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1
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PLAINTIFF MEMBERS SHAREHOLDERS DEUTSCHE POST TRANSACTION COMMON INDIVIDUAL DEFENDANTS DIRECTORS COMMON STOCK SHARES FIDUCIARY DUTIES MERGER AGREEMENT JOHN BREACHING LAW RELIEF DAMAGES YORK PRICE CONSUMMATION PROPOSED TRANSACTION COURT HARTONG GUENTER ROHRMANN INTERNATIONAL CORPORATION CHAIRMAN EXECUTIVE OFFICER |
I
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
----------------------------------------------------x
STEVE SMITH,
Plaintiff,
Civil Action No. )yvyYld c
V.
HENDRIK J. HARTONG, JR.,
GUENTER ROHRMANN, JOHN M.
FOWLER, DONALD J. KELLER,
ANDREW L. LEWIS IV, RICHARD T.
NINER, JOHN RADZIWILL, NOEL E.
VARGAS and AIR EXPRESS
INTERNATIONAL CORPORATION,
Defendants.
-X
CLASS ACTION COMPLAINT
Plaintiff alleges upon information and belief, except for paragraph 2 hereof,
which is alleged upon personal knowledge, as follows:
SUMMARY OF ACTION
1. Plaintiff brings this action on behalf of himself and all other
shareholders of defendant Air Express International Corporation. ("Air Express" or the
"Company"), except defendants and their affiliates, against the directors of Air Express for
breaching their fiduciary duties to Air Express's shareholders in failing to take appropriate
measures to maximize the value of the Air Express stock held by its shareholders.
THE PARTIES
2. Plaintiff owns shares of the common stock of Air Express and has been
the owner of such shares at all times relevant hereto.
3. Air Express is a corporation organized and existing under the laws of
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