\ IN THE COURT OF CHANCERY IN THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
BRUMBAUGH INDUSTRIES, INC.,
a Delaware corporation,
Plaintiff, Civil Action No.:
V.
JAMES SNYDER, JR.,
Defendant.
COMPLAINT
Plaintiff, Brumbaugh Industries, Inc., ("Brumbaugh"), by and its through attorneys,
upon knowledge with respect to itself, and upon information and belief with respect to all
allegations, that it is entitled to a declaratory judgment against James Snyder, Jr.,
Snyder does not own any shares in Brumbaugh.
THE PARTIES
1. Plaintiff Brumbaugh is a Delaware corporation with its principal place of
in Eddystone, Delaware County, Pennsylvania, and is engaged in the business of metal coatings
related industries.
2. Defendant Snyder is a former employee of Brumbaugh and a resident of Delaware
County, Pennsylvania.
FACTUAL ALLEGATIONS
3. Beginning in or about 1990 and subsequently, defendant Snyder has made repeated
claims that he is the owner of 50% of the outstanding shares of all of the capital stock
4. The only true shareholder of Brumbaugh is Charles Brumbaugh.
SNIPPETS:
JAMES SNYDER, JR.,
Plaintiff, Brumbaugh Industries, Inc.,, by and its through attorneys, alleges
allegations, that it is entitled to a declaratory judgment against James Snyder, Jr.,, that
Snyder does not own any shares in Brumbaugh.
Plaintiff Brumbaugh is a Delaware corporation with its principal place of business
Defendant Snyder is a former employee of Brumbaugh and a resident of Delaware
County, Pennsylvania.
claims that he is the owner of 50% of the outstanding shares of all of the capital stock
The only true shareholder of Brumbaugh is Charles Brumbaugh.
exchange for his alleged ownership of 50% of the outstanding capital stock of Brumbaugh.
Delaware Code, $6501 et seq., Brumbaugh seeks a declaratory judgment.
which was formed under Delaware law, and the ownership of its stock, thus giving this Court
While Snyder was an employee of Brumbaugh, he was soliciting existing customers
of Brumbaugh for his competing business that he was starting while employed by Brumbaugh.
BASIS FOR DECLARATORY JUDGMENT SOUGHT
from uncertainty and insecurity with respect to rights, status and other legal relations;
regarding the ownership of Brumbaugh and the entitlement of its only true shareholder to its
Pursuant to Section 65 10 of Title 10 of the Delaware Code, plaintiff requests
Granting such other and further relief as this Court deems proper.
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