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

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I, HELEN J. HODGES, declare as follows:<br />

1. I am a member of Coughlin Stoia Geller Rudman & Robbins LLP (“Coughlin Stoia”),<br />

<strong>Lead</strong> Counsel for <strong>Lead</strong> Plaintiff in this action. 1 I have been actively involved in the prosecution of<br />

this litigation, I am familiar with its proceedings, and have personal knowledge of the matters set<br />

forth here based on my active supervision of and participation in all aspects of the case.<br />

2. I submit this declaration in support of <strong>Lead</strong> Counsel’s motion, pursuant to Rule 23(h)<br />

of the Federal Rules of Civil Procedure (“Rule”), for an award of attorney fees.<br />

I. OVERVIEW<br />

3. For the benefit of the Class, to date, $7.227 billion has been recovered, an<br />

extraordinary outcome, the largest class action securities recovery in history. Coughlin Stoia<br />

requests a fee award of 9.52% of the total recovered plus interest accrued. This request is in accord<br />

with the fee agreement which The Regents of the University of California (“The Regents”)<br />

negotiated at the start of this litigation in January 2002, before it was appointed lead plaintiff<br />

pursuant to the provisions of the Private Securities Litigation Reform Act of 1995 (“PSLRA”). The<br />

recoveries are as follows:<br />

1<br />

On May 1, 2004, <strong>Lead</strong> Counsel, formerly with Milberg Weiss Bershad Hynes & Lerach LLP,<br />

changed its law firm affiliation to Lerach Coughlin Stoia & Robbins LLP, and, on July 1, 2004, to<br />

Lerach Coughlin Stoia Geller Rudman & Robbins LLP. On August 31, 2007, the firm name became<br />

Coughlin Stoia Geller Rudman & Robbins LLP. All references to Coughlin Stoia herein include<br />

Milberg Weiss and Lerach Coughlin and its predecessors.<br />

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