And, a version of step 2 just happend:
Allergan requests block to Ackman, Valeant votes, announces Special Meeting date
Allergan (AGN) announced that it has asked the United States District Court for the Central District of California to set an expedited schedule for discovery and a motion for a preliminary injunction against Valeant Pharmaceuticals (VRX), Pershing Square Capital Management, and its principal, William Ackman, for violations of the federal securities laws. In addition, Allergan announced that it will hold a Special Meeting of Stockholders on December 18, subject to confirmation by Allergan that the meeting has been validly requested in compliance with Allergan’s bylaws. Allergan has established an October 27 record date for stockholders entitled to vote at the Special Meeting. In its preliminary injunction motion, Allergan will seek an order barring Valeant, Pershing Square, Ackman, and entities affiliated with them from exercising any rights or benefits associated with Allergan shares that have been acquired unlawfully. Such an order would prevent Valeant, Pershing Square, and Ackman from voting their shares in any special meeting. Allergan’s proposed schedule would require expedited discovery to be completed in October, and would set a hearing on Allergan’s anticipated preliminary injunction motion in advance of the company’s Special Meeting. Should Allergan succeed in obtaining a preliminary injunction in its federal lawsuit, Valeant, Pershing Square, and Ackman’s shares will not be counted toward the special meeting request.
