harriet goldstein, et al. v. marvell technology group, ltd...

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C-06-06286 RMW] DECLARATION OF DENIS F. SHEILS IN SUPPORT OF THE MOTION FOR APPOINTMENT AS LEAD PLAINTIFF 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Joseph J. Tabacco, Jr. (75484) Email: [email protected] Christopher T. Heffelfinger (118058) Email: [email protected] Nicole Lavallee (165755) Email: [email protected] BERMAN, DeVALERIO, PEASE TABACCO BURT & PUCILLO 425 California Street, 21st Floor San Francisco, California 94104 Telephone: (415) 433-3200 Facsimile: (415) 433-6382 Joseph C. Kohn Email: [email protected] Denis F. Sheils Email: [email protected] William E. Hoese Email: [email protected] KOHN, SWIFT & GRAF, P.C. One South Broad Street, Suite 2100 Philadelphia, PA 19107 Telephone: 215-238-1700 Facsimile: 215-238-1968 Attorneys for Proposed Lead Plaintiff Police and Fire Retirement System of the City of Detroit UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION HARRIET GOLDSTEIN, Individually and on Behalf of All Others Similarly Situated, Plaintiffs, vs. SEHAT SUTARDJA, WEILI DAI, PANTAS SUTARDJA, GEORGE A. HERVEY, and MARVELL TECHNOLOGY GROUP, LTD., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-06-06286 RMW CLASS ACTION DECLARATION OF DENIS F. SHEILS IN SUPPORT OF THE MOTION OF THE POLICE AND FIRE RETIREMENT SYSTEM OF THE CITY OF DETROIT TO CONSOLIDATE RELATED ACTIONS, FOR APPOINTMENT AS LEAD PLAINTIFF AND FOR APPROVAL OF ITS SELECTION OF LEAD COUNSEL DATE: January 26, 2007 TIME: 9:00 a.m. CTRM: 6

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Page 1: Harriet Goldstein, et al. v. Marvell Technology Group, Ltd ...securities.stanford.edu/filings-documents/1036/... · other securities of Marvell Technology Group, Ltd . ("Marvell"

C-06-06286 RMW] DECLARATION OF DENIS F. SHEILS IN SUPPORT OF THE MOTION FOR APPOINTMENT AS LEAD PLAINTIFF

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Joseph J. Tabacco, Jr. (75484) Email: [email protected] Christopher T. Heffelfinger (118058) Email: [email protected] Nicole Lavallee (165755) Email: [email protected] BERMAN, DeVALERIO, PEASE TABACCO BURT & PUCILLO 425 California Street, 21st Floor San Francisco, California 94104 Telephone: (415) 433-3200 Facsimile: (415) 433-6382

Joseph C. KohnEmail: [email protected] Denis F. Sheils Email: [email protected] William E. Hoese Email: [email protected] KOHN, SWIFT & GRAF, P.C. One South Broad Street, Suite 2100 Philadelphia, PA 19107 Telephone: 215-238-1700 Facsimile: 215-238-1968

Attorneys for Proposed Lead Plaintiff Police and Fire Retirement System of the City of Detroit

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

HARRIET GOLDSTEIN, Individually and onBehalf of All Others Similarly Situated,

Plaintiffs,

vs.

SEHAT SUTARDJA, WEILI DAI, PANTAS SUTARDJA, GEORGE A. HERVEY, and MARVELL TECHNOLOGY GROUP, LTD.,

Defendants.

))))))))))))))))))))

Case No. C-06-06286 RMW

CLASS ACTION

DECLARATION OF DENIS F. SHEILS IN SUPPORT OF THE MOTION OF THE POLICE AND FIRE RETIREMENT SYSTEM OF THE CITY OF DETROIT TO CONSOLIDATE RELATED ACTIONS, FOR APPOINTMENT AS LEAD PLAINTIFF AND FOR APPROVAL OF ITS SELECTION OF LEAD COUNSEL

DATE: January 26, 2007 TIME: 9:00 a.m. CTRM: 6

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I, DENIS F. SHEILS, declare as follows :

1 . I am a shareholder in the law firm of Kohn, Swift, & Graf, P .C. I submit this

declaration in support of the Motion of the Police and Fire Retirement System of the City of

Detroit (' PFRS") for Consolidation of Related Actions, for Appointment as Lead Plaintiff and

for Approval of Its Selection of Lead Counsel .

2. Attached are true and correct copies of the following exhibits :

Exhibit 1 : PRIMEZONE Notice, dated October 6, 2006 ;

Exhibit 2: Declaration of Walter Stampor with PFRS' shareholder losses attached;

Exhibit 3 : Firm Resume of Kohn, Swift, & Graf, P.C .

I declare under penalty of perjury under the laws of the United States that the

foregoing is true and correct . Executed this of Demme er, 2006, at Philadelphia,

Pennsylvania .

C-06-06286 RMW] DECLARATION OF DENIS F . SHEILS IN SUPPORT OF THE MOTIONFOR APPOINTMENT AS LEAD PLAINTIFF 1

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EXHIBIT 1

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xoy Jacoos & Associates xtles class Action Lawsuit on Behalf of Ma . .. http://biz .yahoo .cone/pz/061006/106384 .htm1?printer=l

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Press Release Source : Roy L . Jacobs, Esq.

Roy Jacobs & Associates Files Class Action Lawsuit on Behalf ofMarvell Technology Group , Ltd. Investors -- MRVLFriday October 6, 9:30 am E T

NEW YORK, Oct. 6, 2006 (PRIMEZONE) -- Roy Jacobs & Associates announces that it has filed a class action lawsuitin the United States District Court for the Northern District of California on behalf of purchasers of the common stock andother securities of Marvell Technology Group, Ltd . ("Marvell" or the "Company") (NASDAQ : MRVL - News) whopurchased during the period from October 3, 2001 through October 3, 2006 (the "Class Period") .

