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1
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
MKSP PLAINTIFF MEMBERS SHARES OFFICER RICHMONT RCPI MARKETING SPECIALISTS CHIEF RELEVANT TIMES COMMON STOCK EXECUTIVE OFFICER ACQUISITION FOOD CONSUMER PRICE MERGER PROPER DAMAGES ADJUDICATIONS INJUNCTIVE RELIEF COURT PRESIDENT PARTNERS BENEFICIAL OWNER OUTSTANDING SHARES LAW MANUFACTURERS SHAREHOLDERS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
----------------------------------------------------------x
THOMAS KLUG, individually and : C.A.No. \{ i+-fl'j
on behalf of all others similarly situated,
Plaintiff, CLASS ACTION COMPLAINT
- against -
RONALD D. PEDERSEN, GERALD :
:- '
R. LEONARD, TIMOTHY M. BYRD, ;,.,
JOHN P. ROCHON, NICK G. _:
BOURAS, EDWARD P. GRACE, III,
MICHAEL J. MERRIMAN, JAMES A. ;
SCHLINDWEIN, MARKETING
SPECIALISTS CORPORATION, I
( "
_
RICHMONT CAPITAL PARTNERS I,
-5
L.P., and MS ACQUISITION LTD.
Defendants.
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INTRODUCTION
Plaintiff alleges on information and belief, except for those allegations which pertain to
plaintiff which are alleged upon personal knowledge, as follows:
THE PARTIES
1. Plaintiff is and has been at all relevant times the owner of shares of the common
of Marketing Specialists Corporation ("MKSP" or "Company")
2. Defendant Ronald D. Pedersen ("Pedersen") is and was at all relevant times
and a director of MKSP. Pedersen formerly served as President, Chief Executive Officer and a
director of Richmont Marketing Specialists Inc. ("Richmont").
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