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1
.
AMENDED SUPPLEMENTAL COMPLAINT
|
EXTRACTED KEY WORDS
DEFENDANTS STOCKHOLDERS AGREEMENT PLAINTIFF HARPER DRAFT TERMINATE SHARES LATINADVISORCOM FILING EMPLOYMENT MASSIVE DILUTION COMMON STOCK DELAWARE BUSINESS THEREAFTER DELAWARE CORPORATION MCCAUSLAND SUPPLEMENTAL COMPLAINT CO-FOUNDER INCORPORATES TERMINATION FIDUCIARY DUTIES CHRISTOPHER KOSACHUK CERTIFICATE EQUITY FINANCING ADEQUATE REMEDY CONTRASENA INVESTORS PARAGRAPHS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
9c:
IN AND FOR NEW CASTLE COUNTY ,li-ii-i /
- --.
CHRISTOPHER KOSACHUK,
Plainliff,
i
V. C.A. No. 17928
i
HENRY E. HARPER, VIOLY McCAUSLAND, )
anti OMAR ALLAM, >
Defendants, !,
And 1
.
LATINADVISOR.COM, INC., a Delaware ;
Corporation,
1
Norninal Defendant.
- -
AMENDED SUPPLEMENTAL COMPLAINT
Plaintiff Christopher Kosachuk, for his Amended and Supplemental Complaint,
alleges as follows herein upon knowledge as to his own conduct and upon information and belief
as to all o-ther matters:
NATURE OF THIS ACTION
1. Plaintiff brings this action to rescind a "stockholders agreement" and to
obtain declaratory and other relief with respect to his ownership interest in LatinAdvisorcom,
Inc., a Delaware corporation ("l,atinAdvisor.com" or the "Company"). As alleged herein,
defendants conspired to in'duce Plaintiff, a co-founder of the Company, to sign a draft
stockholders agreement pumuant to which Defendants -- just 12 days later -- purported to
terminate Plaintiffs "employment" and thereby divest him of all but 2.4% ownership interest in
LatinAdvisor.com. Thereafter, following the filing of this action, the individual Defendants
SNIPPETS:
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2
.
MEMORANDUM OPINION
|
EXTRACTED KEY WORDS
HARPER STOCKHOLDERS AGREEMENT LATINADVISOR EQUITY COURT DEFENDANTS DUTY COUNTERCLAIM SHARES PLAINTIFF ATTORNEYS ESQUIRE EMPLOYEES COMMON STOCK YORK DELAWARE CORPORATE CARDS PURCHASE TERMINATION EXPENSES FRAUDULENT WACHTELL TESTIMONY PERSONAL LOANS HARPER ADMITS AMERICAN BUSINESS SIGNATURE LAPTOP COMPUTERS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK, ))
Plaintiff, )1
v. 1 C.A. No. 17928
1
HENRY E. HARPER, VIOLY )
McCAUSLAND, and CONTRASENA, 1
S.A., 1
1
Defendants, >
and >
LATINADVISOR.COM, INC., >
a Delaware Corporation, >>
Nominal Defendant. 1
__---_____-_______----------------------------------- -1
HENRY E. HARPER and >
LATINADVISOR.COM, INC., , )
1
Counterclaim-plaintiffs, )
1
v. 1
)
CHRISTOPHER KOSACHUK, 11
Counterclaimdefendant. )
MEMORANDUM OPINION
Submitted: February 26,2002
Decided: July 25, 2002
Peter J. Walsh, Jr., Esquire, John M. Seaman, Esquire, POTTER
ANDERSON Sr CORROON, Wilmington, Delaware, Attorrzeys for
PlairztifS.
David C. McBride, Esquire, Christian D. Wright, Esquire, YOUNG,
CONAWAY, STARGATT & TAYLOR, Wilmington, Delaware; Eric M.
Roth, Esquire, Stephen R. DiPrima, Esquire, WACHTELL, LIPTON,
ROSEN & KATZ, New York, New York, Attorneys for Defenahnts.
LAMB, Vice Chancellor.
