Free Affidavit - District Court of Delaware - Delaware

Case 1 :05-cv-OO272—GI\/IS Document 43 Filed O2/10/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OE DELAWARE
IN RE MBNA CORPORATION Case No. 05—cv·0O272—GMS
SECURITIES LITIGATION CONSOLIDATED
AFFIDAVIT OF RICHARD C. PEPPERMAN. II
STATE OF DELAWARE )
COUNTY OF NEW CASTLE SS'
RICHARD C. PEPPERMAN, II, being duly sworn, deposes and says:
l. I am a member ofthe Bar ofthe State of New York and of Sullivan
& Cromwell LLP, counsel for the defendants in this action. I submit this afndavit to
provide the Court with materials cited in Defendants’ Opening Brief in Support of Their
Motion to Dismiss.
2. Attached hereto as Exhibit A is a true and correct copy of a
January 20, 2005 Press Release issued by MBNA Corporation.
3. Attached hereto as Exhibit B is a true and correct copy of a report
on Form 8-K tiled by MBNA Corporation with the Securities and Exchange Commission
("SEC") on January 20, 2005.
4. Attached hereto as Exhibit C is a true and correct copy ofthe
transcript of a January 21, 2005 analyst conference call hosted by MBNA Corporation.
5. Attached hereto as Exhibit D is a true and correct copy of a report
I on Form 8-K tiled by MBNA Corporation with the SEC on January 21, 2005.

Case 1:05-cv-OO272—G|\/IS Document 43 Filed O2/10/2006 Page 2 of 3
6. Attached hereto as Exhibit E are true and correct copies of relevant
pages hom an annual report on Form 10-K iiled by MBNA Corporation with the SEC on
March 15, 2005.
7. Attached hereto as Exhibit F are true and correct copies of relevant
pages from a report on Form 10-Q tiled by MBNA Corporation with the SEC on May 10,
2004.
8. Attached hereto as Exhibit G are true and correct copies of relevant
pages from a report on Fonn 10-Q filed by MBNA Corporation with the SEC on August
9, 2004,
9. Attached hereto as Exhibit H are true and correct copies of relevant
pages from a report on Form 10-Q tiled by MBNA Corporation with the SEC on
November 9, 2004.
10. Attached hereto as Exhibit 1 is a true and correct copy of an April
21, 2005 Press Release issued by MBNA Corporation.
11. Attached hereto as Exhibit I is a document setting out the closing
price of MBNA Corporation common stock for each trading day in 2005 and obtained
from Bloomberg.
Richard if- pp , 11
Sworn to before me i
on this $__th day of February, 2006 .
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Case 1:05-cv-OO272—Gl\/IS Document 43 Filed O2/10/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I, Richard H. Morse, hereby certify that on February 10, 2006, I caused to be
electronically tiled a true and correct copy of the foregoing document with the Clerk of Court
using CM/ECF which will send notification that such filing is available for viewing and
downloading to the following counsel of record:
Jeffrey S. Goddess, Esquire
Rosenthal Monhait Gross & Goddess, P.A.
Mellon Bank Center
919 Market Street, Suite 1401
P. O. Box 1070
Wilmington, DE 19899
Ralph Nicholas Sianni, Esquire
Seth D. Rigrodsky, Esquire
Milberg Weiss Bershad & Schulman LLP
919 North Market Street, Suite 411
Wilmington, DE 19801
I further certify that on February 10, 2006, I also caused copies of the foregoing
document to be served by hand on the above-listed counsel of record
YOUNG CONAWAY STARGATT & TAYLOR, LLP
Richard H. Morse (LD. No. 531)
17m Floor, Brandywine Building
1000 West Street
P.O. Box 391
Wilmington, Delaware 19899-0391
(302) 571-6651
[email protected]
Attorneys for Defendants
DB0l:l8l52l7.l 0543614901