IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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SYLVIA PIVEN, SCOTT THOMPSON and
LENNARD STEINBERG
Plaintiffs,
V. ; C.A. No.
DONALDSON, LUFKIN & JENRETTE, INC., JOHN S. ;
CHALSTY, ANTHONY F. DADDINO, HENRI de CASTRIES, :
DAVID DELUCIA, DENIS DUVERNE, JANE MACK GOULD, : i
LOUIS HARRIS, MICHAEL J. HEGARTY, ENRI G. ,.
HOTTINGUER, HAMILTON E. JAMES, E. EDWIN
HARMAIN, FRANCIS JUNGERS, EDWARD D. MILLER, ;
STUART D. ROBBINS, JOE L. ROBY, WALTER
JEREMIAH, SANDERS III, STANLEY B.TULIN,
JOHN C. WEST,
Defendants.
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COMPLAINT
Plaintiffs, by their attorneys, allege upon information and belief, except
with respect to their ownership of Donaldson, Lufkin & Jenrette, Inc. ("DLJ") or the
"Company") common stock as follows:
PARTIES
1. Plaintiffs are owners of common stock of DLJ.
2. DLJ is a Delaware corporation with principal executive offices at
277 Park Avenue, New York, NY 10172. DLJ is a holding company with subsidiaries
which provide securities underwriting, sales and trading, merchant banking, financial
advisory, investment research, correspondent brokerage and online brokerage
services, including asset management for institutional, corporate, governmental and
SNIPPETS:
Plaintiffs are owners of common stock of DLJ.
DLJ is a Delaware corporation with principal executive offices at
277 Park Avenue, New York, NY 10172.
DLJ is a holding company with subsidiaries
advisory, investment research, correspondent brokerage and online brokerage
Defendant John S. Chalsty is Chairman of the Board and Chief
The foregoing individual directors of DLJ (collectively the "Director
Defendants"), owe fiduciary duties to DLJ and its shareholders.
brought is so numerous that joinder of all class members is impracticable.
members of the Class and which predominate over any questions affecting any
Class could create a risk of inconsistent or varying adjudications with respect to
For the reasons stated herein, a class action is superior to other
subsidiary of Credit Suisse Group.
The transaction is purportedly valued at $13.4 billion
AXA Financial owns about 71% or about 88.6 million shares of the
primary outstanding shares of DLJ and will realize pre-tax proceeds of about $8 billion
for a pre-tax gain approximating $6.2 billion.
As part of the agreement,
paid in connection with DLJ employees stock option plan and about $1.2 billion is being
Plaintiffs have no adequate remedy at law.
Granting such other and further relief as may be just and proper.
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