IMPERIAL SUGAR COMPANY § Civil Action No
Case 4:11-cv-03250 Document 40 Filed in TXSD on 03/22/12 Page 1 of 81 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re IMPERIAL SUGAR COMPANY § Civil Action No. 4:11-cv-03250-LHR SECURITIES LITIGATION § § JURY TRIAL DEMANDED JUDGE LEE H. ROSENTHAL CONSOLIDATED CLASS ACTION COMPLAINT Case 4:11-cv-03250 Document 40 Filed in TXSD on 03/22/12 Page 2 of 81 By and through its undersigned counsel, Lead Plaintiff Carpenters Pension Fund of Illinois (“Lead Plaintiff” or “Plaintiff”) alleges the following against Defendants Imperial Sugar Company (“Imperial” or the “Company”), John C. Sheptor (“Sheptor”), and Harold P. Mechler (“Mechler”) (collectively, “Defendants”), upon personal knowledge as to those allegations concerning Plaintiff and, as to all other matters, upon the investigation of counsel, which included, without limitation: (a) review and analysis of public filings made by Imperial and other related parties and non-parties with the Securities and Exchange Commission (“SEC”); (b) review and analysis of press releases and other publications disseminated by certain of the Defendants and other related non-parties; (c) review of news articles and shareholder communications; (d) review of other publicly available information concerning Imperial, the other Defendants, and related non-parties; (e) consultation with experts; and (f) interviews with factual sources, including individuals formerly employed by Imperial. I. SUMMARY OF THE ACTION 1. This is a federal securities class action against Imperial and certain of its officers and/or directors for violations of the federal securities laws. Plaintiff brings this action on behalf of itself and the Class under the Securities Exchange Act of 1934 (the “Exchange Act”).