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1
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CLASS ACTION COMLAINT
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EXTRACTED KEY WORDS
CENDANT DEFENDANTS PLAINTIFF MEMBERS TRANSACTION STOCK DIRECTORS COMMON STOCK STOCKHOLDERS SHARES CONTROLLING YORK REASON DAMAGES PRACTICES ACTS BID REPRESENTATIVES ADJUDICATIONS RELIEF VOTING POWER MARKET FOREGOING ACTS AVIS GROUP HOLDINGS MONACO BUSINESS FIDUCIARY DUTIES PROPER |
cl;
f IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
SPENCER FALK AS TRUSTEE FOR THE FALK
GRANTOR RETAINED ANNUITY TRUST,
individually and on behalf of all others similarly
situated,
Plaintiff, CLASS ACTION
COMP#INT
- against - :_
AVIS GROUP HOLDINGS, INC. , CENDANT
CORPORATION, W. ALAN CATHCART,
LEONARD S. COLEMAN, JR.., MARTIN L.
ED'ELMAN, STEPHEN P. HOlLMES, MICHAEL P.
MONACO), A. BARRY RAND, F. ROBERT
SALERNO, and KEVIN M. SHEEIIIAN,
Defendants.
1. Plaintifi`alleges on information and belief, except for those
pertain to plaintiff which are alleged upon personal knowledge, as follows:
THE PARTIES
2. Plaintiff is and has been at all relevant times the owner of the
of Avis Group Holdings, Inc. ("Avis" or the "Company").
3. Avis is a Delaware corporation with offices at 900 Old Country
Cil:y, New York. Avis rents vehicles to business and leisure travelers through about
locations. It is the second largest general use car rental business in the world. Avis
approximately 3 1 million shares outstanding held by hundreds of s hareholders of
1
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