DOCUMENTS: All the Depositions in the Tesla Shareholders Litigation case

[UPDATE (31 October 2019): We are now in the process of breaking out each of the individual depositions so you can just download whichever one you’re looking for instead of having to download the entire sets of depositions and then plow through 800 pages to get to what you want.]

Note by Iwpchi: Thanks to https://www.plainsite.org for obtaining and archiving these *very interesting* documents! They have a lot more if you’d like to learn more about the extent of the Tesla/SolarCity securities fraud case here:

https://www.plainsite.org/dockets/32atfyhh5/delaware-court-of-chancery/in-re-tesla-motors-inc-stockholder-litigation/

************************************************************

Delaware Court of Chancery
Case No. 12711-VCS
In Re Tesla Motors, Inc. Stockholder Litigation

Document 328, Attachment 1

[Exhibits 1-7]

****************************************

Exhibit 1: Hayden Barnard (founder, Paramount Solar; former Chief Revenue Officer, SolarCity)

Tesla Shareholders Litigation_Deposition_Exhibit 1_Hayden Barnard

Relevant emails:

  1.  Tesla Shareholders Litigation_Emails_Exhibit 19_Hayden Barnard (TESLA 3404-3405)
  2. [Not located] (TESLA 412642)
  3. Tesla Shareholders Litigation_Emails_Exhibit 44_Hayden Barnard (TESLA 8245-8246)

*******

Exhibit 2: Gregory Bilicic (Investment banker, Lazard Freres & Co., hired by SolarCity to represent them in the negotiations with Tesla, who were interested in taking over SC)

Tesla Shareholders Litigation_Deposition_Exhibit 2_Gregory Bilicic

Relevant emails and documents:

  1.  [Exhibits 1-11 not located]
  2.  Exhibit 12:  Tesla Shareholders Litigation_Emails_Exhibit 81_TESLA 1882_Exhibit 12_Gregory Bilicic  (Exhibit 81 TESLA 1882)

[Note: It appears that most of these documents have been withheld at the request of Lazard (presumably because they contain information that pertains to Lazard’s own confidential institutional communications which are deemed not relevant to the pertinent legal issues in the Tesla Stockholders Litigation itself (too bad because they would undoubtedly be juicy indeed). It’s important to remember that this proceeding is held under the jurisdiction of the Delaware Chancery Court system; it’s not a regular criminal court proceeding, so the rules of evidence and discovery are presumably not the same as in the latter.  If these emails and documents are included with the materials published so far by PlainSite, we have not been able to locate them. – IWPCHI]

*******

Exhibit 3: Brad Buss (former CFO, SolarCity; former CFO, Board of Directors, Tesla)

Tesla Shareholders Litigation_Deposition_Exhibit 3_Brad Buss

Miscellaneous documents:

  1. Tesla Shareholders Litigation_Emails_Exhibit 73_TESLADIR 57808_Brad Buss (Brad Buss, “SolarCity Corporation Termination Certification”, 17 March 2016)

*******

Exhibit 4: Toby Corey (former Chief Revenue Officer, SolarCity)

Tesla Shareholders Litigation_Deposition_Exhibit 4_Toby Corey

*******

Exhibit 5: Robyn Denholm (Chairman, Tesla Board of Directors)

Tesla Shareholders Litigation_Deposition_Exhibit 5_Robyn Denholm

*******

Exhibit 6: Antonio Gracias (Lead Independent Director, Tesla Board of Directors)

Tesla Shareholders Litigation_Deposition_Exhibit 6_Antonio Gracias

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Exhibit 7: Donald R. Kendall, Jr. (Former member, Solar City Board of Directors)

Tesla Shareholders Litigation_Deposition_Exhibit 7_Donald Kendall Jr

 

Complete set in the original single document format from PlainSite:

Exhibits 1-7: Depositions of Brad Buss, Robyn Denholm et al

 

**********************************************************

Delaware Court of Chancery
Case No. 12711-VCS
In Re Tesla Motors, Inc. Stockholder Litigation
Document 328, Attachment 2

[Exhibits 8-14]

*******

Exhibit 8: Courtney McBean (Lawyer, in Charge of team from Evercore which had been hired by Tesla to advise/represent them on acquisition of Solar City)

Tesla Shareholders Litigation_Deposition_Exhibit 8_Courtney McBean

*******

Exhibit 9: Elon Musk Vol I (CEO, Tesla; CEO, CTO, SpaceX; co-founder, Chairman of Board, SolarCity) (Deposition given Saturday, June 1 2019)

Tesla Shareholders Litigation_Deposition_Exhibit 9_Elon Musk_Vol I

Relevant emails and documents:

  1.  Exhibit 1: Elon Musk SolarCity Shareholders Litigation Deposition Vol I, pg 18_Exhibit 1_detail 10-Q 30sep2016
  2.  Exhibit 2:

 

*******

Exhibit 9: Elon Musk Vol II (Deposition given Sat. Aug. 24, 2019)

Tesla Shareholders Litigation_Deposition_Exhibit 9_Elon Musk_Vol II

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Exhibit 10: Kimbal Musk (Elon Musk’s brother; Member, Board of Directors, Tesla)

Tesla Shareholders Litigation_Deposition_Exhibit 10_Kimbal Musk

*******

Exhibit 11: Lyndon Rive (Cousin of Elon and Kimbal Musk; co-founder, CEO of SolarCity)

Tesla Shareholders Litigation_Deposition_Exhibit 11_Lyndon Rive

*******

Exhibit 12: Tanguy Serra (former COO, President, and CFO of SolarCity)
Tesla Shareholders Litigation_Deposition_Exhibit 12_Tanguy Serra

*******

Exhibit 13: Ira Ehrenpreis

Tesla Shareholders Litigation_Deposition_Exhibit 13_Ira Ehrenpreis

*******

Exhibit 14: Jason Wheeler

Tesla Shareholders Litigation_Deposition_Exhibit 14_Jason Wheeler

*******

Complete set in the original single document format from PlainSite:

Exhibits 8-14: Depositions of Courtney McBean, Elon Musk et al

*******************************************

Delaware Court of Chancery
Case No. 12711-VCS
In Re Tesla Motors, Inc. Stockholder Litigation
Document 338, Attachment 4

[Exhibit 75]

*******

Exhibit 75: Radford Small (CFO, SolarCity; VP of Global Capital Markets, Tesla)

Tesla Shareholders Litigation_Depositions_Exhibit 75_Radford Small

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