UNITED STATES DISTRICT COURT DISTRICT OP HEW JERSEY
PHILIP TULPH BELPASSO CIVIL ACTION N01 81-2268D Plaintiff, COMPLAINT
FOR SECURITIES vs. FRAUD
SMITH EARNEY. HARRIS UPHUN. & C0. PLAINTIPF·6 MORE DEFINA'fE
STATEMENT De fendant .
The plaintiff realleges his initial complaint and wishes to add the
following in his behalft (1) The plaintiff, after suffering $1 689.00 in
loses in two days during the transaction of ICN Pharmaceutical stocks,
con- fronted his broker Mr. Cearge Nazarian lier an explanation con- cerr~ine
plaintiff's loses which amounted to $20,000 in 1981, Mr. ~achI~lan stated
to the plaintiff on the telephor,e 11/23/81 that some person(s) had been
watchine his STO'. LOSE strategy and were using said information to manipulate
the plaintiff out of his securities. Mr. Nazarlan's exact words were, "They
saw your stop and they bought you out." At this point, I stop- ed
trading with Mr. Fr'azarian and Mr. ~azerlan left the employ ment of the
defendant shortly afterwards. See counts 3 and 7 of the plaintiff's complaint.
(2) On statement date of October 13, 1982 his. Sandra Reeves made purchases
in plaintiff's account for one (1) and five (~) Schlumberger Options without
plaintiff's