For further information you may call toll free, 1-800-347-1236, or contact counsel by e-mail by writing toclassattorney(a)_pipeline .com .

The complaint alleges that Marvell and certain of its officers and directors violated the federal securities laws by makingfalse and misleading statements and omissions concerning the backdating of the grant of stock options to management .The Company has now said that its financial statements from June of 2000 to the present cannot be relied upon, andthat it will be restating financial results . The practice of manipulating stock option dates not only potentially lines thepockets of the executives, but here resulted in the overstatement of Marvell's earnings during the Class Period, and theunder-booking of compensation expenses . Under accounting rules, back-dating an option grant is deemed the paymentof additional compensation and must be accounted for as an expense, which Marvell failed to do .

On October 3, 2006, the defendants announced that the Company would be forced to restate its financial statements tocorrect for the backdating of stock options . From the time that assertions were first made in the press that Marvell'soptions practices might be questionable to the date of this announcement, Marvell stock sank from over $28 per share toroughly $16 per share .

If you purchased Marvell stock or other securities during the Class Period, you may qualify to serve as Lead Plaintiff onbehalf of the Class, which . consists of all persons and entities who purchased Marvell stock or other securities fromOctober 3, 2001 through October 3, 2006 . You are not required to have sold your Marvell stock or other securities inorder to claim damages, or to serve in this role . All motions for appointment as Lead Plaintiff must be filed with the Courtby December 5, 2006 .

If you wish to discuss this action or have any questions concerning this notice or your rights or interests with respect tothis matter, please contact Roy L . Jacobs . Mr. Jacobs will personally speak with you at no cost or obligation .

More information on this and other class actions can be found on the Class Action Newsline athttp ://www.primezone .com/ca .

Contact :

Roy Jacobs & AssociatesRoy L . Jacobs, Esq .1-800-347-1236

Source : Roy L. Jacobs, Esq .

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KOy racons st Associates Piles (-lass Action Lawsuit on Behalf of Ma . . . http ://biz,yahoo .com/pz/061006/1063 84 .hbd?printer= l

Copyright © 2006 Yahoo! Inc . All rights reserved . Privacy_P o l__icy - Terms of Service - Co rpy ight Poj y - Ad Fee dbackCopyright @ 2006 PrimeNewswire. All rights reserved . Redistribution of this content is expressly prohibited without prior written

consent . PrimeNewswire makes no claims concerning the accuracy or validity of the information , and shall not be held liable fo rany errors , delays , omissions or use thereof.

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EXHIBIT 2

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DECLARATION OF WALTER STAMPOR IN SUPPORT OF THE POLICE & FIRERETIRMENT SYSTEM OF THE CITY OF DETROIT'S MOTION TO CONSOLIDATEALL ACTIONS, FOR APPOINTMENT AS LEAD PLAINTIFF AND TO APPROVE ITS

SELECTION OF LEAD COUNSE L

Pursuant to 28 U.S.C. § 1746, I, Walter Stampor, Executive Secretary of the Police & Fir e

Retirement System of the City of Detroit ("PFRS") (formerly known as the Policemen and Firemen

Retirement System of the City of Detroit), declares as follows :

1 . I respectfully submit this Declaration in support of the application by PFRS t o

consolidate all actions, for appointment as Lead Plaintiff in this securities class action pursuant to the

Private Securities Litigation Reform Act of 1995 ("PSLRA") and to approve PFRS' selection of lea d

counsel . Unless otherwise noted , the facts set forth herein are based upon my personal knowledge . If

I called as a witness , I could and would testify competently thereto .

2. PFRS is an integrated program to provide economic security to the police officers and

firefighters of the City of Detroit and their beneficia ries . It consists of both a defined pension and a

defined contribution plan and provides pension, death, disability and withdrawal benefits to eligibl e

I participants and their beneficiaries .

3. As of June 30, 2004, PFRS had 5,060 active employee members and 8 ,328 retirees and

beneficiaries . Currently, PFRS' fund balances total approximately $4.0 billion in assets .

4. I have reviewed the various complaints filed in this action and adopt the allegations se t

forth therein . PFRS seeks to become Lead Plaintiff in this action because of its considerable losses as

a result of purchasing stock in Marvell Technology Group, Ltd. ("Marvell") . PFRS purchased

123,600 shares of Marvell stock during the period October 3, 2001 through October 3, 2006 . Based

on trading data provided by PFRS, PFRS' counsel has calculated PFRS' losses to be $ 1,459,665 as

result of the violation of federal securities laws alleged in the lawsuits . See PFRS' Chart of Losses

attached hereto as Exhibit A. PFRS did not purchase the securities that are the subject of this action

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at the direction of its counsel, Kohn, Swift, & Graf, P .C. or in order to participate in any privat e

action arising under the Securities Exchange Act of 1934 (the "Exchange Act") .

5. PFRS is currently serving as Lead or Co-Lead Plaintiff in the following actions filed

during the three years preceding the date of this Certification :

In re Levi Strauss & Co . Securities LitigationAdvanced Marketing Services, Inc . Securities Litigation

Brody v . Dot Hill Systems, et at.KLA-Tencor Corporation Securities Litigation

6. PFRS is also one of several investors that have sought to be appointed as a clas s

representative in In re Williams Sec. Liti ., an action that has been pending for more than 3 years

(although PFRS is not the lead plaintiff in that action .) The court has yet to rule on that application .

In any event, the case has recently settled but has not yet received final approval . PFRS is also a

named plaintiff in the El Paso Corporation Securities Litigation, but PFRS did not seek lead plaintiff

in that case. That action was also commenced more than three years ago . Finally, PFRS is serving as

lead plaintiff in In re King Pharmaceuticals Securities Litigation, a suit that was commenced more

than three years ago, and which has recently settled but is subject to approval by the Court .

