P. Agrawal, V. Gadde & N. Segal v. Twitter, Inc. Court Filing by Friedlander & gorris, April 10 2023

Case Number: 2023-0409

Plaintiff: PARAG AGRAWAL , VIJAYA GADDE, and NED SEGAL

Defendant: TWITTER, INC.

Filing Date: April 10, 2023

Location: THE COURT OF CHANCERY OF THE STATE OF DELAWARE

TABLE OF CONTENTS

VERIFIED COMPLAINT FOR ADVANCEMENT

I- NATURE OF THE ACTION

II- PARTIES
III- JURISDICTION

IX- FACTUAL BACKGROUND

A. Twitter's Bylaws Require Advancement and Indemnification

B. The Indemnification Agreements Require Advancement and Indemnification

C. Plaintiffs Depart Twitter

D. Plaintiffs are Named in Proceedings

E. Twitter Breaches its Advancement Obligation

COUNT I: Advancement/ Breach of Contract

COUNT II: Claim for an Award of Expenses (Including Attorneys Fees) Incurred in Connection with Prosecuting this Verified Complaint

X- PRAYER FOR RELIEF

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