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1
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ANSWER TO COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT TRUTH AVERMENT INFORMATION SUFFICIENT BISHOP COMPLAINT SHAREHOLDER AGREEMENT JAMES PLAINTIFFS BUSINESS AFFIRMATIVE DEFENSE DEMAND SCHEDULE PURCHASE AIRCRAFT EXAMINATION COURT CAITHNESS RESOURCES MANAGING FACTS DATEAD CAIRHTLESS FULLY FAMILIAR FACTS SET PRODUCTION COURIER ACQUISITION CALEDONIA MINING |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CAITHNESS RESOURCES, INC, )
(A New Jersey Corporation) 1
And JAMES BISHOP
1
Plaintiffs,
i CA. No 18226
Vs. 1)
SKYBORNE, INC. >
Defendant. 1
~_~~----~-
ANSWER TO COMPLAINT
DEFENDANT Skyborne, Inc. hereby makes the following Answer to the Plaintiffs'
numbered claims in the Complaint:
1. The Defendant is without knowledge or information sufficient to form a belief as
to the truth of the averment concerning the principal place of business of
Caithness Resources, Inc. However, it is Admitted that said party is a shareholder
of record of the Defendant.
2. The Defendant is without knowledge or information sufficient information to
form a belief as to the truth ofthe averment concerning the residence of James I>.
Bishop
3. Admitted
4. Admitted
5. Denied
6. Admitted in part. -Denied as to sole employee.
7. Admitted.
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2
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COMPLAINT
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EXTRACTED KEY WORDS
CAITHNESS RESOURCES OZDEMIR PLAINTIFFS DEMAND PHILIP OZDEMIR BISHOP BOOKS DELAWARE BUSINESS DIRECTORS JAMES PURPOSES SHAREHOLDER LAW COURT PURSUANT INSPECTION SHARES RESPONSIVE PLEADINGS YORK MANAGING AFFIDAVIT LUCA DAVID REQUEST HERETO SOLE EMPLOYEE CONTACTING MEETING |
IN THE COURT OF CHANCERY OF THE STATE 1OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CAITHNESS RESOURCES, INC.,
A New Jersey Corporation
And. JAMES D. BISHOP,
Plaintiffs,
VS.
SKYBORNE, INC.,
Defendant.
COMPLAINT
PLAINTIFFS, CAITHNESS RESOURCES, INC., and JAMES D. BISHOP, by and
through their attorneys Reed Smith Shaw & McClay, LLP, bring this action against Skybome,
Inc. pursuant to Q 220 of the IDelaware General Corporation Law ("Section 220") seeking an
Order compelling defendant, Skybome, Inc. to provide to plaintiffs certain books and records of
the Company for purposes of inspection and copying.
THE PARTIES
1. Caithness Resources, Inc. is a corporation organized under the laws of the State of
New Jersey with a principal place of business at 161 Chestnut Ridge Road, Saddle River, New
Jersey. Caithness Resources is a record holder of shares of Skybomr:, Inc.
2. Plaintiff James D. Bishop is a resident of the State of New York and a member of
the board of directors of Skyborne, Inc.
3. Defendant Skybome, Inc. ("Skybome" or "the Company"), is a corporation
organized under the laws of the State of Delaware.
4. Skybome formerly had a principal place of business at 1114 Avenue of the
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