IN THE COURT OF CHANCERY OF THE STATE: OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
CHARLES SHAKERDGE, >
>
Plaintiff, >
V. i Civil Action No. 16451
>
ALFRED W. MARTINELLI, C. RICHARD
WILSON, ERNEST R. VARALLI, BRIAN F. 1
BILLINGS, NEIL M. HAHL, EDWARD F. )
KOSNIK, JONATHAN O'HERRON, >
WILLIAM C. PIERCE, ROBERT H. YOUNG,
GLENMOOR, LTD., GLENMOOR PARTNERS,
LLP, BUCKEYE MANAGEMENT COMPANY,
and BUCKEYE PARTNERS, L.P.,
Defendants. i
ANSWER
Defendants hereby answer the complaint herein as follows:
1. Defendants are without information sufficient to form a belief as to the truth of the
averments of paragraph 1 of the complaint.
2. Denied, except that it is admitted that Buckeye Partners L.P. ("Buckeye LIP") is a
limited partnership organized and existing under the laws of the State of Delaware, that Buckeye is
one of the nation's largest independent pipeline common carriers of refined petroleum products, and
that Buckeye operates through its subsidiaries over 3,500 miles of pipeline serving ten states.
3. Denied, except that it is admitted that Buckeye Management Company ("Buckeye
GP") is a corporation organized and existing under the laws of the State of Delaware, that Eluckeye
GP serves as the sole general partner of Buckeye LP, that Buckleye GP owns approximately a 1%
general partnership interest in Buckeye LP, and that directors and officers of Buckeye LP .perform
RLFI-171378-1 - l -
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE: OF DELAWARE
WILLIAM C. PIERCE, ROBERT H. YOUNG, GLENMOOR, LTD., GLENMOOR PARTNERS, LLP, BUCKEYE
and BUCKEYE PARTNERS, L.P.,
Defendants hereby answer the complaint herein as follows:
Defendants are without information sufficient to form a belief as to the truth of the
limited partnership organized and existing under the laws of the State of Delaware,
that Buckeye operates through its subsidiaries over 3,500 miles of pipeline serving ten
except that it is admitted that Buckeye Management Company ("Buckeye
GP") is a corporation organized and existing under the laws of the State of Delaware,
GP serves as the sole general partner of Buckeye LP, that Buckleye GP owns approximately a 1%
general partnership interest in Buckeye LP, and that directors and officers of Buckeye LP
Glenmoor owns all of the common stock of Buckeye GP.
and that shares are also owned by certain employees of Buckeye Pipe Line Services
chairman of the board and the chief executive officer Iof Buckeye GP.
director of Buckeye GP and that prior to 1996, defendant Varalli served as executive vice
Paragraph 11 contains a conclusion of law as to wtiich no response is required.
which Consent Statement speaks for itself and that the Consent Statement seeks consent to
limited partnerships in the petroleum pipeline industry formed afie:r the formation of
are not subject to the restrictions on the issuance of additional limited partnership units,
Defendants respectfully refer the Court to the Consent Statement,
The complaint fails to state a claim upon which relief may be granted.
IT IS HEREBY CERTIFIED that on July 9, 1998 two copies of the attached
|
