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

17. Lead Counsel prosecuted the litigation on a wholly contingent basis, advancing and
incurring all expenses and, by doing so, shouldered the risk of an unfavorable result over more than
six years. Lead Counsel received no fee compensation – only intermittent, and partial, expense
reimbursement – for its extraordinary efforts. The intense and massive document review, fact and
expert discovery, and pre-trial preparation added significant expenditures to an otherwise costly
prosecution, resulting in expenses of more than $40 million, which includes the significant fees and
expenses of investigators, document-coding teams and analysts, consultants, and experts whose
services Lead Counsel required for the successful prosecution and resolution of this portion of the
litigation. Coughlin Stoia professionals have spent over 247,000 hours on this case. The total hours
of attorney and other professional time expended by Coughlin Stoia and co-counsel working with us
exceed 280,000 hours. Major expenses included the costs associated with a comprehensive
investigation; preparation for and participation in depositions; the production, review and analysis of
millions of images in document discovery for use in depositions, summary-judgment oppositions,
and at trial; the work performed by Lead Counsel’s 12 experts in preparation for their depositions
and trial testimony; and pre-trial consultants.
18. As of September 30, 2007, Coughlin Stoia’s lodestar [hours x hourly rates] for
lawyers, paralegals and other professionals was over $112 million. When combined with the
lodestar of our co-counsel, the lodestar of those dedicated to prosecuting the case for over six years
is $127 million. Substantial additional work on, among other things, the Plan of Allocation, has
been done since September 30, 2007. Paragraphs 295 and 296 below and Exhibits 1 and 2 hereto set
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