The Regents - University of California | Office of The President

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272. At the time that these misrepresentations were made and the material
facts not disclosed, and at the time that Plaintiff took the actions herein alleged,
Plaintiff was ignorant of the true facts. If Plaintiff had known the true facts, it
would not have invested in WorldCom stock.
273. Plaintiff reasonably relied on these representations in investing in
WorldCom stock, and its reliance was justified since Plaintiff was unaware of the
true facts; if the true facts had been known to Plaintiff, it would not have acted as
it did.
274. As set forth above, WorldCom engaged in one of the largest financial
frauds in history. Defendants knew that WorldCom was engaged in the conduct
and that such conduct constituted a fraud. Notwithstanding their knowledge of the
improper and unlawful conduct, Defendants, and each of them, engaged in
conduct, hereinbefore described which rendered substantial assistance to,
encouraged and/or aided and abetted the fraud.
275. With knowledge of the unlawful purpose of the fraudulent conduct of
WorldCom, and the Defendants, and each of them, entered into an agreement to
accomplish the aforesaid scheme, and by their actions took steps to further that
scheme.
276. As a result of Defendants’ wrongful conduct, Plaintiff has sustained
and will sustain economic and other general and specific damages, all in an
amount to be determined according to proof.
277. At all times herein alleged, Defendants acted with actual malice to
defraud Plaintiff. At all times herein alleged, Defendants acted willfully,
wantonly, with oppression, fraud and/or malice, and with a conscious disregard of
the rights of others, such that Plaintiff requests that the trier of fact, in the exercise
of its sound discretion, should award Plaintiff additional damages for the sake of
example and in a sufficient amount to punish the Defendants for their conduct, in
an amount reasonably related to Plaintiff’s actual damages and defendants’ wealth
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COMPLAINT