I. 1R"I`IWl)UC'1`10N
SNIPPETS:
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3
.
PLAINTIFFS MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS MOTION FOR PARTIAL SUMMARY JUDGMENT
|
EXTRACTED KEY WORDS
HARPER DEFENDANTS DEL DAMAGES LATINADVISOR SUMMARY JUDGMENT SUPR COURT STOCKHOLDERS MCCAUSLAND DELAWARE STOCKHOLDERS AGREEMENT RESCISSORY DAMAGES LAW MOTION PARTIAL SUMMARY JUDGMENT COMPLAINT BUSINESS DILUTE KOSACHUK DIRECTORS COMMON STOCK COMPENSATION PACKAGE FAIRNESS EMPLOYEES SHAREHOLDER TERMINATE CHANCERY VIOLY MCCAUSLAND DELAWARE CORPORATION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK, >
Plaintiff, i
v.
i CA. No. 17928
HENRY E. HARPER. VIOLY McCAUSLAND,
and OMAR ALLAM, :
Defendants, 1
And
i
LATINADVISOR.COM. INC., a Delaware Corporation, )
Nominal Defendant.
HENRY E. HARPER and LATINADVISOR
HOLDINGS INC..
Counterclaim-Plaintiffs, I
\.
:
CHRISTOPHER KOSACIIIJK, )1
Counterclaim-Defendant. 1
PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION
TO DEFENDANTS' MOTION FOK PARTIAL SUMMARY JUDGMENT
POTTER ANDERSON & CORROON LLP
Peter J. Walsh. Jr.
John M. Seaman
Hercules Plaza, Sixth Floor
13 13 North Market Street
Wilmington, Delaware 19899
(302) 984-6000
December 2 I ., 200 1 Attorney:; for Plaintiff Christopher Kosachuk
JW23J\h
TABLE OF CONTENTS
SNIPPETS:
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4
.
OPENING BRIEF IN SUPPORT OF DEFENDANTS MOTION FOR PARTIAL SUMMARY JUDGMENT
|
EXTRACTED KEY WORDS
HARPER DEFENDANTS KOSACHUK LATINADVISOR ALLAM SUMMARY JUDGMENT DEL COURT MOTION AGREEMENT SHARES SHAREHOLDERS MCCAUSLAND PARTIAL SUMMARY JUDGMENT VENTURE KOSACHUK DEP OMAR ALLAM NOTEHOLDERS COMPANY COMMON STOCK FINANCING LEXIS INVESTORS DECLARATION VIOLY MCCAUSLAND LATINADVISOR HOLDINGS COUNTERCLAIM-PLAINTIFFS PRELIMINARY STATEMENT CONVERSION FIDUCIARY DUTY |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK,
Plaintiff,
v.
HENRY E. HARPER, VIOLY McCAUSLAND, C.A. No. 17928
and OMAR ALLAM,
Defendants,
And
LATINADVISOR.COM, WC., a Delaware corpo-
ration,
Nominal Defendant.
HENRY E. HARPER and LATINADVISOR
HOLDINGS, INC.,
Counterclaim-plaintiffs,
v.
CHRISTOPHER KOSACHUK,
Counterclaim-defendant.
OPENING BRIEF IN SUPPORT OF DEFENDANTS' MOTION
FOR PARTIAL SUMMARY JUDGMENT
Wl'3:712042.2 56960.1001
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5
.
REPLY TO AMENDED COUNTERCLAIM
|
EXTRACTED KEY WORDS
COUNTERCLAIM DEFENDANTS PLAINTIFF HARPER PURPORT COURT COMPANY PURPORT REFERENCED FLORIDA STATUTE PLAINTIFF RESPECTFULLY REFERS QUOTE AFFIRMATIVE DEFENSE DOCTRINE DELAWARE HENRY VIOLY MCCAUSLAND LATINADVISOR CHRISTOPHER KOSACHUK PARAGRAPHS STOCKHOLDERS AGREEMENT YORK NOMINAL DEFENDANT HOLDINGS AMENDED COUNTERCLAIMS ATTORNEYS PLAINTIFF REALLEGES INCORPORATES RESPONSES COUNTERCLAIMS FAIL RELIEF REQUEST |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK, 1
Plaintiff, t
". ; CA. No. 17928
1
HENRY E. HARPER, VIOLY McCAUSLAND,
and OMAR ALLAM,
Defendants,
And
LATINADVISOR.COM, INC., a Delaware
Corporation,
Nominal Defendant.
