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Class Action Complaint

 

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Title:

Class Action Complaint

Entities:

Ford Motor Co.

Date:

2001

Size:

9KB total

Price:

$39

ID:

#240455

 

 

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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY

     
SCHLOMO BIRNBAUM,
Plaintiff,
           against   Civil Action No. 18337NC
FRANK A. OLSON, CRAIG R. KOCH, W. WAYNE CLASS ACTION COMPLAINT
BOOKER, LOUIS C. BURNETT, MICHAEL T.
MONAHAN, PETER J. PESTILLO, JOHN M.
RINTAMAKI, JOHN M. THOMPSON, JOSEPH A.
WALKER, THE HERTZ CORPORATION and
FORD MOTOR COMPANY,
Defendants.

      Plaintiff, by his attorneys, for his complaint against defendants, alleges upon information and belief, except for paragraph 2 hereof, which is alleged upon knowledge, as follows:

      1. Plaintiff has been the owner of the common stock of The Hertz Corporation (Hertz or the Company) since prior to the transaction herein complained of and continuously to date.

      2. Hertz is a corporation duly organized and existing under the laws of the State of Delaware. The Company is one of the worlds leading rental car companies. Hertz has two classes of common stock. The Class A common stock is entitled to one vote per share and the Class B common stock is entitled to five votes per share. Hertz maintains its principal offices at 225 Brae Boulevard, Park Ridge, New Jersey.

 


      3. Defendant Ford Motor Company (Ford) owns or controls approximately 50% of the outstanding Class A common stock and 100% of the Class B common stock of the Company.

      4. Defendant Frank A. Olson is Chairman of the Board of Hertz.

      5. Defendant Craig R. Koch is President and Chief Executive Officer of Hertz.

      6. Defendant W. Wayne Booker is a Director of the Company and Vice Chairman of Ford.

      7. Defendant Peter J. Pestillo is a Director of the Company and Vice Chairman of Ford.

      8. Defendant John M. Rintamaki is a Director of the Company and Group Vice President of Ford.
 

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