless the Company's earnings exceed the prior fiscal year's earnings by a minimum of 20%. Maximum bonus payments are only payable if fiscal year earnings exceed the prior fiscal year's earnings by at least 40%. In addition, both Individual Defendants were major shareholders in two foreign companies acquired by Motorcar in April, 1997 in a stock for stock merger agreement. Between them, the Individual Defendants owned 70% of the foreign subsidiaries, MVR Products Co. PTE, Ltd. ("MVR") and Unijoh Sdn, Bhd ("Unijoh").

26. On May 20, 1996, Motorcar reported record sales and earnings for the fifth consecutive year. The Company reported a net income increase of 127% and a net sales increase of 59% for the year ended March 31, 1996, and increases of 137% and 58% in net income and net sales, respectively, for the quarter:

27. On August 1, 1996, Motorcar again announced record revenue and earnings. The Company reported a 97% increase in net income and a 58% increase in net sales for the quarter ended June 30, 1996, resulting in a correspondingly significant increase in earnings per share:


28. On November 13, 1996, Motorcar reported record sales and earnings for the six month and three month periods ended September 30, 1996. The announced six month net income and net sales increases were 79% and 45%, respectively, and the three month net income and net sales increases were 67% and 36%, respectively:


29. On February 4, 1997, Motorcar announced record sales and earnings figures for the nine months and the quarter ended December 31, 1996. The figures included significant increases in earnings per share as well as a 63% increase in net income ,and a 38% increase in net sales, a 43% increase in net income and a 28% increase in net sales, respectively:


30. On May 25, 1997, Motorcar reported record sales and earnings for the sixth consecutive year. The Company reported a 30% increase in net income and a 27% increase in net sales for the quarter ended March 31, 1997, as well as a 52% increase in net income and a 35% increase in net sales for fiscal year 1997:


31. The above statements were false and misleading when made because the defendants knew that the Company's revenue recognition practices did not comply with Generally Accepted Accounting Principles ("GAAP"), that its internal financial controls were seriously lacking, and that, as a result, revenue was overstated.

32. In April, 1997, Motorcar acquired MVR and Unijoh in a stock for stock merger. The common stock issued in connection with the merger was subject to a lock-up arrangement with the Company releasing for public resale one-fourth of the shares on each of the first four anniversaries of the acquisition. The Individual Defendants together owned 70% of both MVR and Unijoh.
33. On August 12, 1997, Motorcar announced results for the first quarter ended June 30, 1997, including an increase in net sales of 18.6% and an increase in net income of 12.9%. Specifically:


34. In an October 16, 1997 PR Newswire release, the Company announced it had filed a registration statement with the Securities and Exchange Commission for a public offering of 1.5 million shares of common stock, with Smith Barney Inc. and A.G. Edwards & Sons, Inc. to act as managing underwriters in the offering.

35. Motorcar reported second quarter and six months ended September 30, 1997 results on October 30, 1997. The results showed six months figures with a net sales increase of 27% and a net income increase of 23.9%, and quarter increases of 34.2% in net sales and 32% in net income, both figures resulting in dramatic increases in per share earnings:

36. On November 19, 1997, the Company announced it had completed its $ 19.8 million public equity offering, after expenses, selling 1.3 million shares of its common stock.

37. On January 26, 1998, Motorcar announced strong increases for the previous third quarter and nine months, including jumps in net sales of 35.3 % and in net income of 17.8% for the quarter, and a net sales increase of 30% and a net income increase of 21.6% for the nine months ended December 31, 1997:


38. On June 3, 1998, Motorcar announced fourth quarter and year end results for fiscal year 1998. The Company reported a net sales increase of 30% and a net income increase of 14% for the quarter, and a net sales increase of 30% and a net income increase of 19% for the year:


39. The statements in ¶¶ 33, 35, 37 and 38 above were false and misleading when made because the defendants knew that the Company's revenue recognition practices did not comply with Generally Accepted Accounting Principles ("GAAP"), that its internal financial controls were seriously lacking, and that, as a result, revenue was overstated.

