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1
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ANSWER AND AFFIRMATIVE DEFENSE
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EXTRACTED KEY WORDS
VERIFIED COMPLAINT DEFENDANT PRICE PLAINTIFF DEFENDANT ADMITS RESPONSIVE PLEADING INFORMATION SUFFICIENT TRUTH FALSITY VERIFIED COMPLAINT PURPORT JONES CHIEF OFFICER LISN COURT DIRECTORS REPRESENTATIVES MANAGEMENT REORGANIZATION OFTHEVERIFIED COMPL FULLY SET RESPECTFULLY REFERS MEETING PRICE BOARD PLAINTIFFS COUNSEL ATTORNEYS OFTHE VERIFIED COMPLAINT CHIEF OPERATING OFFICER PRESIDENT |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
KENNETH R. MOORE >
Plaintiff,
V. CA. No. 17709NC
LB PRICE COMMUNICATIONS, INC., )
Defendant. ;
ANSWER AND AFFIRMATIVE DEFENSE 7:
CT.-
. . I_
2-y I
Defendant LB Price Communications, Inc. ("LB Price" or "Defendant"), by and
attorneys, hereby answers the Verified Complaint filed by plaintiff Kenneth R. Moo& as follows:
<
THE PARTIES ,' I
_...
1. Defendant is without knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations contained in paragraph 1 of the Verified Complaint.
2. The allegations contained in paragraph 2 of the Verified Complaint are admitted.
JURISDICTION AND VENUE
1. The allegations of paragraph 1 of the Verified Complaint purport to state a legal
conclusion or argument that requires no responsive pleading.
2. The allegations of paragraph 2 of the Verified Complaint purport to state a legal
conclusion or argument that requires no responsive pleading.
3. The allegations of paragraph 3 of the Verified Complaint purport to state a legal
conclusion or argument that requires no responsive pleading.
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2
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MOTION FOR TEMP. RESTRAINING ORDER AND APPOINTMENT OF A CUSTODIAN
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EXTRACTED KEY WORDS
COURT DISSOLUTION MEETING LISN DELAWARE TEMPORARY RESTRAINING ORDER JONES CUSTODIAN EXHIBIT COUNSEL APPOINTMENT STOCKHOLDER MOTION VERIFIED COMPLAINT RELIEF MEMORANDUM DELAWARE LAW EMPLOYMENT AGREEMENT ALLEGATIONS DIRECTORS CASTLE COUNTY ORDER ENJOINING APPROVING SHAREHOLDER TERMINATION MBE PARAGRAPHS INCORPORATES |
IN THE COURT OF CHANCERY OF THE STATE
OF DELAWARE IN AND FOR NEW CASTLE COUNTY
KENNETH R. MOORE *
.
-.`
Plaintiff *
V. *
:-;
LB PRICE COMMUNICATIONS, INC. ;+L
* (I> , -,:*-
Defendant Civil Case -J ; J
* 1 ?fqcf? =
* * * * * * * * * *
MOTION FOR TEMPORARY RESTRAINING ORDER
AND AI'E'OINTMENT OF A CUSTODIAN
l%intiff, Kenneth R. Moore, by his undersigned counsel, submits this Motion for
Temporary Restraining Order containing a memorandum of points and authorities and
Appointment of a Custodian.
FACTS
For its statement of facts, Plaintiff respectfully refers the Court to the factual
allegations contained in Paragraphs 1 through 41 of his Verified Complaint, which are
adopted and incorporated herein (a copy of the Verified Complaint is attached hereto for
the Court's convenience as Exhibit A).
I. MOTION FOR TEMPORARY RESTRAINING ORDER
Plaintiff seeks a temporary restraining order enjoining the Corporation from
taking any action to cause its dissolution, including holding any meeting of
stockholders for the purpose of approving the dissolution of the Corporation.
Plaintiff is entitled to this order for emergency relief under Delaware law.
In Delaware, as a predicate to granting or denying interlocutory injunctive
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3
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VERIFIED COMPLAINT SEEKING A TEMPORARY RESTRAINING ORDER INJUNCTIVE RELIEF AND THE APPOINTMTNE OF A CUSTODIAN
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EXTRACTED KEY WORDS
BUSINESS LISN COURT JONES SHAREHOLDER COUNSEL CUSTODIAN STOCK DELAWARE AGREEMENT MARYLAND APPOINTMENT EMPLOYMENT MEETING DEFENDANT TEMPORARY RESTRAINING ORDER INJUNCTIVE RELIEF PRICE COMMUNICATIONS ENJOINING ELITE STREET DIRECTORS MBE TERMINATION VERIFIED COMPLAINT VERIFIED COMPLAINT SEEKING DISSOLUTION ADMINISTRATION REPRESENTATIVES POSSESSES SUBJECT-MATTER JURISDICTION |
IN THE COURT OF CHANCERY OF THE STATE
OF DELAWARE IN AND FOR NEW CASTLE COUNTY
KENNETH R. MOORE
3916 Elite Street
Bowie, Maryland 20716
Plaintiff
v.
LB PRICE COMMUNICATIONS, INC. .`.
* : ;.
Serve on: The Company Corporation CivilCase ,f3i;9@
-,
1013 Centre Road *
Wilmington, DE 19805 *
Defendant
* * * * * * * * * *
VERIFIED COMPLAINT SEEKING A TEMPORARY RESTRAINING ORDER,
INIUNCTIVE RELIEF AND THE APPOINTMENT OF A CUSTODIAN
Plaintiff, Kenneth R. Moore, a 26% shareholder of the issued and outstanding stock
of Defendant LB PRICE COMMUNICATIONS INC. (hereafter the "Corporation"),
through his undersigned counsel brings the above-captioned verified Complaint.
Plaintiff petitions this Court for injunctive relief enjoining the Defendant
Corporation.
Plaintiff also petitions this Court for the appointment of a custodian.
THE PARTIES
1. PIaintiff is anindividual residing at 3916 Elite Street, Bowie, Maryland 20716
and the registered office is located at 1313 N. Market Street, Wihnington, Delaware
19801-1151.
2. Defendant LB Price Communications, Inc. (hereafter, "the Corporation") is a
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