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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE i
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IN AND FOR NEW CASTLE COUNTY r.' '_^
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KIRK BIERACH,
Plaintiff,
- against - Civil Action No.-'
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THOMAS M. BEGEL, R. PHILIP SILVER, cI,IASS ACTION COMPLAINT
FRANCIS A. STROBLE, CAMILLO SANTOMERO,
ANDREW M. WELLER, and TRANSPORTATION
TECHNOLOGIES, INC.,
Defendants.
Plaintiff, by his attorneys, Rosenthal, Monhait, Gross
& Goddess, P.A., for his complaint against defendants, alleges
upon information and belief, except for paragraph 2 hereof, which
is alleged upon knowledge, as follows:
1. Plaintiff brings this action pursuant to Rule 23
of the Rules of the Court of Chancery on his behalf and as a
class action on behalf of all persons, other than defendants and
those in privity with them, who own the common stock of
Transportation Technologies Industries, Inc. ("Transportation
Technologies" or the "Company").
2. Plaintiff has been the owner of the common stock
of the Company since prior to the transaction herein complained
SNIPPETS:
ANDREW M. WELLER, and TRANSPORTATION
Plaintiff, by his attorneys, Rosenthal, Monhait, Gross
& Goddess, P.A., for his complaint against defendants, alleges
Transportation Technologies Industries, Inc. ("Transportation
Plaintiff has been the owner of the common stock
duty and medium duty trucks and buses and the truck parts
Chief Financial Officer and a Director
and Camillo Santomero are Directors of the Company.
The individual defendants, by reason of their
Said defendants owed the public shareholders of Transportation
care, loyalty, and full, candid and adequate disclosure.
members is impracticable.
There are questions of law and fact which are
relief or damages as a result of the wrongful conduct committed
varying adjudications with respect to individual members of the
defendants Begel and Weller (hereinafter collectively the "Begel
Company's outstanding common stock held by the public for $20 per
The Begel Group announced that it had received commitment
and equity financing for the proposed acquisition.
The proposed transaction represents an improper
Transportation Technologies's valuable business and assets.
buy the Company at an inadequate price.
defendants have violated their fiduciary duties to Transportation
plaintiff demands judgment against the
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