UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

YOLANDA OWENS and EDWARD HUTTON,

Plaintiffs,

-against -

MORGAN STANLEY & CO., INC., GLEN QUINTON,
PETER GALLEA, JAY SOLOMON, DON ELISANO,
LARRY FERRARE, NICHOLAS STEPHENS, PAUL
HARGROVE, and other employees of MORGAN
STANLEY & CO., INC., whose identities are
currently unknown,

Defendants.

COMPLAINT

Index No: 96 CIV 9747

Trial by Jury is
Demanded on all
Counts so Triable

Plaintiffs YOLANDA OWENS and EDWARD HUTTON, by their
attorneys, SHAFRAN, MOSLEY, P.C., of 26 Broadway, 21st
Floor, New York, NY 10004 as and for their complaint
against the defendants herein, alleges the following, upon
information and belief:


PRELIMINARY STATEMENT

1. This is an action seeking declaratory relief and
monetary damages for, inter alia, defendant's unlawful and
discriminatory sexual harassment in violation of
plaintiffs's rights secured by Title VII of the Civil
Rights Act of 1964, 42 U.S.C. Sec. 2000e et. seq. and for
the violation of the duty not to discriminate on the basis
of race by the defendants pursuant to 42 U.S.C. sec 1983.
Plaintiffs also seeks monetary damages for supplemental
claims under New York State Law Executive Law, section 296
and 297 et seq. for unfair discriminatory practices.


JURISDICTIONAL ALLEGATIONS

2. This Court has jurisdiction over this case pursuant to
28 U.S.C. Sec. 1331 in that this action arises under and
seeks redress for the deprivation of rights secured by the
laws of the United States.

3. This Court further has jurisdiction over this case in
that this action seeks relief for discrimination of the
basis of race pursuant to 42 U.S.C. Sec. 2000e et seq. and
for breach of duty of fair representation pursuant to 29
U.S.C. Sec. 185.

4. That plaintiffs have satisfied all statutory
requirements for the bringing of the within action under 42
U.S.C. section 2000(e)(5)(f)(1) and plaintiffs has received
a right to sue letter from the Equal Employment Opportunity
Commission on or about December 3, 1996.

5. This action is being commenced within ninety (90) days
of the issuance of said right to sue letter.

6. Venue is proper in this County in accordance with 28
U.S.C. section 1391.


PARTIES AND RELATIONSHIPS

7. At the time of the commencement of this action plaintiff
YOLANDA OWENS was and is an African American.

8. At the time of the commencement of this action plaintiff
EDWARD HUTTON was and is an African American.

9. At the time of the commencement of this action defendant
MORGAN STANLEY & CO., INC., was and still is a domestic
corporation duly organized and existing under and by virtue
of the laws of the State of New York.

10. At the time of the commencement of this action
defendant MORGAN STANLEY & CO., INC., was and still is
located a. 1221 Avenue of the Americas, County, City and
State of New York.

11. The defendant MORGAN STANLEY & CO, INC., was and is a
company engaged in the business of financial services.

12. That at all the times hereinafter mentioned, defendant
GLEN QUINTON was an employee of defendant MORGAN STANLEY &
CO., INC.,

13. That at all the times hereinafter mentioned, defendant
PETER GALLEA was an employee of defendant MORGAN STANLEY &
CO., INC.,

14. That at all the times hereinafter mentioned, defendant
JAY SOLOMON was an employee of defendant MORGAN STANLEY
CO., INC.,

15. That at all the times hereinafter mentioned, defendant
DON ELISANO was an employee of defendant MORGAN STANLEY
CO., INC.,

16. That at all the times hereinafter mentioned, defendant
LARRY FERRARE was an employee of defendant MORGAN STANLEY
& CO., INC.,

17. That at all the times hereinafter mentioned, defendant
NICHOLAS STEPHENS was an employee of defendant MORGAN
STANLEY & CO., INC.,

18. That at all the times hereinafter mentioned, defendant
PAUL HARGROVE was an employee of defendant MORGAN STANLEY
& CO., INC.,

19. That at all times relevant to the allegations contained
herein, defendant MORGAN STANLEY & CO, INC., is vicariously
and directly liable for the acts and/or omissions of his
trustees, agents, servants and/or employees including
defendants GLEN QUINTON, PETER GALLEA, JAY SOLOMON, DON
ELISANO, LARRY FERRARE, NICHOLAS STEPHENS, PAUL HARGROVE,
and other employees of defendants MORGAN STANLEY & CO.,
INC., whose identities are currently unknown.

