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1
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COMPLAINT
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EXTRACTED KEY WORDS
MEETING STOCKHOLDERS PLAINTIFF DEL ELECT DIRECTORS RELIEF ORDER PURSUANT SSP BUSINESS COMMON STOCK SSP-SPECIAL SITUATIONS PARTNERS ICN PHARMACEUTICALS ATTORNEYS DEFENDANT ICN CALENDAR REQUIRING STATUTORY VOTE LAWS CAYMAN WRITTEN CONSENT ADEQUATE REMEDY WHEREFORE PLAINTIFF RESPECTFULLY REQUESTS CONVENE PURPOSE ELECTING DIRECTORS DESIGNATING |
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Y >,I ,\`) IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
SSP-SPECIAL SITUATIONS
PARTNERS, INC.,
Plaintiff;
V. Civil Action No. j Sk: k AC
ICN PHARMACEUTICALS, INC.,
a Delaware corporation, >1
Defendant. j
COMPLAINT
Plainnff SSP-Special Situations Partners, Inc. ("SSP"), by its
attorneys, upon knowledge as to itself and otherwise upon information and belief, alleges
follows for its complaint against Defendant ICN Pharmaceuticals, Inc. (`YCN") as follows:
NATURE OF THE ACTION
`1 This is an action for equitable relief and for an order pursuant to 8 Del.
$ 211 (c), to require ICN to hold its annual meeting of stockholders for calendar year
Judicial relief is required because ICN has deprived SSP and other stockholders of ICN of
contractual and statutory right to vote to elect directors of ICN in violation of ICN's
obligations, its certificate of incorporation and by-laws, by failing to give notice, hold
of stockholders and permit stockholders to elect directors during calendar year 2000.
PARTIES
2. Plaintiff SSP is a corporation organized under the laws of the Cayman
SNIPPETS:
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