 |
 |
|
|
|
|
|
|
|
| | | |
|
|
|
|
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
1
.
ANSWER AFFIRMATIVE DEFENSES AND COUNTERCLAIM OF YIFAN COMMUNICATIONS
|
EXTRACTED KEY WORDS
PLAINTIFF PARAGRAPH ALLEGATIONS ADMITS SIRAK COMPANY DENIES AMENDMENT ALLEGES DGCL NORMAN INCORPORATION YIFAN COMMUNICATIONS SMART GAMES STOCKHOLDERS COUNTERCLAIM PLAINTIFF GENERAL CORPORATION LAW COMMON STOCK BRANDMAKERS DEFENDANT ACCORDANCE ANNUAL MEETING STOCK CERTIFICATE SUFFICIENT KNOWLEDGE AFFIRMATIVE DEFENSES LEGAL SERVICES TRANSACTION LEGAL COUNSEL PROXY STATEMENT VERIFIED COMPLAINT |
IN THE COURT IOF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
NORMAN L. SIRAK:,
; CIVIL ACTION NO. 18309-NC
Plaintiff,
i
vs. )
YIFAN COMMUNICATIONS, INC., f/k/a
SMART GAMES INTERACTIVE, INC.,
Defendant.
YIFAN COMMUNICATIONS, INC.,
Defendant and )
Counterclaim Plaintiff,
!
vs.
;
NORMAN L. SIRAK,
;
Plaintiff and
Counterclaim Defendant. ;1
ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIM
OF DEFENDANT AND COUNTERCLAIM PLAINTIFF
- YIFAN COMMUNICATIONS, INC.
Yifan Communications, Inc. (the "Company"), for its answer, affirmative defenses and
counterclaim to the verified complaint (the "Complaint") states as follows:
1. The Company denies the allegations set forth in Paragraph 1 of the Complaint,
except it admits and further answers and alleges as follows:
a. that on July 28,2000, the Company's Sole Director acting pursuant to
Section 141(f) of the General Corporation Law of the State of Delaware
("DGCL") adopted a resolution in accordance with Section 242(b) of the
Dot. #365699
SNIPPETS:
|
|
2
.
VERIFIED COMPLAINT
|
EXTRACTED KEY WORDS
PLAINTIFF DEFENDANT DIRECTORS DELAWARE STOCKHOLDERS SHARES EXHIBIT TRANSACTION AMENDMENT CERTIFICATE GENERAL CORPORATION LAW SMART GAMES INCORPORATION COURT DECLARATORY STOCK SHAREHOLDERS VOTE CONVENE YIFAN COMMUNICATIONS DECLARATORY RELIEF CHANCERY COURT SECURITIES CONSENT AUTHORIZE CONTROVERSY EXCHANGE COMMISSION BUSINESS STIPULATES |
.,"~ o-..
[ r ' r 0% f I- E' ,`: R
i., i, L.,; ,_.r ,, j ,'"1
IN THE COURT OF CHANCERY OF DELAWARE I
IN AND FOR NEW CASTLE COUNTY
Norman L. Sirak
4035 Cinwood Street N.W.
Massillon, Ohio 44646
Plaintiff
VS. COMPLAINT FOR DECLARATORY RELIEF
Y ifan Communications, Inc.
(formerly Smart Games Interactive, Inc.)
c/o S.R. Services LLC
919 Market Street / Suite 600
Wilmington, Delaware 19801
Defendant
VERIFIED COMPLA.INT
Plaintiff Norman L. Sirak, acting pro se, approaches the Court and for his
Complaint for Declaratory Relief against the Defendant states as follows.
Introduction
1. On July 28, 2000, the Board of Directors approved a forty-to-one reverse
split and reverse takeover transaction which was orchestrated and then rubber-
stamped by its two largest shareholders. It is submitted by Plaintiff that the Board
has failed to protect the minority's interest and to investigate the fairness of this
transaction for all shareholders. This Complaint for Declaratory Relief is being
filed so as to secure a Declaratory Judgment which renders null and void the
-2-
Defendant's amendment to its Certificate of Incorporation; compel Defendant to
SNIPPETS:
|
|
|
| | | |
|
|
