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1
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COMPLAINT
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EXTRACTED KEY WORDS
STOCKHOLDERS DIRECTORS PLAINTIFF WORLDWIDE DELAWARE ELECTION WRITTEN CONSENT LIEU ELECT DIRECTORS DESIGNATING COURT SETTINERI WORLDWIDE WEB NETWORX COMPLAINT PURSUANT DEL HOLDING CORPORATION FAILS FAILURE CHANCERY WHEREFORE PLAINTIFF RESPECTFULLY REQUESTS SUMMARILY ORDERING DETERMINATION VOTE GRANTING RELIEF COURT DEEMS PROPER GUST |
IN THE CO.LJR'T OF CHANCERY OF THE STATE OF DELAWARE 1
IN .4ND FOR NEW CASTLE COUNTY
TH OMASl SETTINERI,
Plaintiff,
i
V. ) Civil Action No. ~8!Y/~~C.
-__
WORLDWIDE WEB NETWORX
CORPORATION,
Defendant. )
COMPLAINT
Plaintiff, Thomas Settineri ("Plaintiff"), by and through his undersigned
attorneys, for his complaint, alleges as follows:
1. This action is brought pursuant to 8 Del. C.
~- 5 211 to establish a date
for the annual meeting of stockholders of Worldwide Web NetworX Corporation
("WorldWide or the "Company").
2. Plaintiff is currently a director of the Company.
3. WorldWide is a Delaware corporation with its principal executive
offices Iocated at 521 Fellowship Road, Suite 130, Mount Laurel, New Jersey 08034. The
registered agent for the Company in Delaware is The Corporation. Trust Company,
12.09 Orange Street, Wilmington, Delaware 19801.
4. Upon information and belief, the Company has not held an annual
meeting of stockholders for the election of directors within the last 13 months and no
action has been taken by written consent in lieu of an annual meeting within the last
I3 months to elect directors i:n accordance with Section 211(b).
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