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

More documents

Recommendations

Info

ENRON - SUMMARY OF PLAINTIFFS' FIRMS' HOURS AND LODESTAR January 2, 2008 FIRM NAME HOURS LODESTAR Coughlin Stoia Geller Rudman & Robbins LLP 248,803.91 113,251,049.40 Berger & Montague, P.C. 1,535.30 715,920.00 Joseph A. McDermott, III 90.75 21,375.00 Beirne, Maynard & Parsons, LLP 219.40 55,595.00 Law <strong>Of</strong>fices of Bernard M. Gross, P.C. 65.00 36,050.00 Schwartz, Junell, Greenberg & Oathout, LLP 9,604.04 3,173,492.25 Scott + Scott LLP 7,752.65 3,470,460.50 The Bilek Firm 4,438.50 2,326,887.50 Cuneo Gilbert & LaDuca 6,423.70 3,226,100.25 Genovese Joblove & Battista 9,155.80 4,821,703.30 Wolf Popper 883.20 536,794.50 Shapiro Haber & Urmy LLP 621.10 336,155.50 TOTAL: 289,593.35 $ 131,971,583.20
EXHIBIT 3
Page 1 and 2:
UNITED STATES DISTRICT COURT SOUTHE
Page 3 and 4:
2. The Parties Establish a Document
Page 5 and 6:
I, HELEN J. HODGES, declare as foll
Page 7 and 8:
• Reviewed over 70 million pages
Page 9 and 10:
6. The above recoveries were based
Page 11 and 12:
gathered and which the banks and En
Page 13 and 14:
14. In this endeavor, Coughlin Stoi
Page 15 and 16:
17. Lead Counsel prosecuted the lit
Page 17 and 18:
[T]his representation has been unde
Page 19 and 20:
and the necessary involvement with
Page 21 and 22:
case. The Court hereby awards attor
Page 23 and 24:
published an article, “Enron Jolt
Page 25 and 26:
statements. We compiled profiles on
Page 27 and 28:
34. We had no way of knowing whethe
Page 29 and 30:
which witnesses to pursue, but cont
Page 31 and 32:
the market in October 2001. The ana
Page 33 and 34:
said it was unable to determine whe
Page 35 and 36:
depositions because discovery was p
Page 37 and 38:
65. After the motion was filed, The
Page 39 and 40:
institutional plaintiffs, their rep
Page 41 and 42:
drawing on the expertise of our in-
Page 43 and 44:
83. On May 3, 2002, the Preferred P
Page 45 and 46:
finance certain of the partnerships
Page 47 and 48:
and participated in a scheme to def
Page 49 and 50:
(j) Arthur Andersen LLP (Docket No.
Page 51 and 52:
Lead Plaintiff had adequately alleg
Page 53 and 54:
(a) The Court ruled that Lead Plain
Page 55 and 56:
director of New Power, and issuance
Page 57 and 58:
94. On September 26, 2002, Lead Pla
Page 59 and 60:
mandamus review, and that the Court
Page 61 and 62:
106. On May 6, 2003, defendant Citi
Page 63 and 64:
scheme, and certain specific allega
Page 65 and 66:
pled with the requisite particulari
Page 67 and 68:
Merrill Lynch and Deutsche Bank Ent
Page 69 and 70:
4. Motions to Intervene Additional
Page 71 and 72:
Gramm, Jaedicke, LeMaistre, Meyer,
Page 73 and 74:
professionals and experts, and atte
Page 75 and 76:
121. On May 7, 2003, the Outside Di
Page 77 and 78:
of Enron’s prominence and magnitu
Page 79 and 80:
131. As part of discovery, Lead Cou
Page 81 and 82:
Third Parties and Defendants Date S
Page 83 and 84:
Third Parties and Defendants Date S
Page 85 and 86:
133. Document requests and subpoena
Page 87 and 88:
139. In responding to the document
Page 89 and 90:
146. In addition to JPMorgan’s in
Page 91 and 92:
10. Requests for Admission 152. In
Page 93 and 94:
Protocol Order provided for the ord
Page 95 and 96:
privilege. And the defendants agree
Page 97 and 98:
Deponent Entity Date[s] Location No
Page 99 and 100:
Page 101 and 102:
Page 103 and 104:
Page 105 and 106:
promptly responded to all discovery
Page 107 and 108:
Enron securities, and questions con
Page 109 and 110:
securities, understanding of a repr
Page 111 and 112:
187. Lead Counsel made further supp
Page 113 and 114:
April 16, 2004, Lead Counsel filed
Page 115 and 116:
195. On April 13, 2004, defendants
Page 117 and 118:
Plaintiffs’ Investors Partner Lif
Page 119 and 120:
• Outside Directors’ Memorandum
Page 121 and 122: 208. A two-day hearing was held reg
Page 123 and 124: Expert Entity Area of Opinion Dorri
Page 125 and 126: and is the basis for a presumption
Page 127 and 128: nature of Enron’s financial condi
Page 129 and 130: economically valid method and frame
Page 131 and 132: primarily involving Deutsche Bank,
Page 133 and 134: We filed a notice of request for se
Page 135 and 136: 236. Bankruptcy Examiner Batson him
Page 137 and 138: egarding the §11 claims, which wer
Page 139 and 140: proceeds for our settlement. Thus,
Page 141 and 142: egarding the policies and he moved
Page 143 and 144: team; for example, we reviewed info
Page 145 and 146: Court ruled that Lead Plaintiff fai
Page 147 and 148: Opposition to Deutsche Bank’s Mot
Page 149 and 150: Sec. Litig., 443 F.3d 987 (8th Cir.
Page 151 and 152: Plaintiff’s Opposition to Motion
Page 153 and 154: dated June 5, 2006 as It Pertains t
Page 155 and 156: the Pleadings (Docket No. 5019). On
Page 157 and 158: joint-and-several liability for kno
Page 159 and 160: pricing or trade volume data, estim
Page 161 and 162: y the court and cited in In re Cend
Page 163: 296. Attached hereto as Ex. 2 is a
Page 166 and 167: ADDITIONAL SERVICE LIST Stuart Yoes
Page 168 and 169: ENRON COUGHLIN STOIA GELLER RUDMAN
Page 170 and 171: Name Title Hours Rate Lodestar Meye
Page 178: EXHIBIT 4
Page 182 and 183: TOP SECURITIES SETTLEMENTS Case Nam
Page 184 and 185: Exhibit Listings and Notes regardin
show all

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

Create successful ePaper yourself

Delete template?

Save as template?