IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
ASHLEY PALERMO, LANCE
PALERMO, J. ROCK PALERMO, III and
ALISHA PALERMO,
Plaintiffs,
V.
P2 MANAGEMENT, INC., a Delaware
corporation,
Defendant.
COMPLAINT
Plaintiffs Ashley Palermo, Lance Palermo, J. Rock Palermo, III and Alisha Palermo
("Plaintiffs"), by their undersigned counsel, for their Complaint against defendant P2 Management,
Inc. ("P2"), allege upon knowledge as to their own acts, and upon information and belief as to all
other matters, as follows:
1. Plaintiffs are stockholders of P2.
2. P2 is a corporation organized under the laws of the State of Delaware. The
registered agent of P2 in Delaware is The Corporation Trust Company, 1209 Orange Street,
Wilmington, Delaware 19801
3. It has been more than 13 months since the last annual meeting of the
stockholders of P2. No date has been designated for the holding of P2's next annual meeting of
stockholders
4. Because P2 has not held an annual meeting of stockholders in more than 13
months, Plaintiffs are entitled to a summary order pursuant to 8 Del. C. 3 21 l(c) that P2 must hold
RLFI-2120613-l
SNIPPETS:
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
ASHLEY PALERMO, LANCE
P2 MANAGEMENT, INC., a Delaware corporation,
Plaintiffs Ashley Palermo, Lance Palermo, J. Rock Palermo, III and Alisha Palermo
, by their undersigned counsel, for their Complaint against defendant P2 Management,
Plaintiffs are stockholders of P2.
P2 is a corporation organized under the laws of the State of Delaware.
It has been more than 13 months since the last annual meeting of the
Plaintiffs are entitled to a summary order pursuant to 8 Del.
an immediate annual meeting of stockholders.
meeting, and should direct that the meeting be held at The Corporation Trust Company, 1209
Street, Wilmington, Delaware 1980 1.
awarding Plaintiffs their costs and expenses,
attorneys' fees, incurred in the prosecution of this action;
granting to Plaintiffs such other and mrther relief as the Court deems
|
