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ROMESKIE v CHEMICORP INTERNATIONAL Click to find out why . . .
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Keywords & Phrases
CaseNo: C.A. No. 17,197, CourtCode: CC, CourtName: IN THE COURT OF CHANCERY OF THE STATE OF DELA 3Q RI, Plaintiff: ROMESKIE, State: DE Delaware, UniqueCaseRef: DE>CC>00017197, County: New Castle County, Liddy, Allegations, Rybak, Viva, Directors, Bernstein, Viva Holdings, Viva Golf, Officer, Remainder, Complaint, Romeskie, Acquisition Agreement, Delaware, Certificate, Aes, Woolbright, Francois Hubert, President, Mariusz Rybak, Sufficient Knowledge, Opinion, Julian, Sanje Ratnavale, Chief, Ids, Fraudulent, A/k/a Viva Holdings, Del, Secretary/director, Counterclaims, Delaware Corporation, Transaction, Chancery, Expedite, Affirmative Defenses, A/k/a Viva, Ralph, Proper Officers, Filings , ContentID: 120240834
Case Documents
1 1999-07-06 ORDER
[ see first page and extracted highlights below ] ItemID: 103632 4 pages
PDF
2 1999-06-25 MEMORANDUM OF LAW IN SUPPORT OF MOTION TO STRIKE CERTAIN OF DEFENDANTS AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
[ see first page and extracted highlights below ] ItemID: 102881 8 pages
PDF
3 1999-06-18 REPLY TO COUNTERCLAIMS
[ see first page and extracted highlights below ] ItemID: 103624 4 pages
PDF
4 1999-06-16 DEFENDANTS ANSWER TO PLAINTIFFS COMPLAINT
[ see first page and extracted highlights below ] ItemID: 101936 19 pages
PDF
5 1999-06-04 MOTION TO EXPEDITE PROCEEDINGS
[ see first page and extracted highlights below ] ItemID: 103505 13 pages
PDF
6 1999-06-03 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
[ see first page and extracted highlights below ] ItemID: 101937 15 pages
PDF
Total Documents: 6 documents , 63 pages
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Document Details
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1 . ORDER
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
COURT
DEFENDANTS
DIRECTORS
PLAINTIFFS
SETTLEMENT
JULIAN
ROMESKIE
HUBERT
MARIUSZ RYBAK
CHANCERY COURT
DELAWARE
VIVA HOLDINGS
RATNAVALE
CHIEF
SANJE
AGREEMENT
LETTERS
INDIVIDUAL DEFENDANTS
RONON
STEVENS
LLP
ABOVE-REFERENCEID
MATTER
COURT YESTERDAY
FAXES
POSSESSION
ORIGINAL SIGNED SETTLEMENT
SWORN
MCCARTHY
IN THE `CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOIR NEW CASTLE COlJNTY
,e
_-
JULIAN M. ROMESKIE >
FRANCQIS HUBERT, J
MARIUSZ RYBAK, and >
SANJE RATNAVRLE, )
Plaintiffs,
1'. > C.A. No. 17197NC
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA. HOLDINGS CORP., and >
GEOFFREY D. LIDDY, >
STANLEY R. BERNSTEIN, and >
RALPH T. WOOLB RIGHT, >
Defendants. >
ORDER
AND NOW this Gi'@' day of -P I
`,f VLq---) each of the incllvidual
defendants having settled with the plaintiffs and Chemicorp International, Inc. a/k/a Viva Holdings
Corp. ("Company"); having agreed that they are not directors and officers of the Company; and having
withdrawn all claims against the Company and the plaintiff directors and officers of the Company;
the Company having represented to the Court who its officers arrd directors are:
It is hereby HELD that the Icurrent directors and officers of Chemicorp
Inc. a'lu'a Viva Holdings Corp., are as follows:
.DIRECTORS
Julian M. Romeskie
Franicois Hubert
Mariusz Rybak
Sanjc Ratnavale
# SNIPPETS: IN THE `CHANCERY COURT OF THE STATE OF DELAWARE
# defendants having settled with the plaintiffs and Chemicorp International, Inc. a/k/a Viva
# withdrawn all claims against the Company and the plaintiff directors and officers of the
# Mariusz Rybak, Chairman and Chief Executive OfiFicer
# Julian M. Romeskie, President, Assistant Secretary Sanje Ratnavale, Chief Financial Officer
# Francois Hubert, Treasurer
# 1.N THE CHANCERY COURT OF THE ST.ATE OF DELAWARE
# MARIUSZ RYBAK, and SANJE RATNAVAL.l',,
# I, Jane Landes Foster, Esquire, Managing Partner (of Stradley, Ronon, Stevens &.
# Young, LLP,
# state that the settlement agreement letters signed by each of the individual defendants in
# matter that 1 faxed to the Court yesterday, Thursday, July 1, 1999, were true and correct
# I received from each of these individual defendants.
# I am not in possession of original signed settlement letter
# Sworn to and subscribed before me this `.- d a y O f -`
# LI - - - - - -`Z;LEEK A MCCARTHY,
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2 . MEMORANDUM OF LAW IN SUPPORT OF MOTION TO STRIKE CERTAIN OF DEFENDANTS AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
VIVA GOLF
PLAINTIFFS
DEL
COUNTERCLAIMS
ACQUISITION AGREEMENT
CHANCERY
DEFENDANTS
AFFIRMATIVE DEFENSES
COURT
RYBAK
LIDDY
DELAWARE
HOLDINGS
BERNSTEIN
STRIKE
COMPLAINT
PURSUANT
TRANSACTION
BREACH
CASTLE COUNTY
ALLEGE
OFFICERS
CHEMICORP
RESIGNATION
CERTIFICATES
ACTS
PROCEEDING
FRAUD
ALLEGATIONS
JUN. 25. lG99 9:55AM STRADLEY RCNON LLP
XN THE CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKJE, FR4NCOIS HUBERT, :
MARJUSZ RYBAK, and SANJE RATNAVALE, :
Plaintiffs,
V.
