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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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MORTIMER S. COHEN,
C.A. No. ,Ka-qoZlC
Plaintiff,
-ayainst-
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. SE:LL.A, JR., PETER J. TOBIN,
DAVID H. WILLIAMS, DONALD J.
GREENE, WILLIAM EDWIN JARMAIN,
JOHN H.F. HASKELL, JR. and AXA
GROUI?,
Defendants.
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Plaintiff 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
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
JOHN H.F. HASKELL, JR.
Plaintiff alleges upon information and belief,
Plaintiff is a shareholder of AXA Financial,
principal offices located at 1290 Avenue of the Americas, New York,
Defendant AXA Group owns approximately
60.0% of 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.
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 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,
Chancery, on behalf of all common shareholders of AXA Financial, or
of the other members of the Class and plaintiff has the same
is engaging in self-dealing and not acting in good
Plaintiff has no adequate remedy at law.
rescissory damages to the Class;
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