Case3:13-cv-05216-CRB Document1 Filed11/08/13 Page1 of 40 1 LIONEL Z. GLANCY (#134180) 2 MICHAEL GOLDBERG (#188669) ROBERT V. PRONGAY (#270796) 3 GLANCY BINKOW & GOLDBERG LLP 1925 Century Park East, Suite 2100 4 Los Angeles, California 90067 5 Telephone: (310) 201-9150 Facsimile: (310) 201-9160 6 E-mail:
[email protected] [email protected] 7
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[email protected] 9 POMERANTZ GROSSMAN HUFFORD DAHSLTROM & GROSS LLP 10 Jeremy A. Lieberman Matthew L. Tuccillo 11 Lesley F. Portnoy 600 Third Avenue, 20th Floor 12 New York, New York 10016 Telephone: (212) 661-1100 13 Facsimile: (212) 661-8665 Email:
[email protected] 14 Attorneys for Plaintiff 15 [Additional Counsel on signature page] 16 17 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 18 19 ROBERT RAHIMI, Individually and on Behalf ) Case No.: of All Other Persons Similarly Situated, ) 20 ) 21 Plaintiff, ) CLASS ACTION COMPLAINT ) 22 v. 23 JURY TRIAL DEMANDED 24 TESLA MOTORS, INC., ELON MUSK, and DEEPAK AHUJA, 25 Defendants 26 27 28 Case3:13-cv-05216-CRB Document1 Filed11/08/13 Page2 of 40 Plaintiff Robert Rahimi (“Plaintiff”), individually and on behalf of all other persons similarly 1 2 situated, by his undersigned attorneys, for his complaint against Defendants, alleges the following 3 based upon personal knowledge as to himself and his own acts, and information and belief as to all 4 other matters, based upon, inter alia, the investigation conducted by and through his attorneys, which 5 included, among other things, a review of the Defendants’ public documents, conference calls and 6 7 announcements made by Defendants; United States Securities and Exchange Commission (“SEC”) 8 filings, wire and press releases published by and regarding Tesla Motors, Inc.