C.A. No. 17197
CHEMICORP JNTERNATIONAL, INC. :
a/Wa VIVA HOLDINGS CORP., and
GEOFFREY D. LIDDY, STANLEY R. I
BERNSTEIN, and RALPH T. WOOLBFUGHT, :
Defendants. :
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFFS MOTION TO STRIKE CERTAIN OF
DEFENDANTS' AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
Plaintiffs, by their undersigned attorneys, hereby move to strike certain of the
affirmative defenses and counterclaims alleged by tie Defendants in their Answer to the Complaint,
and state as follows:
I. Statement of Facts
On July 8, 1999, Plaintiffs Julian M. Romeskie, Francois Hubert, Mariusz Rybak and
Sanje Ratnavale brought an action pursuant to 8 Del, Ch. Code fj 225 to declarewho are the proper
officers and directors of a Delaware corporation and to enjoin persons unlawfully holding themselves
out to be directors and officers of the corporation from so doing. The Plaintiffs are all Directors
ChmiCorp International, Inc. ("ChemiCorp" or "the Company") a/k/a Viva Holdings Corp. ("Viva
Holdings"). ChemiCorp is a Delaware Corporation engaged in the development and application of
chemical detection technologies and analytical services, with its principal place of business in
# SNIPPETS: XN THE CHANCERY OF THE STATE OF DELAWARE
# MARJUSZ RYBAK, and SANJE RATNAVALE,:
# PLAINTIFFS MOTION TO STRIKE CERTAIN OF DEFENDANTS' AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
# Sanje Ratnavale brought an action pursuant to 8 Del,
# out to be directors and officers of the corporation from so doing.
# The Plaintiffs are all Directors of ChmiCorp International, Inc. ("ChemiCorp" or "the
# and before that as Viva Golf,
# Defendants Geoffrey Liddy, Stanley Bernstein and Ralph Woolbright served as Directors.
# acquisition agreement was entered into among Liddy, Viva Golf,
# Despite his resignation, Liddy, as purported President, and Bernstein, as purported
# rendering null and void the legitimate Certificates of Correction of July 15,
# Company, therefore, cannot complete its contemplated transaction with IDS because of Liddy's
# the Plaintiffs filed a Complaint in this case under 8 Del.
# Plaintiffs seek to have the Court declare who are the proper Directors and Officers of the
# Officers petiorming unauthorized acts on behalf of the Company.
# tendered was a mistake, unconsummated, breached, misrepresented or induced by fraud.
# undifferentiated Affirmative Defenses and Counterclaims - almost all of which allege that
# The Supreme Court of DeIaware has explained, "a proceeding brought pursuant to
# has also held that breach of fiduciary duty claims cannot be heard in a $225 action,
# Chancery Ct., New Castle County, Oct. 6,
# Defendants are comprised of allegations clearly outside the confines of a narrow $ 225
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3 . REPLY TO COUNTERCLAIMS
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The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
COUNTERCLAIMS
COURT
AFFIRMATIVE DEFENSES
MEETING
COUNSEL
DEFENDANTS
COMPLAINT
RESPONSE
CHANCERY COURT RULES
INFORMATION SUFFICIENT
TRUTH
AVERMENT
STOCKHOLDER
ALLEGATION
PROCEEDING
WHEREFORE
PLAINTIFFS REQUEST
JUDGEMENT
GRANT
RELIEF
IANE
FOSTER
ITRADLEY RONON STEVENS
COMMERCE SQUARE
HEREBY CERTIFY
FOREGOING
REGULAR
POSTAGE PREPAID
TRANSMISSION
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
.ilJLtAN M. ROMESKIE, >
I:RANCOIS HUBERT, >
MARIUSZ RYBAK, and >
!+ANJE RATNAVALE >
Plaintiffs, >>
V. ) C.A. No. 17197NC
CHEMICORP INTERNATIONAL, INC. j
:~&/a VIVA HOLDINGS CORP., and >
GEOFFREY D. LIDDY, >
STANLEY R. BERNSTEIN, and >
R4LPH T. WOOLBRIGHT >
Defendants. > `.
-,
---I
REPLY TO COUNTERCLAIMS
`fhe Plaintiffs, by and through their undersigned counsel, make this reply to the extent that the
;rllegations of Defendants' Answer to Plaintiffs Complaint set forth under the heading "Affirmative
Defenses and Counterclaims" may require a response under Rule 12(a) of the Chancery Court Rules:
