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1
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ANSWER
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EXTRACTED KEY WORDS
PLAINTIFFS PARAGRAPH STATES RESPONSE COURT DELAWARE DEFENDANT ATTORNEYS COMPLAINT FIRST SENTENCE SECOND SENTENCE DISCLOSES INTENT CERTIFY REVIEW PURPOSE COUNSEL RICHARDS COSTS RELIEF DONALD DAVID FISCHBEIN BADILLO WAGNER BADILLO WAGNER HARDING YORK HEREBY CERTIFY HAND DELIVERY CHARLES ESQUIRE LAYTON |
lN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
KIMBERLY F. CARLSON and
SHERRI A. CROASDALE, i
Plaintiff!j,
i Civil Action No. 17715 NC
SHARED COMMUNICATIONS
SERVICES, INC.,
)
Defendants. >
ANSWER
The defendant, by and through its attorneys, responds to the numbered paragraphs of the
complaint as follows upon knowledge, information and belief:
1. This paragraph states a legal conclusion that requires no response, but admitted that
plaintiff purports to bring the action under 8 Del. C. 0 220(d).
2. The first sentence of this paragraph states a legal conclusion that requires no response.
The second sentence is admitted.
3. Admitted that SCS is a Delaware corporation but denied that its principal place of
business is in Philadelphia.
4. This paragraph states a legal conclusion that requires no response.
5. The first sentences is denied. The second sentence is denied as stated, and by way of
further response respectfully refer to the text of the demand letter. The third sentence is
admitted.
6. Admitted that this quotes the text of the demand letter, denied that the demand letter
discloses the actual intent of the plaintiffs.
7. This paragraph states a legal conclusion that requires no response.
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2
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COMPLAINT
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EXTRACTED KEY WORDS
PLAINTIFFS SCS DEMAND LETTER DEMANDED MATERIALS DIRECTORS PURSUANT BOOKS BUSINESS REASON DEFENDANT DELAWARE CORPORATION INSPECTION ORDER SCS COMMUNICATIONS PURPOSE PROPER PERMIT COURT SUMMARILY ORDER SCS PERFORMANCE OFTHE MANAGEMENT PROPERLY FULFILL DUTIES STOCKHOLDERS PROVISIONS MANNER FOREGOING WHEXEFORE PLAINTIFFS PRAY |
IN AND FOR NEW CASTLE COUNTY
-'
r
KIMBERLEY F. CARLSON and SHERRI ) `i
A. CROASDALE, 1
Plaintiffs,
V.
SHARED COMMUNICATIONS
SERVICES, INC.,
Defendant.
COMPLAINT
Plaintiffs Kimberley F. Carlson and Sherri A. Croasdale, by and through their undersigned
attorneys, allege for their 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. 9 220(d) ("`Section 220(d)"), to compel defendant Shared
Communications Services, Inc. ("SCS" or the "Company") to make available for inspection by
plaintiffs certain books and records of SCS.
The Parties
2. Plaintiffs are and were at all times relevant to this action directors of SCS.
were elected to the board of directors of SCS as designees of the holders of the Company's Series
A Convertible Preferred Stock.
3. Defendant SCS is a Delaware corporation with its principal place of business in
Philadelphia, Pennsylvania.
FZFl-2100426-l
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