HENRY E. HARPER and LATINADVISOR
HOLDINGS INC.,
)
Counterclaim-Plaintiffs, )
v. i1
CHRISTOPHER KOSACHUK,
i
Counterclaim-Defendant. )
REPLY TO AMENDED COUNTERCLAIMS
Plaintiff Christopher Kosachuk, by and through his attorneys, for his reply to the
Amended Counterclaims by Defendant Henry E. Harper ("Harper"), Violy McCausland
("McCausland") and nominal defendant LatinAdvisor Holdings, Inc. (formerly known as
LatinAdvisorcom, Inc.) (the "Company"), responds as follows:
1. Denied, except admitted that Harper and the Company purport to bring
counterclaims to recover damages they claim to have sustained as a result of Kosachuk's
alleged unlawful conduct.
SNIPPETS:
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6
.
LETTER OPINION
|
EXTRACTED KEY WORDS
KOSACHUK COMMUNICATIONS DEFENDANTS ATTORNEY-CLIENT PRODUCTION DISCOVER COUNSEL MOTION REASONS DEL HARPER ADEQUATE SHAREHOLDERS REPRESENTING ESQUIRE HURPER COMPEL EMPLOYEE WAIVER MATTER ENCLOSURE WILMINGTON CHRISTOPHER KOSACHUK HENRY PARTIES LITIGATION REVIEW WORK PRODUCT PRIVILEGES CONTEXT |
C O U R T O F C H A N C E R Y
OF THE
S T A T E O F D E L A W A R E
STEPrlEN P. LAMB
"ICE-CHANCELLOR
Submitted: November 8, 2000
Decided: December 19, 2000
Peter J. Walsh, Jr., Esquire
Kevin R. Shamron, Esquire
Potter Anderson & Corroon
1313 N. Market Street
P.O. Box 951
Wilmington, DE 19899
David C. McBride, Esquire
Young, Conaway, Stargatt & Taylor
Rodney Square North
P.O. Box 391
Wilmington, DE 19899
RE: Christopher Kosachuk v. Henry E. Hurper, Violy McCausland
and Contrase,na, S.A. and Latinadvisor.com, Inc.
C.A. No. 17928
Dear Counsel:
I understand from Mr. Walsh's letter of November 8, 2000, that the
parties have been unable to agree upon a discontinuance of this litigation. In
light of this development, I have reviewed the parties' submissions and the
transcript of the October 23, 2000 hearing, and am prepared to rule on the
pending motion to compel. For the following reasons, that motion will be
denied.
Kosachuk v. Hurper, et al.
December 19, 2000
Page 2
Plaintiff, Christopher Kosachuk, moved to compel the production of all
SNIPPETS:
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7
.
PLAINTIFFS REPLY BRIEF IN SUPPORT OF MOTION TO COMPEL
|
EXTRACTED KEY WORDS
HARPER KOSACHUK COUNSEL ATTORNEY-CLIENT PRIVILEGE COMMUNICATIONS ATTORNEY COURT DEL STOCKHOLDERS PLAINTIFF MOTION STOCKHOLDERS AGREEMENT CLIENT EMPLOYEES REPRESENTING DELAWARE LEGAL SERVICES BUSINESS STRATEGY HARPER ATTACHING DRAFT CORROON LLP TERMINATION AGREEMENT PUNGILUPPI NEGOTIATIONS DISCOVERY ATTORNEY-CLIENT RELATIONSHIP CONFIDENTIALITY CHRISTOPHER KOSACHUK KOSACHUK AFF HARPER ATTACHING |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`2
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK, >
Plaintiff, ;
V. i CA. No. 17928
HENRY E. HARPER, VIOLY McCAUSLAND, ;
and CONTRASENA S.A., >
Defendants, i
and 11
LATINADVISOR.COM, INC., a Delaware )
Corporation,
1
Nominal Defendant.
