United States District Court Western District of Louisiana Lake Charles Division
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION ) __________, Individually and on Behalf ) of all Others Similarly Situated, ) ) CIVIL ACTION NO. ________ Plaintiff, ) ) vs. ) CLASS ACTION COMPLAINT ) FOR VIOLATIONS OF ) CHRISTOPHER MEAUX, DAVID FEDERAL SECURITIES LAWS ) PRINGLE, JEFF YURECKO, TILMAN J. ) FERTITTA, RICHARD HANDLER, WAITR ) HOLDINGS, INC. f/k/a LANDCADIA ) HOLDINGS, INC., JEFFERIES FINANCIAL ) GROUP, INC., and JEFFERIES, LLC, ) JURY TRIAL DEMANDED Defendants. ) ) This action is brought as a class action by Plaintiff on behalf of himself and all others similarly situated against Waitr Holdings, Inc. (“Waitr” or the “Company”) and certain officers and directors and other individuals and entities associated with the Company for their violations of Sections 11, 12 and 15 of the 1933 Securities Act, 15 U.S.C. §§ 77a, et seq. (the “Securities Act”), and/or Sections 10(b), 14(a) and 20(a) of the Securities Exchange Act of 1934, 15 U.S.C. §§ 78j(b) and 78t(a), (the “Exchange Act”) and Rule 10b-5 promulgated thereunder by the U.S. Securities Exchange Commission (the “SEC”) (17 C.F.R. § 240.10b-5), (A) in connection with Old-Waitr’s (defined below) going public transaction and business combination on November 15, 2018 with Landcadia Holdings, Inc. (“Landcadia”) (the “Going Public Transaction”), and the follow-on secondary offering on May 16, 2019 (the “Secondary Offering”) of Waitr securities (the “Negligence” and/or “Strict Liability” claims), and (B) for making materially false and misleading statements that were published into the market from May 17, 2018 to August 8, 2019 ( the “Class Period”), that Defendants knew and/or recklessly disregarded were materially false and misleading when made and/or that omitted information necessary to make Defendants’ statements, in light of such omissions, true, accurate and reliable.
[Show full text]