IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY I
________________________________________------------------------------------~-- X
JEFFRY TIMMONS,
Plaintiff,
V.
PAINEWEBBER GROUP INC., E. GARRETT BEWKES, JR.
RET0 BRAUN, REGINA A. DOLAN, FRANK P. DOYLE,
JOSEPH J. GRANO, JR., JAMES W. KINNEAR, NAOSHI
KIYONO, ROBERT M. LOEFFLER, DONALD B. MARRON,
EDWARD RANDALL III, HENRY ROSOVSKY, KEN-ICHI
SEKIGUCHI, and JOHN RAYMOND TORELL Ill,
Defendants.
COMPLAINT
Plaintiff, by his attorneys, allege upon information and belief, except with
respect to his ownership of PaineWebber Group Inc. ("PaineWebber" or the "Company")
common stock as follows:
PARTIES
1. Plaintiff is the owner of common stock of PaineWebber.
2. PaineWebber is a Delaware corporation with principal executive
offices at 1285 Avenue of the Americas, New York, New York 10019. PaineWebber
Group is a holding company with subsidiaries which provide financial services and
products, including the purchase and sale of securities, option contracts, commodity
and financial futures contracts.
3. Defendant Donald B. Marron is Chairman of the Board and Chief
Executive Officer the Company.
4. Defendants E. Garrett Bewkes, Jr., Reto Braun, Regina A. Dolan,
SNIPPETS:
PAINEWEBBER GROUP INC., E. GARRETT BEWKES, JR.
offices at 1285 Avenue of the Americas, New York, New York 10019.
products, including the purchase and sale of securities, option contracts, commodity
and financial futures contracts.
Torell III are Directors of the Company.
"Director Defendants"), owe fiduciary duties to PaineWebber and its shareholders.
Plaintiff brings this action on his own behalf and as a class action
brought is so numerous that joinder of all class members is impracticable.
2000, there were over 145,600,OOO shares of PaineWebber common stock outstanding
members of the Class and which predominate over any questions affecting any
Defendants are acting or refusing to act on grounds generally
The prosecution of separate actions by individual members of the
Class could create a risk of inconsistent or varying adjudications with respect to
management of this litigation.
For the reasons stated herein, a class action is superior to other
with UBS AG, a Swiss bank, pursuant to which UBS agreed to purchase
following the transaction.
This $500 million pool of money to be managed by defendant
such a pool of money from which he could manage aind earn fees.
made to financier Pete Peterson, a personal friend and advisor to Marron, who was
to breach their fiduciary duties owed to plaintiff and the Class,
Plaintiff have no adequate remedy at law.
Granting such other and further relilsf as may be just and proper.
|
