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The Regents - University of California | Office of The President

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! <strong>The</strong>re were no records to support decisions to capitalize the Line<br />

Items. <strong>The</strong> amount which was capitalized was exactly the amount<br />

needed by WorldCom to meet its pr<strong>of</strong>it margin goals.<br />

! In testimony to <strong>The</strong> House Financial Services Committee on July 8,<br />

2002, Melvin Dick, a former Andersen manager, admitted that<br />

Andersen had not asked for documentation to backup WorldCom’s<br />

financial statements.<br />

! In March <strong>of</strong> 2002, Andersen knew that the SEC was investigating<br />

WorldCom.<br />

167. As the Chairman <strong>of</strong> the Board <strong>of</strong> WorldCom, Bert C. Roberts, told<br />

the Committee on Financial Services <strong>of</strong> the U.S. House <strong>of</strong> Representatives on July<br />

8, 2002:<br />

<strong>The</strong> accounting irregularities that are the subject <strong>of</strong><br />

today’s hearings are an outrage to me. To my mind, the<br />

failure <strong>of</strong> our outside auditors to uncover them is<br />

inconceivable.<br />

D. Andersen Allowed the Fraud to Continue and Made False<br />

Representations About WorldCom’s Financial Statements<br />

168. Andersen violated its pr<strong>of</strong>essional responsibilities, and knowingly or<br />

recklessly participated with WorldCom a scheme to defraud and in order to<br />

artificially boost WorldCom’s reported revenue and pr<strong>of</strong>its.<br />

169. Although Andersen was aware that practices <strong>of</strong> WorldCom artificially<br />

inflated revenue were in violation <strong>of</strong> GAAP, Andersen provided a “clean” audit<br />

opinion related to the company’s financial statements for year end 1994-2001 in<br />

violation <strong>of</strong> GAAS (Generally Accepted Auditing Standards). For each <strong>of</strong> these<br />

years, Andersen consented to its audit opinion to be filed with WorldCom’s 10-K,<br />

Registration Statements and other public documents knowing that those<br />

documents would be disseminated to the investing public. Plaintiff purchased<br />

WorldCom stock in reliance on these representations.<br />

63<br />

COMPLAINT

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