`\`;oL"- IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JOHN D. CRAWFORD, >>
Plaintiff, >) . . .
V.
IXC COMMUNICATIONS, INC., a
Delaware corporation, j
Defendant. >
COMPLAINT FOR INSPECTION OF CORPORATE RECORDS
Plaintiff, John D. Crawford, by his attorneys, Ashby & Geddes and Pender &
for his complaint against the defendant, alleges as follows on personal knowledge as to
actions and on information and belief as to the actions of others:
1. John D. Crawford ("Crawford") is a record owner of common stock of defendant
Communications, Inc. ("IXC"), a Delaware corporation,
2. On May 18, 1999, Crawford sent a written request, pursuant to 8
Del. C. $220, to inspect and copy the following documents of IXC:
the stock ledger, stockholder list, and all books and records of IXC
Communications, Inc. (I'IXC") relating to proposed purchase offers
made for IXC stock within the six (6) month period immediately
preceding the date of this demand. . . includ[ing], but . . . not
to, memoranda, letters, facsimile transmittals, e-mail, and any other
form of written or reproducible communication relating in any
manner to the proposed or potential purchase, acquisition, or merger
of or with IXC, or a majority of its issued and outstanding capital
stock.
A true and correct copy of Crawford's request is attached as Exhibit A.
3. As explained in Crawford's request, his purpose in seeking to inspect the documents
is to evaluate the advisability of proposed purchase offers made for IXC and evaluate the response
SNIPPETS:
COMPLAINT FOR INSPECTION OF CORPORATE RECORDS
Plaintiff, John D. Crawford, by his attorneys, Ashby & Geddes and Pender & Coward,
John D. Crawford is a record owner of common stock of defendant IXC
Communications, Inc., a Delaware corporation,
On May 18, 1999, Crawford sent a written request, pursuant to 8
Inc. relating to proposed purchase offers
A true and correct copy of Crawford's request is attached as Exhibit A.
As explained in Crawford's request, his purpose in seeking to inspect the documents
is to evaluate the advisability of proposed purchase offers made for IXC and evaluate the
thereto by management and the Board of Directors.
Crawford's interest as a stockholder.
IXC's actions have caused, and continue to cause, Crawford injury.
includes the immediate irreparable harm including, but not limited to, damages resulting from
the costs and expenses, including attorneys' fees, incurred in enforcing Crawford's rights to
Crawford's demand stated a purpose reasonably related to his interests as a stockholder.
WHEREFORE, John D. Crawford respectfully requests that the Court:
Enter an Order shortening the time for the defendant to move, answer, or
otherwise respond to the complaint herein, providing for expedited discovery, and
Grant such other relief as the Court deems just and proper.
Pender & Coward Fourth Floor,
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