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1
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MOTION FOR EXPEDITED PROCEEDINGS
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EXTRACTED KEY WORDS
PLAINTIFFS LIMITED PARTNER INVESTORS EXPEDITING COURT DEFENDANTS DEL STATUTORY IMMEDIATE MOTION EXPEDITED PROCEEDINGS REQUEST SOLICITATIONS OBLIGATION INTERROGATORIES CHANCERY DELAWARE EMERALD BAY INLAND REAL ESTATE COMPLAINT PARTNERSHIP AGREEMENT PURCHASE IRREPARABLE HARM COMMUNICATE PURPOSE INJURY STRENGTH MARKET DELAY |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
EMERALD BAY INVESTORS, LLC
and MADISON PARTNERSHIP
LIQUIDITY INVESTORS 1, LLC,
Plaintiffs,
V .
INLAND CAPITAL FUND, L.P. and
INLAND REAL ESTATE INVESTMENT >
CORPORATION, >
Defendants. >
MOTION FOR EXPEDITED PROCEEDINGS
Plaintiffs move this Court for the entry of an Order in the form attached hereto
the time for the defendants to answer, move or otherwise respond to the complaint herein,
expediting discovery, and setting the earliest practicable date for trial. The grounds for this
motion are as follows:
1. Plaintiff Emerald Bay Investors, LLC ("Emerald Bay") is, and at all relevant times
has been, a Limited Partner of the defendant limited partnership (the "Partnership").
2. Emerald Bay requested a list of limited partners and related information, as
for in the Amended and Restated Agreement of Limited Partnership (the "Partnership
A.greement") and 6 D&C. $17-305. In its demand for the list, Emerald Bay complied with all
statutory and contractual requirements to obtain the list.
3. The defendants have failed to produce the requested information, in violation of
fiduciary duties, Delaware statutory law and the Partnership Agreement.
4. As stated in the demand, the purpose of the request for the list of limited partners is
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2
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COMPLAINT FOR INSPECTION OF PARTNERSHIP RECORDS
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EXTRACTED KEY WORDS
LIMITED PARTNERS PLAINTIFFS LISTS EMERALD BAY REQUEST PARTNERSHIP AGREEMENT GENERAL PARTNER DEFENDANTS DELAWARE COSTS INVESTMENT DUTIES PLAINTIFFS REPEAT REALLEGE INCORPORATE REFERENCE PARAGRAPHS FIDUCIARY DUTIES COURT INLAND REAL ESTATE COMPLAINT MADISON ATTORNEYS RIGHTS WRITTEN REQUEST DEL PURCHASE PAY INJURY IMMEDIATE |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
EMERALD BAY INVESTORS, LLC ) -:
/-
c': "i
and MADISON PARTNERSHIP > - 1:> `, , ;
LIQUIDITY INVESTORS 1, LLC, > _::.
> .
Plaintiffs, >> )Yj&y)& _
V. > Civil Action No. c 1:
> . ./ :
-_/
. . .
INLAND CAPITAL FUND, L.P. and _
> -:_
INLAND REAL ESTATE INVESTMENT )
CORPORATION, 11
Defendants. )
COMPLAINT FOR INSPECTION OF PARTNERSHIP RECORDS
Plaintiffs, Emerald Bay Investors ("Emerald Bay") and Madison Partnership Liquidity
Investors 1, LLC ("Madison"; collectively "plaintiffs"), by their undersigned attorneys, for their
complaint against defendants allege as follows on personal knowledge as to their own actions
and on information and belief as to the actions of others:
1, Emerald Bay is a limited liability company organized under the laws of the State of
Delaware. Emerald Bay is a Limited Partner of defendant InLand Capital Fund, L.P. (the
"Partnership"), a Delaware limited partnership.
2. Defendant Inland Real Estate Investment Corporation (the "General Partner") serves
as the Managing General Partner of the Partnerships.
3. Madison is a Delaware limited liability company that is the beneficial owner of the
units of the Partnership held of record by plaintiff Emerald Bay.
4. The Partnership is the subject of an Amended and Restated Agreement of Limited
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