PLAINTIFF'S REPLY BRIEF
IN SUPPORT OF HIS MOTION TO COMPEL
POTTER ANDERSON & CORROON LLP
OF COUNSEL:
Alan M. Fisch, Esq. Peter J. Walsh, Jr.
Howrey Simon Arnold & White, LLP Kevin R. Shannon
1299 Pennsylvania Avenue, N.W. John M. Seaman
Washington, D.C. 20004-2402 Hercules Plaza, Sixth Floor
(202) 783-~0800 13 13 North Market Street
P.O. Box 95 1
August 23,200O Wilmington, Delaware 19899
(302) 984-6000
Attorneys for Plaintiff Christopher Kosachuk
431574
TABLE OF CONTENTS
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SNIPPETS:
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8
.
DEFENDANTS BRIEF IN OPPOSITION TO PLAINTIFFS MOTION TO COMPEL
|
EXTRACTED KEY WORDS
HARPER COUNSEL DEFENDANTS ATTORNEY-CLIENT MOTION BUSINESS DELAWARE COMPEL ATTORNEY-CLIENT PRIVILEGE COURT ONGOING NEGOTIATIONS STOCKHOLDERS COMMUNICATIONS ATTORNEYS DISCLOSURE INVESTORS STOCKHOLDERS AGREEMENT REPRESENTING HARPER AFF CONTRASENA DOCUMENTS RELATING COMPANY COMMON STOCK BUSINESS STRATEGY DOCTRINE DIRECTORS LLP WILMINGTON SHAREHOLDER ASSERTION INCORPORATION |
RIG/II/AL
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE *
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK.
Plaintiff i
V i
HENRY E. HARPIER, VIOLY McCAUSLAND, ; C.A. No. 17928
and CONTRASENA S.A.,
;
Defendants,
1
And
t
LATINADVI SOR.COM, INC., a Delaware
Corporation, i
Nominal Defendant E)
HENRY E. HARPER and LATWADVISOR.COM,)
INC.,
1
Counterclaim-plaintiffs,
V. 1
CHRISTOPHER KOSACHUK, ;
Counterclaim-defendant.
DEFENDANTS' BRIEF IN OPPOSITION TO
PLAINTIFF'S MOTION TO COMPEL
YOUNG CONAWAY STARGATT & TAYLOR LLP
David C. McBride
Josy W. Ingersoll
John J. Paschetto
1 lri' Floor, Wilmington Trust Center
1100 N. Market Street
SNIPPETS:
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9
.
OPENING BRIEF OF DEFENDANT CONTRASENA IN SUPPORT OF MOTION TO DISMISS AND TO STAY
|
EXTRACTED KEY WORDS
DELAWARE KOSACHUK HARPER DEFENDANTS MCCAUSLAND PLAINTIFF MOTION COMPLAINT YORK DISMISS PERSONAL JURISDICTION DELAWARE CORPORATION CONSPIRACY THEORY DEL MOSERES STOCKHOLDERS AGREEMENT CHRISTOPHER KOSACHUK VIOLY MCCAUSLAND LONG-ARM STATUTE SUBSTANTIAL ACTS NOMINAL DEFENDANT COUNTERCLAIM-PLAINTIFFS ATTORNEYS INSUFFICIENT FORUM STATE ALLEGED CO-CONSPIRATORS DISCOVERY KATZ NATURE |
..I
r
IN THE COURT IOF CHANCERY OF THE STATE OF DELAWARE ,
IN AND FOR NEW CASTLE COUNTY /&'
CHRISTOPHER KOSACHUK,
Plaintiff,
V.
HENRY E. HARPER, VIOLY McCAUSLAND,
and CONTRASENA S.A.,
Defendants,
LATINADVISOR.COM INC., a Delaware
Corporation,
Nominal Defendant.
_.
HENRY E. HARPER and
LATINADVISOR.COM, INC.,
.!
