Case 20-10080-BLS
Doc 5
Filed 01/16/20
Page 1 of 15
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re
Chapter 7
Case No. 20-10080-BLS
CLIO HOLDINGS, LLC
Debtor.
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ZACHARY BENTLEY and TROY LADEHOFF
on behalf of themselves and all others similarly
situated,
Adversary Proceeding
No.________________
Plaintiffs,
v.
USM ACQUISITION, LLC,
TOP MASTER ACQUISITION, LLC, PREMIER
SURFACES ACQUISITION, LLC, GRANITE
SOURCE ACQUISITION, LLC, SOLID
SURFACES, INC., CLIO INTERMEDIATE, LLC
and CLIO HOLDINGS, LLC
CLASS ACTION ADVERSARY
PROCEEDING COMPLAINT
Defendants.
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CLASS ACTION ADVERSARY PROCEEDING COMPLAINT
Zachary Bentley and Troy Ladehoff (“Plaintiffs”) by and through undersigned counsel, on
behalf of themselves and all other similarly situated persons, as and for their complaint against USM
Acquisition, LLC, Top Master Acquisition, LLC, Premier Surfaces Acquisition, LLC, Granite
Source Acquisition, LLC, Solid Surfaces, Inc., Clio Intermediate, LLC And Clio Holdings, LLC
(“Defendants”), allege as follows:
JURISDICTION AND VENUE