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COMPLAINT
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EXTRACTED KEY WORDS
PTI SHARES STOCK SPLITS PLAINTIFFS SHAREHOLDERS INDIVIDUAL DEFENDANTS REVERSE STOCK SPLITS PUBLIC SHAREHOLDERS MEMBERS BIRRITTELLA SCHAEFFER COMMON STOCK OUTSTANDING CAUSED PTI PTI HOLDING DIRECTORS FIDUCIARY DUTIES FAIR DEALING LAW ADEQUATE WARREN SCHAEFFER ALLEGE PROTECT LOYALTY FAITH ULTRA VIRES PROSECUTING COUNSEL REPRESENTATIVES |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COlJNTY
DONALD RYAN and DAVID RYAN,
: CA. No. /a- 73 --Nc_
Plaintiffs,
V.
PTI HOLDING INC., MEREDITH W.
BIRRITTELLA, F:OBERT FUHRMAN,
GARY J. KOCHER, NIKOLAI
NACHAMKIN, WARREN SCHAEFFER,
Defendants.
COMPLAINT
Plaintiffs allege the following upon information and belief, except as to the allegations
relating to themselves which are alleged upon personal knowledge:
1. Plaintiffs are and were shareholders of PTI Holding Inc. ("PTI" or the "Company")
at all times material hereto.
2. The individual defendants named above are the directors of PTI. In addition.
defendant Meredith W. Birrittella ("Birrittella") is Chairman of the Board and Chief Executive
Officer of the Company, and defendant Warren Schaeffer is Secretary of PTI and President of the
Company's subsidiary, Protective Technologies International, Inc.
3. As directors/officers of PTI, the individual defendants owed its public shareholders
the highest fiduciary duties of loyalty, good faith and fair dealing.
CLASS ACTION ALLEGATIONS
SNIPPETS:
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