4' IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
STEVE SCHNIPPER, on behalf of
himself and all others similarly (
situatled,
Plaintiff,
-against--
GLENN E. MONTGOMERY, JR., SCOTT M. /
SCHLEY, ROBERT SHARPE, JERRY
MURDOCK, JOHN W. BLEND III, and
CONVERGENT GROUP COI~PC)RATION
Defendants.
. . . . . . . . . i
CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, alleges upon information and
belief, except as to paragraph 1 which plaintiff alleges upon
knowledge, as follows:
1. Plaintiff is and has been at all relevant times a
holder of the common stock of defendant Convergent Group
Corporation ("Convergent" or the "Company").
2. Convergent is a corporation duly organized and
existing under the laws of the state of Delaware, with its
principal executive offices located at 6399 S. Fiddler's Green
Circle,. Suite 600, Englewood, Colorado 8011.1. Convergent is a
provider of consulting, software engineering, systems integration
and project management services that enable its utility and local
government clients to implement Internet-based business solutions,
also known as eBusiness solutions. These solutions enable its
SNIPPETS:
except as to paragraph 1 which plaintiff alleges upon
Corporation ("Convergent" or the "Company").
and project management services that enable its utility and local
government clients to implement Internet-based business solutions,
approximately 43,417,119 shares of common stock.
more than 6% of the Company's common stock outstanding.
Defendants Scott M. Schley, Robert Sharpe, Jerry
responsibility to plaintiff and the other public stockholders of
network and Internet solutions industries.
Cinergy Corp. is incorporated in Delaware,
The Cincinnati Gas & Electric Company and PSI Energy,
Members of the Class are located throughout the United States.
piaintiff is an adequate representative of the Class and will
v,arying adjudications with respect to individual members of the
SUBSTANTIVE ALLEGATIONS
On October 16, 2000, Schlumberger and Convergent
jointly announced the execution of a definitive merger agreement
affiliate of Convergent's largest client Cinergy,
The 'Individual Defendants suffer from serious
tL-.e Company's public stockholders receive full and fair
The amount offered in the proposed transaction is grossly
By virtue of the acts and conduct alleged herein,
Unles,s enjoined by this Court, defendants will
breach their fiduciary duties owed to plaintiff and the other
plaintiff prays for judgment and relief as follows:
may deem just and proper.
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