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1
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ANSWER AND AFFIRMATIVE DEFENSES OF NANOVATION TECHNOLOGIES
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EXTRACTED KEY WORDS
ALLEGATIONS RESPONSE NANOVATION COMPLAINT COURT RESPECTFULLY REFERS EXHIBIT THEREOF GAYNOR LAW RESPONSIVE PLEADING STAMFORD FIRST SENTENCE SUFFICIENT INFORMATION VERACITY INSPECTION BOOKS PROPER REQUESTS STROOCK GEORGE NANOVATION TECHNOLOGIES ATTORNEYS HEREBY SETH JOSEPH COUNSEL REGISTERED AGENT DELAWARE |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE /
IN AND FOR NEW CASTLE COUNTY
GEORGE N. GAYNOR,
Plaintiff,
V. i C.A. No. 17713-NC
>
NANOVATION TECHNOLOGIES, INC.,
a Delaware corporation. i :
>
Defendant. )
ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANT NANOVATION
TECHNOLOGIES, INC.
Nanovation Technologies, Inc. ("Nanovation" or the "Company"), by and through
its undersigned attorneys, based on its own knowledge as to itself and on information and belief
as to all other matters, hereby responds to the allegations of the complaint of George N. Gaynor
("Gaynor") as follows:
1. The allegations of paragraph 1 are admitted.
2. The allegations of paragraph 2 are admitted.
3. The allegations of paragraph 3 are admitted.
4. The allegations of paragraph 4 are denied.
5. The allegations of paragraph 5 are denied.
6. The allegations of paragraph 6 are denied, except it is admitted that Seth
Joseph, who has acted as counsel to the Company and who currently holds the title of director of
legal affairs for the Company, received copies of Gaynor's letters of September 15, 1999 and
October 4, 1999, which are attached to Gaynor's complaint as Exhibits A and B. By way of
SNIPPETS:
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2
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COMPLAINT FOR INSPECTION AND COPYING OF CORPORATE BOOKS AND RECORDS
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EXTRACTED KEY WORDS
STOCK GAYNOR STOCK OPTIONS SHARES DEMAND STOCKHOLDERS STAMFORD PERTAINING EXCHANGE EXHIBIT DELAWARE INSPECTION CORPORATE BOOKS OFFICERS DIRECTORS REQUESTS OUTSTANDING INSIDER HERETO TRANSACTION RELATING CORPORATION LAW PENDING EMPLOYEES AGREEMENTS SHAREHOLDERS DISCREPANCIES AMOUNT SPECIFY |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE!
IN AND FOR NEW CASTLE COUNTY
GEORGE N. GAYNOR, a stockholder )
of Nanovation Technologies, Inc,
r-
a Delaware corporation, ;
41
Plaintiff,
V. ; C~A~NO.,,~~~~~ 1
1 "'
NANOVATION TECHNOLOGIES, INC., )
a Delaware corporation.
;
Defendant. )
COMPLAINT FOR INSPECTION AND COPYING
OF CORPORATE BOOKS AND RECORDS PURSUANT TO
8 220 OF THE DELAWARE GENERAL CORPORATION LAW
George N. Gaynor ("Gaynor"), by his attorneys, for his complaint herein against
defendant Nanovation Technologies, Inc., a Delaware corporation ("Nanovation"), alleges
as follows:
1. Gaynor, a resident of the state of Illinois, is the owner of 50,000 shares of the
common stock of Nanovation, which he acquired in January, 1998. Upon information
and belief, based upon reported private placements of Nanovation stock, Gaynor's shares
in Nanovation have a current value in excess of $500,000.
2. Nanovation is a Delaware corporation engaged in the business of developing
its proprietary Micro-Cavity Technology ("MCT") to enhance the speed, capacity and
bandwidth of telecommunications and computing products via optical communications.
Nanovation holds several approved and pending patents relative to MCT.
WP3 : 446874.2
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