In re Riverbed Technology, Inc. Stockholders Litigation

COURT OF CHANCERY OF THE SAM GLASSCOCK 111 STATE OF DELAWARE COURT OF CHANCERY COURTHOUSE VICE CHANCELLOR 34 THE CIRCLE GEORGETOWN, DELAWARE 19947 Date Submitted: July 14, 2015 Date Decided: July 14, 2015 Peter B. Andrews, Esquire Joseph Christensen, Esquire Craig J. Springer, Esquire Joseph Christensen PA. 3801 Kennett Pike 921 N. Orange Street Building C, Suite 305 Wilmington, DE 19801 Wilmington, DE 19807 Seth D. Rigrodsky, Esquire Tamika Montgomery-Reeves, Esquire Brian D. Long, Esquire Bradley D. Sorrels, Esquire Gina M. Sera, Esquire Ian Liston, Esquire Jeremy J. Riley, Esquire Wilson Sonsini Goodrich & Rosati, PC Rigrodsky & Long, PA. 222 Delaware Avenue, Suite 800 2 Righter Parkway, Suite 120 Wilmington, DE 19801 Wilmington, DE 19803 William M. Lafferty, Esquire Ryan D. Stottmann, Esquire Morris Nichols Arsht & Tunnell LLP 1201 North Market Street Wilmington, DE 19801 Re: In re Riverbed Technology, Inc. Stockholders Litigation, Civil Action No. 10484-VCG Dear Counsel: I have reviewed the Motion to Compel the Deposition of Sean J. Griffith, together with Mr. Griffith’s response to that Motion. Mr. Griffith has filed an objection to a proposed settlement in this matter. The Plaintiffs seek to depose him concerning his objections. They contend that Mr. Griffith does not have standing and purport to seek a deposition on that ground. However, Mr. Griffith’s standing is a purely legal issue based on the date of acquisition of his stock; no further evidence—gathering on this issue is relevant to Mr. Griffith’s objection. Next, Plaintiffs seek to explore the bases for Mr. Griffith’s legal opinions regarding the settlement. Mr. Griffith’s opinions, however, Speak for themselves; again, there is no relevant discovery identified in the Motion to Compel. Finally, I note that the objection is to be heard, together with the proposed settlement, on July 27, 2015. Given this schedule, the inconvenience and expense of further discovery regarding the objection cannot be justified. For the foregoing reasons, the Motion to Compel the Deposition of Sean J. Griffith is DENIED. To the extent the foregoing requires an Order to take effect, IT IS SO ORDERED. Sincerely, /s/ Sam Glasscock 11] Sam Glasscock III