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1
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AMENDED CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
GENESIS PLAINTIFF SALOMON SSB DISTRIBUTION CRUDE OIL CLASS ACTION PARTNERSHIP ENERGY CASH TRANSACTIONS IPO PROSPECTUS GENERAL PARTNER UNITHOLDERS DISTRIBUTION SUPPORT PROPOSED TRANSACTIONS PROXY STATEMENT RICHARD JANIAK AMENDED CLASS ACTION COMMON UNITS LLC VON BERG CLASS ACTION COMPLAINT SPECIAL COMMITTEE MANAGEMENT GROSS MARGINS NET INCOME PROPOSED RESTRUCTURING OBLIGATION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NE;W CASTLE COUNTY
BRIJC'E E.. ZOREN: on behalf of himself :
and all others similarly situated.
Plaintiff,
1:. Civil Action No. 18096 NC
GEW.;SIS ENERGY, L.P.:
GENl.;SIS ENERGY, LLC; JOHK P.
VON BERG; MARK J. G0RMA.N;
A. RICHARD JANIAK; MICHAEL A.
PEAK.: HERBERT 1. GOODMAN.
J. CO\ILI:Y STONE; SALOMON
SMITH IMRNEY, INC.
Defendants.
NOTICE OF FILING AMENDED CLsASS ACTlON COMPLAINT;
TO: Anne C. Foster, Esquire
Richards Layton & Finger
One Rodney Square
Wilmington, Delaware 19801
PLEASE TAKE NOTICE that plaintiff herewith files an Amended (Class Action
Complaint as OF right pursuant to #Court of Chancery Rule 15. As required by Court of Chancery
Rule 1 j(aa), attached as Exhibit A is a copy of the Amended Class Action Complaint marked to
show changes from the initial pleading
ROSENTHAL, PAONHAIT, GROSS
& GODDESS, P.A.
Suite 1401, Mellon Rank Center
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2
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
CRUDE OIL PARTNERSHIP DEFENDANT SALOMON PLAINTIFF DISTRIBUTION EXCHANGE SSB GENERAL PARTNER PUBLIC UNITHOLDERS OPERATING PARTNERSHIP HOWELL DISTRIBUTION SUPPORT TRANSACTIONS COMMON UNITS OUTSTANDING IPO PROSPECTUS GROSS MARGIN PROPOSED TRANSACTIONS RICHARD JANIAK CONLEY STONE SMITH BARNEY GENESIS ENERGY YORK STOCK EXCHANGE CRUDE OIL PURCHASES NET INCOME PROPOSED RESTRUCTURING MANAGEMENT COMBINED OPERATIONS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
X
BRUCE 1% ZOREN, on behalf of himself
and all others similarly situated,
Plaintiff,
V. Civil Action No. / $0 7krW . '
I :
GENESIS ENERGY, L.P.; . .
GENESIS ENERGY, LLC; JOHN P. c3
_
VON BERG; MARK J. GORMAN; .- . CL-:
A. RICHARD JANIAK; MICHAEL A.
PEAK; HERBERT I. GOODMAN;
J. CONLEY STONE; SALOMON
SMITH BARNEY, INC.
Defendants.
X
CLASS ACTION COMPLAINT
Plaintiff, by his attorneys, alleges upon information and belief except with
respect tiz his ownership of Genesis Energy, L.P. ("Genesis," the "Company" or the
"Partnership") partnership shares ("Units") which is alleged upon personal knowledge, as
follows:
PARTIES
1. Plaintiff is the owner of Units of defendant Genesis.
2.(a) Genesis is a Delaware limited partnership with executive offices at 500
Dallas, Suite 2500, Houston, TX 77002. As of May 9, 2000, Genesis had approximately 8.62
million Units outstanding, which trade publicly on the New York Stock Exchange under the
symbol "GEL".
SNIPPETS:
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