40. On August 10, 1998, the Company reported first quarter results for fiscal year 1999, including a net sales increase of 42% and a net income increase of 38%:

41. On November 10, 1998, Motorcar announced results for the second quarter and six months ended September 30, 1998. The Company reported a net sales increase of 32.8.5% for the six months, and a net sales increase of 25.4% and net income increase of 5.9% for the quarter:


42. Third quarter 1999 and nine months ended December 31, 1998 results were announced February 3, 1999. The Company reported an increase in net sales of 20.5% and a net income decrease of 4.5% for the nine months, and no change in the net sales and a decrease of 44.7% in net income for the quarter. The decreased net income and flat net sales numbers were attributed to a "re-calendarization of purchasing patterns by a significant customer" and the increased number of outstanding shares resulting from the public offering the previous year:


43. The statements in ¶¶ 40-42 above were false and misleading when made because the defendants knew that the Company's revenue recognition practices did not comply with Generally Accepted Accounting Principles ("GAAP"), that its internal financial controls were seriously lacking, and that, as a result, revenue was overstated.

THE TRUTH DISCLOSED


44. Contrary to all of the very positive news and financial success that defendants had been disseminating to the investment community, on May 24, 1999, the Company shocked the investment community with the announcement that it expected to report a significant loss for the fourth quarter 1999, and that it might report a loss for the entire fiscal year. The market's reaction was swift and severe. Motorcar shares closed at $7 per share on extraordinary trading of over 400,000 shares, down over 36% from the previous day's closing price of $11 per share and down over 65% from Motorcar's class period high of $20.5 per share. Over the next few days, another 645,000 shares changed hands, trading as low as $5 3/4 per share.

45. Unfortunately for Motorcar investors, the May 24, 1999 announcement was only the tip of the iceberg. In a press release issued at 11:51 p.m. Eastern Standard Time on Sunday, August 1, 1999 over the PR Newswire , defendants disclosed a "comprehensive investigation" of accounting irregularities that had already been ongoing for some time. Among other things, the Company revealed that, as a result of the investigation, it expected to restate its previously reported financial results for fiscal 1997, 1998, and the first nine months of fiscal 1999. The Company further revealed that its independent auditors, Richard A. Eisner & Company, LLP, had withdrawn their opinion on the Company's financial statements for the three years ended March 31, 1998, that Chairman of the Board of Directors Mel Marks had stepped down as Motorcar's Chief Executive Officer and that the net loss for fiscal 1999 had put it in violation of "certain financial compliance covenants contained in the Company's revolving credit facility". Specifically, the article stated that:

* * *

(Emphasis added).

46. Trading of Motorcar stock was halted by the Nasdaq at 8:30 a.m. Eastern Time on Monday, August 2, 1999, at a last-sale price of $5 5/32.

VII. UNDISCLOSED FACTS


47. Defendants' public statements and others of similar import described above were materially false, misleading and lacking in reasonable basis in that defendants failed to disclose, inter alia, that:
(a) revenue, earnings and net income reported were materially overstated;
(b) the Company lacked a system of internal controls designed to ensure that the revenue, earnings, and net income reported were materially correct; and
(c) there was not a reasonable basis for the Company's statements, made during the Class Period, that the Company's financial growth was excellent, since irregularities in accounting would prevent the Company from achieving its goals of financial and business growth.

48. As a result of Motorcar's irregular accounting activities, defendants have overstated the revenues and net income of the Company throughout fiscal 1997, fiscal 1998 and most of fiscal 1999.

49. In ignorance of the adverse facts concerning Motorcar's true business and financial condition, which were concealed by defendants, plaintiff and other members of the Class purchased Motorcar common stock at artificially high prices, relying upon the statements made and/or upon the integrity of the market and were damaged thereby.

50. Had plaintiff and the other members of the Class known of the materially adverse information not disclosed by the defendants, they would not have purchased Motorcar common stock at the artificially inflated prices that they did, if at all.

COUNT I

(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Promulgated Thereunder)



51. Plaintiff repeats and realleges the allegations above as though fully set forth herein. During the Class Period, the defendants, and each of them, carried out a plan, scheme and course of conduct which was intended to and, throughout the Class Period, did: (i) deceive the investing public, including plaintiff and the other class members, as alleged herein; (ii) artificially inflate and maintain the market price of Motorcar; and (iii) cause plaintiff and other members of the Class to purchase Motorcar securities at inflated prices. In furtherance of this unlawful scheme, plan and course of conduct, defendants, and each of them, took the actions set forth herein.

