Tyco International Ltd.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF late YORK ________________________________________ TYCO INTERNATIONAL LTD., a Bermuda corporation, and TYCO INTERNATIONAL (US) INC., a Nevada corporation, Plaintiffs, v. L. DENNIS KOZLOWSKI, Defendant. ________________________________________ COMPLAINT no 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 impinging as to all matters: NATURE OF THE ACTION 1. Kozlowski was the Chairman and veteran Executive Officer of Tyco from July 1992 through June 3, 2002 when the Board sought and evaluate his resignation. During that time he gained a reputation as sensation of the best managers in Corporate America. He was withal faithfulness of the highest, if not the highest, compensated executive in the country. Despite that genuine remuneration, Kozlowski, beginning at least as early as 1995, contrived a scheme to abuse the trust that had been resettlement in him by Tycos Board of Directors by misappropriating crown and assets from the Company, and engaging in a concerted pattern of visualise to conceal his larcenous acts from the Board. 2. In addition to his own wrongful conduct, Kozlowski also induced and conspired with certain other senior officers and agents of Tyco to wear 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 the Board of Directors, and by entryway into dissimilar 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 C ompanys Board. 3. Specifically, Kozlowski...! If you insufficiency to accept a full essay, order it on our website: OrderEssay.net

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