7. During the three years prior to the date of this Certification, PFRS has sought to serv e

as a Lead Plaintiff for a class in the following actions filed under the federal securities law but wa s

not appointed for various reasons, including due to not having the largest losses :

In re Royal Dutch/Shell Securities LitigationIn re Bisys Securities Litigation

In re CNL Hotels & Resorts Inc. Securities LitigationIn re Shaw Group Inc. Securities Litigation

In re Delphi Corp. Securities LitigationIn re Boston Scientific Corp. Securities Litigation

8. In addition, PFRS has filed Lead Plaintiff motions in Sonus Networks Securities

Litigation , In re Bausch & Lomb Securities Litigation and the SafeNet, Inc. Securities Litigation.

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Those motions have not yet been decided.

9. I am informed and understand the requirements and duties imposed upon a lead

plaintiff by PSLRA . Further, I understand the Congress enacted those statutory amendments in order

to place responsibility for managing securities class actions in the hands of established institutiona l

investors such as PFRS. I have educated myself about the enactment of the PSLRA and the

important role institutional investors serve to ensure the highest quality representation in securitie s

class actions . I have experience working with special class action counsel in complex litigation ,

including participating in significant strategic decisions and interfacing with outside counsel to ensur e

that they work effectively and efficiently .

10. PFRS understands that it owes a fiduciary duty to all members of the proposed Clas s

to provide fair and adequate representation and to work actively with class counsel toward obtaining

the largest possible recovery for the proposed Class consistent with good faith and meritorious

advocacy. PFRS will keep fully informed at all times concerning the status and progress of this case,

the strengths and weaknesses of the case, and the prospects for settlement . As Lead Plaintiff, PFRS

will consult with counsel in advance with respect to each major litigation event, such as important

motions, settlement discussions, trial preparation and trial, and shall have the authority an d

responsibility to direct counsel with respect to each of these events after receiving the benefit of

counsel's advice. To the extent necessary, representatives of PFRS will also attend key hearings an d

Itri al .

11 . PFRS is willing and able to serve both as Lead Plaintiff and a class representative o n

behalf of the Class, including providing testimony at deposition and trial, if necessary . I am

committed to the vigorous representation of PFRS and the other members of the putative Class in thi s

case .

12. PFRS has retained Kohn, Swift, & Graf, P .C. as its counsel and has directed Kohn ,

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Swift, & Graf, P .C. to seek PFRS' appointment as Lead Plaintiff in this case . I am aware that Kohn,

Swift, & Graf, P .C. has extensive experience and a proven track record of success in the area of

securities litigation. PFRS has negotiated a fee structure with Kohn, Swift, & Graf, P .C. that is

acceptable to PFRS and, as it understands, subject to court approval .

13. PFRS will not accept any payment for se rving as representative party on behalf of the

Class beyond its pro rata share of any recovery, except such reasonable costs and expenses (excluding

lost wages) relating to the representation of the Class as ordered or approved by the Court .

1 declare under penalty of perjury that the foregoing is true and correct .

Executed this 3 0 of November, 2006 .

vvWalter StamporExecutive SecretaryPolice and Fire RetirementSystem of the City of Detroit

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11/29/06 WED 13 :10 [TX/RX NO 6384]

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EXHIBIT A

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Marvell Technology Group Shareholder LossesClass Period : 10/3/01-10/3/06

Average Price : $18 .454 (10/4/06-12/4/06)Shareholder : Police & Fire Retirement System of the City of Detroi t

Trade Date Ad' Shares Bought Ad' Shares Sold Adj Shares Remaining Adj Price/Share Cost/Proceeds10/3/2001 Beg . Holdings 06/7/2002 34,800 34,800 $6.0625 ($210,975 .00 )

6/10/2002 6,000 40,800 $6.5350 ($39,210 .00)6/11/2002 25,600 66,400 $6.2350 ($159,616 .006/12/2002 16,000 82,400 $5 .8675 ($93,880 .0 0)6/13/2002 10,400 92,800 $5 .9525 ($61,906 .00 )6/14/2002 2,800 95,600 $5 .5825 ($15,631 .00 )6/17/2002 12,000 107,600 $6.4725 ($77,670 .00 )7/19/2002 (14,000) 93,600 $5.6400 $78,960 .0 09/25/2002 (5,600) 88,000 $4.7350 $26,516 .0 0

11/13/2002 (18,400) 69,600 $4.7125 $86,710 .0 012/13/2002 (69,600) 0 $5.1275 $356,874 .0 012/19/2005 53,400 53,400 $29.0300 $1,550,202 .00)

1/27/2006 800 54,200 $34.9200 ($27,936 .00)1/27/2006 6,600 60,800 $36.2650 ($239,349.00)2/16/2006 5,000 65,800 $32.6800 ($163,400.00)2/24/2006 17,200 83,000 $31 .0400 ($533,888.00)

3/6/2006 16,000 99,000 $32 .0650 ($513,040.00)3/24/2006 14,556 113,556 $28 .8100 ($419,358.36)3/27/2006 4,044 117,600 $28 .8950 ($116,851 .38 )6/27/2006 (27,600) 90,000 $21.9150 $604,854 .0 06/27/2006 (800) 89,200 $21.9700 $17,576.00

8/8/2006 (15,100) 74,100 $17.4600 $263,646.008/8/2006 (3,000) 71,100 $17.3600 $52,080 .008/9/2006 (19,300) 51,800 $17.9400 $346,242 .008/9/2006 (4,200) 47,600 $17.9500 $75,390 .00

8/16/2006 7,700 55,300 $20.0900 $154,693 .00)8/16/2006 16,000 71,300 $20.3400 ($325,440.00)8/16/2006 800 72,100 $19.6900 ($15,752 .0010/3/2006 13,400 85,500 $16.9800 ($227,532.00)

Subtotal : 263,100 (177,600) ($3,037,4 8 1 .74 )Shares Remainin : 85,50 0Shares Remaining X $18 .454 : $1,577,81 7Total Losses : ($1,459,665 )

** There are two 2 :1 stock splits during the class period on 6/29/04 & 7125/06 . The number of shares purchased and sold ,and the purchase and sale prices, in the chart have been adjusted to reflect the effect of the stock splits . The actual numberof shares purchased without adjusting for splits is 123,600, and the number of shares sold prior to the adjustments is 82,700 .

