",
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
:IN AND FOR NEW CASTLE COUNTY
- - X
MAX BOIMAL, C.A. No. ] %a~ Kc
Plaintiff,
-against-
CLASS ACTION COMPLAINT
AXA FINANCIAL, INC, EDWARD D.
MILLER, CLAUDE BEBEAR,
FRANCOISE COLLOC'H, HENRI DE
CASTRIES, JEAN STEELE: CHALSTY,
JEAN-RENE FOURTOU, DIDIER
PINEAU-VALENCIENNE, ANTHONY J.
HAMILTON, MICHAEL HEGARTY,
CLAUS-MICHAEL DILL, JOSEPH L.
DIONNE, JOHN T. HARTLEY, GEORGE
J. SELLA, JR., PETER J. TOBIN,
DAVID H. WILLIAMS, DONALD J.
GREENE, WILLIAM EDWIN JARMAIN,
JOHN H.F. HASKELL, JR. and AXA
GROUP,
DefIendants.
_ - - _ __ _- - - - - - - -x
Plaintif-fi alleges upon information and belief, except as
to paragraph 1 which plaintiff alleges upon knowledge, as follows:
1. Plaintiff is a shareholder of AXA Financial, Inc.
("AXA Financial" or the "Company").
2. AXA Financial is a corporation duly organized and
existing under the laws of the State of Delaware, with its
principal offices located at 1290 Avenue of the Americas, New York,
New York 10104. AXA Financial is a provider of diversified
financial services, including insurance and annuity products,
investment banking and assets management services.
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
JOHN H.F. HASKELL, JR.
Plaintif-fi alleges upon information and belief,
to paragraph 1 which plaintiff alleges upon knowledge,
Plaintiff is a shareholder of AXA Financial,
existing under the laws of the State of Delaware,
principal offices located at 1290 Avenue of the Americas, New York,
60.0% o.E the outstanding shares of common stock of AXA Financial.
Defendant Edward D. Miller is a Director of AXA
Financial and its President and Chief Executive Officer.
Miller is also a Senj.or Executive Vice President of AXA Group.
Financial and the Chairman of the Executive Board of AXA Group.
Financial and a Senior Executive Vice President for Human Resources
Defendant Michael Hegarty is a Director of AXA
Defendant David H. Wil liams is a Director of AXA
Defendant Donald J. Greene is a Director of AXA
Def-endant William Edwin Jarmain is a Director of AXA
Deffendant John H.F. Haskell,
Chancery, on behalf of all common shareholders of AXA Financial, or
of the other members of the Class and plaintiff has the same
directors who are beholden to AXA Group for their offices and the
is engaging in self-dealing and not acting in good
Plaintiff has no adequate remedy at law.
plaintiff prays for judgment and relief as
rescissory damages to the Class;
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