1. No response required.
2. Denied.
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
9. Denied.
10. Denied.
# SNIPPETS: `fhe Plaintiffs, by and through their undersigned counsel, make this reply to the extent that
# No response required.
# For further answer, Plaintiffs are without knowledge or information sufficient to form a
# For further answer, on information and belief, a meeting of the sole director of the Company
# Denied as to any allegation that facts pleaded in the Complaint were mischaracterized.
# AFFIRMATIVE DEFENSES TO COUNTERCLAIMS
# `1`0 the extent Defendants allege, as affirmative counterclaims, any violation of federal
# WHEREFORE, Plaintiffs request the Court:
# To enter judgment in favor of Plaintiffs with respect to each allegation that may be
# To grant such other and further relief as may be just.
# OF COUNSEL:
# .Iane L. Foster:itradley Ronon Stevens & Young LP:!600 One Commerce Square
# I hereby certify that, on this day of June, 1999, two copies of the foregoing Reply
# to Counterclaims were delivered by both regular U.S. mail, postage prepaid, and by facsimile
# transmission to the following:
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4 . DEFENDANTS ANSWER TO PLAINTIFFS COMPLAINT
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ALLEGATIONS
PLAINTIFFS
REMAINDER
LIDDY
VIVA GOLF
COMPLAINT
BERNSTEIN
RYBAK
SUFFICIENT KNOWLEDGE
VIVA HOLDINGS
OPINION
ACQUISITION AGREEMENT
WOOLBRIGHT
COURT
A/K/A VIVA
RALPH
CERTIFICATE
DIRECTORS
ADVANCED ENVIRONMENTAL SOLUTIONS
RESIGNATIONS
AES
INCORPORATE
REFERENCE
REPRESENTATIONS
JOEL BERNSTEIN
CHANCERY COURT
CASTLE COUNTY
MARIUSZ RYBAK
AFFIDAVIT
IN THE CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKIE,
FRANCOIS HUBERT,
MARIUSZ RYBAK, and
SANJE RATNAVALE, ) -; 2 -2
Plaintiffs, _c
> ;
1 1 :`)
C':A. F;. I&
V. >
) w
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA HOLDINGS CORP., and
GEOFFREY D. LIDDY,
STANLEY R. BERNSTEIN, and
RALPH T. WOOLBRIGHT,
Defendants.
DEFENDANTS' ANSWER TO PLAINTIFFS' COMPLAINT
COMES NOW Defendants, ChemiCorp International, Inc. a/k/a Viva
Holdings Corp., and Geoffrey D. Liddy , Stanley R. Bernstein, and Ralph T.
Woolbright, and hereby answer the Complaint as follows:
1. Admitted.
2. Denied.
3. Denied.
4. Denied.
5. Denied.
6. Admitted to the extent that Viva Holdings is a Delaware corporation and
that the company was formerly knows as Advanced Environmental Solutions, Inc.
("AES") and before that as Viva Golf, USA Corp. ("Viva Golf"). Denied as to the
# SNIPPETS: IN THE CHANCERY COURT OF THE STATE OF DELAWARE
# IN AND FOR NEW CASTLE COUNTY
# GEOFFREY D. LIDDY,
# RALPH T. WOOLBRIGHT,
# DEFENDANTS' ANSWER TO PLAINTIFFS' COMPLAINT
# COMES NOW Defendants, ChemiCorp International, Inc. a/k/a Viva
# Holdings Corp., and Geoffrey D. Liddy, Stanley R. Bernstein, and Ralph T.
# Woolbright, and hereby answer the Complaint as follows:
# Admitted to the extent that Viva Holdings is a Delaware corporation and
# that the company was formerly knows as Advanced Environmental Solutions,
# and before that as Viva Golf,
# Denied as to the remainder of the allegations.
# Defendants are without sufficient knowledge to form an opinion as to the
# The executed resignations were never tendered to the
# and M. Rybak, Andy Rybak ("A.
# correct copy of such Acquisition Agreement.
# Viva Golf's officers and directors be delivered at closing.
# price of AES stock and that Liddy and other shareholders were considering formal
# Admitted that on June 22, 1998, Liddy filed a Certificate of Amendment
# Defendants incorporate Paragraphs 1-81 of their Answer above as if set
# Plaintiffs have failed to state a claim upon which relief may be granted.
# Agreement by, inter da, failing to satisfy all representations, warranties, covenants
# See Affidavit of Mr. Joel Bernstein, Esq., attached hereto and incorporated
# by reference herein and made a part hereof.
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5 . MOTION TO EXPEDITE PROCEEDINGS
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COURT
EXPEDITE
DIRECTORS
IDS
VIVA
PLAINTIFFS
FILINGS
OFFICER
RYBAK
TRANSACTION
MOTION
BERNSTEIN
VIVA GOLF
DEL
PROPER
AGREEMENT
CERTIFICATE
FRAUDULENT
PURSUANT
HERETO
DEFENDANTS
STOCK
CHANCERY
VIVA HOLDINGS
ROMESKIE
COMPLAINT
INJUNCTION
REPRESENTATIONS
NASDAQ
IN THE COURT OF CHANCERY OF THE STATE OF DELA!3Q$RI$
IN AND FOR NEW CASTLE COUNTY .- " ' ,,"
JULIAN M. ROMESKIE, >
FRANCOIS HUBERT, >
MARIUSZ RYBAK, and >
SANJE RATNAVALE >
Plaintiffs, >
>
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA HOLDINGS CORP., and >
GEOFFREY D. :LIDDY, >
STANLEY R. B:ERNSTEIN, and >
RALPH T. WOOLBRIGHT >
Defendants. >
NOTICE OF MOTION,
TO: ChemiCorp International, Inc. (a/k/a Viva Holdings Corp.)
Corporate Agents, Inc.
1013 Centre Road
Wilmington, DE 19805
PLEASE; TAKE NOTICE that Plaintiffs' Motion to Expedite Proceedings will be
presented to the Court at the earliest convenience of the Court and counsel.
