Free Affidavit - District Court of Delaware - Delaware

Case 1:04-cv-00831-SLR Document 126-3 Filed 07/22/2008 Page 1 of 3

Case 1 :04-cv-00831-SLR Document 126-3 Filed 07/22/2008 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE VERITAS SOFTWARE CORPORATION Case No. 04-CV-831 (SLR)
SECURITIES LITIGATION Consolidated Action

TO: ALL PERSONS OR ENTITIES THAT PURCHASED OR OTHERWISE ACQUIRED
SECURITIES OF VERITAS SOFTWARE CORPORATION ("VERITAS") DURING THE
PERIOD BETWEEN APRIL 23, 2003 AND JULY 6, 2004, INCLUSNE, AND WHO WERE
DAMAGED THEREBY (THE "CLASS").
YOU ARE HEREBY NOTIFIED, pursuant to an Order of the United States District Court
for the District of Delaware, that a hearing will be held before the Honorable Sue L. Robinson,
United States District Judge, at the United States Courthouse for the District of Delaware,
Caleb Boggs Federal Building, Courtroom 6124, 844 N. King Street, Wilmington, DE 19801
at 4:30 p.m. on July 31, 2008 (the "Settlement Hearing"), in order to consider a proposed
settlement (the "Sef·tlement") of a certified class action (the "Litigation"). At the Settlement
Hearing, the Court will determine: (1) whether the Settlement of the Litigation for the sum
of $21.5 million in cash plus all Interest earned thereon (the “Sett|ement Fund") should be
approved by the Court as lair, reasonable and adequate; (2) whether the l.itigation should
be dismissed with prejudice; (3) whether the Plan of Allocation of the Settlement Fund is lair,
reasonable and adequate; (4) whether the application of Co-Lead Counsel for attorneys' fees
and reimbursement ol costs and expenses (the "Fee and Expense Application") should be
approved; and (5) whether the application lor an award to Lead Plaintiffs pursuant to 15 U.S.C.
§78u-4(a)(4) (the "Lead Plalntilt Expense Application") should be approved.
If you purchased or acquired Veritas securities between Apnl 23, 2003 and July 6, 2004,
inclusive, your rights may be affected by the Settlement of this Litigation and you may be
entitled to share in the Settlement Fund. If you have not received a detailed Notice of Pendency
and Proposed Settlement of Class Litigation and the Proof of Claim and Release form, you may
obtain copies by writing to the Claims Administrator at Veritas Software Corporation Securities
Litigation, c/o Berdon Claims Administration LLC, RO. Box 9014, Jericho, NY 11753-8914.
lf you are a Class Member, in order to share in the distribution of the Settlement Fund, you
must submit a Proof of Claim and Release so that it is received no later than August 28, 2008
establishing that you are entitled to recovery.
Il you desire to be excluded from the Class and not recover from the Settlement, you must
submit a request for exclusion so that it is actually received by the Claims Administrator no later
than June 30, 2008, in the manner and form explained in the detailed Notice referred to above.
All Members of the Class who have not requested exclusion from the Class will be bound by
any judgment entered in the Litigation pursuant to the Stipulation of Settlement.
Any objection to any of the matters before the Court must be mailed or delivered so that
it is received by each of the following no later than June 30, 2008, and must indicate that it is
an Objection in the action: In re Veritas Software Corp. Securities Litigation, Case No. 04-CV-
831 (SLR):
CLERK OF THE COURT
United States District Court
District Of Delaware
Caleb Boggs Federal Building
844 N. King Street
Wilmington, DE 19801
Co—Lead Counsel for Lead Plainti//s and the Class:
SCHATZ NOBEL IZARD P.C. HARWOOD FEFFER LLP
Jeffrey S. Nobel Robert I. Harwood
Seth R. 10ein Jef1rey M. Norton
20 Church Street. Suite 1700 488 Madison Avenue
Hartford, CT 06103 New York, NY 10022
LABATON SUCHAFIOW LLP
Ira A. Schochet
Stephen W. Tountas
140 Broadway
New York, NY 10005
Counsel for Defendants:
WILSON SONSINI GOODRICH POTTER ANDERSON &
& ROSATI, PC CORROON LLP
Nina E Locker Peter J. Walsh, Jr.
Peri Nielsen 1313 North Market Street
650 Page Mill Road Wilmington, DE 19801
Palo Alto, CA 94304-1050
PLEASE DO NOT CONTACT THE COURT OR THE CLERK'S OFFICE REGARDING THIS
NOTICE.
DATED; May 14, 2008 BY ORDER OF THE COURT
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE

