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L :IN THE ClOlJRT OF CHANCERY OF THE STATE OF
\ 1:N AND FOR NEW CASTLE COUNTY
HERBERT M. DEUTSC'H, X
Plaintiff,
v.
Civil
JACQUZC: A. NASSER, MICHAEL D.
DINGIYLAN, EDSEL B. FORD, II,
WILLIAM CLAY FORD, WILLIAM CLAY
FORD, JR., IRVINE 0. HOCKADAY,
JR., M?\RIE-JOSEE KRAVIS, ELLEN R.
X?XRAM, HOMER A. NEAL,, JORMA J.
OLLILA, CARL E. REICtARDT, ROBERT
E. RUBZN, and JOHN 1,. THORNTON,
Defendants,
and
FORD MOTOR COMFANY,
Nominal Defendant.
DERIVATIVE COMPLAINT
Plaintiff, by and through his attorneys, alleges upon
inform,stion as to himself and upon information and belief as to
other matters, as f'o:.lows:
NATURE OF THE ACTION
1. This is a shareholder derivative action
SNIPPETS:
failing to ensure that the vehicles manufactured and distributed by
the Company were equipped with safe tires; failing to act
of Company's vehicles rendered unsafe by defective
liabil:.ty through numerous lawsuits and possible regulatory action.
Defendant Jacques A. Nasser has been President
and Chief Executive Officer of the Company since 1999 and a member
Henry Ford, is Chairman of the .Board and has served on the Board
is a Board member and a lifelong Ford Executive.
16 Defendants Jacques A. Nasser,
Ford manufactures and distributes the Ford Explorer.
19" The reported safety problems with Bronco II should have
prompted the Individual Defendants to cause the Company to take
tire manufacturers competed to supply tiers for the new Explorer,
2 Michelin has at all times held a worldwide reputation
recalls," Firestone was forced to recall 13 million of its
performance and safety record of the tires supplied by Firestone.
Ford kept no safety r^.ecords on the Firestone tires it installed on
and Wilderness AT .-- standard equipment on the Explorer - both
Ii-inch ATX, ATX II and Wilderness AT models mounted on SUVs and
2 As early as 1992, motorists in Saudi Arabia complained
regulatory scrut:Lny in the United States.
interest of public safety, some more sharing of information between
breached his or her fiduciary duties and thus
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