STRADLEY RONQN STEVEN.S & YOUNG, LLP
Mellon Bank Center - Suite 600
9 19 North Markelt Street
Wilmington, DE 19899-2170
(302) 576-,585O
Jane Land,es Foster
Stradley, Ronon, Stevens c5r. Young, LLP
2600 One Commerce Square
Philadelphia, PA 19103-7098
(2 15) 564,-8000
Attorneys for Plaintiffs
DATED: June 4-, 1999
Doc.#206989v.01
# SNIPPETS: IN THE COURT OF CHANCERY OF THE STATE OF DELA!3Q$RI$
# ChemiCorp International, Inc. (a/k/a Viva Holdings Corp.) Corporate Agents, Inc.
# PLEASE TAKE NOTICE that Plaintiffs' Motion to Expedite Proceedings will be presented to
# Order in the form attached hereto expediting these proceedings by shortening the time required
# The grounds for this motion are as stated herein and in the Verified Complaint
# This action is brought by Julian M. Romeskie, Francois Hubert,
# Mariusz Rybak and Sanje Ratnavale pursuant to 8 Del.
# determine who are the proper directors and officers of defend.ant ChemiCorp International,
# Liddy and Bernstein have likewise held themselves out as officers of the
# the corporate governance of the Company, has now put a hold on &l fLlture filings of the
# into a transaction with a third party that is of vital importance to the Company's future.
# Bernstein and Woolbright were among the original elected directors of Viva
# On April 11, 1997, pursuant to an acquisition agreement signed by Liddy, Viva Golf
# in fact resigned as a director and officer of Viva Golf as of the conclusion of a special
# Those representations were dernonstrably false
# Liddy had no authorization to deal with NASDAQ on the Company's behalf
# Romeskie filed a certificate of amendment with the Delaware Secretary of State to change the
# Delaware Secretary of State by tiling a fraudulent certificate of correction that purported to
# formed by the Rybaks that owned 20% of the stock of the Colrnpany.
# Company entered into a subscription agreement with IDS pursuant to which, among other things,
# Perhaps the most important adverse effect of the defendants' unauthorized actions is the
# on the 5 225 proceeding and the related injunction application.
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6 . COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
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LIDDY
RYBAK
DIRECTORS
OFFICER
VIVA HOLDINGS
BERNSTEIN
ROMESKIE
DELAWARE
FRANCOIS HUBERT
PRESIDENT
PLAINTIFF
AES
JULIAN
SANJE RATNAVALE
VIVA GOLF
MARIUSZ RYBAK
A/K/A VIVA HOLDINGS
CHIEF
SECRETARY/DIRECTOR
CERTIFICATE
DELAWARE CORPORATION
FRAUDULENT
PROPER OFFICERS
ACQUISITION AGREEMENT
IDS
WOOLBRIGHT
COMPLAINT
DECLARATORY
EXECUTIVE OFFICER
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKIE,
FRANCOIS HUBERT,
MARIUSZ RYBAK, and
SANJE RATNAVALE
Plaintiffs,
cmhmcow YNTERNATIONAL, INC.
a/k/a/ VIVA HOLDINGS CORP.
and
GEOFFREY D. LIDDY,
STANLEY R. BERNSTEIN, and
RALPH T. WOOLBRIGHT Defendants. )
COMPLAINT FOR DECLARATORY
AND INJUNCTIVE RELIEF
PURSUANT TO 8 DEL. C. 4 225
1. This is an action brought pursuant to 8 Del. C. 9 225 to declare who are
the proper officers and directors of a Delaware corporation and to enjoin persons unlawfully
holding themselves out to be directors and officers of the corporation from so doing.
2. Plaintiff, Julian M. Romeskie ("Romeskie") is a Director and is the
President of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
3. Plaintiff, Francois Hubert ("Hubert") is a Director of ChemiCorp
International, Inc. a/k/a Viva Holdings Corp.
4. Plaintiff, Mariusz Rybak ("M. Rybak") is a Director and is the Chief
Executive Officer of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
5. Plaintiff, Sanje Ratnavale ("Ratnavale") is a Director and is the Chief
Financial Officer of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
6. Defendant ChemiCorp International, Inc. ("ChemiCorp") (the
"Company") a/k/a Viva Holdings Corp. ("Viva Holdings"), is a Delaware corporation engaged in
