IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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SARAH WOLHENDLER,
Plaintiff,
- against -
CLAUDE BEBEAR, JOHN S. CHALSTY, FRANCIOSE
COLLOC'H, HENRI DE CASTRIES, CLAUS MICHAEL :
DILL, JOSEPH L. DIONNE, JEAN-RENE FOURTOU, :
DONALD J. GREENE, ANTHONY J. HAMILTON, JOHN :
T. HARTLEY, JOHN H.F. HASKELL, JR., MICHAEL :
HEGARTY, NINA HENDERSON, W. EDWIN JARMAIN, :
EDWARD D. MILLER,DIDIER PINEAU-VALENCIENNE, :
GEORGE J. SELLA, JR., PETER J. TOBIN, DAVE H.:
WILLIAMS, AXA FINANCIAL, INC. and AXA GROUP, :
Defendants.
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CLASS ACTION COMPLAINT
Plaintiff alleges upon information and belief, except
for paragraph 1 hereof, which is alleged upon knowledge, as
fOllOWS:
1. Plaintiff has been the owner of shares of the
common stock of AXA Financial, Inc. ("AXA" or the "Company")
since prior to the transaction herein complained of and
continuously to date.
2. AXA is a corporation duly organized and existing
under the laws of the State of Delaware. The Company is one of
the world's leading financial services companies that owns such
brards as The Equitable Life Assurance Society, AXA Advisors,
SNIPPETS:
WILLIAMS, AXA FINANCIAL, INC. and AXA GROUP,:
Plaintiff alleges upon information and belief,
Plaintiff has been the owner of shares of the
AXA also owns a majority stake in Donaldson Lufkin
offices at 1290 Avenue of the Americas, New York, New York.
Defendant AXA Group owns or controls approximately
60% of the outstanding common stock of the Company.
Company and Chairman of DLJ.
Company and an Officer or Director of various AXA Group
Company an Officer or Director of various AXA Group subsidiaries.
Defendant Donald J. Greene is a Director of the
on behalf of all security holders of the Company
members is impracticable.
There are questions of law and fact which are
breached their fiduciary and other common law duties owed by them
public stockholders who are members of the class;
breach of the duty of fair dealing with respect to the plaintiff
entitled to injunctive relief or damages as a result of the
appr'opriate injunctive relief and/or corresponding declaratory
received a proposal from AXA Group for the acquisition by AXA
The price of $53.50 per share to be paid to the
AXA in light of its business, earnings and earnings power,
The proposal will, for inadequate consideration,
benefits from the transaction.
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