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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`
`IN RE TRUECAR, INC.
`STOCKHOLDER DERIVATIVE
`LITIGATION
`
`CONSOL.
`
`C.A. No. 2019-0672-AGB
`
`
`[PROPOSED] ORDER GRANTING THE INDIVIDUAL DEFENDANTS’
`AND NOMINAL DEFENDANT’S MOTION TO DISMISS THE VERIFIED
`CONSOLIDATED STOCKHOLDER DERIVATIVE COMPLAINT
`
`WHEREAS, Defendants Abhishek Agrawal, Robert Buce, Christopher Claus,
`
`Steven Dietz, Neeraj Gunsagar, Michael Guthrie, John Krafcik, Erin Lantz, John
`
`Mendel, Wesley Nichols, Victor “Chip” Perry, John Pierantoni, Brian Skutta, Jeff
`
`Swart, and Ion Yadigaroglu (collectively, the “Individual Defendants”), and
`
`Nominal Defendant TrueCar, Inc., by and through their undersigned counsel, having
`
`moved the Court for an order dismissing Plaintiff’s Verified Consolidated
`
`Stockholder Derivative Complaint with prejudice pursuant to Court of Chancery
`
`Rules 12(b)(6) and 23.1;
`
`IT IS HEREBY ORDERED, this _______ day of ____________, 20___ that
`
`the Individual Defendants’ and Nominal Defendant’s Motion to Dismiss the Verified
`
`Consolidated Stockholder Derivative Complaint is GRANTED.
`
`
`
`
`
`
`________________________________________
` Chancellor Andre G. Bouchard
`
`EFiled: Dec 19 2019 04:55PM EST
`Transaction ID 64543947
`Case No. 2019-0672-AGB
`
`
`
`
`
`
`
`

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