Case 2:18-cv-01758-APG-PAL Document 34 Filed 10/22/18 Page 1 of 78 1 Patrick R. Leverty LEVERTY & ASSOCIATES LAW CHTD 2 832 Willow Street 3 Reno, Nevada 89502 Telephone: (775) 322-6636 4 Facsimile: (213) 322-3953 5 Email:
[email protected] 6 Liaison Counsel for Plaintiffs 7 8 [additional counsel listed on signature page] 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 DANIEL CHECKMAN, Individually Case No: 18-CV-01758-APG-PAL 12 And On Behalf Of All Others Similarly 13 Situated, AMENDED CLASS ACTION COMPLAINT FOR VIOLATIONS 14 Plaintiffs, OF THE FEDERAL SECURITIES 15 LAWS v. 16 JURY TRIAL DEMANDED 17 ALLEGIANT TRAVEL COMPANY, 18 MAURICE J. GALLAGHER, JR., SCOTT SHELDON, STEVEN E. 19 HARFST, and JUDE I. BRICKER, 20 Defendants. 21 22 23 Lead Plaintiff Charles Brendon and Named Plaintiff Daniel Checkman 24 (collectively, “Plaintiffs”), individually and on behalf of all other persons similarly 25 situated, by Plaintiffs’ undersigned attorneys, for Plaintiffs’ complaint against 26 Defendants (defined below), alleges the following based upon personal knowledge as 27 to Plaintiffs and Plaintiffs’ own acts, and information and belief as to all other 28 matters, based upon, inter alia, the investigation conducted by and through Plaintiffs’ - 1 - Amended Class Action Complaint for Violations of the Federal Securities Laws Case 2:18-cv-01758-APG-PAL Document 34 Filed 10/22/18 Page 2 of 78 1 attorneys, which included, among other things, a review of the Defendants’ public 2 documents, conference calls and announcements made by Defendants, United States 3 Securities and Exchange Commission (“SEC”) filings, wire and press releases 4 published by and regarding Allegiant Travel Company (“Allegiant” or the 5 “Company”), analysts’ reports and advisories about the Company, information 6 readily obtainable on the Internet, and interviews with former employees of 7 Allegiant.