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EXHIBIT 3

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KOHN, SWIFT & GRAF, P .C

Since its founding in 1969, the firm of Kohn, Swift & Graf, P .C., has been a

national leader in class actions and other complex commercial litigation . The firm has 1 9

lawyers, 6 paralegals and an administrative staff of 21 . Over its more than 35 year history, th e

firm has continuously been involved in securities class actions and was one of the first law firm s

in the country to handle shareholder class and derivative litigation and other matters of corporat e

governance .

Kohn, Swift & Graf, P .C. and its partners have been selected by courts an d

co-counsel to be lead counsel, or members of the executive committee of counsel, in scores of

class actions throughout the country in the securities fraud, antitrust, tort and consumer

protection fields . Recently, the firm has been co-lead counsel in the Holocaust Era cases and

other ground breaking international human rights litigation which have resulted in settlements in

the billions of dollars for the plaintiff classes from Swiss Banks and German and Austrian

industries. The firm also maintains a general business litigation practice representing plaintiffs

and defendants, including Fortune 500 and other publicly traded corporations, in state and

federal courts .

The firm' s partners are regularly requested to lecture at continuing legal educatio n

programs and bench-bar conferences on the subjects of class action litigation and complex trial

skills . In 2001 Joseph C . Kohn was appointed by Chief Judge Edward Becker of the Third

Circuit Court of Appeals to a Third Circuit Task Force examining the use of auctions to select

lead counsel in class action cases .

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Drawing on its 35 years of experience in the prosecution of securities clas s

actions, the Kohn firm has been retained by pension funds, including several multi-billion dollar

funds, to monitor the fund's investments and to commence litigation when appropriate. The firm

has brought litigation on behalf of the Retirement System of the City of Philadelphia, the Detroit

Policemen and Firemen's Retirement System and has been lead or co-lead counsel in th e

following securities class actions among others : In re KLA-Tencor Corp . Securities Litigation,

Master File No . 06-cv-04065-MJJ, (N .D. Cal), In re Calpine Corporation Securities Litigation,

Master File No . C-02-1200 (N .D. Cal) ; In re Schulman Partnerships Securities Litigation, MDL

753- AAH (C.D. Ca.) ; Goldenberg, et al . v. Marriott PLP Corp ., et al ., No. PJM 95-3461 (D .

Md.); In re : Intelligent Electronics, Inc . Securities Litigation, Master File No . 92-CV-1905 (E .D .

Pa.); WEBBCO v . Tele-Communications, Inc ., et al ., No. 94-WM-2254 (D . Colo .); The Carter

Revocable Trust v. Tele-Communications, Inc ., et al ., No . 94-WM-2253 (D . Colo.); Rabin v .

Concord Assets Group, Inc., et al ., 89 Civ . 6130 (LBS) (S .D.N.Y.); Sadler v . Stonehenge Capital

Corp., et al ., 89 Civ. 6512 (KC); Ramos, et al . v. Patrician Equities Corp ., et al ., 89 Civ . 5370

(TPG) (S .D.N.Y.) ; In re Advacare Securities Litigation, (E .D. Pa. 1993) ; Solo, et al . v. Duval

County Housing Finance Authority, et al ., No. 94-1952-CA (Duval Cty. Fla.); In re Clinton Oil

Securities Litigation, (D. Kan. 1982) .

The firm is also lead counsel in numerous antitrust class actions throughout th e

country, including the following: In re Compact Disc Minimum Advertised Price Antitrust

Litigation , MDL No . 1361 (D. Me .) ; In re Graphite Electrodes Antitrust Litigation , MDL No .

1244 (E.D. Pa .) ; In re Stock Exchanges Options Antitrust Litigation, MDL No . 1283

(S.D.N.Y.) ; In re Pillar Point Partners Antitrust Litigation , MDL No . 1202 (D . Arizona); In re

Metal Building Insulation Antitrust Litigation , C.A. No. H-96-3490 (S .D. Tex .) .

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The Kohn firm has maintained a business litigation practice and represented

private clients as plaintiffs in securities and antitrust cases where it was the sole counsel, or

assisted by a few co-counsel. These cases were hard fought and several have proceeded through

trial and appeals : Alvord-Polk, Inc. v. F. Schumacher & Co ., 37 F.3d 996 (3d Cir . 1994),

cert . denied, 514 U.S . 1063 (1995) (summary judgment in favor of defendants reversed by Third

Circuit; certiorari denied by the Supreme Court ; case tried to conclusion before a jury and settled

after trial) ; Gulfstream III Associates, Inc. v. Gulfstream Aerospace Corp . , 995 F.2d 425 (3d Cir .

1993) (jury verdict in favor of plaintiff; case settled) ; Big Apple BMW, Inc. v. BMW of North

America, Inc . , 974 F .2d 1358 (3d Cir. 1992), cert, denied, 507 U.S. 912 (1993) (summary

judgment in favor of defendant reversed by Third Circuit ; case settled prior to trial) .

The firm was appointed special counsel to the trustee in bankruptcy by forme r

Third Circuit Judge Arlin Adams in the In re Foundation for the New Era Philanthrophx , No .

95-1372a (E .D. Pa. Bankr. 1995) case, one of the largest bankruptcies ever filed in the Eastern

District of Pennsylvania, and successfully prosecuted claims against Prudential Securities,

accounting firms and law firms on behalf of the bankrupt estate .

