`“nicnoos
`HeeGTEEMEINE>
`1AIGRODSKY
`ransactign
`ae,
`EB; ey
`eLAWP.a.
`eeeangeteueYSSy
`
`5 a
`
`Attorneys at Law
`
`Seth D. Rigradsky
`Admitted in OF MY
`
`Timothy J. MacFail
`Aarnitted in NY
`
`Gina M. Serra
`Adinittadd in OE NL NY, FA
`
`VIA FILE & SERVEXPRESS
`
`Register In Chancery
`New Castle County Courthouse
`500 North King Street
`Wilmington, DE 19801
`
`Herbert W. Moricdras
`Aamitiod in QE PA
`
`VineentA, Licata
`Admittedin NY
`
`Samir Aougab
`Admitted in MHD
`
`March 29, 2024
`
`Re: Roman Lavrenovv. Robert Scaringe, etal.
`C.A. No. Unassigned eO¢_ 93So-m72
`
`Dear Sir/Madam:
`
`I write on behalf of plaintiff in the above-captioned action to respectfully
`
`request that the Register in Chancery issue summonses for the parties listed below
`
`via special process server, DLS Discovery LLC,pursuant to Court of Chancery Rule
`
`A(c).
`
`Robert Scaringe
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`.
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Claire McDonough
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 OrangeStreet
`Wilmington, Delaware 19801
`
`300 Delaware Avenue | Suite 270
`Wilmington, Delaware | 19801
`T 302.295.5310
`
`
`825 East Gate Boulevard | Suite 300
`GardenCity, New York{ 11530
`T 516.683.8516
`
`EFiled: Apr 02 2024 11:20AM EDT
`Transaction ID 72654895
`Case No. 2024-0330-MTZ
`
`
`
`Register In Chancery
`March 29, 2024
`Page 2
`
`Pamela Thomas-Graham
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Karen Boone
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Sanford Schwartz
`c/o Rivian Automotive,Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 OrangeStreet
`Wilmington, Delaware 19801
`
`Jay Flatley
`c/o Rivian Automotive,Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`John Krafcik
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Rose Marcario
`c/o Rivian Automotive, Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Peter Krawiec
`c/o Rivian Automotive,Inc.
`(Pursuant to 10 Del. C. § 3114)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Rivian Automotive,Inc.
`(Pursuant to 10 Del. C. § 3111)
`c/o The Corporation Trust Company
`Corporation Trust Center
`1209 Orange Street
`Wilmington, Delaware 19801
`
`Thank you for your assistance.
`
`If you require any additional information,
`
`please do nothesitate to call.
`
`
`
`Register In Chancery
`March 29, 2024
`Page 3
`
`
`
`Respectfully,
`
`/s/ Seth D. Rigrodsky
`
`Seth D. Rigrodsky (#3147)
`Words: 323
`
`
`
`fiz:
`A‘
`
`=<Wey,
`,
`sopHb
`ania?
`7.
`At)
`at,
`& aes
`
`= Sree va
`
`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`
`ROMAN LAVRENOV, DERIVATIVELY ON BEHALFOF RIVIAN
`AUTOMOTIVE,INC.,
`
`C.A. No. 2024-0330-MTZ
`
`VS.
`
`SUMMONS
`
`Plaintiffs,
`
`ROBERT SCARINGE, CLAIRE MCDONOUGH, PAMELA
`THOMAS-GRAHAM, KAREN BOONE, SANFORD SCHWARTZ,
`ROSE MARCARIO, JAY FLATLEY, PETER KRAWIEC, AND JOHN
`KRAFCIK,
`
`Defendants,
`
`AND
`
`RIVIAN AUTOMOTIVE,INC.,
`Nominal Defendant,
`
`THE STATE OF DELAWARE
`
`TO:
`
`SPECIAL PROCESS SERVER-DLSDiscovery LLC
`
`YOU ARE COMMANDED:
`
`To summon the above-named defendants so that, within 20 days after service hereof upon defendants,
`exclusive of the day of service, defendants shall serve upon Seth D. Rigrodsky. Esq., Plaintiff's counsel, whose
`
`address is 300 Delaware Avenue, Suite 210, Wilmington, DE 19801, an answer to the verified complaint.
`To serve upon defendants a copy hereofand of the complaint.
