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1
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COMPLAINT
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EXTRACTED KEY WORDS
DAIMLERCHRYSLER MERGER STATEMENT/PROSPECTUS DAIMLER-BENZ SCHREMPP SECURITIES PLAINTIFF SHARES EXCHANGE MANAGEMENT MEMBERS DEFENDANTS EXECUTIVES COMMON STOCK UNITED STATES MANAGEMENT BOARD PROXY STATEMENT/PROSPECTUS SECURITIES ACT ACQUISITION STOCKHOLDERS MATERIAL FACTS MISLEADING SHAREHOLDERS SECURITIES ANALYSTS REPORTS TRANSACTION CONSTITUENCIES CONNECTION GOVERNANCE STRUCTURE REPRESENTATIONS |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DAVID ROSENBERG, ))
Plaintiff, ))
v. )) Civil Action No.
DAIMLERCHRYSLER AG, DAIMLER- )
BENZ AG and JUERGEN SCHREMPP, ))
Defendants. ))
Plaintiff for his complaint herein alleges the following on information and belief,
to allegations pertaining to himself which are based on personal knowledge, based on, inter alia, a
review of United States Securities and Exchange Commission ("SEC") filings by DaimlerChrysler
AG and Daimler-Benz AG, as well as regulatory filings and reports, securities analysts reports
and advisories about those companies, press releases and other public statements issued by those
companies, media reports about the companies and other reliable sources, and plaintiff believes
that substantial additional evidentiary support will exist for the allegations set forth herein
reasonable opportunity for discovery.
NATURE OF THE ACTION
1. This is a securities class action brought on behalf of all former shareholders
Chrysler Corporation ("Chrysler") who held shares of Chrysler on August 6, 1998 and exchanged
those shares for shares of DaimlerChrysler AG ("DaimlerChrysler") as a result of a merger (the
"Merger") between Chrysler and Daimler-Benz AG.
2. This action concerns material misrepresentations and omissions arising from
Daimler-Benz AG's acquisition of Chrysler in 1998. Specifically, defendants promised and
F:\POSSIBLE\shr00279.wpd - November 28, 2000 (4:22PM)
assured that Chryslers's well-regarded management team would remain in control of the Chrysler
operations as part of a "merger of equals." In truth and fact, defendants never intended to honor
any such commitments but used them as a device to secure shareholder approval, and then steadily
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