Case 1:04-cv-00831-SLR Document 126-3 Filed 07/22/2008 Page 3 of 3
LLP Announce the Pendency and Proposed Settlement of Class Litigation
Regarding Veritas Software Corporation
NEW YORK, May 14 /PRNewswire/ -- Co-Lead Counsel for Lead Plaintiffs and the Class have announced,
pursuant to an Order of the United States District Court for the District of Delaware, that a hearing will be held
before the Honorable Sue L. Robinson, United States District Judge, at the United States Courthouse for the
District of Delaware, Caleb Boggs Federal Building, Courtroom 6124, 844 N. King Street, Wilmington, DE
19801 at 4:30 p.m. on July 31, 2008 (the "Settlement Hearing"), in order to consider a proposed settlement
(the "Settlement") of the certified class action, In re Veritas Software Corporation Securities Litigation, Case
No. 04-CV- 831 (SLR) ("Veritas" or the "Litigation"). At the Settlement Hearing, the Court will
determine; (1) whether the Settlement of the Litigation for the sum of
$21.5 million in cash plus all interest earned thereon (the "Settlement
Fund") should be approved by the Court as fair, reasonable and adequate;
(2) whether the Litigation should be dismissed with prejudice; (3) whether the Plan of Allocation of the
Settlement Fund is fair, reasonable and adequate; (4) whether the application of Co-Lead Counsel for
attorneys' fees and reimbursement of costs and expenses should be approved; and (5) whether the
application for an award to Lead Plaintiffs pursuant to 15 U.S.C. '78u-4(a)(4) should be approved.
lf you purchased or otherwise acquired Veritas securities between April 23, 2003 and July 6, 2004,
inclusive, and were damaged thereby, your rights may be affected by the Settlement of this Litigation, and you
may be entitled to share in the Settlement Fund. lf you have not received a detailed Notice of Pendency and
Proposed Settlement of Class Litigation and the Proof of Claim and Release form, you may obtain copies by
writing to the Claims Administrator at Veritas Software Corporation Securities Litigation, c/o Berdon Claims
Administration LLC, P.O. Box 9014, Jericho, NY 11753-8914. If you are a Class Member, in order to share in
the distribution of the Settlement Fund, you must submit a Proof of Claim and Release so that it is received no
later than August 28, 2008 establishing that you are entitled to recovery.
lf you desire to be excluded from the Class and not recover from the Settlement, you must submit a request
for exclusion so that it is actually received by the Claims Administrator no later than June 30, 2008, in the
manner and form explained in the detailed Notice referred to above. All Members of the Class who have not
requested exclusion from the Class will be bound by any judgment entered in the Litigation pursuant to the
Stipulation of Settlement.
Any objection to any of the matters before the Court must be mailed or delivered so that it is received by
each ofthe following no later than June 30, 2008, and must indicate that it is an Objection in the
action: In re Veritas Software Corp. Securities Litigation, Case No.
04-CV-831 (SLR); (1) CLERK OF THE COURT, United States District Court, District Of Delaware, Caleb
Boggs Federal Building, 844 N. King Street, Wilmington, DE 19801; (2) Co-Lead Counsel for Lead Plaintiffs
and the
Class: SCHATZ NOBEL IZARD P.C., Jeffrey S.
Nobel, Seth R. Klein, 20 Church Street, Suite 1700, Hartford, CT 06103; HARWOOD FEFFER LLP, Robert l.
Han/vood, Jeffrey M. Norton, 488 Madison Avenue, New York, NY 10022; and LABATON SUCHAROW LLP,
Ira A. Schochet, Stephen W.
Tountas, 140 Broadway, New York, NY 10005; and (3) Counsel for
Defendants;
WILSON SONSINI GOODRICH & ROSATI, PC, Nina F. Locker, Peri Nielsen, 650 Page Mill Road, Palo Alto,
CA 94304-1050; and POTTER ANDERSON & CORROON LLP, Peter J. Walsh, Jr., 1313 North Market Street,
Wilmington, DE 19801. 2
PLEASE DO NOT CONTACT THE COURT OR THE CLERK'S OFFICE REGARDING THIS NOTICE.
DATED: May 14, 2008 BY ORDER OF THE COURT
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
SOURCE Berdon Claims Administration LLC
-0- 05/14/2008
/CONTACT: Jeffrey Norton, Esq., Han/vood Feffer LLP,
+1 -212-935-7400/
/\Nebsite: http://www.berdonc|aims.com/
2

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