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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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ROBERT SEIDENBERG,
Civil Action No.
Plaintiff,
V.
ALFRED J. BLAKE, ROBERT H. HOTZ,:
JOSEPH S. MUTO, GEORGE T.
ARATANI, ANTHONY F. SANTARELLI, : _I
RAYMOND B. DINGMAN, NORMAN R. : --
HIGO, RAYMOND E. INOUYE, and c.
MIKASA, INC.,
Defendants. ,' -
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CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, alleges upon information and
belief, except as to paragraph 1 which is alleged upon personal
knowledge, as follows:
THE PARTIES
1. Plaintiff Robert Seidenberg ("plaintiff") is the owner of
common stock of Mikasa, Inc. ("Mikasa" or the "Company") and has
been the owner of such shares continuously since prior to the
wrongs complained of herein.
2. Mikasa is a corporation duly organized and existing
under the laws of the State of Delaware, with its principal
executive offices located at 3600 Sunset Avenue, Waukegan,
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
ROBERT SEIDENBERG,
CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, alleges upon information and
common stock of Mikasa, Inc. and has
Defendant Alfred J. Blake is and at all times
Blake owns approximately 24% of the Company's outstanding
relevant hereto has been President,
Defendant Anthony Santarelli is and at all
Aratani owns approximately 14.5% of the Company's
Defendants Blake, Dingman, Santarelli and Aratani are
hereinafter collectively referred to as the "Continuing Directors".
The Continuing Directors own and/or control approximately 55% of
the outstanding common stock of the Company.
them the highest obligations of good faith, fair dealing, due care,
CLASS ACTION ALLEGATIONS
The Class is so numerous that joinder of all members is
million shares of Mikasa common stock outstanding.
There are questions of law and fact which are common to
whether the transaction described herein is gross lY unfair to the Class;
or adjudications with respect to individual members of the Class
themselves to the detriment of the Company's public shareholders.
to the detriment of the Mikasa' public stockholders.
conflicts of interest and are acting to better their own interests
the other Individual Defendants have breached and are breaching
Plaintiff and the Class have no adequate remedy at law.
plaintiff prays for judgment and relief as follows:
rescinding it and setting it aside or awarding rescissory damages
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