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IN THE COURT CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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HARBOR FINANCE PARTNERS, on behalf
of itself and all others
similarly situated,
Plaintiff,
V
CLASS ACTION COMPLAINT
CHARLES G. MCCLURE, LUDVIK F. KOCI,
ROGER S. PENSKE, DIETER E. ZETSCHE,
ECKHARD CORDES, WILLIAM E. HOGLUND,
R. JAMISON WILLIAMS, JR., JOSEPH F.
WELCH, (GARY G. JACOBS, RICHARD M.
DONNELLY, JOHN E. DODDRIDGE, and
DETROIT DIESEL CORE'.,
Defendants.
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Plaintiff, by its attorneys, alleges upon personal
know:Ledge as to its own acts and upon information and belief as to
all other matters, as follows:
NATURE OF THE ACTION
1. Plaintiff brings this action individually and as a
class action on behalf of all persons, other than defendants, who
own the common stock of Detroit Diesel Corp. (`Detroit Diesel" or
the l'Company") and who are similarly situated (the "Classtt), for
injunctive and other relief. Plaintiff seeks injunctive relief
herein, inter u, to enjoin the implementation of a transaction
SNIPPETS:
DETROIT DIESEL CORE'.,
Plaintiff brings this action individually and as a
class action on behalf of all persons, other than defendants, who
whereby DaimlerChrysler AG, through its North American subsidiary,
cash in a transaction valued at approximately $423 million.
breach of fiduciary duties owed by the defendants.
which is described in offering materials
disseminated on July 31, 2000 and amendments thereto, is being
Defendants have breached their fiduciary duties owed
the members of a special committee.
the owner of shares of Detroit Diesel common stock.
.under the laws of IDelaware with its principal executive offices
of common stock outstanding and hundreds of stockholders of record.
relevant times, President, Chief Executive Officer and a Director
Detroit Diesel Board of Directors and was formerly the Presiden,t
Defendant Roger Penske is,
Defendants William E. Hoglund, R. Jamison Williams,
and disclosure to plaintiff and the other members of the Class.
There are questions of law and fact common to the
have retained competent counsel experienced in litigation of this
The tender offer,
Securities & Exchange Commission (the "solicitation materials").
proposefd employment agreements were to be entered into with eleven
The employment agreements have never been annexed as exhibits to
shareholders are forced to make a determination whether or not to
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