20. That at all times relevant to the allegations contained
herein, defendants GLEN QUINTON, PETER GALLEA, JAY SOLOMON,
DON ELISANO, LARRY FERRARE, NICHOLAS STEPHENS, PAUL
HARGROVE, and other employees of defendant MORGAN STANLEY
& CO. INC., whose identities are currently unknown, are
vicariously and directly liable for the acts and/or
omissions of defendant MORGAN STANLEY & CO, INC.,

21. That defendants MORGAN STANLEY & CO., INC., and
defendants GLEN QUINTON, PETER GALLEA, JAY SOLOMON, DON
ELISANO, LARRY FERRARE, NICHOLAS STEPHENS, PAUL HARGROVE,
and other employees of defendant MORGAN STANLEY & CO.,
INC., whose identities are currently unknown, are subject
to the legal requirements of equal employment opportunity
and as specified in 42 U.S.C. Sec. 2000e et seq. and for
the duty of fair representation pursuant to 29 U.S.C. Sec.
185, as well as certain state and city civil rights laws as
discussed, infra. 4

22. That this Court may exercise pendant jurisdiction of
certain state law claims under 28 U.S.C. 1367 et. seq.


ALLEGATIONS AS TO THE FACTS

A. OWENS' EMPLOYMENT

23. Plaintiffs, YOLANDA OWENS was retained and employed by
defendant, MORGAN STANLEY & CO., INC., beginning in or
about 1992 and continuously through the present time.

24. That pursuant to agreement and contract, plaintiff
OWENS was offered and accepted the position of Circuit
Provisioning Analyst with MORGAN STANLEY & CO., INC.

25. During the entire time that OWENS was employed by the
MORGAN STANLEY & CO., INC., she was told that she was
working under the terms and conditions of the said
Agreement.

26. That plaintiff OWENS properly and fully performed the
responsibilities of her position as a Circuit Provisioning
Analyst with defendant MORGAN STANLEY & CO., INC. up until
the present time.


B. MUTTONS' EMPLOYMENT

27. Plaintiffs, EDWARD HUTTON was retained and employed by
defendant, MORGAN STANLEY & CO., INC., beginning in or
about 1992 and continuously through the present time.

28. That pursuant to agreement and contract, plaintiff
OWENS was offered and accepted the position of Logistics
Technology Analyst with MORGAN STANLEY & CO., INC.

29. During the entire time that MUTTONS was employed by the
MORGAN STANLEY & CO., INC., he was told that he was working
under the terms and conditions of the said Agreement.

30. That plaintiff MUTTONS properly and fully performed the
responsibilities of his position as a Logistics Technology
Analyst with defendant MORGAN STANLEY & CO., INC. up until
the present time.


C. THE DENIAL OF A PROMOTION OR ADVANCEMENT

31. On October 4, 1995, and prior thereto, plaintiffs
YOLANDA OWENS and EDWARD HUTTON were repeatedly subjected
to a continuous course of conduct that discriminated
against them on the basis of their race and/or national
origin, and have been and remain subjected to such
employment discrimination and have repeatedly and
consistently been wrongfully denied promotion or
advancement in their respective positions at defendant
MORGAN STANLEY & CO., INC., despite demonstrated ability
and despite persons of Caucasian and otherwise non-African
American decent with equal or lesser ability, experience,
skill, and tenure receiving such promotion and advancement.


D. THE DISSEMINATION OF VILE RACIST E-MAIL THROUGHOUT THE
COMPUTER SYSTEM OF DEFENDANT MORGAN STANLEY & CO., INC.

32. That on or about October 4, 1995, an employee of
defendant MORGAN STANLEY & CO., INC., believed to be
defendant GLEN QUINTON, authored and sent an electronic
message, referred to herein as an E-mail message, of vile,
offensive nature, containing racist "jokes" throughout the
computer systems of said corporate defendant.

33. That said defendants, including but not limited to GLEN
QUINTON, knew of its vile, offensive nature before
disseminating said electronic message throughout the
corporate computer systems.

