IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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THOMAS ROLLE,
Plaintiff,
Civil Action No. /
JOE L. ROBY, JOHN S. CHALSTY, ANTHONY F.
DADDINO, DAVID DELUCIA, HAMILTON E.
JAMES, STUART M. ROBBINS, HENRl
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.
1
SNIPPETS:
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
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 oftices 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
Defendant David DeLucia is a Director of the Company and is the head of the DLJ
the Chairman of the Board of AXF; Senior Executive Vice President Financial Services and Life
Denis Duverne is a Director of the Company,
Defendant Jane Mack Gould is a Director of the Company and has been a Senior
Defendant Louis Harris is a Director of the Company.
Defendant Henri G. Hottinguer is a Director of the Company and is Chairman of
Defendant W. Edwin Jarmain is a Director of the Company and is a director of
Francis Jungers is a Director of the Company since 199.5.
The individual defendants have denied holders
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