Court Order Appointing Receiver for Cyberoad.com Corporation – Pelican Cove Investments, Inc. v. Cyberoad.com Corporation

Summary

Pelican Cove Investments, Inc., a shareholder and foreign corporation, filed a legal action against Cyberoad.com Corporation, a dissolved Florida corporation, in Miami-Dade County, Florida. The plaintiff seeks the appointment of a court-ordered receiver, at its own initial expense, to assess whether Cyberoad.com Corporation can be revived and operated for the benefit of its shareholders, instead of being dissolved and liquidated. The court is asked to consider alternative remedies under Florida law to protect shareholder investments and determine the company's future viability.

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EX-2.2 4 scc_s1-ex22.htm COURT ORDER APPOINTING RECEIVER IN JUNE 2007. scc_s1-ex22.htm
Exhibit 2.2
 
   
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT, IN
AND FOR MIAMI-DADE COUNTY,
FLORIDA
     
PELICAN COVE INVESTMENTS,
  
CASE NO.:
INC., a foreign corporation,
    
     
Plaintiff,
    
vs.
    
     
CYBEROAD.COM CORPORATION,
a Florida corporation,
    
     
Defendant.
    
     


COMPLAINT FOR ALTERNATIVE REMEDIES TO JUDICIAL DISSOLUTION
PURSUANT TO FLORIDA STATUTE ###-###-#### AND FOR APPOINTMENT
OF RECEIVER

PLEASE TAKE NOTICE that Plaintiff, PELICAN COVE INVESTMENTS, INC. ("PLAINTIFF") sues the Defendant, CYBEROAD.COM CORPORATION ("CRPI") stating as follows:

1.           This is an action for relief within the jurisdictional limits of this Court.

2.           PLAINTIFF is a foreign corporation and a shareholder of CRPI.

3.           CRPI is an involuntarily dissolved Florida corporation that was doing business in Miami-Dade County, Florida.

4.           This action is filed pursuant to Florida Statute § 607.

5.           That the business and operation of CRPI has been discontinued and/or abandoned by the then existing management of CRPI and the Corporation has been administratively dissolved by the State of Florida.

 
 
 
6.           PLAINTIFF believes that the CRPI can be reactivated and operated in such a manner so that the Corporation can be productive, successful, and so that it and the other shareholders of CRPI will not lose their investment in the Corporation.
 
7.           PLAINTIFF seeks the alternative remedy to dissolution and liquidation provided under Florida Statute § 607.1434 to determine as to whether the Corporation can be saved.

8.           Pursuant to Section § 607.1432 of the Florida Statutes, PLAINTIFF seeks an order of this Honorable Court, for the appointment of a Receiver, to be funded at the initial expense to PLAINTIFF, to work with PLAINTIFF to determine the viability of CRPI, its current status, and to determine if the Corporation can be successfully operated in some fashion in the future for the benefit of its shareholders.

WHEREFORE Plaintiff, Pelican Cove Investments, Inc. sues the Defendant, Cyberoad.com Corporation and seeks Alternative Remedies pursuant to Florida Statue 607 including, but not limited to, the appointment of a receiver in the above styled cause, and for such further relief as this Court may deem necessary and proper.

  ARNSTEIN AND LEHR LLP  
  Counsel for Plaintiff  
  200 East Las Olas Boulevard  
  Suite 1700  
  Fort Lauderdale, FL 33301  
  Telephone: (954) 713-7600  
  Facsimile: (954) 713-7700  
       
Dated: December 20, 2006.
By:
/s/ Alan G. Kipnis  
    Alan G. Kipnis, Esquire  
   
Florida Bar No.181788