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

Case 1:04-cv-00831-SLR Document 130-2 Filed 07/24/2008 Page 1 of 3
EXHIBIT A

Case 1:04-cv-00831-SLR Document 130-2 Filed 07/24/2008 Page 2 of 3
IN TI-IE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
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IN RE VERITAS SOFTWARE CORPORATION Case No. 04-CX/-831 (SLR)
SECURITIES LITIGATION : Consolidated Action
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DECLARATION OF MARK LEONOV
IN SUPPORT OF APPLICATION FOR AN AWARD TO LEAD PLAINTIFF S
MARK LEONOV declares as follows:
1. I am one of the Court-appointed Lead Plaintiffs in the above-captioned
action (the "Litigation"). I submit this Declaration in support of the Application for an
Award To Plaintiffs Pursuant To 15 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 in the Litigation
(including drafts of Plaintiffs’ filings),
4. I engaged in numerous telephone conversations and several in-person
meetings with Plaintiffs’ Counsel throughout the course of the Litigation to discuss all
aspects ofthe case, including the evidence developed during discovery, overall litigation
strategy, avenues of potential factual investigation, and the strengths and weaknesses of
the pa1ties’ various arguments.

Case 1:04-cv-00831-SLR Document 130-2 Filed 07/24/2008 Page 3 of 3
5. I traveled from my residence in California to New York City to attend and
actively participate in a mediation session with Defendants. This required me to spend
three (3) entire days away from my business
6. I actively participated in discussions with my counsel conceming the
appropriate settlement of this Litigation.
7. I complied with Defendants? document requests and interrogatories.
8. I estimate that I devoted approximately one hundred and fifty (I50) hours
in connection with the above-described activities on behalf of the Class.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this L7 day ofIuly 2008 at Los Altos Hills, California.

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