 |
 |
|
|
|
|
|
|
|
| | | |
|
|
|
|
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
1
.
AMENDED AND SUPPLEMENTAL PETITION PURSUANT TO 8 DEL. CODE SECS. 225 AND 227
|
EXTRACTED KEY WORDS
CASANOVA MEETING OFFICER CITRON MADINA ANNUAL MEETING PETITIONERS LAWFUL SARIEGO CONTROL SOLE SHARES BYLAWS INSTALLMENT AGREEMENTS STOCKHOLDERS PURSUANT PRESIDENT PURCHASE SUBSTITUTE ANNUAL MEETING RIGHTS MESSRS SPANISH COURT COUNSEL WRITTEN CONSENT VOTE DIRECTORS HOLDING |
~ --7
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE ;:
IN AND FOR NEW CASTLE COUNTY c _
r..: . .
MASTEC, Inc., a Florida corporation, ) - .;
Le. .-
t3
JOEL-TOMAS CITRON, and JOSE
M. SARIEGO, and MASTEC i
INTERNATIONAL INC.
i
Petitioners,
;
V . Civil Action No. 17624-NC
i
JUAN ANTONIO CASANOVA,
i>
Respondent. >
AMENDED AND SUPPLEMENTAL
PETITION PURSUANT TO 8 DEL. CODE 66 225 AND 227
The petitioners, by and through their attorneys, Ashby & Geddes and
Morgan, Lewis & Bockius LLP, for their etition
allege the following upon knowledge, information and belief:
1. This is an action seeking a judicial determination of who is the lawful
director, and who are the lawful officers, of MasTec International, Inc.
("International"), a Delaware corporation. Petitioner, MasTec, Inc. ("MasTec"), is
a publicly traded Florida corporation that designs, builds and installs advanced
telecommunications networks and systems. Petitioners, Joel-Tomas Citron and
Jose M. Sariego are employees of MasTec. Mr. Citron is MasTec's President and
1
Chief Executive Officer and Mr. Sariego its Senior Vice President and General
SNIPPETS:
|
|
2
.
RESPONDENTS OPENING BRIEF IN SUPPORT OF MOTION TO DISMISS
|
EXTRACTED KEY WORDS
COURT PETITIONERS MASTEC PURSUANT PETITION EXCLUSIVE JURISDICTION PLEDGE AGREEMENT CASANOVA DUNNING CHANCERY RULE DISMISSED PURSUANT FAILURE MOTION DELAWARE JOEL-TOMAS CITRON YORK DISPUTES SPANISH COURTS FORUM SELECTION PROVISION JUAN ANTONIO CASANOVA RESPONDENT DUNNING AFF PURCHASE PRICE FORUM SELECTION COUNSEL HOGUET NEWMAN LLP FACIALLY INVALID CLAIMS COMMIT |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
MASTEC, Inc., a Florida corporation,
JOEL-TOMAS CITRON, and JOSE M.
SARIEGO,
CA. No. 17624-NC
Petitioners,
V.
JUAN ANTONIO CASANOVA,
Respondent.
RESPONDENT'S OPENING BRIEF
IN SUPPORT OF HIS MOTION TO DISMISS
MORRIS, NICHOLS, ARSHT & TUNNELL
Martin P. Tully
Donna L. Culver
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899-1347
(302) 658-9200
Attorneys for Respondent
Juan Antonio Casanova
OF COUNSEL:
Brian C. Dunning
HOGUET NEWMAN & REGAL, LLP
10 East 40th Street
New York, New York 10016
(212) 689-8808
January 7,200O
i.
TABLE OF CONTENTS
SNIPPETS:
|
|
3
.
INC. V. CASANOVA PETITION PURSUANT TO 8 DEL. CODE SEC 225 AND 227
|
EXTRACTED KEY WORDS
CASANOVA OFFICER MEETING CITRON ANNUAL MEETING SARIEGO MADINA SHARES BYLAWS SOLE STOCKHOLDERS PETITIONERS LAWFUL INSTALLMENT PRESIDENT PURCHASE CONTROL AGREEMENTS RIGHTS MESSRS SPANISH COURT STOCK SALE PURCHASE PRICE PARTIES INSTALLMENT PAYMENTS DIRECTORS HOLDING |
`,& <7
,;i li. \; ('
i' y, .J\..-, ._
`2 \1-"
i\ IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
MASTEC, Inc., a Florida corporation, >
JOEL-TOMAS CITRON, and JO& )
M, SARIEGO, >>
Petitioners,
V.
JUAN ANTONIO CASANOVA,
Respondent.
PETITION PURSUANT TO 8 DEL. CODE 66 225 A N D 227
The petitioners, by and through their attorneys, Ashby & Geddes
Morgan, Lewis & Bockius LLP, for their petition allege the following upon
knowledge, information and beliefi
1. This is an action seeking a judicial determination of who is
director, and who are the lawful officers, of MasTec International, Inc.
("IntemationaI"), a Delaware corporation. Petitioner, MasTec, Inc.
a publicly traded Florida corporation that designs, builds and installs
telecommunications networks and systems. Petitioners, Joel-Tomas Citron
Jo& M. Sariego are employees of MasTec. Mr. Citron is MasTec's
Chief Executive Officer and Mr. Sariego its Senior Vice President and General
SNIPPETS:
|
|
|
| | | |
|
|
