Joint Declaration of Lynn L. Sarko and Marc I ... - Cohen Milstein

95. We believe that the proposed Plan of Allocation is fair, reasonable and not unduly
complicated or expensive and accordingly urge the Court to adopt and approve it.
VII. TIME AND EFFORT DEDICATED TO THIS CASE
96. Co-Lead Counsel and additional Plaintiffs’ Counsel, defined below, devoted more
than 18,268 attorney and professional hours to the prosecution of this case.
97. We have gathered and reviewed time and expense reports of our firms, as well as
time and expense reports from the following additional Plaintiffs’ Counsel: Gainey & McKenna;
Harwood Feffer LLP; Law Offices of Curtis V. Trinko, LLP; Lockridge Grindal Nauen P.L.L.P.;
Milberg LLP; Shalov Stone Bonner & Rocco LLP; Spector, Roseman Kodroff & Willis PC;
Stember Feinstein Doyle & Payne, LLC; and Zimmerman and Reed, PLLP.
98. In the Fee Memo, Plaintiffs seek an award of fees and expenses only on behalf of
Co-lead Counsel and the additional Plaintiffs’ Counsel listed immediately above, who are the
firms that (a) performed work on the case pursuant to direction of or approved by Co-Lead
Counsel; and (b) followed the time reporting requirements established by Co-Lead Counsel, in
an effort to avoid duplicative or unproductive activities as set forth in Paragraph 8 of the
Consolidation Order.
99. Co-Lead Counsel and additional Plaintiffs’ Counsel identified herein successfully
created a common fund of $75 million plus interest, and accordingly are entitled to a reasonable
share of that fund as a fee, to be awarded to and equitably distributed by Co-Lead Counsel to the
Plaintiffs’ Counsel identified herein.
100. Co-Lead Counsel allocated the work in this case to maximize efficiency. We
assigned tasks based on a number of considerations, with the goal of minimizing duplication of
effort. If Co-Lead Counsel had not been stringent in these efforts, the number of hours devoted
to the case would have been much higher. In addition, we carefully assigned work (within our
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