Parviz Izadjoo, Et Al. V. Helix Energy Solutions Group, Inc., Et Al. 15-CV
Case 4:15-cv-02213 Document 23 Filed in TXSD on 03/14/16 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION PARVIZ IZADJOO, Individually and on behalf of all others similarly situated, Plaintiff, Civ. Action No. : 4:15-CV-2213 v. OWEN KRATZ, and HELIX ENERGY SOLUTIONS JURY TRIAL DEMANDED GROUP, INC. Defendants. AMENDED CLASS ACTION COMPLAINT Lead Plaintiffs Steven Strassberg (“Strassberg”) and Bruce R. Siegfried (“Siegfried” and together with Strassberg, “Plaintiffs”), by and through their counsel, individually and on behalf of all others similarly situated, for their Amended Class Action Complaint against defendants Helix Energy Solutions Group, Inc. (“Helix” or “Company”) Owen Kratz (“Kratz”) Anthony Tripodo (“Tripodo”), and Clifford V. Chamblee (“Chamblee”), allege the following based upon personal knowledge as to themselves and their own acts, and information and belief as to all other matters, based upon, inter alia, the investigation conducted by and through their attorneys, which included, among other things, conversations with witnesses, 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 Helix Energy Solutions Group, Inc. (“Helix” or “Company”), analysts’ reports and advisories about the Company, and information readily obtainable on the Internet. Plaintiffs believe that substantial Case 4:15-cv-02213 Document 23 Filed in TXSD on
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