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1
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COMPLAINT
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EXTRACTED KEY WORDS
PLAINTIFF STOCKHOLDERS MEETING ANNUAL MEETING DIRECTORS COURT DELAWARE JEMO KANG LVI DEFENDANT PURSUANT ELECTION SHARES BUSINESS DETERMINATION CONDUCTING PROPER MOREOVER WHEREFORE PRAYS SUMMARILY ORDER WORLDWIDE PURPOSE REQUESTS VOTE PRESCRIBE GRANT PLAINTIFF RELIEF FEES COSTS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JEMO KANG,
Plaintiff,
V.
WORLDWIDE MEDICAL
CORPORATION, a Delaware
corporation,
Defendant.
COMPLAINT
Plaintiff Jemo Kang, by and through his undersigned attorneys, alleges for his complaint
as follows:
Nature of the Action
1. This is an action brought pursuant to Section 211 of the Delaware General
Corporation Law, 8 Del. C. 3 211 ("Section 21 l"), to compel defendant Worldwide Medical
Corporation, a Delaware corporation ("Worldwide" or the "Company"), to conduct an annual
meeting of stockholders at which directors are elected and other action taken.
The Parties
2. Plaintiff is and was at all times relevant to this action one of the two directors
Worldwide. In addition, plaintiff is a stockholder of the Company. Plaintiff was initially elected
to the Board of Directors of Worldwide on or around November l,, 1994, and at all times since
such election has continuously served as a director of Worldwide. Plaintiff and his family
LVI 23628v102/15/00
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