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1
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PLAINTIFFS MOTION FOR DEFAULT JUDGMENT
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EXTRACTED KEY WORDS
CARAPICO COURT COUNSEL JUDGEMENT BY-LAW DELAWARE PENNSYLVANIA SCHEDULE MEMBERS SUBMITTING MOTION BRIEFING PLAINTIFF LITIGATION CONSCIOUS DISREGARD DEL AWARD PREJUDICE COSTS TRANSACTION COMMON PLEAS DISMISS GALLAGHER RECCHUITI OPENING CONTRAST WITHDRAW REPRESENTING PROCEEDING |
Ofi&hlAL 19
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
PHILADELPHIA STOCK EXCHANGE, INC. )1
Plaintiff, ))
V. )) C.A. No. 16809 :"
JOSEPH 1). CARAPICO, ))
Defendant. )
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PLAINTIFF'S MOTION FOR DEFAULT JUDGMEti -*
- L r`..3
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Plaintiff, Philadelphia Stock Exchange, Inc.
"Exchange"), hereby moves for a default judgment against
defendant Joseph D. Carapico. The grounds for this motion are
as follows:
BACKGROUND
I.. In the autumn of 1998, the Exchange
negotia-ting the terms of a potential transaction with the
American Stock Exchange and the National Association of
Securities Dealers that contemplated the transfer of
Exchange's assets to certain subsidiaries of the AMEX/NASD.
Mr. Carapico led a faction of members opposed to that proposed
transaction, and filed a Section 220 action in this Court as
well as an action in the Pennsylvania Court of Common Pleas
seeking a preliminary and permanent injunction against the
transaction.
2. On or about November 20, 1998, Mr. Carapico and
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2
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DEFENDANTS ANSWER TO MOTION FOR DEFAULT JUDGMENT
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EXTRACTED KEY WORDS
DELAWARE LAW SUIT EXCHANGE PENNSYLVANIA COURT LITIGATE MEMBERS BY-LAW REQUEST UNDERLYING ACTION JUDGEMENT DISREGARD JOSEPH CARAPICO NEGOTIATING TRANSACTION STOCK EXCHANGE DELAWARE COUNSEL WITHDREW SIGNATURE ADDRESSING RECCHUITI BRIEFING SCHEDULE AGREEMENT GALLAGHER CONFERENCE MATTER LAWYERS ABRAMCZYK INDICATING STATING |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN A.ND FOR NEW CASTLE COUNTY
i
PHILADELPHIA STOCK EXCHANGE, INC. :
Plaintiff
VS
. . - ._. .- llll._ A..--. ". . Ij_&. . . ..--. - _......._, I.&.. _. . . I
JOSEPH D. CARAPICO
De-fendant
DEFENDANT'S ANSWER TO
PLAINTIFF'S MOTION FOR DEFAULT JUDGMENT
AND NOW, comes Joseph D. Carapico, defendant, in his own
i right, representing himself, and answers the plaintiffs motion as follows:
1. What is stated here is only partly correct. It is true that in the autumn of
1998 the Exchange was negotiating terms of a transaction with the American
Stock Exchange and National Association of Securities Dealers. It is not true that
I lead a faction of members opposed to that proposed transaction; however, I was
one of. many concerned members who believed the negotiations were on a path
which would lead to diluting of Exchange assets and therefore filed a Section 220
action in this Court as well as an action in Pennsylvania Court of Common Pleas
i seeking a preliminary and permanent injunction.
2. To the extent that this is stated, it is true.
3. I do not know about that, since I was not aware of this
i action until later.
4. Delaware counsel may have filed certain actions, especially
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