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1
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COMPLAINT
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EXTRACTED KEY WORDS
VINTON LYMAN-RICHEY SPECIAL COMMITTEE SUNDERLAND PLAINTIFF MERGER LYMAN-RICHEY ACQUISITION SHAREHOLDERS AGREEMENT EARNINGS STOCK REPORT FINANCIAL STATEMENTS DIRECTORS TRANSACTIONS DEMAND COMMON STOCK MEMBERS SHARES INVESTMENT WELLS ACCORDING RECEIVING NET SALES OUTSTANDING PRESIDENT CONTROL ANNUAL REPORT ASSETS |
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
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DANIEL F. RAIDER,
Plaintiff,
V. Civil Action No. /8'?83
ASH GROVE CEMENT COMPANY, :
Defendant. m
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COMPLAINT IT:3
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Plaintiff, by his attorneys, alleges as follows: -7s 2 f-3
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1. Plaintiff Daniel F. Raider ("Plaintiff"), together with his-wife, is a
record owner of 3,000 shares of Ash Grove Cement Company ("Ash Grove"). After
concluding a career as corporate counsel of a major corporation, Plaintiff has been, since
1999, self-employed as a private investor.
2. Ash Grove is a Delaware corporation with principal executive offices
in Overland Park, Kansas. Ash Grove's business is the production of materials, primarily
cement and lime products, for the construction industry.
3. Prior to December 31, 2000:
a. Vinton Corporation ("Vinton"), a Delaware corporation,
owned approximately 63% of Ash Grove's issued and outstanding common stock and
71% of Ash Grove's issued and outstanding Class B common stock, which constituted
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