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1
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ANSWER
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EXTRACTED KEY WORDS
RESPONDENT MILESTONE COURT DELAWARE BYRNE COUNSEL DEL DISMISSING MILESTONE SERIES PREFERRED SHARES MERGER CERTIFICATE WHEREFORE RESPONDENT RESPECTFULLY REQUESTS PREJUDICE ENTERING JUDGMENT AWARDING RESPONDENT COSTS REASONABLE ATTORNEYS FEES DEFENSE GRANTING RELIEF COURT DEEMS JOHN FOREGOING KEVIN ESQUIRE WILMINGTON |
IN THE CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
DEBRA L. BYRNE,
Petitioner,
V. ~ Civil Action No. 19231NC
MILESTONE PROPERTIES, INC., a i
corporation of the State of Delaware,
Respondent.
ANSWER
Respondent Milestone Properties, Inc., a Delaware corporation ("Milestone"), by
its undersigned counsel, hereby answers the Petition for Appraisal in this Action as
follows:
1. Admitted that Petitioner is Debra L. Byrne. For further answer, denied
that Ms. Byrne has standing under 8 Del. C. $262 to serve as a Petitioner in this
Action.
2. Admitted.
3. Denied.
4. Denied.
5. Denied.
6. Denied that Petitioner is entitled to seek the requested relief.
FIRST DEFENSE
7. The Petition fails to state a claim upon which relief can be granted.
17651.2\148475vI
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2
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APPRAISAL ACTION
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EXTRACTED KEY WORDS
MILESTONE PROPERTIES PETITIONER DEBRA BYRNE DELAWARE RESPONDENT MERGER PARTICIPANT APPRAISAL RIGHTS DEPOSITORY TRUST STOCK FEES FLOOR CUSTOMER YORK PREFERRED SET DTC NATIONAL INVESTORS SERVICES SHAMS ACCORDANCE RESPEET FUTURE CORRESPONDENCE MATTER RAMSEY AVENUE MARLTON ATTENTION JEAN SALADINO NATIONAL INRESTORS SEWICES WATER |
COURT OF CHANCERY
IN AND FOR THE STATE OF DELAWARE, NEW CASTLE COUNTY
DEBRA L. BYRNE,
Petitioner, CIVIL ACTION NO.: 1 w I&?
V.
MILESTONE PROPERTIES, INC., a
corporation of the State of Delaware,
Respondent.
APPRAISAL ACTION
1. Petitioner is Debra L. Byrne.
2. Respondent is Milestone Properties, Inc., a Delaware corporation.
3. Petitioner is the owner of 3,000 shares of Milestone Properties Series A
Preferred Shares, which shares were the subject of a merger which became effective on
July 8,200 1.
4. At all times, petitioner continuously held her shares through the effective
date of said merger; nor has she voted in favor of the merger, nor consented thereto in
writing.
5. Petitioner perfected her appraisal rights by her written demand for appraisal
of her shares through her agent's letter (Cede & Co., c/o The Depository Trust Company)
of July 3 1,200 1 directed to Respondent, a copy of which is attached hereto.
6. Petitioner respectfully requests that an appraisal hearing be scheduled to
determine the fair value of her shares of stock, and that she be awarded the said fair
value, together with pre and post judgment compounded interest at the maximum legal
rate and costs, reasonable attorney fees and the fees and expenses of experts, to be
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