11C V.S.A. § 1303: Pleading

In a derivative action to enforce a right of a mutual benefit enterprise, the complaint shall state:

(1) the date and content of the plaintiff’s demand under subdivision 1301(1) of this title and the enterprise’s response;

(2) if 90 days have not expired since the demand, how irreparable harm to the enterprise would result by waiting for the expiration of 90 days; and

(3) if the enterprise agreed to bring an action demanded, that the action has not been brought within a reasonable time.