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1
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COMPLAINT
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EXTRACTED KEY WORDS
LIMITED PARTNERSHIP PLAINS DEFENDANTS GENERAL PARTNER CONTROLS PLAINS RESOURCES LOSSES PRESIDENT FIDUCIARY DUTIES OFFICER PLAINTIFF BUSINESS DIRECTORS ALLEGES OPERATING ACCOUNTING PRACTICES TRADES CREDIT INVESTMENT MARKETING PLAINS MIDSTREAM SUBSIDIARIES EMPLOYEES VICE PRESIDENT AUDIT WRONGFUL REASONS SUPERVISION CLASS ACTIONS |
rk,' `- `1 ;,,c
\\\-. IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
DONALD SENDEROWITZ
Plaintiff,
v.
PLAINS ALL AMERICAN INC., GREG L.
ARMSTRONG, HARRY N. PEFANIS, PHILLIP D.
KRAMER, GEORGE R. COINER,
MICHAEL R. PATTERSON, CYNTHIA A. FEEBACK,
ROBERT V. SINNOTT and ARTHUR L. SMITH,
Defendants,
- and -
PLAINS ALL AMERICAN PIPELINE, L.P., a Delaware
Limited Partnership,
Nominal Defendant.
COMPLAINT
Plaintiff brings this action derivatively on behalf of nominal
Plains All American Pipeline, L.P. ("Plains" or the "Limited Partnership") and
upon personal knowledge as to his own acts and as to all other matters upon
information and belief, as follows:
INTRODUCTION
1. This is a unitholder's derivative action brought
Del. C. §17-1001 by plaintiff who is now and at all relevant tiimes was a
Plains. This action is brought for the benefit of Plains against defendants for
their fiduciary duties causing serious damage to Plains and to its reputation and credit
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