`
`TO THE ABOVE-NAMED DEFENDANTS:
`In case of yourfailure, within 20 days after service hereof upon you, exclusive of the day ofservice,to
`serve on plaintiffs attorney named above an answerto the complaint, judgment by default will be rendered
`against youfor the relief demanded in the complaint.
`
`Dated:
`
`April 2, 2024
`Register in Chancery
`
`
`
`C.A. # 2024-0330-MTZ
`
`ROMAN LAVRENOV
`
`Plaintiff
`
`V.
`
`RIVIAN AUTOMOTIVE,INC., ET AL
`
`Defendant
`
`SUMMONS
`
`Please effectuate service pursuant to 10 Del.C.sec. 3111 upon:
`
`Rivian Automotive, Inc.
`c/o The Corporation Trust Company
`1209 OrangeSt.
`Wilmington, DE 19801
`
`Service by Special Process Server
`
`Seth D. Rigrodsky. Esq..
`Plaintiff's Counsel
`
`
`
`
`
`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`/ ROMAN LAVRENOV,DERIVATIVELY ON BEHALF OF RIVIAN
`AUTOMOTIVE,INC.,
`
`VS.
`
`Plaintiffs,
`
`ROBERT SCARINGE, CLAIRE MCDONOUGH, PAMELA THOMAS-
`GRAHAM, KAREN BOONE, SANFORD SCHWARTZ, ROSE
`MARCARIO, JAY FLATLEY, PETER KRAWIEC, AND JOHN
`KRAFCIK,
`
`AND
`
`Defendants,
`
`C.A. No. 2024-0330-MTZ
`
`SUMMONS
`
`
`Pursuant to 10 Del.C. Sec. 3114
`
`
`
`RIVIAN AUTOMOTIVE,INC.,
`
`Nominal Defendant.
`
`THE STATE OF DELAWARE
`
`TO SPECIAL PROCESS SERVER -_
`
`DLSDiscovery LLC
`
`YOU ARE COMMANDED:
`
`To Summonthe above-named defendants by service pursuant to 10 Del.C. Sec. 3114 upon
`
`Rivian Automotive, Inc., a Delaware corporation, by serving its registered agent, The Corporation Trust
`Company, which is designated for service of process in Delaware, so that within the time required by
`law, such defendants shall serve upon Seth D. Rigrodsky, Esquire plaintiff's attorney, whose addressis
`300 Delaware Avenue, Suite 210. Wilmington, DE 19801, an answerto the verified complaint.
`To serve upon defendants a copy hereof, of the complaint, and of a statement ofplaintiff filed
`pursuant to Chancery Court Rule 4(dc)(1).
`
`TO THE ABOVE-NAMED DEFENDANTS:
`
`In case of yourfailure, within the time permitted by 10 Del.C. Sec. 3114*, to serve onplaintiff's
`attorney named above an answerto the complaint, judgment by default may be rendered against you for
`the relief demanded in the complaint.
`.
`
`Dated: April 2, 2024
`Register in Chancery
`
`*Thetext of 10 Del.C. Sec. 3114 is set out on the reverse of this Summons
`
`
`
`C.A. No. 2024-0330-MTZ
`
`trustee or memberatthe time suit is commenced, Suchacceptanceorservice as suchdirector, trustee
`or membershall be a signification ofthe consentof such director, trustee ormemberthat any process
`whenso servedshall be ofthe samelegal force and validity as if served upon suchdirector,trustee or
`memberwithin this State and such appointmentof the registered agent(or, if there is none, the
`Secretary of State) shall be irrevocable.
`
`ROMAN LAVRENOV
`Plaintiff,
`
`v.
