On August 11th, the Delaware Chancery Court issued its sixth written opinion in a case brought by a bank's employees who invested in a bank-formed employee investment fund that co-invested with the bank. Denying in part the defendants' motion for summary judgment, the Delaware Chancery Court discussed the funds' independent directors and their 'studious impersonation of a rubber stamp.' The Court also refused to dismiss the aiding-and-abetting claim against the bank since every member of the advisory board was a bank executive. Forsythe v. ESC Fund Management Co.