had fully described the stop ship report in question, and had indicated the source of their information about it, there would be no need for defendants to attempt to file extraneous documents in an effort to defend themselves. As discussed infra Part C.2.b., the SRA requires more complete disclosures than plaintiffs have made in the FAC. 8 . Defendants McCracken and Kelly do not contest that plaintiffs would state a claim against them for making false and misle U.S. -, 116 S.Ct. 274, 133 L.Ed.2d 195 (1995); Adam v. Silicon Valley Bancshares, 884 F.Supp. 1398, 1401 (N.D.Cal.1995) (finding auditor primarily liable for represenling that proper accounting procedures had been followed in drafting financial statements); In re ZZZZ Best Secs. Litig., 864 F.Supp. 960, 968-72 (C.D.Cal.1994) (<HOLDING>). The pre-Central Bank cases cited by
holding that defendant could not be liable for distributing defamatory statements unless it knew or had reason to know of statements holding that an auditor intricately involved in the creation of misstatements and omissions may be liable under  10b even if the statements could not be reasonably attributable to him holding auditor primarily liable due to role in drafting and editing letters to sec holding auditor liable for reviewing public statements holding the government liable to plaintiffs for breach of contract