COMPLAINT for VIOLATIONS of the FEDERAL SECURITIES LAWS Plaintiff ______(“Plaintiff”), Individually and on Behalf of All Others Similarly Situated
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO YOUNGSTOWN DIVISION ______, Individually and on Behalf of All ) No. Others Similarly Situated, ) ) Judge Plaintiff, ) ) CLASS ACTION vs. ) ) LORDSTOWN MOTORS CORP., STEPHEN ) S. BURNS, JULIO C. RODRIGUEZ, RICH ) SCHMIDT and MICHAEL FABIAN, ) ) Defendants. ) ) DEMAND FOR JURY TRIAL COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS Plaintiff ______(“plaintiff”), individually and on behalf of all others similarly situated, by plaintiff’s undersigned attorneys, for plaintiff’s complaint against defendants, alleges the following based upon personal knowledge as to plaintiff and plaintiff’s own acts and upon information and belief as to all other matters based on the investigation conducted by and through plaintiff’s attorneys, which included, among other things, a review of the U.S. Securities and Exchange Commission (“SEC”) filings by Lordstown Motors Corp. (“Lordstown”), along with its predecessor, DiamondPeak Holdings Corp. (“DiamondPeak,” collectively, “Lordstown” or the “Company”), Company press releases and media reports about the Company. Plaintiff believes that substantial additional evidentiary support will exist for the allegations set forth herein after a reasonable opportunity for discovery. NATURE OF THE ACTION 1. This is a securities fraud class action on behalf of all purchasers of the publicly traded shares of Class A common stock and warrants to purchase the Class A common stock of Lordstown and/or DiamondPeak between August 3, 2020 and March 24, 2021, inclusive, and all holders of DiamondPeak common stock entitled to participate in the August 22, 2020 shareholder vote on the merger with Lordstown (the “Class Period”), seeking to pursue remedies under the Securities Exchange Act of 1934 (“1934 Act”).
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