BASIS OF ALLEGATIONS
Plaintiffs have alleged the foregoing on information and belief, based upon the investigation of thier counsel, which included an extensive review of documents and numerous interviews of persons with knowledge. Among other things, plaintiffs' counsel has obtained sworn affidavits from at least ten (10) witnesses supporting substantially all of the factual allegations set forth in this pleading including the declarations from Sherri Cuono, Peter G. Demos, Jr., Shelley Felix, Thomas H Ferneau, Edward Gallagher, Mara Hochman, Kain Johnson, and Richard Miller. Plaintiffs believe that substantial evidentiary support exists for all of the allegations in this complaint.
PRAYER FOR RELIEF
WHEREFORE, plaintiffs and the Class pray for judegement against defendants, and each of them, as follows:
1. Declaring this action to be a proper class action on behalf of the Class defined herein'
2. Awarding plaintiffs and the members of the Class compensatory and/or punitive damages, according to proof;
3. Awarding plaintiffs and the members of the Class prejudgement and post - judgement interest, as well as reasonable attorneys' fees, expert witness fees and other costs'
4. Declaring that defendants hold any property of (or misappropriated from ) WWWC in trust for the benefit of plaintiffs and the Class, and compelling defendants to convey any such property or assets currently in their possession;
5. Ordering the defendants to account for all monies owed to WWWC and the Class;
6. Granting such other relief as the Court deems just and proper.
Respectfully submitted,
LAW OFFICES OF JOHN N. ZARIAN
JOHN N. ZARIAN |
