In Re SS & C Technologies, Inc. Shareholders Litigation

948 A.2d 1140, 2008 Del. Ch. LEXIS 31, 2008 WL 2267036
CourtCourt of Chancery of Delaware
DecidedMarch 6, 2008
DocketC.A. 1525-VCL
StatusPublished
Cited by9 cases

This text of 948 A.2d 1140 (In Re SS & C Technologies, Inc. Shareholders Litigation) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re SS & C Technologies, Inc. Shareholders Litigation, 948 A.2d 1140, 2008 Del. Ch. LEXIS 31, 2008 WL 2267036 (Del. Ct. App. 2008).

Opinion

OPINION

LAMB, Vice Chancellor.

In this opinion, the court considers a motion to impose sanctions on the plaintiffs and their counsel. The occasion for this request is (i) a motion filed by the plaintiffs for leave to withdraw, but only on notice to the putative class and (ii) their related opposition to a request that the discovery record pertaining to the plaintiffs (other than personal information of a confidential nature) be made part of the public record. On the record before it, the court concludes that the plaintiffs and their counsel acted in bad faith in connection with their motion to withdraw and should be required to reimburse the defendants for their attorneys’ fees and costs incurred in connection with this aspect of the litigation.

*1142 I. 1

A. Procedural History

This litigation began in 2005 when Carlyle Investment Management L.L.C. sponsored a deal to acquire SS & C Technologies Inc. The SS & C board of directors approved the Carlyle transaction on July 27, 2005. SS & C publicly announced the terms of the transaction and filed a preliminary proxy statement the following day. The SS & C stockholders approved the acquisition, and it closed on November 23, 2005.

1. The 2006 Proposed Settlement

Following the announcement of the Carlyle transaction, Paulena Partners and Dr. Stephen R. Landan, filed lawsuits in this court on July 28, 2005, and on August 3, 2005. 2 This court consolidated the two actions and appointed The Brualdi Law Firm and Coughlin Stoia Geller Rudman & Robbins as co-lead counsel on August 31, 20Q5. 3 In late September, the lawyers for the parties began settlement discussions and, on October 18, 2005, the parties entered into a memorandum of understanding to settle the consolidated action. This agreement provided for the dismissal of the litigation in exchange for supplemental disclosures and the payment of attorneys’ fees.

The parties never advised the court of this agreement and never sought leave to present the settlement after the closing of the acquisition. In the months following the closing, the parties performed confirmatory discovery and on, July 7, 2006, submitted the stipulation of settlement for court approval.

At the September 2006 settlement hearing, nearly a year after the closing of the transaction, the parties asked this court to approve the settlement, which had been fully performed in all respects except for the payment of the plaintiffs’ counsel fees. In light of the procedural posture of the settlement, this court declined to approve it “as having been untimely presented.” 4 Relying on Chancellor Duffy’s decision in Chickering v. Giles, 5 this court noted the “necessity” in presenting settlements quickly and advising the court “when some exigent circumstance makes it difficult or impossible to give the necessary notice and seek formal approval before the performance of some part of the settlement.” 6

This court also declined to approve the settlement because the record did not support a finding that “the plaintiffs’ counsel adequately represented the interests of the class or that the settlement terms [were] fair and reasonable.” 7 Indeed, the plaintiffs’ counsel failed to “correctly identify *1143 basic terms of the transaction or the basic set of legal issues thereby raised.” 8

2. The Subsequent Proceedings

Despite this court’s disapproval of the settlement, the plaintiffs and their counsel chose to continue prosecuting the case. Their interest in pursuing the litigation ended, however, after several damaging facts emerged regarding the adequacy and credibility of the named plaintiffs, and the accuracy of numerous statements made in court filings. Consequently, on November 28, 2007, the plaintiffs moved to withdraw. In response, on January 8, 2008, the defendants filed a motion seeking sanctions and an award of all the fees they incurred in connection with the litigation. The defendants also demanded the removal of the confidentiality restrictions placed on the plaintiffs’ deposition transcripts and other discovery materials.

At oral argument, this court concluded that the action should be dismissed without prejudice and without notice to the putative class. 9 In reaching this decision, the court noted the stockholders’ convincing approval of the transaction and the apparent adequacy of the disclosures in the proxy materials that were revised as part of the rejected settlement proposal. 10 Indeed, even with the benefit of fairly extensive discovery following the closing of the transaction, the plaintiffs make no substantial added challenges to the proxy statement. 11 The court also relied on the lack of any stockholder interest regarding the proposed settlement and the fact that no stockholder sought to intervene in the case after the rejection of the settlement. In short, nothing about this case suggested the need to notify the putative class of a “without prejudice” dismissal. In addition, at the hearing the court learned that the discovery materials at issue had become part of the public record in the case, thus mooting the issue of continued confidentiality.

As a result, the only remaining claim is the defendants’ request for attorneys’ fees based on the plaintiffs’ and their counsel’s conduct in connection with aspects of the litigation. 12

B. Facts Pertinent To The Motion For Sanctions

Following this court’s rejection of the proposed settlement, the defendants conducted discovery of the plaintiffs, including the deposition of Dr. Landan and Paule-na’s managing partner, Dean W. Drulias. The defendants argue that the facts they discovered reveal a disturbing pattern of *1144 conduct by the plaintiffs and their counsel in connection with this and other litigation. Most notably, they allege that Drulias manages a web of small investment partnerships for the sole purpose of bringing stockholder lawsuits primarily through his attorney in this action, Richard B. Brualdi. The defendants further contend that Druli-as and Brualdi have attempted to conceal the existence of this enterprise from the court. The defendants also challenge the adequacy of both plaintiffs, but particularly Landan, due to their inability to recall basic aspects of the SS & C litigation at their depositions.

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Bluebook (online)
948 A.2d 1140, 2008 Del. Ch. LEXIS 31, 2008 WL 2267036, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ss-c-technologies-inc-shareholders-litigation-delch-2008.