34. That in order to disseminate said racist electronic
message (hereinafter referred to as "e-mail"), without
revealing his identity, said defendant GLEN QUINTON
attempted to disguise his identity or "ghost" said e-mail
by misappropriating or otherwise using without knowledge,
permission or consent, the computer identification password
of an African American employee of said corporate
defendant, believed to be one Anthony Williams, and
thereafter proceeded to disseminate and otherwise
proliferate said e-mail to various of employees, and the
individual defendants herein, and other Caucasian corporate
employees.

35. That defendant PETER GALLEA, transmitted the e-mail to
defendant JAY SOLOMON, who also thereafter proceeded to
disseminate and otherwise proliferate said e-mail to
various of employees, and the individual defendants herein,
and other Caucasian corporate employees.

36. That defendant PAUL HARGROVE, after receiving said
e-mail also thereafter proceeded to disseminate and
otherwise proliferate said e-mail to various of employees,
and the individual defendants herein, and other Caucasian
corporate employees.

37. That defendant LARRY FERRARE, after receiving said
e-mail also thereafter proceeded to disseminate and
otherwise proliferate said e-mail to various of employees,
and the individual defendants herein, and other Caucasian
corporate employees.

38. The incidents of discrimination alleged herein were in
furtherance of an existing and ongoing policy of racial
discrimination against the plaintiffs and against African
Americans generally.


AS AND FOR THE FIRST CLAIM FOR RELIEF AGAINST DEFENDANTS
MORGAN STANLEY & CO., INC. and GLEN QUINTON, PETER GALLEA,
JAY SOLOMON, DON ELISANO, LARRY FERRARE, NICHOLAS STEPHENS,
PAUL HARGROVE, and other employees of MORGAN STANLEY & CO.,
INC., whose identities are currently unknown FOR CIVIL
RIGHTS VIOLATIONS UNDER TITLE VII OF THE CIVIL RIGHTS OF
1964.

39. That plaintiffs repeat, reiterate and reallege each and
every allegation contained in those paragraphs of the
complaint designated as "1" through "38" with the same full
force and effect as if fully set forth herein at length.

40. By its acts and omissions as aforesaid, defendant(s),
either directly or through their agents, servants, trustees
and/or employees unlawfully discriminated against the
plaintiffs on the basis of their gender, denied plaintiffs
equal opportunity to employment, wrongfully denied
plaintiffs promotions and advancements in their employment
by unlawful acts of discrimination, discriminated against
plaintiffs by creating a hostile work environment, engaged
in conduct that unreasonably interfered with plaintiffs'
work performance, engaged in conduct that created a hostile
and offensive working environment, made unwelcome, vile and
offensive racial epithets and "jokes" directed at
plaintiffs and at African Americans generally, and engaged
in a pervasive and intentional course of corporate conduct
and established corporate policy which discriminated a
against plaintiffs, because of their race and/or national
origin of African Americans, and threatened termination and
or demotion and/or caused plaintiffs to be demoted in
retaliation to objecting to said racist e-mail, and general
policy of discrimination toward the promotion or
advancement of African Americans, all of the foregoing in
violation of 42 U.S.C. 2000e et seq. and sections 296 and
297 et seq. of the New York State Executive Law.

41. That the racist e-mail complained of herein was
unwelcome.

42. That the racist e-mail complained of herein was of a
racial nature.

43. That the discrimination complained of herein affected
a term, condition, or privilege of plaintiffs' employment.

44. That by reason of the foregoing, plaintiffs, and each
of them, were caused damage to their business reputation,
and loss of earnings and was caused to suffer certain
serious, severe and permanent physical and non-physical
injuries and conditions, and have been caused to be
rendered sick, sore and lame, and to suffer emotional
distress, mental injury and suffering, loss of employment,
loss of past and future earnings, commissions and bonuses,
damage to business reputation, and have otherwise been
caused to be damaged thereby.

45. That by reason of the foregoing acts and/or omissions
of defendants, plaintiffs have each been caused to be
damaged thereby in the sum of Five Million ($5,000,000.00)
Dollars in compensatory damages and Twenty Five Million
($25,000,000.00) Dollars in punitive damages.


AS AND FOR AN SECOND CLAIM FOR RELIEF AGAINST DEFENDANTS
FOR HUMAN RIGHTS VIOLATIONS UNDER SECTIONS 296 AND 297 OF
THE EXECUTIVE LAW OF THE STATE OF NEW YORK AND TITLE 8 OF
THE ADMINISTRATIVE CODE OF THE CITY OF NEW YORK

46. That plaintiffs repeats, reiterates and reallege each
and every allegation contained in those paragraphs of the
complaint designated as "1" through "45" with the same full
force and effect as if fully set forth herein at length.

