Plaintiffs Parag Agrawal, Vijaya Gadde, and Ned Segal, Depart Twitter

VERIFIED COMPLAINT FOR ADVANCEMENT

Plaintiffs Parag Agrawal, Vijaya Gadde, and Ned Segal (Plaintiffs), by and through their undersigned attorneys, upon knowledge as to themselves and their own actions and upon information and belief as to all other matters, allege as follows:

FACTUAL BACKGROUND

Plaintiffs Depart Twitter

29. On or about October 27, 2022, Elon Musk informed each of Agrawal, Gadde, and Segal that their employment with the Company was terminated as of the close of the merger by which Musk took control of the Company.

    
    

30. Section 11 of the Agreements provides that the Company's obligation to indemnify and advance Expenses incurred by Plaintiffs remains in effect following Plaintiffs' terminations, as the Company's obligations "shall continue thereafter so long as Indemnitee shall be subject to any Proceeding . . . by reason of his Corporate Status, whether or not he is acting or serving in any such capacity at the time any liability or expense is incurred for which indemnification can be provided under this Agreement." Id. § 11; see also id. § 14(g) (providing that a "Proceeding" includes that in which Indemnitee "was, is or will be involved as a party or otherwise, by reason of the fact that Indemnitee is or was an officer or director of the Company") (emphasis added).

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This court case No. 2023-0409 retrieved on April 10, 2023, from int.NYT is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction.