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1
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ANSWER OF FONAR
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EXTRACTED KEY WORDS
KOPSTEIN COMPLAINT COURT FAILS ALLEGATIONS BYLAWS ANNUAL SHAREHOLDER MEETING CORPORATION LAW RELIEF DEFENDANT FONAR CORPORATION PARAGRAPHS DEMAND REQUESTS FONAR ACT OBLIGATIONS SET INSPECTION WHEREFORE DISMISS PREJUDICE AWARD FONAR COSTS ATTORNEYS COURT DEEMS RICHARD COBB ESQUIRE CERTI FIRST-CLASS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
ISADORE KOPSTEIN, 6
Plaintiff, 4 C.A. No. 17296-NC
0
V. 0
FONAR CORPORATION, 80
Defendant.
ANSWER OF FONAR CORPORATION
Defendant Fonar Corporation ("Fonar") answers the Complaint of plaintiff Isadore
Kopstein ("Kopstein") as follows:
1. Inasmuch as the Complaint fails to set forth allegations in numbered
paragraphs, all allegations which Fonar believes Kopstein has asserted are answered in this
paragraph. Admitted that Kopstein has made demands for a shareholder list from Fonar, and for
a copy of Fonar's bylaws. Admitted further that Kopstein has demanded that Fonar hold an
annual shareholder meeting. Certain documents are referenced in the Complaint, the contents of
which speak for themselves; therefore, any representations made by Kopstein about such
documents are denied. By way of further answer, Fonar has agreed to hold an annual shareholder
meeting on March 6, 1999. Admitted also that Fonar has not permitted Kopstein to inspect its
shareholder list, nor has Fonar copied its bylaws and delivered a copy to Kopstein, because
Kopstein's demands failed to comply with Section 220 of the Delaware General Corporation Law.
WLM\115802.1
Further, Kopstein's demands require that Fonar act beyond the obligations set forth under the
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