Declaration Of Helen J. Hodges In Support Of Lead Counsel's ...

thereby. On May 28, 2003, Lead Plaintiff filed an amended motion for class certification, which
mirrored in most respects the opening motion (Docket No. 1445). After Lead Plaintiff’s motions
were filed, defendants took extensive discovery related to class certification.
202. In October of 2003, oppositions to Lead Plaintiff’s amended motion for class
certification were filed. The following oppositions were filed by various defendants and other
plaintiffs:
• Defendant Stanley C. Horton’s Joinder in Certain Defendants’ Brief in Opposition to
Class Certification of Plaintiffs’ Section 10(b) and Rule 10b-5 Claims (Docket No.
1796);
• Andrew Fastow’s Joinder in Certain Individual Defendants’ Opposition to Class
Certification with Respect to Plaintiffs’ §20A claims (Docket No. 1794);
• Partial Objection by Putative Class Members to Lead Plaintiff’s Amended Motion
for Class Certification and Memorandum of Law Thereon (Docket No. 1789);
• Response of Defendant Ken L. Harrison to Plaintiffs’ Motion for Certification of
Class Claims (Docket No. 1798);
• Memorandum of Law of Bank of America Corporation and Banc of America
Securities LLC in Opposition to Lead Plaintiff’s Amended Motion for Class
Certification (Docket No. 1778);
• Certain Defendants’ Brief in Opposition to Class Certification of Plaintiffs’ Section
10(b) and Rule 10b-5 Claims (Docket No. 1780);
• Financial Institution Defendants’ Memorandum of Law in Opposition to Lead
Plaintiff’s Amended Motion for Class Certification (Docket No. 1788);
• Certain Individual Defendants’ Opposition to Class Certification With Respect to
Plaintiffs’ Section 20A Claims (Docket No. 1795);
• Outside Directors’ Amended Memorandum Concerning Certification of Class Claims
Under Section 11 (Docket No. 1785);
• Defendant Rebecca Mark-Jusbasche’s Response to Lead Plaintiff’s Amended Motion
for Class Certification (Docket No. 1792);
• Vinson & Elkins L.L.P.’s Opposition to Class Certification (Docket No. 1799);
• Andrew Fastow’s Joinder in Outside Directors’ Memorandum Concerning
Certification (Docket No. 1769);
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