IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE : i
IN AND FOR NEW CASTLE COLJNT'Y
- _ - _ - - - - - - - - ._ - - _ - . ..x
REBEKAH BENISON,
Plaintiff,
-against-
CLASS ACTION COMPLAINT
ROBERT F. TANNENHAUSER, PETER
D. BLANCK, JEROME B. ALENICK,
ROBERT W. D'LOREN, IRWIN E.
RE:DLENER, KENNETH S. SCHWARTZ,
ROBERT W. WIEN, BLC FINANCIAL
SE:RVICES, INC. and ALLIED
CAPITAL, CORPORATION,
Defendants.
Plaintiff alleges upon information and belief, except as
to paragraph 1 which plaintiff alleges upon knowledge, as follows:
1. Plaintiff is a shareholder of BLC Financial
Services, Inc. ( "BLC" c'r the "Company") .
2. BLC is a corporation duly organized and existing
ulder the laws of the state of Delaware, with its principal offices
.Located at 645 Madison Avenue,. 13th Floor, New York, New York
13022-1010. BLC, through a wholly-owned subsidiary, originates,
sells, and servi-ces loans to small businesses under the Guaranteed
Loan Program sponsored by the United States Small Business
Administration.
3. Defendant Allied Capital 'Corporation ("Allied
Capital") is a closed--end management investment company. On
November 1, 2000, Allied Capital announced that it plans to acquire
SNIPPETS:
Defendants.
Plaintiff alleges upon information and belief,
Inc. ("BLC" c'r the "Company").
13th Floor, New York, New York
Chancery, on behalf of all common stockholders of BLC, or their
There are quesions of law and fact which are
shareholders; and whether plaintiff and the other members of the
from committing the wrongs complained of herein;
Plaintiff is committed to prosecuting this action .and has retained (competent counsel
pl.aintiff is an adequate representative of the Class and will
fairly and adequately protect the interests of the Class.
would receive 0.18 shares of Al Lied Capital common stock for each
share of BLC stock.
Express operations with BLC to create a new private portfolio
acquisition of BLC and Futronics,
These cumulative benefits to the Tannenhauser/Blanck
none of the directors can be
treaches of fiduciary duty committed by the individual defendants.
Allied Capital has agreed to the overall transaction,
which fiduciaries owe to BLC's pub?.ic shareholders.
suffer irreparable damage unless the individual defendants,
or granting the Class rescissory damages;
Granting plaintiff and the clther members of the
Ctass such other and further re..Lief as may be just and proper.
|
