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1
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COMPLAINT
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EXTRACTED KEY WORDS
CHANCELLOR GOSMAN DEFENDANTS ABRAHAM GOSMAN VICE PRESIDENT INDIVIDUAL DEFENDANTS DIRECTORS MICHAEL GOSMAN FEES LEASE RIGHTS ANDREW GOSMAN MANAGEMENT PLAINTIFF SHAREHOLDERS ALLEGES PARTNER REVENUE CAREMATRIX PAID ASSETS ANDERSON SUFFER SHARES CHAIRMAN EXECUTIVE VICE PRESIDENT CONTROL SONS SOLE SELF-DEALING |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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PATTY LISA, C.A. No. /766/
Plaintiff, COMPL,AINT
-against-
ABRAHAM D. GOSMAN, ANDREW D.
GOSMAN, MICHAEL M. GOSMAN,
DONALD J. AMARAL, H. LOY
ANDERSON, BEDROS BAHARIAN,
ROBERT CATALDO and STEPHEN
E. RONAI,
Defendants,
-and- :
CAREMATRIX CORPORATION,
Nominal Defendant. : ;: -'., f-Y.-!
6,
-----------------------------------x - .,
Plaintiff, by her attorneys, alleges as follows upon
information and belief, except as to the allegations which pertain
to plaintiff which are alleged upon knowledge:
1. This is a shareholder derivative action brought on
behalf and in the right of CareMatrix Corporation ("CareMatrix" or
the lVCompanyl') for injuries suffered by CareMatrix.
THE PARTIES
2. Plaintiff is and at all relevant times was the owner
of shares of common stock of nominal defendant CareMatrix.
3. CareMatrix is a Delaware corporation. CareMatrix is
a provider of assisted living and other long-term care services.
The Company owns, leases and/or manages assisted living facilities.
4. Defendant Abraham D. Gosman ("Abraham Gosman") has
served as Chairman of the Company's Board of Directors since
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