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

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

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Firm Expenses<br />

Lockridge Grindal Nauen P.L.L.P. $ 21.47<br />

Milberg LLP $ 4,344.39<br />

Shalov Stone Bonner & Rocco LLP $ 1,169.72<br />

Spector Roseman Kodr<strong>of</strong>f & Willis PC $ 3,374.88<br />

Stember Feinstein Doyle & Payne, LLC $ 124.26<br />

Zimmerman <strong>and</strong> Reed, PLLP $ 4,287.25<br />

TOTAL $372,312.94<br />

156. Co-Lead Counsel also incurred expenses for mailing <strong>and</strong> publishing the Class<br />

Notice as detailed in the accompanying Keough <strong>Declaration</strong>, attached as Exhibit A hereto. The<br />

Court has already approved payment <strong>of</strong> these expenses from the Settlement Fund, however, so<br />

we do not include those expenses in our request for reimbursement.<br />

157. Plaintiffs’ Counsel are entitled to reimbursement for their reasonable expenses<br />

advanced in class litigation.<br />

158. Because the expenses incurred here were incurred with no guarantee <strong>of</strong> recovery,<br />

Plaintiffs’ Counsel had a strong incentive to keep them at a reasonable level, <strong>and</strong> did so. We<br />

made a concerted effort to avoid unnecessary expenditures <strong>and</strong> economized whenever possible.<br />

The expenses were essential to the successful development <strong>and</strong> prosecution <strong>of</strong> the case, <strong>and</strong><br />

amount to less than 0.5% <strong>of</strong> the Class’ recovery.<br />

49

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