47. By its acts and omissions as aforesaid, defendants,
either directly or through its agents, servants, trustees
and/or employees unlawfully discriminated against the
plaintiffs on the basis of their race, denied plaintiffs
equal opportunity to employment, wrongfully denying
plaintiffs promotion, advancement, equal opportunity of
employment and a non-hostile work environment by their
unlawful acts of discrimination, discriminated against
plaintiffs by creating a hostile work environment, engaged
in conduct that unreasonably interfered with plaintiffs'
work performance, engaged in conduct that created a hostile
and offensive working environment, made unwelcome and
offensive racial epithets and "jokes" directed toward
plaintiffs, threatened termination of plaintiffs if they
filed the very complaint now filed, in retaliation for
objecting to said unlawful and discriminatory behavior, all
of the foregoing in violation of the New York State Human
Rights Law, (Executive Law Sec. 296, et seq.), and the
Civil Rights Law of the City of New York, (Title 8 of New
York City Administrative Code).

48. That the discrimination complained of herein was
unwelcome.

49. That the discrimination complained of herein was of a
racial nature.

50. That the discrimination complained of herein affected
a term, condition, or privilege of plaintiffs' employment.

51. That by reason of the foregoing, plaintiffs were caused
damage to their business reputations, and loss of earnings
and was caused to suffer certain serious, severe and
permanent physical and non-physical injuries and
conditions, and have been caused to be rendered sick, sore
and lame and to suffer emotional distress, mental injury
and suffering, loss of employment, loss of past and future
earnings, commissions and bonuses, damage to business
reputation, and have otherwise been caused to be damaged
thereby.

52. That by reason of the foregoing acts and/or omissions
of defendants, plaintiffs have each been caused to be
damaged thereby in the sum of Five Million ($5,000,000.00)
Dollars in compensatory damages and Twenty Five Million
($25,000,000.00) Dollars in punitive damages.


AS AND FOR A THIRD CLAIM FOR RELIEF AGAINST DEFENDANT
MORGAN STANLEY & CO., INC., MORGAN STANLEY & CO., INC. FOR
BREACH OF EMPLOYMENT CONTRACT

53. That plaintiffs repeats, reiterates and reallege each
and every allegation contained in those paragraphs of the
complaint designated as "1" through "52" with the same full
force and effect as if fully set forth herein at length.

54. That ever since plaintiff OWENS complained about the
racist e-mail and the denial of advancement and promotions
at said corporate defendant she as her work reassigned and
had been given no new work assignments.

55. That plaintiff OWENS was denied the promotion to the
position of Quality Care Detailing Reporting as a
consequence of her voicing complaint of the racist e-mail,
and because of her race and/or national origin of African
American.

56. That plaintiff HUTTON was specifically told by
defendant, MORGAN STANLEY, through its Legal and Human
Resources Department, that his complaints concerning the
aforestated systematic racial discrimination, would be
dealt with and that he my rely upon the confidentiality of
his complaint, whereupon said complaint was not maintained
as confidential, and was also disseminated to management of
defendant MORGAN STANLEY & CO., INC., and also caused him
to be denied promotion and advancement and caused
co-workers to inform him they no longer wished to work with
him, and otherwise caused him to be ostracized in a
professional and social way, creating a hostile work
environment.

57. That by reason of the actions and/or omissions by
defendants their agents, servants, trustees, licensees
and/or employees, said defendants did breach their
contractual obligations to the plaintiffs by improperly
denying plaintiffs promotion or advancement and otherwise
professionally isolating plaintiffs without cause and
without justification.

58. That said breach of agreement by defendants, and each
of them, did cause reasonably foreseeable harm and damage
to plaintiffs.

59. That the breach of contract by the defendants, was
wilful, wanton, reckless and demonstrated callous disregard
for the rights of the plaintiffs and also evidenced a
degree of bad faith evincing a disingenuous and/or
dishonest failure to carry out the contract so as to
warrant an assessment of punitive damages.