.
Counterclaim-plaintiffs,
i
V.
i
CHRISTOPHER KOSACHUK,
i
Counterclaim-defendant. )
OPENING BRIEF OF DEFENDANT CONTRASENA S.A.
IN SUPPORT OF ITS MOTION TO DISMISS
AND TO STAY DISCOVERY
SNIPPETS:
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10
.
REPLY TO COUNTERCLAIMS
|
EXTRACTED KEY WORDS
PLAINTIFF COUNTERCLAIM DEFENDANTS PURPORT COURT HARPER REFERENCE PARAGRAPHS COMPANY PURPORT RESPONSES PLAINTIFF RESPECTFULLY REFERS PLAINTIFF REALLEGES INCORPORATES QUOTE REFERENCED FLORIDA STATUTE DOCTRINE DELAWARE CHRISTOPHER KOSACHUK ADMIT STOCKHOLDERS AGREEMENT REQUEST REASON COUNSEL LLP ESQUIRE YORK HENRY MCCAUSLAND ATTORNEYS ALLEGES |
IN THE COURT OF CHANCERY OF THE STA.TE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK,
Plaintiff, ; Civil Action No. 17928
V.
;
HENRY E. HARPER, VIOLY McCAUSLAND,
and CONSTRASENA S.A., ;
Defendants,
And
LATIN ADVISOR.COM, INC., a Delaware
Corporation, _-..
:r; 7
Nominal Defendant. -1 `> z.:
..:. _.
`2: .`."
CI>C> . .
ZT,?!
--.--, nJ
REPLY TO COUNTERCLAIMS d.i
< .G-
Plaintiff Christopher Kosachuk, by and through his attorneys, for his reply to the
Counterclaims by Defendant Henry E. Harper ("Harper") and Nominal Defendant
LatinAdvisor.com, Inc. (the "Company"), alleges as follows:
1. Denied, except admit that Harper and the Company purport to bring
counterclaims to recover damages they claim to have sustained as a result of Kosachuk's
alleged unlawful conduct.
2. Admitted.
3. Admitted.
4. Denied.
5. Plaintiff admits the first and second sentences of paragraph 5 and denies the
third sentence.
SNIPPETS:
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11
.
ANSWER AND COUNTERCLAIMS
|
EXTRACTED KEY WORDS
PARAGRAPH HARPER STOCKHOLDERS AGREEMENT ALLEGATIONS DENY ADMIT DEFENDANTS EMPLOYMENT MCCAUSLAND SHARES CONTRASENA COMPLAINT TERMINATE COMPANY COMMON STOCK RELIEF ATTORNEYS EMPLOYEE CO-FOUNDER BANK ACCOUNT DEFENDANTS INCORPORATE RESPONSE COUNTERCLAIMS TERMINATION REFERENCE ACCORDANCE BUSINESS FLORIDA ANTI-FENCING ACT COMPANY FUNDS MIAMI BEACH |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE 7
IN AND FOR NEW CASTLE COUNTY
-1
CHRISTOPHER KOSACHUK, i
Plaintiff, I
v 1 CA. No. 17928
HENRY E. HARPER, VIOLY McCAUSLAND, i
and CONTRASENA S.A., >
Defendants, 1
and i
LATINADVISOR.COM, INC., a Delaware 1
Corporation,
i
Nominal Defendant. >
ANSWER AND COUNTERCLAIMS
Defendants Henry EC. Harper ("Harper"), Violy McCausland ("McCausland") and
Contrasena S.A. ("Contrasena"), and nominal defendant Latin Advisor.com, Inc. (the "Com-
pany"), by their attorneys, for their answer to the Complaint, respond as follows:
1. Deny the allegations in paragraph 1, except admit that: (a) piaintiff
Christopher Kosachuk (`Kosachuk") seeks to rescind the stockholders agreement annexed as
Exhibit A to the Complaint (the "Stockholders Agreement") and to obtain declaratory and other
relief; (b) Kosachuk is a co-founder of the Company and signed the Stockholders Agreement; (c)
Kosachuk's employment with the Company has been terminated; and (d) in accordance with the
Stockholders Agreement, 95% of the shares of Company common stock owned by Kosachuk at
the time his employment was terminated have been purchased from him.
