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1
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ANSWER
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EXTRACTED KEY WORDS
COMPLAINT DEFENDANT EXHIBIT DOCUMENT SPEAKS COURT THOMAS HALL REGISTERED AGENT DELAWARE PLAINTIFF FAILS RELIEF PROPER CERTIFICATE FILINGS SECURITIES EXCHANGE COMMISSION SECOND AFFIRMATIVE DEFENSE PROPER PURPOSE DEL UNCLEAN HANDS WHEREFORE DEFENDANT GIMMEABIDCOM REQUESTS JUDGMENT AWARD COSTS ATTORNEYS FEES COURT DEEMS HEREBY CERTIFY |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
THOMAS J. HALL,
Plaintiff, 1
v. i C.A. No. 19284-NC y:~
.~~
GIMMEABID.COM, INC., i
Defendant. I
1. Paragraph 1 ofthe Complaint states a legal conclusion to which no response
is reqired. It is admitted that attached to the Complaint as Exhibit A is a copy of a letter
dated August 13, 2001, from Plaintiff Thomas J. Hall ("Plaintiff') to Defendant
GimmeaBid.com, Inc. ("Defendant"), which document speaks for itself
2. Admitted that Plaintiff is a shareholder of Defendant.
3. Admitted that Defendant is a corporation organized under the laws of the
StateofDelaware, doingbusiness at 2100NorthMainStreet, Suite215, Box22,Fort Worth,
Texas 76106. Further admitted that the Corporation Trust Company, 1209 Orange Street,
Wilmington, Delaware lOSO ("Registered Agent") is Defendant's registered agent.
4. Denied, except admitted that attached to the Complaint as Exhibit A is a copy
of a letter dated August 13,2001, from Plaintiff to Defendant, which document speaks for
itself.
,i,`"z'w\vP,~
5 . Denied, except admitted that attached to the Complaint as Exhibit B is a copy
of an envelope, which document speaks for itself.
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2
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COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANT DEMAND LETTER REQUEST FORM SB-2 INSPECTION SHAREHOLDERS DEL SECURITIES EXCHANGE COMMISSION AMENDMENT COURT COPYING EXHIBIT PERMIT OFFERING PRICE DELAWARE PURSUANT TEXAS MISMANAGEMENT DECREASE BUSINESS PAYMENT TANTAMOUNT DENYING PLAINTIFF PAID INVESTMENT FRANCHISE TAX INTERNET SITE WRITTEN CONTRACTS SHOWING |
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RIGINA,L /J
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
THOMAS J. HALL
Plaintiff
Civil Action No. /yg Tq /vc
GIMMEABID.COM, INC.
A Delaware corporation
Defendant
COMPLAINT UNDER 8 DEL. C. 8 220(c)
Plaintiff Thomas J. Hall ("Plaintiff'), pro se, for his Complaint against
GimmeaBid.com, Inc. (`Defendant") alleges as follows:
1. This action, brought pursuant to 8 Del. C. $220(c), seeks relief in the form
of an order compelling the Defendant to make certain records available for inspection and
copying by Plaintiff, as demanded by Plaintiff in a notarized demand letter dated August
13. 2001, (the "Demand Letter"). A copy of the Demand Letter which is attached as
Exhibit A.
2 At all times relevant to this action, Plaintiff has been a shareholder of
Defendant.
3. At all times relevant to this action, Defendant was a general corporation
organized under the laws of the State of Delaware (DE Corp. No. 209 1190). Defendant can
-l-
be served through the Corporation Trust Company, 1209 Orange Street, Wilmington, DE
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