Stefan Sachsenberg, Et Al. V. IRSA Inversiones Y Representaciones
Case 1:16-cv-05743-VSB Document 24 Filed 02/13/17 Page 1 of 44 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK STEFAN SACHSENBERG, INDIVIDUALLY No. 16-cv-5743-VSB AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, AMENDED CLASS ACTION COMPLAINT FOR VIOLATIONS OF PLAINTIFF, FEDERAL SECURITIES LAWS VS. JURY TRIAL DEMANDED IRSA INVERSIONES Y REPRESENTACIONES SOCIEDAD ANÓNIMA, EDUARDO SERGIO ELSZTAIN, ALEJANDRO GUSTAVO ELSZTAIN, CRESUD SOCIEDAD ANÓNIMA COMERCIAL, INMOBILIARIA, FINANCIERA Y AGROPECUARIA, SAÚL ZANG, and MATÍAS IVÁN GAIVIRONSKY, DEFENDANTS. Plaintiff Stefan Sachsenberg (“Plaintiff”), individually and on behalf of all other persons similarly situated, by his undersigned attorneys, for his complaint against Defendants, alleges the following based upon personal knowledge as to himself and his own acts, and information and belief as to all other matters, based upon, inter alia, the investigation conducted by and through his attorneys, which included, among other things, a review of the defendants’ public documents, conference calls and announcements made by defendants, United States Securities and Exchange Commission (“SEC”) filings, wire and press releases published by and regarding IRSA Inversiones y Representaciones Sociedad Anónima (“IRSA” or the “Company”), analysts’ reports and advisories about the Company, and information readily obtainable on the Internet. Plaintiff believes that substantial evidentiary support will exist for the allegations set forth herein after a reasonable opportunity for discovery. 1 Case 1:16-cv-05743-VSB Document 24 Filed 02/13/17 Page 2 of 44 NATURE OF THE ACTION 1. This is a federal securities class action on behalf of a Class, consisting of all persons other than Defendants who purchased or otherwise acquired IRSA Global Depositary Receipts (“GDRs”) between February 11, 2015 and December 30, 2015, inclusive (the “Class Period”).
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