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

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Exhibit Listings and Notes regarding Top Settlements Calculations McKesson Cardinal Health Lucent In re McKesson HBOC, Inc. Sec. Litig., No. 99-CV-20743 RMW (PVT), Order Awarding Attorneys’ Fees and Reimbursement of Expenses (N.D. Cal. Feb. 24, 2006); In re McKesson HBOC, Inc. Sec. Litig., No. 99-CV- 20743 RMW (PVT), Notice of Motion, Motion, and Memorandum of Points and Authorities in Support of Lead Counsel’s Application for an Award of Attorneys’ Fees and Reimbursement of Expenses (N.D. Cal.), relevant pages of the order and memorandum are attached hereto as Exhibit F. In re Cardinal Health, Inc. Sec. Litig., No. C2-04-575, Opinion and Order (S.D. Ohio Dec. 31, 2007), attached hereto as Exhibit G. In re Lucent Techs., Inc. Sec Litig., No. 00-cv-621 (JAP), Amended Final Order Approving Counsel’s Joint Petition for an Award of Attorney’s Fees and Reimbursement of Expenses (D.N.J. July 23, 2004); , In re Lucent Techs., Inc. Sec Litig., No. 00-cv-621 (JAP) Memorandum of Law in Support of Application of Lead Counsel for an Award of Attorneys’ Fees and Reimbursement of Expenses (D.N.J.), relevant pages of the order and memorandum are attached hereto as Exhibit H. Bankamerica In re Bankamerica Corp. Sec. Litig., 228 F. Supp. 2d. 1061 (E.D. Mo. 2002). Dynegy In re Dynegy, Inc. Sec. Litig., No. H-02-1571, Order Awarding Attorneys’ Fees and Reimbursement of Expenses (S.D. Tex. July 8, 2005); In re Dynegy, Inc. Sec. Litig., No. H-02-1571, ,Lead Plaintiff’s Counsel’s Memorandum of Law in Support of Application for an Award of Attorneys’ Fees and Reimbursement of Expenses (S.D. Tex.), relevant pages of the order and memorandum are attached hereto as Exhibit I. Raytheon In re Raytheon Co. Sec. Litig., No. 99-12142-PBS, Order and Final Judgment (D. Mass. Dec. 6, 2004); In re Raytheon Co. Sec. Litig., No. 99-12142-PBS, Memorandum of Law in Support of Plaintiff’s Counsel’s Application for an Award of Attorneys’ Fees and Reimbursement of Expenses (D. Mass.), relevant pages of the order and memorandum are attached hereto as Exhibit J. Waste Management In re Waste Management, Inc. Sec. Litig., No. H-99-2183, Findings of Fact and Conclusions of Law (S.D. Tex. May 10, 2002), relevant pages are attached hereto as Exhibit K.
Exhibit Listings and Notes regarding Top Settlements Calculations Adelphia In re Adelphia Comms. Corp. Sec. & Deriv. Litig., No. 03-MD-1529 (LMM), Order Awarding Attorneys’ Fees and Reimbursement of Expenses in Connection with the Deloitte & Touche Settlement (S.D.N.Y. Nov. 17, 2006); In re Adelphia Comms. Corp. Sec. & Deriv. Litig., No. 03-MD-1529 (LMM), Order Awarding Attorneys’ Fees and Reimbursement of Expenses in Connection with the Banks Settlement (S.D.N.Y. Nov. 17, 2006); In re Adelphia Comms. Corp. Sec. & Deriv. Litig., No. 03-MD-1529 (LMM), Plaintiffs’ Memorandum in Support of the Proposed Settlements, Plans of Allocation, Final Certification of the Class for Settlement Purposes and for an Award of Attorneys’ Fees and Reimbursement of Expenses (S.D.N.Y.), relevant pages of the orders and memorandum are attached hereto as Exhibit L. Global Crossing Freddie Mac Qwest The information provided is taken from the Joint Declaration of Jay Eisenhofer and others in In re Tyco Int’l, Ltd. Multidistrict Litig., No. 02-md-1355-PB (D.N.H). Relevant pages of the First Amended Stipulation of Settlement are attached hereto as Exhibit M. Ohio Pub. Emps. Ret. Sys., et al. v. Freddie Mac a.k.a. Federal Home Loan Mortgage Corp. et al., No. MDL- 1584, Order and Judgment (S.D.N.Y. Oct. 27, 2006); Ohio Pub. Emps. Ret. Sys., et al. v. Freddie Mac a.k.a. Federal Home Loan Mortgage Corp. et al., No. MDL-1584, Notice of Lead Plaintiffs’ Motion for Final Approval of Settlement and Plan of Allocation and Application of Lead Counsel and Co-lead Counsel for an Award of Attorneys’ Fees and Reimbursement of Litigation Expenses (S.D.N.Y.), relevant pages of the order and memorandum are attached hereto as Exhibit N. In re Qwest Commc’ns. Int’l, Inc. Sec. Litig., No. 01-cv-01451-REB-CBS, 2006 U.S. Dist. LEXIS 71267 (D. Colo. Sept. 28, 2006); In re Qwest Commc’ns. Int’l, Inc. Sec. Litig., No. 01-cv-01451-REB-CBS, Lead Counsel’s Motion for Award of Attorneys’ Fees and Reimbursement of Expenses (D. Colo.), relevant pages of the memorandum are attached hereto as Exhibit O.
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UNITED STATES DISTRICT COURT SOUTHE
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2. The Parties Establish a Document
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I, HELEN J. HODGES, declare as foll
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• Reviewed over 70 million pages
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6. The above recoveries were based
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gathered and which the banks and En
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14. In this endeavor, Coughlin Stoi
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17. Lead Counsel prosecuted the lit
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[T]his representation has been unde
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and the necessary involvement with
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case. The Court hereby awards attor
