|
Management Argument to Exclude Shareholder Proposal for Determining Director Indemnification (September 12, 2003) Representing the management of Farmer Bros. Co., Joseph J. Giunta of Skadden Arps Slate Meagher & Flom LLP submitted a September 12, 2003 to the Securities and Exchange Commission ("SEC") arguing that the company should not be required to present shareholders with a proposal of Franklin Mutual Advisers, LLC for shareholder determination of director indemnification relating to past conduct. The letter seeks SEC concurrence with management's position that the shareholder proposal may be excluded from the company's proxy statement pursuant to Rule 14a-8 because, in the attorney's opinion, allowing shareholders to determine whether the past conduct of directors met the standards required for indemnification would be inconsistent with Section 317 of the California Corporations Code. Copies of the letter and its referenced exhibits can be accessed from the links below. Franklin Mutual is expected to submit a reply letter* to the SEC for its consideration. The SEC staff normally responds to such "no action" requests within six weeks. ______________ * Franklin Mutual submitted a reply letter on October 2, 2003.
|
|