The firm has also represented a number of defendants in securities class actions,

including U.S. Healthcare, Inc . (now Aetna , Inc .) .

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JOSEPH C. KOHN

Joseph C. Kohn is a shareholder and director in the firm of Kohn, Swift & Graf,

P.C., with which he has been associated since 1982 . He has personally tried jury and non jury

cases and argued cases in the Third Circuit Court of Appeals, the Judicial Panel on Multidistrict

Litigation, and in Federal Courts in Pennsylvania, New York, New Jersey, Illinois, Texas,

Georgia and the District of Columbia and in various State trial and appellate Courts throughout

Pennsylvania .

Mr. Kohn has a Cum Laude Bachelor's Degree from the University o f

Pennsylvania and a 1982 J .D . Degree, Cum Laude, from Villanova Law School, where he was

both Editor-in-Chief of the Villanova Law Review and winner of the prestigious Reimel Moot

Court competition, an accomplishment unique in the law school's history . He was elected to the

Order of the Coif, and later served on the Villanova Law School Board of Consultors .

Since joining the Kohn firm in 1982, he has represented both plaintiffs and

defendants in securities law, antitrust, civil rights, toxic tort, consumer fraud, product liability,

RICO and other complex litigation in class and non-class cases . He has been appointed by

courts or co-counsel as lead or co-lead counsel in the following securities fraud class actions: In

re Calpine, Securities Liti ag tion, C-02-1200 (SBA) (N.D. Ca.) ; In re Schulman Partnerships

Securities Litigation , MDL 753- AAH (C .D. Ca.) ; In re: Intelligent Electronics, Inc . Securities

Litigation , Master File No . 92-CV-1905 (E .D. Pa.); Rabin v. Concord Assets Grou Inc., et al .,

89 Civ. 6130 (LBS) (S .D.N.Y.) ; Sadler v. Stonehenge Capital Corp., et al . , 89 Civ. 6512 (KC) ;

Ramos, et al . v. Patrician Equities Ca et al., 89 Civ. 5370 (TPG) (S .D.N.Y.) ; In re Advacare

Securi ties Litigation, (E.D. Pa. 1993) . He has been appointed by Courts and co-counsel as co-

lead counsel in the following pending or recently concluded cases : In re Compact Disc Minimum

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Advertised Price Antitrust Litigation, MDL No. 1361 (D. Me) ; In re Graphite Electrodes

Antitrust Litigation, MDL No. 1244 (E .D. Pa.); In re Stock Exchanges Options Trading Antitrust

Litigation, No. M-21-79 (RCC) (S .D .N.Y.); In re S throid Marketing Litigation, MDL No .

1182 (N.D . Ill .) ; In re Pillar Point Partners Antitrust Litigation, MDL No. 1202 (D. Ariz .) ; In re

Toys "R" Us Antitrust Litigation, MDL No. 1211 (E.D. N.Y .) ; In re Metal Building Insulation

Antitrust Litigation , H-96-3490 (S .D. Tex.); In re Sorbates Antitrust Litigation (Calif. Sup. Ct.) .

He has also participated in the following complex cases among others as lead counsel or a

member of the executive committee of counsel : In re Pennsylvania Diet Drugs Litigation ,

Master File No . 0031262 (C .C.P. Phila . Co., Pa .) ; In re Copley Pharmaceutical Products Liability

"Albuterol" Liti ag tion , MDL No. 1013 (D. Wyo) ; In re Chlorine and Caustic Soda Antitrust

Liti ag tion, Master File No . 86-5428 (E.D. Pa.); Cumberland Farms, Inc. v . Browning Ferris

Industries, et al . , No. 87-3717 (E.D. Pa.) ; In Re Plastic Tableware Antitrust Litigation, No. 94-

CV-3594 (E.D. Pa.); In re Tampico Fibers Antitrust Litigation, (E.D. Pa.) ; In re Residential

Doors Antitrust Litigation, No. 94-CV-3744 (E .D. Pa.) ; In re Amino Acid Lysine Antitrust

Litigation, MDL No. 1083 (N.D. Ill .) ; In re New York State Beer Antitrust Litigation (E.D .

N.Y.) ; In re Paoli Railroad Yard PCB Litigation, Master File No . 86-2229 (E .D . Pa.), In re

Montgomery Ward Catalog Franchise Litigation , MDL No. 685 (E.D. Pa.) and Schwab v .

America On Line, Inc . , No. 96 CH 13732 (Cook Co ., Ill .) .

He has been lead trial counsel in several major class action jury trials, including

the Montgomery Ward franchise termination litigation which was settled after five weeks of trial

immediately prior to closing arguments for $25 million plus forgiveness of all indebtedness from

the former franchisees to Ward in the approximate additional amount of $2 million . In February

1999, he tried Crawley v. Chrysler Corp . , a consumer class action which resulted in a 'jury

2

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verdict of $62 million for the plaintiff class . In September, 2000, he was trial counsel in Stewart

v. Associates, et al . , a consumer fraud and RICO class action which was settled after three weeks

of trial for $12 million . He also tried Parkway Corp . v. City of Philadelphia, a federal civil rights

case, and won a $6 million jury verdict .

He has lectured at Continuing Legal Education courses of the Pennsylvania Ba r

Institute on commercial trial practices, expert evidence, class actions and antitrust law .

In January, 2001 he was appointed by Chief Judge Becker of the Third Circuit t o

a task force analyzing whether competitive auctions should be used to select lead counsel in clas s

actions. He also serves as a "Judge Pro Tem" in the Philadelphia County Commerce Cour t

Program .

He is a member of the American, Pennsylvania and Philadelphia Bar

Associations, and has served as a member of the Pennsylvania Bar's House of Delegates, and th e

Federal Courts Committee of the Philadelphia Bar Association . He has been listed in The Bes t

Lawyers in America , (2005, 2006) and as a "Super Lawyer" In Pennsylvania .