`
`RIVIAN AUTOMOTIVE,INC., ET AL
`Defendants,
`
`(b) Every nonresientofthis State who after January 1, 2004, accepts election or appointmentas
`a officer of a corporation organized underthe lawsofthis State, or whoafter such date servesin such
`capacity, and every residentof this State whoso accepts election or appointment orserves in such
`capacity and thereafter removes residence from this State shall, by such acceptance or by such
`service, be deemed thereby to have consented to the appointmentof the registered agent of such
`corporation(or, if there is none, the Secretary of State) as an agent upon whom service of process
`may be madeinall civil actions or proceedings brought in this State, by or on behalf of, or against
`such corporation,in which suchofficer is a necessary or properparty,or in any action or proceeding
`SUMMONS
`against suchofficer for violation of a duty in such capacity, whether or not the person continuesto
`Please effectuate service upon:
`serveas suchofficeratthe time suit is commenced, Suchacceptanceor service as such officer shall
`beasignification ofthe consentof such officer that any process when so servedshall be of the same
`legal force and validity as if served upon suchofficer within this State and such appointmentofthe
`registered agent(or, if there is none, the Secretary of State) shall be irrevocable, As used in this
`section, the word "officer" meansanofficer of the corporation who(i) is or was the president, chief
`executive officer, chief operating officer, chief financial officer, chief legal officer, controller,
`treasurer or chief accounting officer of the corporation at any time during the course of conduct
`alleged in the action or proceeding to be wrongful,(ii) is or was identified in the corporation's public
`filings with the United States Securities and Exchange Commission because such person is or was |
`of the most highly compensated executive officers of the corporation at any time during the course of
`conductallegedin the action or proceeding to be wrongful, or(iii) has, by written agreement withthe
`corporation, consentedto be identified as an officer for purposesofthis section.
`
`(c) Service ofprocess shall be effected by serving the registered agent (or, if there is none,the
`Secretary of State) with 1 copy of suchprocessin the mannerprovided by lawfor service of writs of
`summons. In addition, the Prothonotary or the Register in Chancery of the court in which the civil
`action or proceeding is pending shall, within 7 days of such service, deposit in the United States
`mails, by registered mail, postage prepaid, true andattested copies of the process, together with a
`statement that service is being made pursuantto this section, addressed to such director, trustee,
`memberorofficer(i) at the corporation's principal place of businessand(ii) at the residence address
`as the same appearsonthe recordsofthe Secretary ofState,or, if no such residence address appears,
`at the address last known to the party desiring to make suchservice; provided, however, that if any
`suchdirector's, trustee's, member's or officer's addressas describedin clause(ii) ofthis subsection (c)
`shall be the same asthe address describedin clause(i) of this subsection, then the Prothonotary or
`Register in Chancery shall be required to make only 1 such mailing to such director, trustee, member
`orofficer, at the address described in clause(i) of this subsection.
`
`(d) In any action in which any suchdirector, trustee, memberor officer has been served with
`processashereinaboveprovided,the time in which a defendantshall be required to appear andfile a
`responsive pleading shall be computed from the date of mailing by the Prothonotary or the Register
`in Chancery as provided in subsection (c) of this section; however, the court in which such action has
`been commenced mayorder such continuanceor continuances as may be necessary to afford such
`director, trustee, memberorofficer reasonable opportunity to defendthe action.
`
`(e) Nothing herein containedlimits or affects the right to serve processin any other manner now
`or hereafter provided by law. This section is an extension of and not a limitation upon theright
`otherwise existing of service of legal process upon nonresidents.
`
`(f) The Court of Chancery and the Superior Court may makeall necessary rules respecting the
`form of process, the manner ofissuance and retum thereof and such other rules which may be
`necessary to implementthis section andare notinconsistent with this section.
`
`1-Robert Scaringe
`2-Claire McDonough
`3-Pamela Thomas-Graham
`4-Karen Boone
`5-Sanford Schwartz
`6-Rose Marcario
`7-Jay Flatley
`8-Peter Krawiec
`9-John Krafcik
`
`Byserving the registered agent for Rivian
`Automotive, Inc.:
`
`The Corporation Trust Company
`1209 OrangeSt.
`Wilmington, DE 19801
`
`By Special Process Server
`
`§3114. Service of process on nonresident directors,
`governing bodyor officers of Delaware corporations.
`
`trustees, members of the
`
`(a) Every nonresidentof this State who after September 1, 1977, accepts election or
`appointmentasa director, trustee or memberof the governing bodyofa corporation
`organized under the laws of this State or whoafter June 30, 1978, serves in such
`capacity, and every residentof this State who so acceptselection or appointment or
`serves in such capacity and thereafter removesresidencefrom this State shall, by such
`acceptance or by such service, be deemed thereby to have consented to the
`appointment of the registered agent of such corporation (or, if there is none, the
`Secretary of State) as an agent upon whomservice ofprocess may be madeinall civil
`actions or proceedings brought in this State, by or on behalf of, or against such
`corporation, in which suchdirector, trustee or memberis a necessary or properparty,
`or in any action or proceeding against such director, trustee or memberforviolation of
`a duty in such capacity, whether or notthe person continuesto serve as suchdirector,
`
`