`?\, y-` IN THE COURT OF THE CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
3ENVER E:MI?I,OYEES RETIREMENT PLAN, :
C.A. No.
Plaintiff,
--against- CLASS ACTION COMPLAINT
AXA FINANCIAL, INC., EDWARD D.
MILLER, CLAUDE BEBEAR, FRANCOISE
COLLCC'H, HENRI DE CASTRIES,
JEAN STEELE CHALSTY, JEAN-RENE
FORTOU, DIDIER PINEAU-VALENCIENNE, :
ANTHONY J. HAMILTON, MICHAEL
HEGAF.TY,, CLAUS-MICHEL DILL,
JOSEPH -;. DIONNE, JOHN T. MARTLEY,
GEORGE ,J. SELLA, JR., PETER J.
TOESIN, IAVID H. WILLIAMS, DONALD J.
GREENE, WILLIAM E:DWIN JARMAIN,
JOHN H.F. HASKELL, JR. AND AXA
GROUP,
Defendants.
Plai.ntiff alleges upon information and belief, except as to
paragraph 1 which plaintiff alleges upon knowledge, as follows:
1. Plaintiff Employees Denver Retirement Plan manages
retirement funds on behalf of employees of the City and County of
Denver, Colorado. Plaintiff is the holder of 122,400 shares of
AXA Financial, Inc. ("AXA Financia.1" 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
ooio , CM,' / 0004`l832.W?D vl
SNIPPETS:
AXA FINANCIAL, INC., EDWARD D.
JOHN H.F. HASKELL, JR.
Plai.ntiff alleges upon information and belief,
existing under the laws of the State of Delaware,
60.3% of the outstanding shares of common stock of AXA Financial.
chiller is also a Senior Executive Vice President of AXA Group.
Finaricial and a Senior Executive Vice President for Human
Financial and the Vice Chairman of the Executive Board of AXA
Defendant Michael Hegarty is a Director of AXA
E'inancial and its Chief Operating Officer.
Defendant Donald J. Greene is a Director of AXA
Defendant William Edwin Jarmain is a Director of AXA
The individual defendants, as officers and/or directors
of AXA Financial, and AXA Group, as controlling shareholder, have
a fiduciary relationship and responsibility to plaintiff and the
other public shareholders of AXA Financial and owe to them the
Chancery, on behalf of all common shareholders of AXA Financial,
the other members of the Class would be irreparably damaged
Financial's directors who are beholden to AXA Group for their
is engaging in self-dealing and not acting in good
Plaintiff- has no adequate remedy at law.
plaintiff prays for judgment and relief as
damages to the Class;
SELlNGER, P.C. The Gateway One lJorth Lexington Avenue White Plains, NY 10601-1714
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