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1
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ANSWER
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EXTRACTED KEY WORDS
ANNUAL MEETING CYBERSAFE CORPORATION ALLEGATIONS COMPLAINT ADMITS SCHESSEL PARAGRAPH SCHEDULE COURT HEREBY DEFENDANT DENIES SECOND SENTENCE DEMAND RELIEF WHEREFORE DEFENDANT RESPECTFULLY REQUESTS DISMISSING MOOT DENYING PLAINTIFF GRANTING KENNETH NACHBAR HEREBY CERTIFY FOREGOING IHE MANNER HARRY APT YORK |
IN THE, COURT OF CHANCERY OF THE STATE OF DELAWARE
IN .4ND FOR NEW CASTLE COUNT?'
HARRY B. SCHESSEL, 1
Plaintiff, j
V. ! C.A. Nci. 18469-NC
CYBERSAFE CORPORATION,
a Delaware corporation, I
Defendant.
ANSWER
Defendant CyberSafe Corporation hereby answers ttle Complaint as follows:
1. Defendant lacks information to admit or deny the allegations of the first
sentence of this Complaint. Defendant denies the allegations 0` the second sentence of this
Complaint, except admits that Schessel is a record holder of shares of the outstanding common
and preferred stock of defendant CyberSafe Corporation.
2. Admitted.
3. Defendant admits the allegations of the first sentence of this paragraph.
Defendant denies the allegations of the second sentence of this paragraph, and affirmatively
states that an annual meeting date of December 15, 2000 has been designated.
4. Denied, except admitted that CyberSafe has over 400 shareholders, has not
held an annual meeting in at least 24 months, and that the Company has an immediate need to
raise capital.
5. This paragraph states legal conclusions as to which no response is
necessary
&FIRMATlVE DEFENSE
6. After receiving, Mr. Schessel's demand for an annual meeting, and after
discussing with Mr. Schessel his demand for an annual meeting., the Company exercised its
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