Doc.#205685v.01
# SNIPPETS: IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
# the proper officers and directors of a Delaware corporation and to enjoin persons unlawfully
# holding themselves out to be directors and officers of the corporation from so doing.
# Julian M. Romeskie is a Director and is the
# President of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
# Plaintiff, Francois Hubert is a Director of ChemiCorp
# Mariusz Rybak is a Director and is the Chief
# Executive Officer of ChemiCorp International,
# Sanje Ratnavale is a Director and is the Chief
# Advanced Environmental Solutions, Inc. and before that as Viva Golf, USA Corp.
# Defendant Geoffrey D. Liddy is a citizen of Florida,
# Defendant Stanley R. Bernstein is a citizen of Florida,
# This Court has jurisdiction over Liddy, Bernstein and Woolbright under 8
# On April 11, 1997, a share acquisition agreement (the "Acquisition
# On April 16, 1997, a Certificate of Amendment was filed with the
# Secretary of State changing the name of the Company from Viva Golf to AES.
# A true and correct copy of the fraudulent
# were President/Director and Secretary/Director, respectively, of AES.
# the Company was negotiating a transaction with IDS
# DECLARATORY RELIEF UNDER 8 DEL.
# adjudication as to the proper officers and directors of the Company.
# the foregoing Complaint for Declaratory and Injunctive Relief Pursuant to 8 De1.C.
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Keywords & Phrases
CaseNo: C.A. No. 17,197, CourtCode: CC, CourtName: IN THE COURT OF CHANCERY OF THE STATE OF DELA 3Q RI, Plaintiff: ROMESKIE, State: DE Delaware, UniqueCaseRef: DE>CC>00017197, County: New Castle County, Liddy, Allegations, Rybak, Viva, Directors, Bernstein, Viva Holdings, Viva Golf, Officer, Remainder, Complaint, Romeskie, Acquisition Agreement, Delaware, Certificate, Aes, Woolbright, Francois Hubert, President, Mariusz Rybak, Sufficient Knowledge, Opinion, Julian, Sanje Ratnavale, Chief, Ids, Fraudulent, A/k/a Viva Holdings, Del, Secretary/director, Counterclaims, Delaware Corporation, Transaction, Chancery, Expedite, Affirmative Defenses, A/k/a Viva, Ralph, Proper Officers, Filings , ContentID: 120240834
Case Documents
1 1999-07-06 ORDER
[ see first page and extracted highlights below ] ItemID: 103632 4 pages
2 1999-06-25 MEMORANDUM OF LAW IN SUPPORT OF MOTION TO STRIKE CERTAIN OF DEFENDANTS AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
[ see first page and extracted highlights below ] ItemID: 102881 8 pages
3 1999-06-18 REPLY TO COUNTERCLAIMS
[ see first page and extracted highlights below ] ItemID: 103624 4 pages
4 1999-06-16 DEFENDANTS ANSWER TO PLAINTIFFS COMPLAINT
[ see first page and extracted highlights below ] ItemID: 101936 19 pages
5 1999-06-04 MOTION TO EXPEDITE PROCEEDINGS
[ see first page and extracted highlights below ] ItemID: 103505 13 pages
6 1999-06-03 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
[ see first page and extracted highlights below ] ItemID: 101937 15 pages
Total Documents: 6 documents , 63 pages
Price: $ 44.95
Note: Buying these documents places them in the Briefcase section.
You are only charged once for unlimited access to the documents.
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Document Details
This section displays text extracted from the first page of each corresponding document. The keywords are the most common terms found within the document.
(Note that the documents which you purchase may appear different from the text shown below. The purchased items will more closely resemble the original paper documents.)
1 . ORDER
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
COURT
DEFENDANTS
DIRECTORS
PLAINTIFFS
SETTLEMENT
JULIAN
ROMESKIE
HUBERT
MARIUSZ RYBAK
CHANCERY COURT
DELAWARE
VIVA HOLDINGS
RATNAVALE
CHIEF
SANJE
AGREEMENT
LETTERS
INDIVIDUAL DEFENDANTS
RONON
STEVENS
LLP
ABOVE-REFERENCEID
MATTER
COURT YESTERDAY
FAXES
POSSESSION
ORIGINAL SIGNED SETTLEMENT
SWORN
MCCARTHY
IN THE `CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOIR NEW CASTLE COlJNTY
,e
_-
JULIAN M. ROMESKIE >
FRANCQIS HUBERT, J
MARIUSZ RYBAK, and >
SANJE RATNAVRLE, )
Plaintiffs,
1'. > C.A. No. 17197NC
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA. HOLDINGS CORP., and >
GEOFFREY D. LIDDY, >
STANLEY R. BERNSTEIN, and >
RALPH T. WOOLB RIGHT, >
Defendants. >
ORDER
AND NOW this Gi'@' day of -P I
`,f VLq---) each of the incllvidual
defendants having settled with the plaintiffs and Chemicorp International, Inc. a/k/a Viva Holdings
Corp. ("Company"); having agreed that they are not directors and officers of the Company; and having
withdrawn all claims against the Company and the plaintiff directors and officers of the Company;
the Company having represented to the Court who its officers arrd directors are:
It is hereby HELD that the Icurrent directors and officers of Chemicorp
Inc. a'lu'a Viva Holdings Corp., are as follows:
.DIRECTORS
Julian M. Romeskie
Franicois Hubert
Mariusz Rybak
Sanjc Ratnavale
# SNIPPETS: IN THE `CHANCERY COURT OF THE STATE OF DELAWARE
# defendants having settled with the plaintiffs and Chemicorp International, Inc. a/k/a Viva
# withdrawn all claims against the Company and the plaintiff directors and officers of the
# Mariusz Rybak, Chairman and Chief Executive OfiFicer
# Julian M. Romeskie, President, Assistant Secretary Sanje Ratnavale, Chief Financial Officer
# Francois Hubert, Treasurer
# 1.N THE CHANCERY COURT OF THE ST.ATE OF DELAWARE
# MARIUSZ RYBAK, and SANJE RATNAVAL.l',,
# I, Jane Landes Foster, Esquire, Managing Partner (of Stradley, Ronon, Stevens &.
# Young, LLP,
# state that the settlement agreement letters signed by each of the individual defendants in
# matter that 1 faxed to the Court yesterday, Thursday, July 1, 1999, were true and correct
# I received from each of these individual defendants.
# I am not in possession of original signed settlement letter
# Sworn to and subscribed before me this `.- d a y O f -`
# LI - - - - - -`Z;LEEK A MCCARTHY,
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2 . MEMORANDUM OF LAW IN SUPPORT OF MOTION TO STRIKE CERTAIN OF DEFENDANTS AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
VIVA GOLF
PLAINTIFFS
DEL
COUNTERCLAIMS
ACQUISITION AGREEMENT
CHANCERY
DEFENDANTS
AFFIRMATIVE DEFENSES
COURT
RYBAK
LIDDY
DELAWARE
HOLDINGS
BERNSTEIN
STRIKE
COMPLAINT
PURSUANT
TRANSACTION
BREACH
CASTLE COUNTY
ALLEGE
OFFICERS
CHEMICORP
RESIGNATION
CERTIFICATES
ACTS
PROCEEDING
FRAUD
ALLEGATIONS
JUN. 25. lG99 9:55AM STRADLEY RCNON LLP
XN THE CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKJE, FR4NCOIS HUBERT, :
MARJUSZ RYBAK, and SANJE RATNAVALE, :
Plaintiffs,
V.
