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| | Complaint: Vivendi Universal, S.A., Jean-Marie Messier, and Guillaume Hannezo |
 | | As Vivendi and its executive officers, including Messier and Hannezo, knew or were reckless in not knowing, the Company's financial condition at this time was worse than Vivendi indicated because of its inability unilaterally to access the earnings and cash flow of two of its most profitable subsidiaries, Cegetel and Maroc Telecom. |
 | | As Vivendi, Messier, Hannezo and other Vivendi executive officers knew or were reckless in not knowing during the relevant time period, Vivendi's inability unilaterally to access that cash flow substantially impaired Vivendi's ability to satisfy the debt obligations and other operating costs that Vivendi had amassed in connection with its many acquisitions. |
 | | Issue an Order requiring Defendants Messier and Hannezo to provide an accounting of all proceeds received, directly or indirectly, as a result of the acts and/or courses of conduct complained of herein, including, but not limited to, bonuses and salaries received during the relevant time period. |
| www.sec.gov /litigation/complaints/comp18523.htm (6208 words) |
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