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1
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INC. V. CALLOWAY BRIEF
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EXTRACTED KEY WORDS
PLAINTIFF COURT VERNON CALLOWAY NORTH PENN ACCOUNTS FACTS ASSERTION OPENING CONTENTIONS DISREGARD CORPORATE FORM AMBIGUITY MONEY SEPARATE CERTIFICATE ESQ PLAINTIFF RESPECTFULLY PRAYS COURT DECLARE VERNON JUDGEMENT NPR ELWYN EVANS HEREBY CERTIFY COUNSEL PARTIES HANDDELIVERING DARRYL FOUNTAIN WILMINGTON ATTORNEY |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
SYL WASTE MANAGEMENT, INC.,
Plaintiff, ;
V. ) C.A. No. 13825
VERNON CALLOWAY, VICTORIA
CALLOWAY, NORTH PENN
RECYCLING, INC., NORTH PENN
SANITATION, INC., NORTH PENN ;
EQUIPMENT CORP. and REFUSE
MANAGEMENT, INC., !
Defendants.
PLAINTIFF'S PRE-TRIAL REPLY BRIEF
ELWYN EVANS, JR. (#785)
1210 N. King Street
P.O. Box 1037
Wilmington, DE 19899
302.656.5999
Attorney for Plaintiff
Dated: March 12, 1999
INTRODUCTION
Defendants' answering brief denies in general terms a
few of the facts asserted in Plaintiff's opening brief.
Plaintiff's opening brief supported those facts with references
to the exhibits which in almost all cases were obtained from the
defendants. This brief will deal with the three following
enumerated contentions made by defendants.
1. Defendants maintain that they kept full financial
records: those records they were unable to produce were lost.
(Defendants' brief, p.9).
Plaintiff's Comment: Assuming that the absence of
records indicates one type of disregard for corporate form
Defendants ask the Court not to draw that conclusion simply
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2
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INC. V. CALLOWAY BRIEF
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EXTRACTED KEY WORDS
NPR CALLOWAY VERNON CALLOWAY ACCOUNTS NPE NPS JOURNALS BUSINESS OFFICER BOOKS MONEY DISBURSEMENT JOURNALS CORPORATE FORM MONIES WASTE CORPORATE FORMALITIES DELAWARE FACTS PLAINTIFF DISSOLUTION ALTER EGO DISREGARD INDICATION ASSETS JUDGEMENT INCORPORATION STOCK RECEIVABLES PAID |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
SYL WASTE MANAGEMENT, INC.,
Plaintiff, 1 C.A. No. 13825 .;.' 7
.- -,i : :
1 I _,, i1..I
V . ) i ..--
1 i 2
VERNON CALLOWAY, et al. 1 -
1 _.. -
PLAINTIFF'S PRE-TRIAL OPENING BRIEF
Elwyn Evans, Jr., Esquire (#785)
1210 N. King Street
P.O. Box 1037
Wilmington, DE 19899
302.656.5999
Attorney for Plaintiff
dated: February :-& 1999
TABLE OF CONTENTS
Table of Authorities i
Nature and Stage of the Proceedings...................... 2
Statement of Facts....................................... 3
ARGUMENT
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