C.A. No. 17197
CHEMICORP JNTERNATIONAL, INC. :
a/Wa VIVA HOLDINGS CORP., and
GEOFFREY D. LIDDY, STANLEY R. I
BERNSTEIN, and RALPH T. WOOLBFUGHT, :
Defendants. :
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFFS MOTION TO STRIKE CERTAIN OF
DEFENDANTS' AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
Plaintiffs, by their undersigned attorneys, hereby move to strike certain of the
affirmative defenses and counterclaims alleged by tie Defendants in their Answer to the Complaint,
and state as follows:
I. Statement of Facts
On July 8, 1999, Plaintiffs Julian M. Romeskie, Francois Hubert, Mariusz Rybak and
Sanje Ratnavale brought an action pursuant to 8 Del, Ch. Code fj 225 to declarewho are the proper
officers and directors of a Delaware corporation and to enjoin persons unlawfully holding themselves
out to be directors and officers of the corporation from so doing. The Plaintiffs are all Directors
ChmiCorp International, Inc. ("ChemiCorp" or "the Company") a/k/a Viva Holdings Corp. ("Viva
Holdings"). ChemiCorp is a Delaware Corporation engaged in the development and application of
chemical detection technologies and analytical services, with its principal place of business in
# SNIPPETS: XN THE CHANCERY OF THE STATE OF DELAWARE
# MARJUSZ RYBAK, and SANJE RATNAVALE,:
# PLAINTIFFS MOTION TO STRIKE CERTAIN OF DEFENDANTS' AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
# Sanje Ratnavale brought an action pursuant to 8 Del,
# out to be directors and officers of the corporation from so doing.
# The Plaintiffs are all Directors of ChmiCorp International, Inc. ("ChemiCorp" or "the
# and before that as Viva Golf,
# Defendants Geoffrey Liddy, Stanley Bernstein and Ralph Woolbright served as Directors.
# acquisition agreement was entered into among Liddy, Viva Golf,
# Despite his resignation, Liddy, as purported President, and Bernstein, as purported
# rendering null and void the legitimate Certificates of Correction of July 15,
# Company, therefore, cannot complete its contemplated transaction with IDS because of Liddy's
# the Plaintiffs filed a Complaint in this case under 8 Del.
# Plaintiffs seek to have the Court declare who are the proper Directors and Officers of the
# Officers petiorming unauthorized acts on behalf of the Company.
# tendered was a mistake, unconsummated, breached, misrepresented or induced by fraud.
# undifferentiated Affirmative Defenses and Counterclaims - almost all of which allege that
# The Supreme Court of DeIaware has explained, "a proceeding brought pursuant to
# has also held that breach of fiduciary duty claims cannot be heard in a $225 action,
# Chancery Ct., New Castle County, Oct. 6,
# Defendants are comprised of allegations clearly outside the confines of a narrow $ 225
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3 . REPLY TO COUNTERCLAIMS
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
COUNTERCLAIMS
COURT
AFFIRMATIVE DEFENSES
MEETING
COUNSEL
DEFENDANTS
COMPLAINT
RESPONSE
CHANCERY COURT RULES
INFORMATION SUFFICIENT
TRUTH
AVERMENT
STOCKHOLDER
ALLEGATION
PROCEEDING
WHEREFORE
PLAINTIFFS REQUEST
JUDGEMENT
GRANT
RELIEF
IANE
FOSTER
ITRADLEY RONON STEVENS
COMMERCE SQUARE
HEREBY CERTIFY
FOREGOING
REGULAR
POSTAGE PREPAID
TRANSMISSION
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
.ilJLtAN M. ROMESKIE, >
I:RANCOIS HUBERT, >
MARIUSZ RYBAK, and >
!+ANJE RATNAVALE >
Plaintiffs, >>
V. ) C.A. No. 17197NC
CHEMICORP INTERNATIONAL, INC. j
:~&/a VIVA HOLDINGS CORP., and >
GEOFFREY D. LIDDY, >
STANLEY R. BERNSTEIN, and >
R4LPH T. WOOLBRIGHT >
Defendants. > `.
-,
---I
REPLY TO COUNTERCLAIMS
`fhe Plaintiffs, by and through their undersigned counsel, make this reply to the extent that the
;rllegations of Defendants' Answer to Plaintiffs Complaint set forth under the heading "Affirmative
Defenses and Counterclaims" may require a response under Rule 12(a) of the Chancery Court Rules:
