IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY /
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CAROLE BAJKO,
Plaintiff,
- against - : C.A. No. /z/j--z& I\x'-
STANTON D. ANDERSON, GARY J. BEBAN, : COMPLAINT
RICHARD C. BLUM, JAMES J. DUDION, BRADFORD
M. FREEMAN, DONALD M. KOLL, PAUL C. LEACH,
DAVID R. L,IND, FRFLDERIC TJ. MALEK, RAY
ELIZABETH UTTENHOVE, W. BRETT WHITE, GARY
L. WILSON, RAYMOND E. WIRTA, CB RICHARD
ELLIS SERVICES, INC., BLUM CAPITAL PARTNERS
L-P., KOLL HOLDING COMPANY and FREEDMAN
SPOGLI & CO. LX,
Defendanfs.
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Plaintiff alleges upon information and belief, except
for paragraph 1 hereof, which is alleged upon knowledge, as
follows :
1. Plaintiff has been the owner of shares of the
common stock of CB Richard Ellis Services, Inc. ("Richard Ellis"
or the "Company") since prior to the wrongs herein complained of
and continuously to date.
2 . Richard Ellis is a corporation duly organized and
existing under the laws of the State of Delaware. The Company is
a real estate management company and manages a portfolio of over
422 million square feet of property in the Americas and 600
SNIPPETS:
MALEK, RAY ELIZABETH UTTENHOVE, W. BRETT WHITE, GARY L. WILSON, RAYMOND E. WIRTA, CB RICHARD
KOLL HOLDING COMPANY and FREEDMAN
Plaintiff alleges upon information and belief,
Plaintiff has been the owner of shares of the
common stock of CB Richard Ellis Services,
Defendant B1.um Capital Partners,
Capital") owns or controls approximately 16% of the equity of the
Defendant Freeman Spogli 6 Co. LLC ("Freeman
Defendant Raymond E. Wirta is Chief Executive
Company and President and Chairman of Richard C. Blum &
Defendant Donald M. Koll is a Director of the
Company and controls Koll Holding Company.
Defendant Frederic V. Malek is a Director of the
Defendant W. Brett White is a Director of the
Defendants Blum Capital, Kol.1 Holding, Freeman
collectively referred to as the Blum Group.
Elizabeth Uttenhove and Gary L. Wilson are Directors of the
the Company's public shareholders and owe the public shareholders
members is impracticable.
There are questions of law and fact which are
re.Lief or damages as a result of the wrongful conduct committed
Under the proposed transaction, the Company's public
The price of $15.50 per share to be paid to class
unfairly aggrandize the B-turn Group at the expense of Richard
fiduciaries at the expense of the public shareholders of the
certifying plaint.iff as the Class representative and her counsel
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