Free Motion for Attorney Fees - District Court of Delaware - Delaware

Case 1:04-cv-00831-SLR Document 130-3 Filed 07/24/2008 Page 1 of 3
EXHIBIT B

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

IN RE VERITAS SOFTWARE CORPORATION Case No. 04-CV—83I (SLR)
SECURITIES LITIGATION : Consolidated Action
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DECLARATION OF TAY SIQEW CHOON
IN SUPPORT OF APPLICATION FOR AN AWARD TO LEAD PLAINTIFFS
TAY SIEW CHOON declares as follows:
I. I am one of the Court-appointed Lead Plaintiffs in the above-captioned
action (the "Litigation"). I submit this Declaration in support ofthe Application for an
Award To Plaintiffs Pursuant To I5 U.S.C. §78u-4(a)(4). I have personal knowledge of
the matters referred to herein.
2. I have performed various duties in furtherance of my fiduciary obligations
to the Class as Co—Lead Plaintiff and Class representative, as set forth below.
3. I reviewed and commented on numerous pleadings and briefing on various
motions in the Litigation (including drafts on PlaintiB“s’ filings).
4. I reviewed, commented upon and consulted with counsel on various
discovery requests as well as reviewed and commented upon a number of specific
documents produced by defendants where counsel relied on my unique business
experience and professional knowledge of software company operations.
5. I engaged in numerous telephonic and email communications with counsel
and my Co—Lead Plaintifi Mr. Mark Leonov, throughout the course ofthe Litigation to
discuss all aspects of the case, including the evidence developed during discovery, overall
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litigation strategy, avenues of potential factual investigation, and the strengths and
weaknesses ofthe parties’ various arguments.
6. I complied with Defendants’ document requests and interrogatories,
reviewing, compiling and copying voluminous personal financial records for production
to defendants.
7. I traveled from my residence in Singapore to New York City to meet with
counsel and sit for a deposition in connection with Plaintiffs’ Motion for Class
Certification. This required me to spend 3 entire days away from my business, not
including extensive intemational travel time.
8. I actively participated in discussions with my counsel conceming the
appropriate settlement of this Litigation.
9. I estimate that I devoted more than 165 hours in connection with the
above—described activities on behalf ofthe Class.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this@_[ day of July 2008, Singapore
_,¢ _ _
TAY SI W Cl-IOON
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