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No. 83 Consolidated Amended Verified Stockholder Derivative Complaint; Demand for Jury Trial against ...

Document In re Wells Fargo & Company Shareholder Derivative Litigation, 4:16-cv-05541, No. 83 (N.D.Cal. Feb. 24, 2017)
Defendants nonetheless continued imposing relentless pressure on employees, while continually touting to investors and others the Company’s “record” cross-selling, which allowed Stumpf and other Defendants to reap millions in ...
... [committee].” While (as detailed below) Stumpf and the other Defendants actually knew of or consciously disregarded facts relating the illicit account-creation scheme long before 2013, Stumpf’s admissions to Congress were nonetheless ...
... strong and weak economic cycles, as we can grow by expanding the number of products our current customers have with us.” The same Report highlighted that Wells Fargo was “known across [its] industry as number one, second to none, ...
So we have some investigation to do to figure out what the real facts are because none of our internal systems for getting feedback like that have been tripped until this came along.
... and inaccurate in that he failed to recount the facts demonstrating he and the Board knew or consciously disregarded facts concerning the illicit account-creation scheme well before December 2013, his admission is nonetheless ...
Defendants nonetheless represented that they maintained a robust risk management system where the Board and senior executives have overall and ultimate responsibility for the management of risk, and which were carried out ...
The risk controls and oversight policies Defendants touted were not strong and robust but rather were weak and near-nonexistent in several operational segments.
At the time of these stock transactions, the Insider Selling Defendants knew about or recklessly disregarded material, non-public information regarding the illicit account-creation scheme as detailed in Section VI above, but nonetheless ...
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No. 270-1 Co-Lead Plaintiffs' Notice of Motion and Motion for Preliminary Approval of Settlement filed ...

Document In re Wells Fargo & Company Shareholder Derivative Litigation, 3:16-cv-05541, No. 270-1 (N.D.Cal. Feb. 28, 2019)
Nonetheless, the Defendants also have taken into account the expense, uncertainty and risks inherent in any litigation, especially in complex cases like the Derivative Action.
... represents, on behalf of their respective clients, that (i) their 23 clients have been continuous shareholders of Wells Fargo at all times relevant to the allegations in 24 the Complaint and through the date of this Stipulation; and (ii) none ...
16 Nonetheless, the Defendants also have taken into account the expense, uncertainty and 17 risks inherent in any litigation, especially in complex cases like the Derivative Action.
26 Nonetheless, the Defendants also have taken into account the expense, uncertainty and 27 risks inherent in any litigation, especially in complex cases like the Derivative Action.
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