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1
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AMERICAN CENTENNIALS OPENING BRIEF IN SUPPORT OF MOTION TO AMEND
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EXTRACTED KEY WORDS
COMPLAINT INSURANCE DEL WESCO AMEND CONSOLIDATED GROUP AMENDMENT PLEADING COURT DEFENDANT AGREEMENT YOUSSEF CPI AMENDED COMPLAINT EXHIBIT WOODS YOUSSEF DEP MATTER PURCHASE SETTLEMENT PERMIT DELAWARE AMERICAN CENTENNIAL INSURANCE PLAINTIFF AFFILIATE DISMISS PARTY DISCOVERY RESPONSIVE PLEADING |
->7',,: . 1st ,1
i
/ . -_ . . i.; ..J
IN THE CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
ci
AMERICAN CENTENNIAL INSURANCE
COMPANY, a Delaware corporation, z
Plaintiff,
vs.
HOUSEHOLD INTERNATIONAL, INC.,
a Delaware corporation,
IDefendant.
AMERICAN CENTENNIAL INSURANCE COMPANY'S OPENING
BRIEF IN SUPPORT ITS OF MOTION TO AMEND
SEITZ, VAN OGTROP & GREEN, P.A.
GEORGE H. SEITZ, III
222 Delaware Avenue
Suite 1500
P.O. Box 68
Wilmington, DE 19899
(302)888-0600
Attorneys for Plaintiff, American Centennial
Insurance Company
15729 vl
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2
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AMENDED COMPLAINT
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EXTRACTED KEY WORDS
CLASS ACTION WESCO HOUSEHOLD SETTLEMENT WOODS CLASS AGREEMENT ROLL STIPULATION SUCCESSOR CIG REFUNDS LITIGATION CONSOLIDALXD RIGHTS PURCHASE ASSERT PURSUANT AFFILIATES ASSIGNMENT SALE OBLIGATIONS COMPLAINT STOCK PURCHASE DEFEND RELATING INDEMNIFICATION COURT DELAWARE PREMIUMS |
IK THE CHANCERI' COURT OF THE STATE OF DELA1VAltE
I.?: .4ND FOR NEX' CASTLE COUN'TI-
M OTI ON TO AMEND
AAmcfl:ican Centennial Insurances Company ("ACIC `), pursuant to Del. Ch.
l3.1.e~ 15(a) and 20(w), moves this (loud for leave to file an Amended Complaint in
1Ec fotm attached hereto as Exhibit `A'. The purpose Yoor the amendment ia to
ccstatc: cwtain claims, dclcte others, and add \;I:esco Inswxnce Company ("Wesco")
:I:; a &fe.ltlant in the claims centering on the \?l'oods Class Action Lit.igation (as
defined herein), as is more spec,ificallg set forth below:
1. The claima originally asswted in this action stem from litigation and
;Iclrnru.i,,Liative proceedingi involving entities affiliated with a group of companiw
lvhich 1.0~ ~wyoscs of thi;i Motion will be referred to as the "Consolidated Gloup 'I_
SMX the time these claims arose, those companies have gone through varioLt,i
wb:truc tu ~+tigs. mc rgers, arulior name changes. cawing some difficulty in
itientif!+ng s~~:cessors to the critities originally involved in these transactions
,I
L< -At t.he time of filing the Complaint, >1C!IC had yeceivcd an assignment
("A~srgnment") from White Mountains Insurance Group ("WMIG"), a successor 1;o
Consohdr: Icd Interxat.ional Group, Inc. ("GIG'), the p.xent corporation of the
li5i3il
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3
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COMPLAINT
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EXTRACTED KEY WORDS
BENEFICIAL/HOUSEHOLD ROLLBACK AGREEMENT HOUSEHOLD OBLIGATIONS REFUND POLICYHOLDERS STIPULATION APPLICANT CALIFORNIA WESCO CPI PURSUANT PREMIUMS ROLL PAID AMOUNT ADMINISTRATION POLICIES COURT INSURERS INDEMNIFY IUI EXPENSES SUBSEQUENT SETTLEMENT FEES COSTS INITIATE |
IN THE CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
AMERICANCENTENNIAL INSURANCE 5
COMPANY, a Delaware corporation,
Plaintiff,
vs.
HOUSEHOLD INTERNATIONAL, INC.,
a Delaware corporation,
Defendant.
COMPLAINT
INTRODUCTION:
1. This action seeks specific performance, declaratory relief, and other
related relief arising out of agreements relating to the purchase in June 1993 by Beneficial
Insurance Group Holding Company ("Beneficial") of all the issued and outstanding shares
of Wesco Insurance Company ("Wesco") from Consolidated Insurance Group of America,
Inc. ("Consolidated) and other transactions between Beneficial Corporation ("Beneficial
Corp."), an affiliate of Beneficial, and American Centennial Insurance Company ("AC/C"),
formerly a subsidiary of Consolidated.
PARTIES:
2. Plaintiff ACIC is a Delaware corporation.
3. Defendant Household International, Inc. ("Household") is a Delaware
corporation and a successor of Beneficial and Beneficial Corp. Household may be served
by serving its registered agent at Corporation Trust Company, Corporation Trust Center,
1209 Orange Street, Wilmington, Delaware 19801.
1114OVl
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