SNIPPETS:
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12
.
COMPLAINT
|
EXTRACTED KEY WORDS
STOCKHOLDERS AGREEMENT DEFENDANTS PLAINTIFF HARPER DRAFT TERMINATE EMPLOYMENT BUSINESS SCHEME SHARES CHRISTOPHER KOSACHUK EXPENSES MCCAUSLAND EMPLOYEE DELAWARE CORPORATION ORCHESTRATING TERMINATION CO-FOUNDER STOCKHOLDERS AGREEMENT PURSUANT FRAUDULENT SCHEME CONTRASENA FIDUCIARY DUTIES INCORPORATES PARAGRAPHS PLAINTIFF REALLEGES REFERENCE ALLEGATIONS OWNERSHIP INVESTED CONSIDERABLE TIME |
IN THE ICOURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK,
Plaintiff,
V.
>
HENRY E. HARPER, VIOLY McCAUSLAND, >
and CONTRASENA S.A., >>
Defendants, >>
and >>
LATINADVISOR.COM, INC., a Delaware >
Corporation, >>
Nominal Defendant. >)>
COMPLAINT
Plaintiff Christopher Kosachuk, for his Complaint, alleges as follows herein upon
knowledge as to his own conduct and upon information and belief as to all other matters:
NATURE OF THIS ACTION
1. Plaintiff brings this action to rescind a "stockholders agreement" and to
obtain declaratory and other relief with respect to his ownership interest in LatinAdvisor.com,
Inc., a Delaware corporation ("LatinAdvisor.com" or the "Company"). As alleged herein,
defendants conspired to induce Plaintiff, a co-founder of the Company, to sign a draft
stockholders agreement pursuant to which Defendants -- just 12 days later -- purported to
terminate Plaintiffs "employment" and thereby divest him of all but 2.4% ownership interest in
LatinAdvisor.com. This fraudulent scheme was orchestrated by Defendants' after Plaintiff had
invested considerable time and expense in the development of LatinAdvisor.com. Realizing that
the Company was poised to command substantial value in the marketplace, Defendants violated
SNIPPETS:
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13
.
SECOND AMENDED AND SUPPLEMENTAL COMPLAINT
|
EXTRACTED KEY WORDS
HARPER DEFENDANTS STOCKHOLDERS AGREEMENT PLAINTIFF LATINADVISOR DRAFT TERMINATE SHARES ALLAM DELAWARE EMPLOYMENT BUSINESS COMMON STOCK COURT MCCAUSLAND OMAR ALLAM CHRISTOPHER KOSACHUK DELAWARE CORPORATION INCORPORATES COMPLAINT CO-FOUNDER FIDUCIARY DUTIES PARAGRAPHS TERMINATION INVESTORS EQUITY FINANCING WRITTEN CONSENT REFERENCE ALLEGATIONS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHRISTOPHER KOSACHUK,
i
Plaintiff,
1
V. ) C.A. No. 17928 I-,.;:
HENRY E. HARPER, VIOLY McCAUSLAND, t
and OMAR ALLAM,
t
Defendants,
;
And
i
LATINADVISOR.COM, INC., a Delaware
Corporation, ;
Nominal Defendant. i
HENRY E. HARPER and LATINADVISOR
HOLDINGS INC.,
Counterclaim-Plaintiffs, t
V. ;
CHRISTOPHER KOSACHUK, ;
Counterclaim-Defendant.
SECOND AMENDED AND SUPPLEMENTAL COMPLAINT
Plaintiff Christopher Kosachuk, for his Second Amended and Supplemental
Complaint, alleges as follows herein upon knowledge as to his own conduct and upon
information and belief as to all other matters:
NATURE OF THIS ACTION
1. Plaintiff brings this action to rescind a "stockholders agreement" and to
obtain declaratory and other relief with respect to his ownership interest in LatinAdvisorcom,
SNIPPETS:
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