3

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DENTS F . SHEILS

Denis F . Shells is a shareholder in the firm of Kohn, Swift & Graf, P .C ., with

which he has been since 1987 .

Mr. Sheils is a 1983 graduate of LaSalle University and a 1986 graduate of

Fordham University School of Law . He is admitted to practice in the Commonwealth of

Pennsylvania, the State of New York, the State of Nevada and before the United States Suprem e

Court, the United States Court of Appeals for the Second and Third Circuits, the United State s

District Courts for the Northern, Southern and Eastern Districts of New York, the Eastern

District of Pennsylvania and the District of Nevada .

Since joining the Kohn firm in 1987, Mr. Sheils' practice has been concentrated i n

the areas of complex litigation, corporate matters and trusts and estates .

Mr. Sheils has represented plaintiffs and defendants in many high-profile cases,

including the following: In re KLA-Tencor Co oration Securities Litigation, Master File No .

06-ev-04065-MJJ (N .D. Cal .) ; In re Calpine Corporation Securities Litigation , Master File No .

C-02-1200 (N .D. Cal .) ; In re Montgomery Ward Franchise Litigation , MDL-685 (E .D. Pa.) ;

Aero ulse Inc . v. Armstrong & Brooks, Ltd., 89-CV-0677 (E .D.N.Y.) ; In re Estate of Ferdinand

Marcos Human Rights Litigation, MDL-840 (D.Haw.); Gurfein v . Sovereign Group, Inc ., 92-

CV-2083 (E .D. Pa.) ; Castle v . Cohen, Civ. No. 87-1042 (E .D. Pa.) ; In re Intel PentiumTM

Processor Liti a~tion , Master File No . 745729 (Santa Clara, California) ; Perish v . Intel

Corporation , Civ . No . 755101 (Santa Clara, California) ; Manning v. Microsoft Cg M., Civ. No .

93-1198 (Harrison County, Texas) ; Schwab v . America Online , No. 96 CH 13732 (Cook County,

Illinois). Mr. Sheils has also been involved in the Holocaust-related litigation, including, but not

limited to In re: Holocaust Victim Assets Litigation, ("Swiss Bank Holocaust Litigation") Cas e

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No. 96-4849 (E .D .N.Y.) and In re Austrian and German Bank Holocaust Litigation, Master File

No . 98 Civ. 3938 (S.D.N.Y.) .

Mr. Sheils has also handled corporate matters for a number of the firm's corporate

clients . Mr. Sheils' representation has included employment discrimination matters, acquisition

and sales of businesses and assets, real estate and collection matters .

Mr. Sheils and the firm also have a diverse and active trusts and estates practice,

including trusts and estates with assets in millions of dollars .

Mr. Shells is a biographee in Marquis ' Who's Who in the World, Who's Who i n

America and Who's Who in American Law .

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WILLIAM E . HOESE

William E . Hoese, a shareholder in the firm of Kohn, Swift & Graf, P .C., joined

the firm in April 1989 . He is AV rated by Martindale-Hubbell . Immediately prior to joining th e

firm he was senior trial counsel in the Philadelphia Regional Office of the United State s

Securities and Exchange Commission .

Mr. Hoese received his Juris Doctor degree, m agna cum laude, from the Syracuse

University College of Law in 1984 . He was inducted into the Justinian Honor Society and th e

Order of the Coif.

Mr. Hoese received his B .A. degree with honors in political science from The

College of Wooster in 1980 . He is a member of Phi Beta Kappa .

Mr. Hoese was co-lead counsel for the plaintiffs in In re Skin-Cap Product s

Liability Litig . , MDL 1243 (S.D. Fla.) . Mr . Hoese is also participating and has part icipated in

numerous antitrust cases, as well as securities, mass tort, consumer, and other commercial cases ,

including : In re Calpine Corporation Securities Liti&, Master File No . C-02-1200 (N .D. Cal.) In

re Dollar General Corporation Securities Litig_ , Civil Action No. 3 :01-0388 (M .D. Tenn.) ; In re

SmithKline Beckman Corp . Securities Litig . , 751 F .Supp. 525 (E .D. Pa. 1990) ; In re

SmithKline/Beecham Shareholders Litig . , Phila . Ct . Common Pleas No. 2303; In re Northwest ,

Court File No. 89-5506 (Hennepin County Dist . Court, 4th Dist .) ; In re First Bank Systems,

Court File No . 88-22227 (Hennepin County Dist . Court, 4th Dist .) ; Pacific Gas and Electric

Securities Litig . , Master File No . 893849 (Cal . Super . Ct .) ; In re Sulfuric Acid Antitrust Litig.,

MDL Docket No . 1536, Master File No. 03 CV 4576 (N.D . Ill .) ; In re Plastics Additives

Antitrust Litig . , Master Docket No . 03-CV-2038 (E .D. Pa.) ; In re Isostatic Graphite Antitrus t

Li. 'tig . , Master File No . 00-CV-1857 (E .D. Pa) ; In re Bulk Extruded Gra hite Products Antitrust

Litig . , Master File No . 02 CV 06030 (D.N.J.); In re Graphite Electrodes Antitrust Litig., Master

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File No . 97-CV-4182 and MDL No . 1244 (E .D. Pa.) ; In re Commercial Explosives Antitrust

Litig . , MDL No. 1093S (D. Utah); In re Amino Acid Lysine Antitrust Liti ., Civil Action No . 95

C 7679 and MDL No . 1083 (N .D. Ill .) ; In re Metal Building Insulation Antitrust Litig . , Civil

Action No. H-96-3490 (S .D . Texas) ; In re Commercial Tissue Antitrust Liti ., MDL No. 1189

(N.D. Fla.) ; Sorbate Prices Cases , J .C.C.P. No. 4073 (Superior Court for the City and County of

San Francisco); In re Domestic Air Transportation Antitrust Litig ., Master File No . 1 :90-CV-

2485-MHS and MDL No . 861 (N.D. Ga.) ; Alvord-Polk, Inc ., et al . v. F. Schumacher & Co . et

al., Civil Action No . 90-3617 (E .D. Pa.) ; Fulton, Mehring & Hauser Co ., Inc. v. The Stanley

Works, et al . , Civil Action No. 90-0987 C(5) (E.D . Mo.) .Fulton, Mehring & Hauser Co ., Inc. v.

