IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE:
lN 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, allege for his complaint
as follows:
Nature of the Action
1. This is an action brought pursuant to Section 220(d) of the Delaware General
Corporation Law, 8 Del. C. 5 220(d) ("Section 220(d)"), to compel defendant Worldwide
Medical Corporation, a Delaware corporation ("Worldwide" or the "`Company"), to make
available for inspection by plaintiff certain books and records of Worldwide.
The Parties
2. Plaintiff is and was at all times relevant to this action one of the two
Worldwide. In addition, plaintiff, his wife and two sons, together constitute the single largest
stockholder of Worldwide. Plaintiff was initially elected to the Board of Directors of
Worldwide on or around November 1, 1994, and at all times since such election has
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SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE:
Plaintiff Jemo Kang, by and through his undersigned attorneys, allege for his complaint
to compel defendant Worldwide
Medical Corporation, a Delaware corporation, to make
available for inspection by plaintiff certain books and records of Worldwide.
Pursuant to Section 220, directors of Delaware corporations are entitled to
On or about November 15, 1999, plaintiff, by and through counsel, sent a written
demand to inspect the books and records of Worldwide,
at the principal place of business of Worldwide.
Mr. Morris has control
In the First Demand Letter, plaintiff demanded the right, pursuant to Section
attorney to Jeffrey H. Nicholas, an attorney and agent for plaintiff, for purposes of
written demand to inspect the books and records of Worldwide ("Second Demand Letter") by
Exhibit B.
The Second Demand Letter followed shortly after Mr. Morris' delivery of audited
financial statements for Worldwide for the year ended December 3'1,
and its stockholders.
the form and manner of making a demand for inspection of the demanded materials.
nor has the Company permitted inspection of the documents requested in the
By reason of the foregoing, plaintiff is entitled, pursuant to Section 220, to
power of attorney to inspect all of the demanded materials or, alternatively, order Worldwide
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