UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
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SECURITIES AND EXCHANGE COMMISSION,
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Plaintiff,
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v.
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Civil Action No.
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LUCENT TECHNOLOGIES INC.,
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COMPLAINT
NINA AVERSANO,
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JAY CARTER,
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JURY DEMANDED
ALICE LESLIE DORN,
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WILLIAM PLUNKETT,
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JOHN BRATTEN,
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DEBORAH HARRIS,
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CHARLES ELLIOTT,
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VANESSA PETRINI,
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MICHELLE HAYES-BULLOCK and
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DAVID ACKERMAN,
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Defendants.
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_______________________________________________ )
Plaintiff Securities and Exchange Commission (the “Commission”) alleges:
ADDRESSES OF THE PARTIES
1.
The address of the Commission is 450 Fifth Street, N.W., Washington,
D.C. The principal executive offices of Lucent Technologies Inc. (“Lucent”) are located
in Murray Hill, New Jersey. Nina Aversano resides in Kinnelon, New Jersey. Jay Carter
resides in Far Hills, New Jersey. Alice Leslie Dorn (“Leslie Dorn” or “Dorn”) resides in
New York, New York. William Plunkett resides in Little Rock, Arkansas. John Bratten
resides in Alpharetta, Georgia. Deborah Harris resides in Shaker Heights, Ohio. Charles
Elliott resides in Roswell, Georgia. Vanessa Petrini resides in Davidsonville, Maryland.
Michelle Hayes-Bullock resides in Orange, New Jersey. David Ackerman resides in
McLean, Virginia.
SUMMARY OF ALLEGATIONS
2.
Lucent fraudulently and improperly recognized approximately $1.148
billion dollars of revenue and $470 million in pre-tax income in violation of Generally
Accepted Accounting Principles (“GAAP”) during its fiscal year 2000 (October 1, 1999
to September 30, 2000). As a result, Lucent improperly overstated its pre-tax income for
its fiscal year 2000 by 16 percent. $511 million of revenue and $91 million in pre-tax
income were recognized prematu