The Stanley Works, et al . , Civil Action No . 90-0987 C(5) (E .D. Mo.) ; In re Factor VIII or Factor

IX Concentrate Blood Products Litig . , Civil Action No. 93-5969 and MDL No . 986 (N.D. Ill .) ;

In re: Silicone Gel Breast Implants Products Liability Litig., MDL-926, Master File No . CV 92-

P-1000-S (N .D . Ala .) ; In re : Pennsylvania Diet Drugs Litig . , Master Docket No . 9709-3162

(Common Pleas Court, Philadelphia County) ; In re: TMJ Implant Products Liability Litig. , MDL

1001 and 94-MD-1001 (D . Minn.) ; In re: Copley Pharmaceutical, Inc . "Albuterol" Products

Liability Litig . , MDL-1013 (D . Wy.); In re General Motors Co oration Pickup Truck Fuel Tank

Products Liability Litig. , Master File No . 92-6450 and MDL No . 961 (E.D. Pa.); In re Chrysler

Motors Corporation Overnight Evaluation Program Litig . , MDL 740 (E.D. Mo.) ; In re Norelco

Clean Water Machine Litig . , Master File 88-8423 (E .D . Pa.) ; Barron v . Bolar Pharmaceutical

Company, Inc . , Civil Action No. 90-0536 (E.D. Pa.) .

Mr. Hoese is a member of the Pennsylvania bar, and is admitted to practice before

the United States District Court for the Eastern District of Pennsylvania and the United States

Court of Appeals for the Seventh Circuit .

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KOHN, SWIFT & GRAF, P .C.SECURITIES CASE S

Kohn, Swift & Graf, P .C. has represented investors in shareholder class actio n

and derivative litigation for thirty years, and was among the first law firms in the country to

handle these cases . The firm has been recognized as a leader in the field of class action litigation

by courts and lawyers throughout the country. Over the last quarter century the firm has been

counsel in cases which have resulted in recoveries of over $5 billion for investors, consumers

and other victims of illegal conduct .

Recently, the Kohn firm has been the lead or co-lead counsel in securities case s

against KLA-Tencor Corp., Marriott Corp., Calpine Corp ., Compaq and other technology

companies, and various partnership syndicators . The firm has also represented corporate

defendants in securities cases, including U.S . Healthcare Inc . (now Aetna, Inc .), a major clothing

retailer and a number of regional banks .

Kohn, Swift & Graf, P .C. was lead counsel, or a member of the steering

committee of counsel, in the following securities class actions, among others :

1 . In re KLA-Tencor Corp . Securities Litigation, Master File No . 06-cv-04065-MJJ (N.D. Cal . )

2 . In re Cal inp e Corporation Securities Litigation , Master File No . C-02-1200 (N .D.Cal . )

3 . Berger, et al . v. Coma Computer Corp., et al .,Consolidated C .A. No. H-98-1148 (S .D. Tx . )

4 . Livestock Breeders Int'l of New Jersey Securities Litigation ,C.A . No . 85-2082 (D . N.J. )

5. In re SmithKline Beckman Co oration Securities Litigation,Master File No . 88-7474 (E.D. Pa. )

6 . SmithKline Beecham Securities Litigation ,(Common Pleas of Phila . Co., April Term, 1989, No. 2562)

7 . Sunrise Securities Litigation,

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MDL 655, (E.D. Pa . )

8 . Union Carbide Secu rities Litigation ,MDL 692 (S .D. N.Y. 1989)

9. Upjohn Securities Liti ag tion ,C .A. No. 86-3625 (E.D. Pa 1988)

10. Pacific Gas and Electric Shareholder Derivative Liti ation,Cal . Superior Ct . Master File 89384 7

11 . Snyder v. Oneok, Inc., et al . ,C.A. No . 88-C- 1500 (N. D. Okla.)

12 . In re Schulman Partnerships Secu rities Litigation ,MDL 753- AAH (C.D. Ca. )

13 . Arenson v. Board of Trade of City of Chicago,(N.D. Ill . )

14 . Kohn v. American Metal Climax ,(E.D. Pa . )

15 . In re Ivan F. Boesky Securities Litigation ,MDL No. 732, M21-45-MP

16. Graf, et al . v . Commercial Properties Group , Inc., et al . ,No. 89-CV-2400 (E .D. N.Y . )

17 . Ramos , et al . v. Patrician Equities Corp ., et al . ,89 Civ. 5370 (TPG) (S .D.N.Y.)