52. Defendants (a) employed devices, schemes, and artifices to defraud; (b) made untrue statements of material fact and/or omitted to state material facts necessary to make the statements not misleading; and (c) engaged in acts, practices, and a course of business which operated as a fraud and deceit upon the purchasers of the Company's stock in an effort to maintain artificially high market prices for Motorcar securities in violation of section 10(b) of the Exchange Act and
Rule 10b-5.

53. The statements made by defendants during the Class Period were materially false and misleading because at the time they were made, the Company and persons acting as corporate officers knew, but failed to disclose, the matters set forth herein.

54. In ignorance of the artificially high market prices of Motorcar's publicly traded securities, and relying directly on defendants or indirectly on the false and misleading statements made by defendants, upon the integrity of the market in which the securities trade, on the integrity of the regulatory process and the truth of representations made to appropriate agencies throughout the Class Period and/or on the absence of material adverse information that was known to defendants but not disclosed in public statements by defendants during the Class Period, plaintiff and the other members of the Class acquired Motorcar securities during the Class Period at artificially high prices and were damaged thereby.

55. Had plaintiff and the other members of the Class and the marketplace known of the true financial condition, business prospects and character of leadership of Motorcar which were not disclosed by defendants, plaintiff and other members of the Class would not have purchased or otherwise acquired their Motorcar securities during the Class Period, or would not have done so at the artificially inflated prices which they paid. Hence, plaintiff and the Class were damaged by defendants' violations of Section 10(b) and Rule 10b-5.

COUNT II

(Violation of Section 20(a) of the Exchange Act Against Individual Defendants)


56. Plaintiff incorporates by reference the above paragraphs above as if set forth fully herein. This Count is asserted against the Individual Defendants.

57. The Individual Defendants acted as controlling persons of Motorcar within the meaning of Section 20 of the Exchange Act as alleged herein. By reasons of their executive, managerial and/or directorial positions with Motorcar, the Individual Defendants had the power and authority to cause the Company to engage in the wrongful conduct complained of herein.

58. By reasons of the aforementioned wrongful conduct, the Individual Defendants are liable pursuant to Section 20(a) of the Exchange Act. As a direct and proximate result of their wrongful conduct, plaintiff and the other members of the Class suffered damages in connection with purchasing the Company's securities during the Class period.


WHEREFORE, plaintiff prays for relief and judgment, as follows:

(i) Determining that this action is a proper class action, certifying plaintiff as class representative under Rule 23 of the Federal Rules of Civil Procedure and his counsel as class counsel;

(ii) Awarding compensatory damages in favor of plaintiff and the other class members against all defendants, jointly and severally, for all damages sustained as a result of defendants' wrongdoing, in an amount to be proven at trial, including interest thereon;

(iii) Awarding plaintiff and the Class their reasonable costs and expenses incurred in this action, including counsel fees and expert fees; and

(iv) Such other and further relief as the Court may deem just and proper.

DATED: August 4, 1999
WEISS & YOURMAN
KEVIN J. YOURMAN
MICHELLE R. JOHNSON



By: _________________________
Kevin J. Yourman
10940 Wilshire Blvd.
24th Floor
Los Angeles, CA 90024
Telephone: 310/208-2800

WEISS & YOURMAN
JOSEPH H. WEISS
551 Fifth Avenue, Suite 1600
New York, NY 10176
Telephone: 212/682-3025

STULL, STULL & BRODY
MICHAEL D. BRAUN
10940 Wilshire Blvd.
Suite 2300
Los Angeles, CA 90024
Telephone: 310/209-2468

Attorneys for Plaintiff




JURY TRIAL DEMANDED


Plaintiff hereby demands a trial by jury pursuant to Rule 38(b) of the Federal Rules of Procedure.

DATED: August 4, 1999
WEISS & YOURMAN
KEVIN J. YOURMAN
MICHELLE R. JOHNSON


By: _________________________
Kevin J. Yourman
10940 Wilshire Blvd.
24th Floor
Los Angeles, CA 90024
Telephone: 310/208-2800

WEISS & YOURMAN
JOSEPH H. WEISS
551 Fifth Avenue, Suite 1600
New York, NY 10176
Telephone: 212/682-3025

STULL, STULL & BRODY
MICHAEL D. BRAUN
10940 Wilshire Blvd.
Suite 2300
Los Angeles, CA 90024
Telephone: 310/209-2468


Attorneys for Plaintiff




CLASS ACTION COMPLAINT FOR THE VIOLATION OF
FEDERAL SECURITIES LAWS

1 Emphasis added unless otherwise indicated.

 


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