OCT 1 6 2014 DOROTHY BROWN VERIFIED COMPLAINT CLERK of CIRCUIT Court' Plaintiff Wade D
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION -------------------------------------------------------------- )( WADE D. MIQUELON, ·· Plaintiff, v. JURY TRIAL DEMANDED WALGREEN CO., Defendant. F1LED -------------------------------------------------------------- )( OCT 1 6 2014 DOROTHY BROWN VERIFIED COMPLAINT CLERK OF CIRCUIT COURt' Plaintiff Wade D. Miquelon ("Miquelon"), through his undersigned counsel, complains against defendant Walgreen Co. ("Walgreens" or the "Company") and alleges as follows: INTRODUCTION 1. This past August 4, Miquelon stepped down as the Chief Financial Officer ("CFO") and President, International of Walgreens, the largest drugstore chain in the United States. The decision was personal, based on his desire to pursue opportunities outside of Walgreens after an outstanding six-year tenure. In announcing Miquelon's decision, the Company issued a press release that hailed Miquelon's "remarkable leadership, strategic vision and expertise." These words faithfully captured the Company's internal assessment ofMiquelon: Only last April, Miquelon was offered a promotion by Walgreens' Chief Executive Officer ("CEO") Gregory Wasson ("Wasson") and was told both verbally and in writing that, ifhe accepted the offer, he would be in line to succeed Wasson as CEO. 2. Over the new few days, from August 5 through August 8, Wasson and Walgreens' Director and largest shareholder Stefano Pessina ("Pessina") met with certain investors, 15401055 including "activist" investors, to discuss the past
[Show full text]