IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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ANDREW LOGUERCIO,
Plaintiff,
V. Civil Action No.
JOE L. ROBY, JOHN S. CHALSTY, ANTHONY F. :
DADDINO, DAVID DELUCIA, HAMILTON E. :
JAMES, STUART M. ROBBINS, HENRI
DE CASTRIES, DENIS DUVERNE, JANE
MACK GOULD, LOUIS HARRIS, MICHAEL
HEGARTY, HENRI HOTTINGUER,
W. EDWIN JARMAIN, FRANCIS JUNGERS,
EDWARD D. MILLER, W. J. SAUNDERS, III, :
STANLEY B. TULIN, JOHN C. WEST,
AXA FINANCIAL INC. AND
DONALDSON, LUFKiN & JENRETTE, INC.,
Defendants. _
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CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, allege upon information and belief, except for paragraph 5,
which is alleged upon knowledge:
OVERVIEW
1. This class action is brought to recover damages suffered by the holders of the
million shares of DLJ Direct tracking stock (the "Tracking Stock") by reason a self-dealing
transaction orchestrated and approved by the members of the Donaldson, Lufkin & Jenrette, Inc.
(`DLJ") Board of Directors, who have personal financial interests which are in conflict with those
of the Tracking Stock holders.
2. Although DLJ Tracking Stock is designed to reflect the performance of DLJ's
online brokerage unit, DLJ Direct, the Tracking Stock shareholders are nonetheless still
SNIPPETS:
JAMES, STUART M. ROBBINS, HENRI DE CASTRIES, DENIS DUVERNE, JANE MACK GOULD, LOUIS HARRIS,
WEST, AXA FINANCIAL INC.
Plaintiff, by his attorneys, allege upon information and belief, except for paragraph 5,
This class action is brought to recover damages suffered by the holders of the 18.4
million shares of DLJ Direct tracking stock by reason a self-dealing
transaction orchestrated and approved by the members of the Donaldson, Lufkin & Jenrette, Inc.
Board of Directors, who have personal financial interests which are in conflict with those
Although DLJ Tracking Stock is designed to reflect the performance of DLJ's
Although we intend DLJdirect common stock to reflect the
will be common stockholders of Donaldson, Lufkin & Jenrette,
investment banking subsidiary, Credit Suisse First Boston.
Tracking Stock shareholders, to whom they owe an undivided duty of loyalty, care and good
Defendant DLJ is a Delaware corporation with its offices located at 277 Park
AXF is a Delaware corporation.
Defendant Joe L. Roby is a Director and Chief Executive Officer and has also
Defendant Anthony F. Daddino is a Director, Executive Vice President and Chief
the Chairman of the Board of AXF; Senior Executive Vice President Financial Services and Life
Denis Duverne is a Director of the Company,
Defendant Duverne is a director of Alliance, and Equitable Life.
Defendant Jane Mack Gould is a Director of the Company and has been a Senior
Defendant Louis Harris is a Director of the Company.
Francis Jungers is a Director of the Company since 1995.
and --through DLJ Direct--the seventh largest online brokerage.
Each of the individual defendants owe the Class members an undivided duty of
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