8
only after reasonable inquiry as required by C.R.C.P. 11.” Id. at
¶ 28 n.9.
¶ 15 Five months after the division decided Houser I, the
shareholder filed the amended complaint that is the subject of this
appeal. His counsel began by detailing the scope of his inquiry,
stating that the allegations were
based upon personal knowledge as to [the
shareholder] and [the shareholder’s] own acts
and upon information and belief as to all other
matters based on the investigation conducted
by and through [the shareholder’s counsel],
which included, among other things, a review
of [SEC] filings by [the corporation], the
[corporation’s] press releases and earnings
calls, analyst reports and media reports about
the [corporation], review of public filings in the
related cases, including [In re CenturyLink],
and discussions with plaintiffs’ counsel in
those actions, and review of other publicly-
available information about [the corporation].
[The shareholder] believes that substantial
additional evidentiary support will exist for the
allegations set forth herein after a reasonable
opportunity for discovery.
¶ 16 Among the allegations that followed in the amended
complaint, several were copied or adapted from allegations in the In
re CenturyLink complaint, which had been based on interviews with