IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY i ,. ,,
IN RE STAUFFER CHEMICAL COMPANY `7
FOUNDATION, a Delaware corporation Civil Action No. :
i ISdyQtiC ; :
-:
VERIFIED PETITION FOR APPOINTMENT OF A TRUSTEE UNDER
SECTION 279 OF THE GENERAL CORPORATION LAW
Petitioner, Richard P. Bennett ("Bennett"), by and through his undersigned attorneys, for
verified petition pursuant to Section 279 of the General Corporation Law of the State of Delaware
(the "General Corporation Law"), 8 Del. C. $279, states as follows:
1. Petitioner, Richard P. Bennett, is an attorney duly licensed to practice law in
Commonwealth of Massachusetts.
2. Until December 3, 1985, the Stauffer Chemical Company Foundation (the
"Foundatiosn") was a corporation duly authorized and existing under the General Corporation Law
of the State of Delaware (the "General Corporation Law"). The Foundation was incorporated as a
charitable corporation on July 1, 1963, A true and correct copy of the Certificate of Incorporation
of the Foundation, as amended, is attached hereto as Exhibit A.
3. On December 3, 1985, the Foundation filed a Certificate of Dissolution with the
Secretary of State of the State of Delaware. A true and correct copy ofthe Certificate of
filed by the Foundation is attached hereto as Exhibit B
4. A title search revealed that an approximately 5,400 square foot parcel
"Parcel") had been deeded in 1963, from Stauffer Chemical Company to the Foundation. A true and
correct copy of the deed is attached hereto as Exhibit C.
RLFl-2195997-I
SNIPPETS:
VERIFIED PETITION FOR APPOINTMENT OF A TRUSTEE UNDER
Petitioner, Richard P. Bennett, by and through his undersigned attorneys, for his
verified petition pursuant to Section 279 of the General Corporation Law of the State of
A true and correct copy ofthe Certificate of Dissolution
filed by the Foundation is attached hereto as Exhibit B
"Parcel") had been deeded in 1963, from Stauffer Chemical Company to the Foundation.
Foundation's predecessor in interest, F&L Salvage and Land Improvement Company, Inc., by deed
dated November 2 1, 193 1, and recorded in the Middlesex South Registry of Deeds in Book 56
On or about June 3, 2000, Bennett paid all outstanding real estate taxes to the City
of Woburn assessed against the Parcel in the amount of $4,865.35.
Tax Collector, City of Woburn for the payment of such taxes is attached as Exhibit D.
If a person other than the owner of the fee rightmlly pays the taxes
assessed on land to the collector or treasurer, before a taking or sale,
Estate Taxes by Other Than Owner Pursuant to Massachusetts General Laws, Chapter 60, Section
evidence of recording is attached hereto as Exhibit E.
Section 279 ofthe General CorporationLaw authorizes this Court to appoint a trustee
Petitioner respectfully requests that the Court:
|