1. No response required.
2. Denied.
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
9. Denied.
10. Denied.
# SNIPPETS: `fhe Plaintiffs, by and through their undersigned counsel, make this reply to the extent that
# No response required.
# For further answer, Plaintiffs are without knowledge or information sufficient to form a
# For further answer, on information and belief, a meeting of the sole director of the Company
# Denied as to any allegation that facts pleaded in the Complaint were mischaracterized.
# AFFIRMATIVE DEFENSES TO COUNTERCLAIMS
# `1`0 the extent Defendants allege, as affirmative counterclaims, any violation of federal
# WHEREFORE, Plaintiffs request the Court:
# To enter judgment in favor of Plaintiffs with respect to each allegation that may be
# To grant such other and further relief as may be just.
# OF COUNSEL:
# .Iane L. Foster:itradley Ronon Stevens & Young LP:!600 One Commerce Square
# I hereby certify that, on this day of June, 1999, two copies of the foregoing Reply
# to Counterclaims were delivered by both regular U.S. mail, postage prepaid, and by facsimile
# transmission to the following:
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4 . DEFENDANTS ANSWER TO PLAINTIFFS COMPLAINT
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
ALLEGATIONS
PLAINTIFFS
REMAINDER
LIDDY
VIVA GOLF
COMPLAINT
BERNSTEIN
RYBAK
SUFFICIENT KNOWLEDGE
VIVA HOLDINGS
OPINION
ACQUISITION AGREEMENT
WOOLBRIGHT
COURT
A/K/A VIVA
RALPH
CERTIFICATE
DIRECTORS
ADVANCED ENVIRONMENTAL SOLUTIONS
RESIGNATIONS
AES
INCORPORATE
REFERENCE
REPRESENTATIONS
JOEL BERNSTEIN
CHANCERY COURT
CASTLE COUNTY
MARIUSZ RYBAK
AFFIDAVIT
IN THE CHANCERY COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKIE,
FRANCOIS HUBERT,
MARIUSZ RYBAK, and
SANJE RATNAVALE, ) -; 2 -2
Plaintiffs, _c
> ;
1 1 :`)
C':A. F;. I&
V. >
) w
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA HOLDINGS CORP., and
GEOFFREY D. LIDDY,
STANLEY R. BERNSTEIN, and
RALPH T. WOOLBRIGHT,
Defendants.
DEFENDANTS' ANSWER TO PLAINTIFFS' COMPLAINT
COMES NOW Defendants, ChemiCorp International, Inc. a/k/a Viva
Holdings Corp., and Geoffrey D. Liddy , Stanley R. Bernstein, and Ralph T.
Woolbright, and hereby answer the Complaint as follows:
1. Admitted.
2. Denied.
3. Denied.
4. Denied.
5. Denied.
6. Admitted to the extent that Viva Holdings is a Delaware corporation and
that the company was formerly knows as Advanced Environmental Solutions, Inc.
("AES") and before that as Viva Golf, USA Corp. ("Viva Golf"). Denied as to the
# SNIPPETS: IN THE CHANCERY COURT OF THE STATE OF DELAWARE
# IN AND FOR NEW CASTLE COUNTY
# GEOFFREY D. LIDDY,
# RALPH T. WOOLBRIGHT,
# DEFENDANTS' ANSWER TO PLAINTIFFS' COMPLAINT
# COMES NOW Defendants, ChemiCorp International, Inc. a/k/a Viva
# Holdings Corp., and Geoffrey D. Liddy, Stanley R. Bernstein, and Ralph T.
# Woolbright, and hereby answer the Complaint as follows:
# Admitted to the extent that Viva Holdings is a Delaware corporation and
# that the company was formerly knows as Advanced Environmental Solutions,
# and before that as Viva Golf,
# Denied as to the remainder of the allegations.
# Defendants are without sufficient knowledge to form an opinion as to the
# The executed resignations were never tendered to the
# and M. Rybak, Andy Rybak ("A.
# correct copy of such Acquisition Agreement.
# Viva Golf's officers and directors be delivered at closing.
# price of AES stock and that Liddy and other shareholders were considering formal
# Admitted that on June 22, 1998, Liddy filed a Certificate of Amendment
# Defendants incorporate Paragraphs 1-81 of their Answer above as if set
# Plaintiffs have failed to state a claim upon which relief may be granted.
# Agreement by, inter da, failing to satisfy all representations, warranties, covenants
# See Affidavit of Mr. Joel Bernstein, Esq., attached hereto and incorporated
# by reference herein and made a part hereof.
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5 . MOTION TO EXPEDITE PROCEEDINGS
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
COURT
EXPEDITE
DIRECTORS
IDS
VIVA
PLAINTIFFS
FILINGS
OFFICER
RYBAK
TRANSACTION
MOTION
BERNSTEIN
VIVA GOLF
DEL
PROPER
AGREEMENT
CERTIFICATE
FRAUDULENT
PURSUANT
HERETO
DEFENDANTS
STOCK
CHANCERY
VIVA HOLDINGS
ROMESKIE
COMPLAINT
INJUNCTION
REPRESENTATIONS
NASDAQ
IN THE COURT OF CHANCERY OF THE STATE OF DELA!3Q$RI$
IN AND FOR NEW CASTLE COUNTY .- " ' ,,"
JULIAN M. ROMESKIE, >
FRANCOIS HUBERT, >
MARIUSZ RYBAK, and >
SANJE RATNAVALE >
Plaintiffs, >
>
CHEMICORP INTERNATIONAL, INC. )
a/k/a VIVA HOLDINGS CORP., and >
GEOFFREY D. :LIDDY, >
STANLEY R. B:ERNSTEIN, and >
RALPH T. WOOLBRIGHT >
Defendants. >
NOTICE OF MOTION,
TO: ChemiCorp International, Inc. (a/k/a Viva Holdings Corp.)
Corporate Agents, Inc.
1013 Centre Road
Wilmington, DE 19805
PLEASE; TAKE NOTICE that Plaintiffs' Motion to Expedite Proceedings will be
presented to the Court at the earliest convenience of the Court and counsel.