60. That by reason of the foregoing breach of contract,
plaintiffs, and each of them, have been caused to suffer
compensatory and special damages, including but not limited
to loss of employment, loss of past earnings, commissions
and bonuses, loss of future earnings, commissions and
bonuses, damage to business reputation and have otherwise
been caused to be damaged thereby in the sum of Five
Million ($5,000,000.00) Dollars for compensatory damages
and Twenty Five Million ($25,000,000.00) Dollars in
punitive damages


AS AND FOR A FOURTH CLAIM FOR RELIEF AGAINST DEFENDANTS
MORGAN STANLEY & CO., INC., AND GLEN QUINTON, PETER GALLEA,
JAY SOLOMON, DON ELISANO, LARRY FERRARE, NICHOLAS STEPHENS,
PAUL HARGROVE, and other employees of MORGAN STANLEY & CO.,
INC., whose identities are currently unknown, FOR BREACH OF
COVENANT OF GOOD FAITH AND FAIR DEALING

61. That plaintiffs repeats, reiterates and reallege each
and every allegation contained in those paragraphs of the
complaint designated as "1" through "60" with the same full
force and effect as if fully set forth herein at length.

62. That defendants had an affirmative duty and covenant of
good faith and fair dealing in the performance of their
business dealings with and with the enforcement of their
contract with plaintiffs.

63. That by the wrongful acts as described herein, and by
callously creating and publishing said racist em-mail, and
by perpetuating said racist comments and "jokes" throughout
the company, and by professionally and socially isolating
plaintiffs and by failing, refusing and/or neglecting to
assign work assignments to plaintiffs, and by ostracizing
plaintiffs from the routine and daily functioning of the
corporate defendant and by improperly denying plaintiffs
advancement and promotion without just cause as aforesaid,
defendants breached their covenant of good faith and fair
dealing.

64. That the breach of covenant of good faith and fair
dealing by the defendants, was wilful, wanton, reckless and
demonstrated callous disregard for the rights of the
plaintiffs and also evidenced a degree of bad faith
evincing a disingenuous and/or dishonest failure to carry
out the contract so as to warrant an assessment of punitive
damages.

65. That by reason of the foregoing breach of covenant of
good faith and fair dealing, plaintiffs, and each of them,
have been caused to suffer compensatory and special
damages, including but not limited to loss of employment,
loss of past earnings, commissions and bonuses, loss of
future earnings, commissions and bonuses, damage to
business reputation and have otherwise been caused to be
damaged thereby in the sum of Five Million ($5,000,000.00)
Dollars for compensatory damages and Twenty Five Million
($25,000,000.00) Dollars in punitive damages.


AS AND FOR A FIFTH CLAIM FOR RELIEF AGAINST MORGAN STANLEY
& CO., INC., GLEN QUINTON, PETER GALLEA, JAY SOLOMON, DON
ELISANO, LARRY FERRARE, NICHOLAS STEPHENS, PAUL HARGROVE,
and other employees of MORGAN STANLEY & CO., INC., whose
identities are currently unknown, FOR INTERFERENCE WITH
CONTRACTUAL RELATIONS

66. That plaintiffs repeats, reiterates and reallege each
and every allegation contained in those paragraphs of the
complaint designated as "1" through "65" with the same full
force and effect as if fully set forth herein at length.

67. That defendants, through its agents, servants,
licensees and/or employees without just cause or excuse,
did, in fact, interfere with the contract between
plaintiffs and MORGAN STANLEY & CO., INC..

68. That plaintiffs was wrongfully and improperly engaged
in a continuous course of racial discrimination directed at
plaintiffs and persons of African American decent, and did
threaten to discharge plaintiffs in retaliation by reason
of their filing the very complaint filed herein, and did
result in humiliation, embarrassment, professional and
social ostracizing and scorn, ridicule and isolation as a
result of defendants interference with plaintiffs'
contract.

69. That the conduct of defendants was willful, wanton and
reckless and demonstrated a callous disregard for the
rights of the plaintiffs so as to warrant an assessment of
punitive damages.

70. That by reason of the foregoing interference with
contract plaintiffs, and each of them, have been caused to
suffer compensatory and special damages, including but not
limited to loss of employment, loss of past earnings,
commissions and bonuses, loss of future earnings,
commissions and bonuses, damage to business reputation and
have otherwise been caused to be damaged thereby in the sum
of Five Million ($5,000,000.00) Dollars for compensatory
damages and Twenty Five Million ($25,000,000.00) Dollars in
punitive damages.


