From the filing:
> As part of the transaction for the acquisition of Otto, Uber agreed to indemnify Mr. Levandowski for claims Google might raise against him. These claims included claims Google might assert for breach of fiduciary duty, breach of the duty of loyalty, breaches of various restrictive covenants, and trade secret misappropriation.
> Uber was aware of Mr. Levandowski’s conduct through the extensive investigation it conducted prior to and after entering into the indemnity agreement with him, and long before it purported to rescind. To the extent Uber claims it was unaware of certain facts, those facts were not material and were fully available to Uber had they cared to look more carefully at the materials it was provided by Mr. Levandowski. In fact, Mr. Levandowski repeatedly told Uber to search those devices for the most accurate information.
> Mr. Levandowski therefore commences the Adversary Proceeding to obtain declaratory relief as to the impact of Uber’s purported rescission on the parties’ respective rights and obligations, to enforce Uber’s obligations arising from the Otto transaction, and to disallow the Proof of Claim.
If I’m reading it correctly, Levandowski says Uber was in on the whole thing as early as Otto’s acquisition (if not earlier), and Uber did not deliver on what was promised per their arrangement.
That makes whatever was promised for Otto essentially reward for a crime, which incredibly Levandowski expects to rectify in a court of law.