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published an article, “Enron Jolt
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statements. We compiled profiles on
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34. We had no way of knowing whethe
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which witnesses to pursue, but cont
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the market in October 2001. The ana
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said it was unable to determine whe
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depositions because discovery was p
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65. After the motion was filed, The
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institutional plaintiffs, their rep
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drawing on the expertise of our in-
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83. On May 3, 2002, the Preferred P
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finance certain of the partnerships
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and participated in a scheme to def
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(j) Arthur Andersen LLP (Docket No.
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Lead Plaintiff had adequately alleg
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(a) The Court ruled that Lead Plain
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director of New Power, and issuance
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94. On September 26, 2002, Lead Pla
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mandamus review, and that the Court
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106. On May 6, 2003, defendant Citi
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scheme, and certain specific allega
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pled with the requisite particulari
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Merrill Lynch and Deutsche Bank Ent
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4. Motions to Intervene Additional
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Gramm, Jaedicke, LeMaistre, Meyer,
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professionals and experts, and atte
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121. On May 7, 2003, the Outside Di
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of Enron’s prominence and magnitu
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131. As part of discovery, Lead Cou
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Third Parties and Defendants Date S
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Third Parties and Defendants Date S
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133. Document requests and subpoena
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139. In responding to the document
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146. In addition to JPMorgan’s in
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10. Requests for Admission 152. In
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Protocol Order provided for the ord
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privilege. And the defendants agree
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Deponent Entity Date[s] Location No
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promptly responded to all discovery
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Enron securities, and questions con
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securities, understanding of a repr
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187. Lead Counsel made further supp
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April 16, 2004, Lead Counsel filed
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195. On April 13, 2004, defendants
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Plaintiffs’ Investors Partner Lif
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• Outside Directors’ Memorandum
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208. A two-day hearing was held reg
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Expert Entity Area of Opinion Dorri
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and is the basis for a presumption
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nature of Enron’s financial condi
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economically valid method and frame
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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
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Page 139 and 140: proceeds for our settlement. Thus,
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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
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Page 155 and 156: the Pleadings (Docket No. 5019). On
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Page 161 and 162: y the court and cited in In re Cend
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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 172 and 173: ENRON - SUMMARY OF PLAINTIFFS' FIRM
Page 178: EXHIBIT 4
Page 182 and 183: TOP SECURITIES SETTLEMENTS Case Nam
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