AS AND FOR A SIXTH CLAIM FOR RELIEF AGAINST DEFENDANT
MORGAN STANLEY & CO. INC. FOR NEGLIGENT HIRING AND
RETENTION

71. That plaintiffs repeats, reiterates and reallege each
and every allegation contained in those paragraphs of the
complaint designated as "1" through "70" with the same full
force and effect as if fully set forth herein at length.

72. That the defendant MORGAN STANLEY & CO., INC., did
employ and continue to employ defendants GLEN QUINTON,
PETER GALLEA, JAY SOLOMON, DON ELISANO, LARRY FERRARE,
NICHOLAS STEPHENS, PAUL HARGROVE, and other employees of
MORGAN STANLEY & CO., INC., whose identities are currently
unknown, despite its actual knowledge of the racist
attitudes and views of said employees, and did condone,
ratify and otherwise encourage said racist and
discriminatory employment practices by retaining said
defendants and did actually know of such acts of
inappropriate and offensive behavior by its employees
making them unsuitable for the positions in which they were
employed.

73. That the corporate defendant's employees, the
defendants GLEN QUINTON, PETER GALLEA, JAY SOLOMON, DON
ELISANO, LARRY FERRARE, NICHOLAS STEPHENS, PAUL HARGROVE,
and other employees of MORGAN STANLEY & CO., INC., whose
identities are currently unknown, lacked the qualification,
training, temperament, abilities, and suitability for the
positions in which they were employed.

74. That the defendant MORGAN STANLEY & CO., INC., knew or
should have known of the defendants' racist attitudes and
of their offensive and discriminatory policies and denial
of promotion and advancement to persons of African American
decent, and generally of their unsuitability for the
positions for which they were employed.

75. That the defendant MORGAN STANLEY & CO., INC., acted in
a negligent way by hiring and retaining defendants GLEN
QUINTON, PETER GALLEA, JAY SOLOMON, DON ELISANO, LARRY
FERRARE, NICHOLAS STEPHENS, PAUL HARGROVE, and other
employees of MORGAN STANLEY & CO., INC., whose identities
are currently unknown, after they knew or should have known
of their background of extreme and vile racist attitudes
and of their aggressive nature of imposing their racist
attitudes upon others, including the plaintiffs that made
them unsuitable for the position in which they were
employed.

76. That the defendant MORGAN STANLEY & CO., INC., acted in
negligent way by retaining defendants GLEN QUINTON, PETER
GALLEA, JAY SOLOMON, DON ELISANO, LARRY FERRARE, NICHOLAS
STEPHENS, PAUL HARGROVE, and other employees of MORGAN
STANLEY & CO., INC., whose identities are currently
unknown, after they knew or should have known of their
racist attitudes and vile and racist behavior and their
discriminatory employment practices that made them
unsuitable for the position in which they were employed.

77. That defendants' conduct was a proximate cause of the
injuries suffered by plaintiffs and in violation of
plaintiffs' civil rights and human rights and all damages
concomitant thereto.

78. That by reason of the foregoing, plaintiffs, and each
of them, were caused to suffer certain serious, severe and
permanent physical and non-physical personal injuries and
conditions, emotional distress, mental injury and
suffering, loss of employment, loss of past and future
earnings, commissions and bonuses, damage to business
reputation, and have otherwise been caused to be damaged
thereby.

WHEREFORE, plaintiffs YOLANDA OWENS and EDWARD HUTTON
demand judgment against defendants as follows:

A. for a declaratory judgement[sic] that the defendants'
acts, practices and procedures complained of herein
violated plaintiffs's rights as secured under Title VII of
the Civil Rights Act of 1964, the Human Rights Law of the
State of New York and the Civil Rights Law of the City of
New York.

B. on each claim for relief for a monetary judgement in the
sum of Five Million ($5,000,000.00) Dollars in compensatory
damages and Twenty Five Million ($25,000,000.00) Dollars in
punitive damages, together with the costs of this action,
interest, disbursements and attorney's fees to counsel for
plaintiffs.

Dated:
New York, N.Y.
December 26, 1996

SHAFRAN & MOSLEY, P.C.

Attorneys for Plaintiffs
Office & P.O. Address
26 Broadway, 21st Floor
New York, N.Y. 10004
(212) 785-2800