IN THE COURT OF CHANCERY IN THE STATE OF DELAWARE I
IN AND FOR NEW CASTLE COUNTY
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RITA AUMAN,
Plaintiff, 1 C.A. No. /3068 jvb
- against -
THOMAS H. O'BRIEN, RICHARD B. PRIORY, r.. ! -.
HILDA OCHOA-BRILLEMBOURG, PETER M. GEORGE, : : .: . ..-
: _ I .
_
ROBERT L. JOHNSON, RAYMOND W. SMITH, . .:
JOHN G. MEDLIN, STEPHEN M. WOLF, r _ 'I
ROBERT LEBUHN, MATHIAS J. DEVITO, -_
HANNE M. MERRIMAN, RAKESH GANGWAL, ;*
US AIRWAYS GROUP, INC. AND UAL CORPORATION : i;
.*
Defendants.
Plaintiff alleges upon information and belief, except
as to herself, which she alleges upon knowledge, as follows:
THE PARTIES
1. Plaintiff has been, at all times relevant to this
action, and continues to be, an owner of shares of the common
stock of US Airways Group, Inc. ("US Air" or the "Company").
2. US Air is a Delaware corporation with its
principal executive offices located at 2345 Crystal Drive,
Arlington, Virginia 22221. US Air is a holding company for US
Airways, Allegheny Airlines and Piedmont Airlines.
3. Defendant UAL Corporation ("UAL") is a Delaware
corporation with its principal executive offices located at 1200
East Algonquin Road, Elkgrove Township, Illinois.
SNIPPETS:
Plaintiff alleges upon information and belief,
stock of US Airways Group, Inc..
principal executive offices located at 2345 Crystal Drive,
Allegheny Airlines and Piedmont Airlines.
Defendants Thomas H. O'Brien, Richard B. Priory,
Hilda Ochoa-Brillembourg, Peter M. George, Robert L. Johnson,
Defendants") are the members of US Air's Board of Directors.
defendant Wolf is Chairman of the Company and defendant
stockholders fiduciary obligations and were and are required to:
manner; act in furtherance of the best interests of US Air's
directors at the expense of US Air's stockholders.
CLASS ACTION ALLEGATIONS
pursuant to Rule 23 of the Rules of the Court
There are more than 66 million shares
of US Air common stock outstanding,
There are questions of law and fact which are
appropriate injunctive relief and/or corresponding declaratory
impair or impede their ability to protect their interests.
will be sold to defendant Johnson, a member of US Air's Board.
Johnson plans to use these assets to establish a new carrier
for the Company's public shareholders in connection with the
substantially assisted in the breaches of fiduciary duty
Class will suffer irreparable injury and damages absent
and their counsel, agents, employees and all persons acting under, in concert with, or for
In the event that the wrongful elements of the
proposed transactions are consummated, rescinding the same;
further relief as the Court may deem just and proper.
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