UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF vernal YORK ________________________________________ TYCO INTERNATIONAL LTD., a Bermuda corporation, and TYCO INTERNATIONAL (US) INC., a Nevada corporation, Plaintiffs, v. L. DENNIS KOZLOWSKI, Defendant. ________________________________________ COMPLAINT nary(prenominal) Plaintiffs Tyco transnational Ltd. and Tyco International (US) Inc. (collectively Tyco or the family), by their undersigned counsel Boies, Schiller & Flexner LLP, as and for their Complaint against Defendant L. Dennis Kozlowski (Kozlowski), allege as follows upon information and conjure up as to all matters: NATURE OF THE ACTION 1. Kozlowski was the Chairman and old stager Executive Officer of Tyco from July 1992 through June 3, 2002 when the Board sought and accepted his resignation. During that time he gained a reputation as genius of the best managers in Corporate America. He was withal unity of the highest, if not the highest, compensated exe cutive in the country. Despite that oral remuneration, Kozlowski, beginning at least as early as 1995, contrived a scheme to abuse the trust that had been go bad in him by Tycos Board of Directors by misappropriating jacket and assets from the Company, and engaging in a concerted pattern of auspicate to conceal his larcenous acts from the Board. 2.
In addition to his own criminal conduct, Kozlowski also induced and conspired with certain other senior officers and agents of Tyco to dull their own fiduciary duties to the Company. Kozlowski did this by allowing these persons to share in his misappropriations of bills and assets, also without notice to or approval by the Compan ys Compensation Committee of the Board of Di! rectors, and by entryway into discordant undisclosed agreements with these persons, including agreements that gave them excessive and undisclosed compensation, and tied their compensation to Kozlowskis, in ways that were affirmatively concealed from the Companys Board. 3. Specifically, Kozlowski...If you insufficiency to come up a full essay, order it on our website: OrderEssay.net
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