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1
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CLASS ACTION COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS PLAINTIFF MERGER STOCK PFIZER STOCKHOLDERS AGREEMENT AHP INDIVIDUAL DEFENDANTS COMMON DIRECTORS ADEQUATE SHAREHOLDER VINK SHARES GEORGE WILLIAM COMPLAINT OFFICER REASON MEMBERS MARKET BUSINESS PROPER BREACH FIDUCIARY DUTIES DAMAGES FAILING FAIR DEALING |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
MATILDA SCHULMAN,
Plaintiff,
:
-against- C.A. No.
:
LODEWIJK J. R. DE VINK, GEORGE A. :
LORCH, ROBERT N. BURT, ALEX J.
MANDL, MICHAEL I. SOVERN,
WILLIAM H. GRAY, III, LASALLE
D. LEFFALL, JR., DONALD C. CLARK, :
JOHN A. GEORGES, WILLIAM R.
HOWELL, and WARNER-LAMBERT COMPANY,:
Defendants.
CLASS ACTION COMPLAINT
Plaintiff, by her attorneys, alleges upon information
and belief, except as to paragraph 1 which is alleged upon
knowledge, as follows:
THE PARTIES
1. Plaintiff is the owner of shares of common stock
of Warner-Lambert Company ("Warner-Lambert" or the "Company") and
has been the owner continuously of such shares since prior to the
wrongs complained of herein.
2. Warner-Lambert is a corporation duly organized and
existing under the laws of the state of Delaware. Warner-Lambert
discovers, develops, manufactures, and markets pharmaceutical,
consumer health care, and confectionery products. The Company's
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