Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv-00831-SLR Document 55 Filed 07/20/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
IN RE VERITAS SOFTWARE CORP. ) Case No: 04-CV-831 (SLR)
SECURITIES LITIGATION ) Consolidated Action
)
STATE OF DELAWARE )
COUNTY OF NEW CASTLE ) ss.
DECLARATION OF PETER J. WALSH, JR.
I, Peter J. Walsh, Jr., having been first duly sworn, hereby depose and say:
1. I am a partner in the Wilmington, Delaware law firm of Potter
Anderson & Corroon LLP and a member of the Bar of the State of Delaware. I submit
this Declaration in support of the Opening Brief in Support of Defendants’ Motion to
Dismiss The Consolidated Amended Class Action Complaint, filed concurrently
herewith.
2. Attached as Exhibit A hereto is a true and correct copy of selected
pages from VER1TAS’ Form 10-Q for the quarter ended September 30, 2003 (filed with
the Securities and Exchange Commission ("SEC") on November 14, 2003).
3. Attached as Exhibit B hereto is a tme and correct copy of selected
pages from VERITAS’ Form 10-K for the fiscal year ended December 31, 2003 (filed
with the SEC on June 14, 2004).
4. Attached as Exhibit C hereto is a true and correct copy of selected
pages from VER1TAS’ form 10-Q for the quarter ended March 31, 2004 (filed with the
SEC on June 14, 2004).

Case 1:04-cv-00831-SLR Document 55 Filed 07/20/2005 Page 2 of 4
5. Attached as Exhibit D hereto is a true and correct copy of selected
pages from VERITAS’ Proxy Statement (filed with the SEC on July 21, 2004).
6. Attached as Exhibit E hereto is a true and correct copy of selected
pages from VERITAS’ Form 10-Q for the quarter ended June 30, 2004 (filed with the
SEC on August 9, 2004).
7. Attached as Exhibit F hereto is a true and correct copy of a Press
Release, dated March 15, 2004, attached to VER1TAS’ Form 8-K (filed with the SEC on
March 15, 2004).
8. Attached as Exhibit G hereto is a true and correct copy of a Press
Release, dated April 21, 2004, attached to VERITAS’ Form 8-K (filed with the SEC on
April 21, 2004).
9. Attached as Exhibit H hereto is a true and correct copy of a Press
Release, dated July 6, 2004, attached to VERITAS’ form 8-K (filed with the SEC on July
6, 2004).
10. Attached as Exhibit I hereto is a true and correct copy of
VERITAS’ Conference Call Transcript, dated January 28, 2004.
11. Attached as Exhibit J hereto is a true and correct copy of selected
pages from VERITAS’ transcript of Second Q 2004 guidance announced May 5, 2004 at
Analyst Day Conference in Las Vegas, Nevada.
12. Attached as Exhibit K hereto is a true and correct copy of
VERITAS’ Conference Call Transcript, dated July 27, 2004.
13. Attached as Exhibit L hereto is a true and correct copy of the
Forms 4 tiled by Gary L. Bloom during the class period.
2

Case 1:04-cv-00831-SLR Document 55 Filed 07/20/2005 Page 3 of 4
14. Attached as Exhibit M hereto is a true and correct copy of the
Forms 4 filed by Edwin J. Gillis during the class period.
15. Attached as Exhibit N hereto is a true and correct copy of the Press
Release, dated July 7, 2004, attached to BMC’s Form 8-K (tiled with the SEC on July 7,
2004).
16. Attached as Exhibit O hereto is a true and correct copy of the Press
Release, dated July 7, 2004, attached to Siebel’s Form 8-K (filed with the SEC on July 7,
2004).
!- A Y _' / ' * 4
Peter sh, Jr. (DSB O. 2437)
SWORN TO AND SUBSCRIBED before me this 20th day of July, 2005.
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691275vl/28298
3

Case 1:04-cv-00831-SLR Document 55 Filed 07/20/2005 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
1, Peter J. Walsh, Jr., hereby certify that on July 20, 2005, I caused true and
correct copies of the foregoing DECLARATION OF PETER J. WALSH, JR. to be
electronically filed with the Clerk of the Court using CM/ECF which is available for
public viewing an downloading, and which will send notification of such filing to the
following counsel of record:
Norman M. Monhait, Esquire (DSB ID No. 1040)
Rosenthal, Monhait, Gross & Goddess, P.A.
919 Market Street, Suite 1401
Post Office Box 1070
Wilmington, Delaware 19899-1401
Tel: (302) 656-4433
Email: [email protected]
I hereby further certify that on July 20, 2005, I have caused the foregoing document to
also be delivered by FedEx/Next Business Moming delivery to the following
non-registered participant:
Christopher J. Keller, Esquire
Goodkind Labaton Rudoff & Sucharow LLP `
100 Park Avenue
New York, New York 10017
\;.u.QQt
Peter . sh, Jr. (D No. 2437)
POTTER ANDERSON & CORROON, LLP
Hercules Plaza, 6th Floor
1313 North Market Street
Wilmington, Delaware 19801
Tel: (302) 984-6000
Email: [email protected]
691275vl/28298

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