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

296. Attached hereto as Ex. 2 is a lodestar summary chart, which summarizes the time
spent by plaintiffs’ counsel litigating this case, as well as each firm’s total lodestar. As reflected
therein, plaintiffs’ counsel have collectively devoted 289,593.35 hours resulting in an overall
lodestar of $131,971,583.20 over the six years of this case. 15
Thus, the average hourly rate for
plaintiffs’ counsel is $456 per hour.
297. To compensate for the delay plaintiffs’ counsel have experienced in receiving any
compensation for their work in this case, it is appropriate to use their current billing rates. In
calculating the lodestar and determining whether the rates are reasonable, the Court should take into
account the attorneys’ reputation and experience. No more need be said than to note that Professor
Coffee has stated that Coughlin Stoia is the plaintiffs’ firm most feared by defense firms in the
securities class action field. Clearly, the experience and reputation of plaintiffs’ counsel support the
hourly rates charged. The Class received the highest quality representation in this case.
15
Hours and lodestar information that appear elsewhere in this declaration, the memorandum of
law and the expert declarations use Lead Counsel’s time and lodestar through September 30, 2007
(and does not include the time of one of plaintiffs' law firms). Since that time, substantial additional
work on, among other things, the Plan of Allocation, has been done. The charts at Exs. 1 and 2
reflect time and lodestar through December 15, 2007 (and include the time of the firm previously
omitted), the day after the hearing for preliminary approval of the Plan of Allocation. It should be
noted that the lodestar figures do not include time which counsel has expended in preparing the fee
motion.
- 159 -