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1
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MOTION TO DISMISS COUNTERCLAIMS AND THIRD-PARTY CLAIM
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EXTRACTED KEY WORDS
THIRD-PARTY CLAIM PLAINTIFFS JACOBS COURT DISMISS COUNTERCLAIMS MOTION ALLEGE DEFENDANT WILMINGTON PAIN MANAGEMENT CHANCERY DELAWARE CORPORATION JAMES AGREEMENT ALLEGATION CASTLE COUNTY PREDECESSOR HEREBY CLAIM FAILS PURPORTED AGREEMENT PARTIES BELONGS FAILURE THIRD-PARTY DEFENDANT BRYANT DENY CORPORATE FORM PERPETRATE FRAUD DEL DIRECTORS |
IN THE COURT OF CHANCERY OF THE STATE OF DE:I-AWARE
IN AND FOR NEW CASTLE COUNTY
WILMINGTON PAIN MANAGEMENT )
CLINIC, INC., a Georgia corporation, )
predecessor in interest to
4TH STREET CHIROPRACTIC
CLINIC, INC., a Delaware corporation, )
Plaintiffs,
V. : >
- _
JAMES J. MCCREADY, . :
i ,i
Defendant. )
NOTICE OF MOTION
To: James J. McCready, pro se
44 Summit Hill Drive
Strasburg, PA 17579
PLEASE: TAKE NOTICE that the within Motion to Dismiss will be presented to the
Court on at a time convenient to the Court.
L -
rr, P.A.
e Center
1201 Orange Street, Suite 725
Wilmington, DE 19801-I 155
(302) 884-6766
Attorney for movants
Date: May 17, 2001
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE: COUNTY
WILMINGTON PAIN MANAGEMENT )
CLINIC, INC., a Georgia corporation, )
SNIPPETS:
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2
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ANSWER AND COUNTERCLAIM
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EXTRACTED KEY WORDS
JACOBS PLAINTIFFS DEFENDANTS WPMC COUNTERCLAIM DEFENDANTS PARAGRAPH WILMINGTON STOCK RELIEF AFFIRMATIVE DEFENSE GEORGIA PATIENTS GOLD DELAWARE THIRD PARTY DEFENDANT TRUTH ALLEGATIONS BASIS DENIES COURT OBTAINING FAILURE OPERATING DAMAGES INFORMATION SUFFICIENT WPMC OFFICES EQUIPMENT DOCTRINE AGREEMENT MCCREADY REALLEGES PARAGRAPHS |
IN THE COURT OF CHANCERY
FOR THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
WILMINGTON PAIN MGT, CLINIC INC.
4TH STREET CHIROPRACTIC CLINIC,
INC. Plaintiff,
V.
I /
JAMES J. MCCREADY AND /dr'7ud- v'
SOVEREIGN BANK,
CA. No. 4&f@@%
IDefendants. _
V.
WILMINGTON PAIN MGT. CLINIC INC. c
4TH STREET CHIROPRACTIC CLINIC,
INC. AND BRYANT JACOBS, ~-
INDIVIDUALLY AND AS THE ALTER .
EGO OF PLAINTIFFS
V.
BRYANT JACOBS
THIRD PARTY DEFENDANT
ANSWER AND COUNTERCLAIM
Defendant James J. M&ready ("McCready") answers plaintiffs' Complaint as
follows:
1. Denied, except admitted that WPMC was incorporated in Georgia on the
date specified.
2. McCready is without knowledge or information sufficient to form a belief
as to the truth of allegations in this paragraph and on that basis denies them.
3. Admitted.
4. Admitted.
5. McCready is without knowledge or information sufficient to form a belief
as to the truth of allegations in this paragraph and on that basis denies them.
SNIPPETS:
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3
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COMPLAINT
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EXTRACTED KEY WORDS
MCCREADY PATIENTS WILMINGTON PLAINTIFFS DEFENDANT MANAGEMENT EMPLOYEE PERSONNEL FILES COURT DEFENDANT JAMES DECLARATORY STOCKHOLDER SOLE POLICE RENT MONEY WPMC/4TH STREET PLAINTIFFS WILMINGTON PAIN COMPLAINT GEORGIA DISSOLUTION PURSUANT LAWS DELAWARE RESIDES JACOBS OFFICER BRYANT COMPENSATION |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
WILMINGTON PAINI MANAGEMENT )
CLINIC, INC., a Georgia corporation, )
predecessor in interest to -
4TH STREET CHIROPRACTIC i
CLINIC, INC., a Delaware corporation, ) ,. ~-
)
Plaintiffs, ) (-A, No. /s+aa;`: ?
,' '
c, `_
V. i :., <.,-
I - - .
JAMES J. MCCREADY,
i
Defendant. )
COMPLAINT
Plaintiffs Wilmington Pain Management Clinic, Inc. and 4th Street Chiropractic
Clinic, Inc., by and through their undersigned counsel, file this Complaint for declaratory
and injunctive relief, and in support thereof state as follows:
1. Plaintiff Wilmington Pain Management Clinic, Inc. ("WPMC") was
incorporated in the State of Georgia effective June 18, 1999. WPMC was dissolved
effective August 28, 2000, but continues to exist for the purposes of prosecuting claims
arising prior to its dissolution pursuant to Georgia Code 5 14-2-1410
2. Plaintiff 4th Street Chiropractic Clinic, Inc. ("4th Street") is a corporation duly
organized and existing under the laws of the State of Delaware. 4th Street provides health
services in the location formerly occupied by WPMC.
3. Defendant James J. McCready (`McCready") resided at the times relevant
hereto at 918 New Road, Elsmere, DE 19805. On information and belief, McCready has
since moved and currently resides at 44 Summit Hill Road, Strasberg, PA 17.579-9718.
SNIPPETS:
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