FOR THE NORTHERN DISTRICT OF OKLAHOMA.
Defendants.
1. JOSEPH EARLE;
(2) GORDAN MCDOUGALL;
(3) MARK LIVINGSTON;
(4) UPPER STREET MARKETING, INC.;
(5) LINEAR PARK MARKETING INC.;
(6) GROWING SPRINGS HOLDINGS
CORPORATION;
(7) PRIMAPHARMA, INC;
(8) ICC INC.,
JURY TRIAL DEMANDED
NATURE OF DERIVATIVE ACTION
1. This is a shareholder derivative action brought on behalf of Nominal Defendant
UPPR against Corporate Defendants by Plaintiffs who are, and at all times relevant hereto, UPPR
shareholders. Plaintiffs, derivatively on behalf of UPPR, seek relief for the damages sustained, and
that will be sustained by UPPR as a result of Corporate Defendants’ conversions, breaches of their
fiduciary duties and Defendant Joseph Earle’s wrongful refusal of Plaintiffs’ well-grounded
demand on the Board of Directors pursuant to Okla. Stat. tit 18, § 1065 to inspect and make copies
and extracts of certain books and records of UPPR.
2.
3.
4.
5.
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