STRADLEY RONQN STEVEN.S & YOUNG, LLP
Mellon Bank Center - Suite 600
9 19 North Markelt Street
Wilmington, DE 19899-2170
(302) 576-,585O
Jane Land,es Foster
Stradley, Ronon, Stevens c5r. Young, LLP
2600 One Commerce Square
Philadelphia, PA 19103-7098
(2 15) 564,-8000
Attorneys for Plaintiffs
DATED: June 4-, 1999
Doc.#206989v.01
# SNIPPETS: IN THE COURT OF CHANCERY OF THE STATE OF DELA!3Q$RI$
# ChemiCorp International, Inc. (a/k/a Viva Holdings Corp.) Corporate Agents, Inc.
# PLEASE TAKE NOTICE that Plaintiffs' Motion to Expedite Proceedings will be presented to
# Order in the form attached hereto expediting these proceedings by shortening the time required
# The grounds for this motion are as stated herein and in the Verified Complaint
# This action is brought by Julian M. Romeskie, Francois Hubert,
# Mariusz Rybak and Sanje Ratnavale pursuant to 8 Del.
# determine who are the proper directors and officers of defend.ant ChemiCorp International,
# Liddy and Bernstein have likewise held themselves out as officers of the
# the corporate governance of the Company, has now put a hold on &l fLlture filings of the
# into a transaction with a third party that is of vital importance to the Company's future.
# Bernstein and Woolbright were among the original elected directors of Viva
# On April 11, 1997, pursuant to an acquisition agreement signed by Liddy, Viva Golf
# in fact resigned as a director and officer of Viva Golf as of the conclusion of a special
# Those representations were dernonstrably false
# Liddy had no authorization to deal with NASDAQ on the Company's behalf
# Romeskie filed a certificate of amendment with the Delaware Secretary of State to change the
# Delaware Secretary of State by tiling a fraudulent certificate of correction that purported to
# formed by the Rybaks that owned 20% of the stock of the Colrnpany.
# Company entered into a subscription agreement with IDS pursuant to which, among other things,
# Perhaps the most important adverse effect of the defendants' unauthorized actions is the
# on the 5 225 proceeding and the related injunction application.
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6 . COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Below is text extracted from the first page of the corresponding document.
The documents which you purchase will more closely resemble the original paper documents. EXTRACTED KEY WORDS
LIDDY
RYBAK
DIRECTORS
OFFICER
VIVA HOLDINGS
BERNSTEIN
ROMESKIE
DELAWARE
FRANCOIS HUBERT
PRESIDENT
PLAINTIFF
AES
JULIAN
SANJE RATNAVALE
VIVA GOLF
MARIUSZ RYBAK
A/K/A VIVA HOLDINGS
CHIEF
SECRETARY/DIRECTOR
CERTIFICATE
DELAWARE CORPORATION
FRAUDULENT
PROPER OFFICERS
ACQUISITION AGREEMENT
IDS
WOOLBRIGHT
COMPLAINT
DECLARATORY
EXECUTIVE OFFICER
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
JULIAN M. ROMESKIE,
FRANCOIS HUBERT,
MARIUSZ RYBAK, and
SANJE RATNAVALE
Plaintiffs,
cmhmcow YNTERNATIONAL, INC.
a/k/a/ VIVA HOLDINGS CORP.
and
GEOFFREY D. LIDDY,
STANLEY R. BERNSTEIN, and
RALPH T. WOOLBRIGHT Defendants. )
COMPLAINT FOR DECLARATORY
AND INJUNCTIVE RELIEF
PURSUANT TO 8 DEL. C. 4 225
1. This is an action brought pursuant to 8 Del. C. 9 225 to declare who are
the proper officers and directors of a Delaware corporation and to enjoin persons unlawfully
holding themselves out to be directors and officers of the corporation from so doing.
2. Plaintiff, Julian M. Romeskie ("Romeskie") is a Director and is the
President of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
3. Plaintiff, Francois Hubert ("Hubert") is a Director of ChemiCorp
International, Inc. a/k/a Viva Holdings Corp.
4. Plaintiff, Mariusz Rybak ("M. Rybak") is a Director and is the Chief
Executive Officer of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
5. Plaintiff, Sanje Ratnavale ("Ratnavale") is a Director and is the Chief
Financial Officer of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
6. Defendant ChemiCorp International, Inc. ("ChemiCorp") (the
"Company") a/k/a Viva Holdings Corp. ("Viva Holdings"), is a Delaware corporation engaged in
Doc.#205685v.01
# SNIPPETS: IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
# the proper officers and directors of a Delaware corporation and to enjoin persons unlawfully
# holding themselves out to be directors and officers of the corporation from so doing.
# Julian M. Romeskie is a Director and is the
# President of ChemiCorp International, Inc. a/k/a Viva Holdings Corp.
# Plaintiff, Francois Hubert is a Director of ChemiCorp
# Mariusz Rybak is a Director and is the Chief
# Executive Officer of ChemiCorp International,
# Sanje Ratnavale is a Director and is the Chief
# Advanced Environmental Solutions, Inc. and before that as Viva Golf, USA Corp.
# Defendant Geoffrey D. Liddy is a citizen of Florida,
# Defendant Stanley R. Bernstein is a citizen of Florida,
# This Court has jurisdiction over Liddy, Bernstein and Woolbright under 8
# On April 11, 1997, a share acquisition agreement (the "Acquisition
# On April 16, 1997, a Certificate of Amendment was filed with the
# Secretary of State changing the name of the Company from Viva Golf to AES.
# A true and correct copy of the fraudulent
# were President/Director and Secretary/Director, respectively, of AES.
# the Company was negotiating a transaction with IDS
# DECLARATORY RELIEF UNDER 8 DEL.
# adjudication as to the proper officers and directors of the Company.
# the foregoing Complaint for Declaratory and Injunctive Relief Pursuant to 8 De1.C.
http://www.legalcasedocs.com/120/240/834.html#item1
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