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Proposed Bear Stearns Shareholder Settlement

Proposed Bear Stearns Shareholder Settlement

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Published by DealBook
Proposed settlement of an investor lawsuit against Bear Stearns, resolving claims for $275 million.
Proposed settlement of an investor lawsuit against Bear Stearns, resolving claims for $275 million.

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Published by: DealBook on Jun 07, 2012
Copyright:Attribution Non-commercial

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07/10/2013

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK 
 –––––––––––––––––––––––––––––––––—————xIN RE THE BEAR STEARNS COMPANIES,INC. SECURITIES, DERIVATIVE, AND ERISALITIGATIONThis Document Relates To:Securities Action, 08-Civ-2793 (RWS):::::::::Master File No.:08 M.D.L. No. 1963 (RWS) –––––––––––––––––––––––––––––––––—————x
NOTICE OF LEAD PLAINTIFF’S UNOPPOSED MOTION FOR PRELIMINARY APPROVAL OF PARTIAL SETTLEMENT,APPROVAL OF NOTICE TO THE SETTLEMENT CLASS ANDCERTIFICATION OF THE SETTLEMENT CLASS FOR SETTLEMENT PURPOSES
PLEASE TAKE NOTICE that The State of Michigan Retirement Systems (“LeadPlaintiff”), through counsel, hereby moves this Court before the Honorable Robert W. Sweet, for an order pursuant to Rule 23 of the Federal Rules of Civil Procedure: preliminarily approving the proposed partial settlement; approving the proposed forms of the notice of pendency of classaction and proposed partial settlement and the summary notice of pendency of class Action and proposed partial settlement; approving the proposed methods of disseminating notice; certifyingthe Settlement Class for settlement purposes only; appointing Lead Plaintiff as ClassRepresentative and Berman DeValerio and Labaton Sucharow LLP as Class Counsel; setting adate for the Settlement Hearing; and such other and further relief as the Court deems just and proper. The Bear Stearns Defendants will not oppose the motion.PLEASE TAKE FURTHER NOTICE that in support of this motion, Lead Plaintiff submits herewith (1) Lead Plaintiff’s Memorandum of Law in Support of its Unopposed Motionfor Preliminary Approval of Partial Settlement, Approval of Notice to the Settlement Class andCertification of the Settlement Class for Settlement Purposes, (2) the Declaration of James W.
Case 1:08-md-01963-RWS Document 275 Filed 06/06/12 Page 1 of 2
 
Case 1:08-md-01963-RWS Document 275 Filed 06/06/12 Page 2 of 2
 
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK 
 –––––––––––––––––––––––––––––––––—————xIN RE THE BEAR STEARNS COMPANIES,INC. SECURITIES, DERIVATIVE, AND ERISALITIGATIONThis Document Relates To:Securities Action, 08-Civ-2793 (RWS):::::::::Master File No.:08 M.D.L. No. 1963 (RWS) –––––––––––––––––––––––––––––––––—————x
DECLARATION OF JAMES W. JOHNSON
I, JAMES W. JOHNSON, declare as follows pursuant to 28 U.S.C. § 1746:1.I am a member of the law firm of Labaton Sucharow LLP, Court-appointed Co-Lead Counsel for The State of Michigan Retirement Systems (“Lead Plaintiff”) and the proposedclass in this Action. I am admitted to practice before this Court.2.I respectfully submit this declaration in support of Lead Plaintiff’s UnopposedMotion for Preliminary Approval of Partial Settlement, Approval of Notice to the SettlementClass and Certification of the Settlement Class for Settlement Purposes. I have personalknowledge of the matters testified to herein.3.Annexed hereto as Exhibit 1 is a true and correct copy of the Stipulation andAgreement of Settlement with the Bear Stearns Defendants, dated as of June 5, 2012. TheStipulation contains several exhibits negotiated by the Settling Parties: the proposed preliminaryapproval order (Exhibit A); the notice (Exhibit A-1); summary notice (Exhibit A-3); proof of claim (Exhibit A-2); and judgment (Exhibit B).
Case 1:08-md-01963-RWS Document 275-1 Filed 06/06/12 Page 1 of 127

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