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1
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COMPLAINT UNDER 8 DEL. C. SEC 220
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EXTRACTED KEY WORDS
PLAINTIFF BOOKS INSPECTION HUDSON MANAGEMENT DELAWARE COLONIAL INVESTMENT DIRECTORS POTTER ANDERSON EXPENSES DAGMAR SCHWABE STOCK PAID OFFICERS EMPLOYEES RELATING DEFENDANT ATTORNEYS CORROON LLP CORPORATION LAW AGENTS ESQUIRE DESIGNATIONS FEES REMUNERATION PURPOSES FOREGOING AUTHORITY ENCLOSURES |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
Dagmar Schwabe,
Plaintiff,
V. C.A. No. 1%2//G &,, :, _
, :
-:.
Colonial Investment & Management Company, i
a Delaware corporation, >
1 .-
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Defendant.
mvlPlLAINT UNDER 8 DEL. C. 6 220
Plaintiff Dagmar Schwabe, by and through her attorneys, Potter Anderson &
Corroon LLP, for her complaint against defendant, alleges upon knowledge as to herself and
otherwise upon information and belief as follows:
NATURE OF THE ACTION
1. This action, brought pursuant to Section 220 ("`Section 220") of the
Delaware G~eneral Corporation Law, seeks relief in the form of an order compelling defendant
Colonial Investment & Management Company ("Colonial" or the "Company") summarily to
make available to the Plaintiff for inspection and copying certain books and records of the
Company as demanded by the Plaintiff in a letter dated August 2, 2000.
THE PARTIES
2. Plaintiff Dagmar Schwabe ("Ms. Schwabe") is a resident of Ontario,
Canada, and at all times relevant hereto has been a record holder of common stock of Colonial
and a director of the Company.
3. Colonial is a Delaware corporation with its principal place of business
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