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1
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COMPLAINT
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EXTRACTED KEY WORDS
KARAN DKI WEISS PLAINTIFF GABRIELLE LVMH MEMBERS DONNA KARAN DIRECTORS AGREEMENT SHAREHOLDERS SALES PROPOSING LICENSE AGREEMENT IDOL OFTHE STOCK TRANSACTIONS INDIVIDUALITY NEGOTIATING YORK DESIGNEE PUBLIC SHAREHOLDERS LOYALTY COMMON BREACHES DUTIES PROTECT ACQUISITION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
---_.___-_- -- .._---- -------- _ _---- I ____._- - _______._________-----.. .--x
E. .JANET ALLRED,
Plaintiff,
V.
DONNA KARAN, STE:PHEN WEISS,
JOHN D. IDOL, DONNA KARAN
INTERNATIONAL INC., and LVMH
MOET HENNESSY LOUIS VUITTON SA, :
Defendants.
--.---C-*aemm-I_I -- -__------- _ -.--_____-------____-- s-,.----x
COMP'LAINT
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Plaintiff alleges upon information and belief, except as to paragraph 1
personal knowledge, as follows:
1. Plaintiff is the owner of shares ofrhe common stock of Donna Karan
Inc. ("DKI" or the "Company"j and has been the owner of such shares continuously since prior to
the wrongs complained of herein.
2. DKI is a corporation organized under the laws of the State of Delaware,
principal executive offices located at 550 Seventh Avenue, New York> NY.
3. Defendant Donna Karan ("Karan"), one ofthe founders of the Company, is
times relevant hereto has been Chairman of the Board of Directors of DKI. Karan and her husband,
defendant Stephen Weiss ("Weiss"), beneficially own approximately 23.8% ofthe outstanding stock
of DKI.
4. Defendant Weiss, also a co-founder of the Company, is and at all times
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