UNITED STATES DISTRICT COURTDISTRICT OF COLUMBIA
In re Federal National Mortgage AssociateSecurities, Derivative, and “ERISA” LitigationMDL No. 1688In re Fannie Mae Securities Litigation Consolidated Civil ActionNo. 1:04-cv-01639 (RJL)
FILED WITH REDACTIONS EXHIBITS UNDER SEAL TO FOLLOW
DEFENDANTS’ MOTION TO STRIKE EXPERT WITNESS,OR IN THE ALTERNATIVE, TO COMPEL THE IMMEDIATECONTINUATION OF HIS DEPOSITION
For the reasons stated in the accompanying Memorandum of Law, Defendants FranklinD. Raines, KPMG, J. Timothy Howard, and Leanne G. Spencer, by their undersigned counsel,respectfully move to strike the expert opinion of Mr. Harvey Pitt, or in the alternative, to compelthe immediate continuation of his deposition, to be held on March 3-4, 2011. Given the urgentnature of this motion, Defendants will file the exhibits that accompany this Motion under seal onMonday, February 28, 2011.Pursuant to Local Civil Rule 7(m), counsel for the Defendants conferred with counsel forthe Lead Plaintiffs concerning the matters discussed herein prior to filing the motion. Counselwere not, however, able to resolve their differences. Accordingly, Defendants seek the requestedrelief from the Court. A proposed Order is attached.
Case 1:04-cv-01639-RJL Document 892 Filed 02/25/11 Page 1 of 4