First Amended Complaint Case Study

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I. INTRODUCTION

1. This First Amended Complaint contains causes of action for Federal violations of Sections 20 (b) 20 (d) (1) and 22(a) of the Securities Act of 1933 ("Securities Act of 1933 ("Securities Act"), 15 U.S.C. § 77t(b), 77t(d)(1), and 77v(a), and Sections 21(d)(1) 21(d)(3)(A), 21)e), and 27 of the Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. § 78u(d)(1), 78u(d)(3)(A), and 78u(e), and 78aa. The first cause of action pertains to Defendant, Gerard Warrens, individually. 2. The First Amended Complaint also contains a cause of action for violations of A.R.S. § 44-1801(26) which defines "offers to sell" or "offers for sale" pursuant to A.R.S. § 44-1801(15) and sales as defined pursuant to A.R.S. § 44-1801(21) and A.R.S. § 44-1841 requiring registration of any dealer or salesperson from
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11. The First Amended Complaint illustraes with particularity how each of the Defendants ' through the use of subterfuge, false statements, and material misrepresentations made by WARRENS, individually and as the sole shareholder, director, officer and manager of each of the foreign co-defendants, conducted business in the State of Arizona, resulting in damages to Plaintiff, for failure to pay wages, FICA, withholding, unemployment insurance and other benefits due him as an Employee of STEALTH SOFTWARE, L.L.C., and in violation of the Fair Labor Standards Act ("FLSA"), Arizona Labor Law ("AZL") and under federal and state labor regulations. 12. The First Amended Complaint illustrates with particularity, that as a direct result of the policies, practices, customs, material misrepresentations, falsehoods, and fraudulent schemes of Defendants ', Plaintiff HOOPER has been damaged. All of the defendant WARRENS actions and omissions, including but not limited to his non exempt status under federal and state security laws, has damaged HOOPER, individually. 13. At all relevant times, plaintiff, STEVEN HOOPER, was and remains a domiciliary of the State

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