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1
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CLASS ACTION AND DERIVATIVE COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS SHAREHOLDERS PLAINTIFF LOWELL PUBLIC SHAREHOLDERS DIRECTORS NBC COMMON STOCK SHARES AGREEMENT OFFICER PRICE WILLIAM BERLESE PAXSON COMMUNICATIONS EXPENSE EXERCISE PRICE FIDUCIARY DUTIES INVESTMENT AGREEMENT SUBSTANTIAL PREMIUM STOCKHOLDERS CONSECUTIVE TRADING COMMON LAW DUTIES ACQUISITION IRA NOMINAL DEFENDANT DERIVATIVE COMPLAINT ENJOIN WRONGFUL ACTIONS BUSINESS JUDGMENT INJUNCTIVE RELIEF |
~,~~~~~~ P, $j
bJ b `g 2 i, s
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
WILLIAM BERLESE, IRA
Plaintiff,
Civil Action No.
V.
LOWELL W. PAXSON, JEFFREY
SAGANSKY, JAMES B. BOCOCK,
BRUCE L. BURNHAM, JAMES L.
GREENWALD and WILLIAM E.
SIMON, JR.
Defendants,
-and-
PAXSON COMMUNICATIONS
CORPORATION,
Nominal Defendant. :
------------------------------------------------------x
CLASS ACTION AND DERIVATIVE COMPLAINT
Plaintiff alleges upon information and belief, except for paragraph 4 hereof,
which is alleged upon personal knowledge, as follows:
SUMMARY OF ACTION
1. Plaintiff brings this as a class action on behalf of himself and all other
shareholders of defendant Paxson Communications Corporation ("Paxson" or the "Company")
who are similarly situated, and as a derivative action on behalf of Paxson, against the
directors and/or senior officers of Paxson to enjoin wrongful actions by the Individual
Defendants (defined herein) which are intended to benefit defendant Lowell W. Paxson and
SNIPPETS:
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