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1
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PLAINTIFFS PRE-TRIAL MEMORANDUM
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EXTRACTED KEY WORDS
CHRISTIANA MARINE SERVICE BRANDYWINE MARINE SERVICE CORPORATION PARTNERSHIP AGREEMENT TUGBOAT PARTIES DELAWARE REGGIE ACCOUNT DEL BUSINESS DISTRIBUTION GROSS RECEIPTS WILMINGTON BATES DISSOLUTION CHARTERS COURT TUG TWO-THIRDS COMMENCING REVENUE CREW THIRD PARTIES PROFITS COSTS EMPLOYEES EXPENSES |
L
AW OFFICES
POTTER, CARMINE 2% LEONARD, PA.
040 N . U N I O N S T R E E T
S T E P H E N B . P O T T E R P.O. BOX 514
K E N N E T H F . C A R M I N E WILMINGTON. DELAWARE uxo~
T E 101
J A M E S R . L E O N A R D T E L E P H O N E (302) 058-8040
J E N N I F E R - K A T E A A R O N S O N ' TELECOPIER (302) 054-8377
` A L S O A D M I T T E D I N N J . P A
November 9, 1999
The Honorable Vice Chancellor Strine
Court of Chancery
1020 North King Street
Wilmington, DE 1980 1
:- ?
,": 81 J
:<
RE: Brandywine Joint Venture, et al v. Christiana
is
I ,p
C.A. No.: 16418-NC
`,i
4
SNIPPETS:
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2
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BRANDYWINE JOINT VENTURE V. CHRISTIANA MARINE SERVICE AMENDED COMPLAINT
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EXTRACTED KEY WORDS
JOINT VENTURE MARINE BRANDYWINE PLAINTIFF DEFENDANT TUGBOAT SUM ACCOUNTING DELAWARE AGREEMENT REGGIE ONE-THIRD IOINT VENTURE CERTIFICATE COURT HERETO COMPLAINT PURSUANT CREW NAVIGATION FUELS OILS BRANDVWINE TWO-THIRDS CHARTER DOCK TOTAL SUM MONEV TERMLNATION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
BRANDYWINE JOINT VENTURE, and
BRANDYWINE MARINE, INC.,
Plaintiff,
p :_
V. C.A. No. 16418 - NC ^_ _
CHRISTIANA MARINE SERVICE s I\._
CORPORATION, a Delaware Corp., _. -
r .:
Defendant.
AMENDED COMPLAINT
1. Plaintiff, Brandywine Joint Venture, is a joint venture created by agreement
between Christiana Marie Service Corp. (Christiana) and Brandywine Marine, Inc. Plaintiff,
Brandywine Marine, Inc. is a Delaware Corporation.
2. Defendant. Christiana Marine Service Corporation is a corporation of the State of
Delaware and service of process may be made upon defendant by serving its registered agent,
Christiana Marine Service Corporation, 10 1 Rogers Road, Suite 20 1, Wilmington, DE 19801 a
in the alternative, its attornev, William D. Sullivan, Esquire.
. .
3. On or about June 24, 1992, the parties hereto P
entered into a joint venture agreement, a
copv of which is attached hereto and made part of this complaint. v
l3+ Pursuant thereto, Brandywine Marine was to provide crew, navigation and supply fuels and
oils and other cost incidental to the business of the joint venture. Christiana was to provide the
tugboat "Reggie B" and insurance on said tugboat for Brandvwine Marine.
SNIPPETS:
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