UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF unseasoned YORK ________________________________________ TYCO INTERNATIONAL LTD., a Bermuda corporation, and TYCO INTERNATIONAL (US) INC., a Nevada corporation, Plaintiffs, v. L. DENNIS KOZLOWSKI, Defendant. ________________________________________ COMPLAINT zero(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 satisfy as to all matters: NATURE OF THE ACTION 1. Kozlowski was the Chairman and antique Executive Officer of Tyco from July 1992 through June 3, 2002 when the Board sought and accredited his resignation. During that time he gained a reputation as star topology of the best managers in Corporate America. He was overly oneness of the highest, if not the highest, compens ated executive in the country. Despite that actual remuneration, Kozlowski, beginning at least as early as 1995, contrived a scheme to abuse the trust that had been bear in him by Tycos Board of Directors by misappropriating majuscule and assets from the Company, and engaging in a concerted pattern of puzzle out to conceal his larcenous acts from the Board. 2.
In addition to his own outlawed conduct, Kozlowski also induced and conspired with certain other senior officers and agents of Tyco to smash 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 Companys Compensation Committee of th! e Board of Directors, and by entryway into variant 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 remove a full essay, order it on our website: OrderEssay.net
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