`3 i IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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LEE KONECHE and SCOTT SPIEGEL,
C.A. No.
Plaintiffs,
-against-
CLASS ACTION COMPLAINT
AXA FINANCIAL, INC, EDWARD D.
MILLE:R, CLAUDE BEBEAR,
FRANCOISE COLLOC'H, HENRI DE
CASTRIES, JEAN STEE:LE CHALSTY,
JEAN-RENE FOURTOU, DIDIER
PINEAU-VALENCIENNE, ANTHONY J.
HAMILTON, MICHAEL HEGARTY,
CLAUS-MICHAEL DILL, JOSEPH L.
DIONIJE, JOHN T. HARTLEY, GEORGE
J. SELLA, JR., PETER J. TOBIN,
DAVID H. WILLIAMS, DONALD J.
GREENE, WILLIAM EDWIN JARMALN,
JOHN H.F. HASKELL, JR. and AXA
GROU:?,
Defendants.
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Plaintiffs allege upon information and belief, except as
to paragraph 1 which plaintiffs al:Lege upon knowledge, as follows:
1. Plaintiffs are shareholders of AXA Financial, Inc.
("AXA Financial" or the "Company").
2. AXA Financial is a corporation duly organized and
existi..ng 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
fi-nancial services, including insurance and annuity products,
investment bank:ing and assets management services.
SNIPPETS:
JOHN H.F. HASKELL, JR.
Plaintiffs allege upon information and belief,
Plaintiffs are shareholders of AXA Financial,
Defendant AXA Group owns approximately
0% ofi 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.
Finarcial and the Chairman of the Executive Board of AXA Group.
Financ.ial and a Senior Executive Vice President for Human Resources
Defendant Michael Hegarty is a Director of AXA
Defendant John T. Hartley is a Director of AXA
Defendant George J. Sella,
Defendant Peter J. Tobin is a Director of AXA
Defendant David H. Williams is a Director of AXA
Defendant Donald J. Greene is a Director of AXA
Defendant William Edwin Jarmain is a Director of AXA
Defendant John H.F. Haskell,
of the other members of the Class and plaintiffs have the same
AXA Grollp has voting control ofi the Company and controls it proxy
is engaging in self-dealing and not acting in good
Plaintiffs have no adequate remedy at law.
plaintiffs pray for judgment and relief as
::heir damages sustained as a result of the wrongs complained ofherein;
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