IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
----------------------------------------x
MICHELLE KINGSTON,
Plaintiff,
- against - : Civi.1 Action No. /J (g 4 ifJ(q /' j (1.
LE:ROY C. HANNEMAN, JR., GLENN W.
SCHAEFFER, C. ANTHONY WAINWRIGHT,
D. KENT ANDERSON, MICHAEL E. ROSSI, :
SAM YELLEN, PHILLIP J. DION, MICHAEL
0. MAFFIE, J. RUSSELL NELSON and
DEL WEBB CORPORATION,
Defendants.
----------------------------------------x
CLASS ACTION COMPLAINT
Plaintiff, by her attorneys, Rosenthal, Monhait, Gross &
Goddess, P.A., for her complaint against defendants, alleges upon
information and belief, except for paragraph 2 hereof, which is
alleged upon knowledge as follows:
1. Plaintiff brings this action pursuant to Rule 23 of
t.he Rules of the Court of Chancery individually and as a class
action on behalf of all persons, other than defendants and those in
privity with them, who own the common stock of Del Webb Corporation
("Del Webb" or the "Company").
2. Plaintiff has been the owner of the common stock of
the Company since prior to the events complained of herein and
continuously to date.
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
Plaintiff, by her attorneys, Rosenthal, Monhait, Gross &
Goddess, P.A., for her complaint against defendants, alleges upon
who own the common stock of Del Webb Corporation
is a leading develop'er of active adult and lifestyle communities.
Company's Board of Directors.
Deferdant Leroy Hanneman, Jr., is and was at all
The class is so numerous that joinder of all members
outstanding, owned by shareholders located throughout the country.
There are questions of law and fact which are common
duties owed by them to plaintiff and the members of the class;
improperly seeking to entrench themselves in their own positions at
the expense of the public shareholders of Del Webb;
and whether the class is entitled to injunctive relief
family and country club communities located in Arizona, California,
to the overall market.
Pacific wrote a letter to defendant Hanneman requesting a meeting
acquiring control of the Company or proposing a business
California based developer of residential communities
pursuant to which Shea would purchase all of the
which would make an unsolicited takeover of the Company
Del Webb has a shareholder's rights plan (the
IDel Webb holdings either in a transaction with Shea or some other
just and proper in the premises.
|
