IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY /
.NALINE YASSIN, C.A. No. b=-=~
Plaintiff,
-against- CLASS ACTION COMPLAINT
INFINITY BROADCASTING
CORPORATION., MEL KARMAZIN,
DAVID T. MCLAUGHLIN, GEORGE H.
CONRADES ROBERT DOWNS WALTER,
FA'RID S&'lAN, WILLIAM S.
LEVINE, ARTURO R. MORENO,
BRUCE S. GORDON, JEFFREY
SHERMAN and VIACOM INC.,
Defendants.
-X
Plaintiff, by her attorneys, alleges upon information and
belief, except as to paragraph 1 which plaintiff alleges upon
knowledge, as follows:
1. Plaintiff Naline Yassin is a shareholder of
defendant Infinity Broadcasting Corporation ("Infinityl' or the
llClompan.yll ) .
2. Defendant Infinity is a corporation duly organized
and existing under the laws of the state of Delaware, with its
principal offices located at 40 West 57th Street, New York, New
York 10019. Infinit-y operates radio stations and provides outdoor
adverti.sing. The Company operates radio stations in cities across
the United States. Infinity's advertising business is conducted in
the United States, Canada, Mexico, Great Britain, Ireland and the
NetherILands.
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
INFINITY BROADCASTING CORPORATION., MEL KARMAZIN, DAVID T. MCLAUGHLIN, GEORGE H.
SHERMAN and VIACOM INC.,
Plaintiff, by her attorneys, alleges upon information and
except as to paragraph 1 which plaintiff alleges upon
principal offices located at 40 West 57th Street, New York, New
the United States, Canada, Mexico, Great Britain, Ireland and the
Inc. is a corporation duly organized and existing under the laws of the State of Delaware
which represents approximately 64.3% of the equity
Infinity's Class A and Class B common stock.
Board o:E Directors and the Company's President and Chief Executive
Defendant Bruce S. Gordon is a Director of Infinity.
Defendant Jeffrey Sherman is a Director of Infinity.
The individual defendants, as officers and/or
other public shareholders of Infinity and owe to them the highest
of the other members of the Class and plaintiff has the same
or adjudications with respect to
glass and, therefore, preliminary and final injunctive relief on
Infinity and controls approximately 90.0% of the combined voting
power of Infinity shareholders.
is engaging in self-dealing and not acting in good faith
Plaintiff has no adequate remedy at law.
rescissory damages to the Class;
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