18 . Sadler v . Stonehenge Capital Corp ., et al . ,89 Civ . 6512 (KC)

19 . Rabin v. Concord Assets Group, Inc ., et al .. ,89 Civ. 6130 (LBS) (S .D .N.Y . )

20. In re VMS Limited Partnership Secu rities Litigation,No. 90 C 2412 (N .D. I11 .)

21 . WEBBCO v . Tele-Communications . Inc . . et al . ,No. 94-WM-2254 (D . Colo . )

22 . The Carter Revocable Trust v. Tele-Communications, Inc. et al . ,

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No. 94-WM-2253 (D. Colo . )

23 . Solo , et al . v . Duval County Housing Finance Autho rity,No . 94-1952-CA (Duval Cty. Fla . )

24. Goldenberg, et al . v. Marriott PLP Corp ., et al . ,No. PJM 95-3461 (D . Md.)

25. In re Nantucket Island Associates , L.P. Litigation,C .A. No. 1739 (Del. Ch. )

26. Alexander v. Two Winthrop Properties, Inc.,C.A. No. 5602-00 (D.C. Sup. Ct . )

27 . In re: AMC Shareholder Derivative Litigation,No. 12855 (Del . Chancery)

28. In re : Intelligent Electronics, Inc . Securities Litigation ,Master File No. 92-CV- 1905 (E.D. Pa. )

29 . Bird v . Lida, Inc . ,C.A. No . 14486 (Del. Chancery)

30. Akins, et al . v. Cobb, et al . ,C.A. No. 18266-NC (Del . Chancery)

31 . Kaufman v. Motorola ,(N.D. Ill . )

32 . In re Clinton Oil Securities Litigation,(D. Kan. 1982)

33 . In re Advacare Securities Litigation,(E.D. Pa. 1993)

In addition, Kohn, Swift & Graf, P.C. has participated as co-counsel for the

plaintiffs in the following securities cases , among others :

34 . David S . Mielziner v . Public Service Company of New Mexico, et al ,CIV-89-0456 (D . N.M.)

35. In re Bank of Boston Corp . Securities Litigation,Master File No . 89-2269-H (D . Ma . )

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36. Richard E . Bernstein v . Firstrust Savings Bank ,C .A. No. 88-14261 (C.P. - Mont . Cty. )

37. In re First Fidelity Bancorporation Securities Litigation,Master file No . 88-5297 (D . N.J . )

38 . Rodney B . Shields v . Mellon Bank Corp.,C.A. No. (87-2155 (W .D. Pa. )

39. In re Bally - Trump Securities Litigation,Master File No. 87-0373 (D. N.J . )

40 . In re First Federal Savings & Loan,C.A. No . 86-1104 (E.D . Pa . )

41 . Charles & Berte Budman v . Duquesne Light Company,No. 86-1756 (W.D. Pa. )

42. Sedran v . Frank B . Hall,C.A. No . 86 Civ . 2698 (S .D. N.Y . )

43 . In re Duquesne Light Securities Litigation,C.A. Nos . 86.1046 , 86-1756 and 86-2085 (W .D. Pa. )

44 . T. Peter Bridge, M.D. v. First Jersey Securities Inc . ,C.A. No. 85-7059 (E.D. Pa .)

45. In re Bank Ame rica Corporation Securities Litigation ,Master File No. C-85-4779 (Bx) (C .D. Ca . )

46 . Reba A . Seidel , et al. v. Public Service Company of New Hampshire, et al . ,84-541-D (D. N.H.)

47 . Western Union Securities Liti a~ tion ,Master File No . 84-5092 (D. N.J .)

48. In re Pe~sico Securities Liti ate ,82 Civ. 8403 (S.D. N .Y.)

49. In re Data Access Systems Securities Litigation ,C .A. No. 81-1923 (D . N.J .)

50 . In re Union Carbide Corporation Consumer Products Business SecuritiesLitigation, MDL 692 (S .D . N.Y . )

51 . In re Days Inns Corp . Shareholders Litigation ,

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Consolidated Action No. 9455 (Del. Chancery Ct . )

52 . Goodwin v . Boesky, et al . ,MDL 732 (S .D. N.Y . )

53 . In re Crocker Shareholders Litigation ,Consolidated Action No. 7405 (Del. Chancery Ct . )

54 . In re Commonwealth Oil/Tesoro Petroleum Securities Litigation,MDL 347 (W .D. Tex . )

55. Singer v . Magnavox ,C.A. No . 76-98 (Del . Chancery Ct .)

56 . Palmer v. ARA ,C.A. No. 75-254-C5 (D. Kan.)

57 . Flight Transportation Securities Liti ag tion,MDL No . 517 (D. Minn.)

58 . In re Mack Trucks Securities Litigation,Master File No . 90-4467 (E.D. Pa.)

59. In Re Frank B . Hall & Co . . Inc. Secu rities Litigation ,C.A. No. 86 Civ 2709 (MJL) (S .D . N.Y . )

60. Howard Fine et al . v. Houston Oil Trust, et al .,C .A. No. H-82-551 (S .D. Tex . )

61 . In re Farmers Group Stock Option Litigation,Master File No . 88-4994 (F .D. Pa.)

62 . In re First Boston , Inc . Shareholders Litigation,C.A . No . 10338 (State of Delaware)

63. First Republic Bank Securities Litigation,No. CA3-88-0641-H (N .D. Tex . )

64 . Judith R . Swiskay, et al . v. Irving Bank corp. et al . ,Index No. 2419/87 (Supr. Ct. N.Y.)

65. In re Lilco Securities Litigation,84 Civ . 2588 (LDW) (E .D . N.Y . )

66 . Phillip Petroleum Securities Litigation ,

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Master File No. 85-75 (D . Del . )

67 . In re Caesars World Shareholder Litigation,No . CA 001019 (Superior Court of California)

68 . Richard G. Aranso, et al ., et al ., v . Capitol Products Corp ., et al . ,C.A. No . 90-1937 (SSB), (D . N.J . )

69. In re Apple Computer Securities Liti ag tion ,Master File No. C-84-20148 (A)-RPA (N.D . Ca . )

70. BankAmerica Securities Litigation,Master File No . CV 85-4779 WDK (BX) (C .D. Cal .)

71 . First Bank Systems ,

Court File No . 88-22227 ( Hennegen County, Minn . Dist . Court, 4th District)

72 . Farber v. Public Service Company of New Mexico ,C.A. No . 89-0456JB (D . N.M . )

73 . Ramada Inns Securities Litigation,Master File No. 81-456 (D. De . )

74. In re Wyse Technology Securities Litigation ,Case No. C-89-1818 WHO (N .D. Cal . )

75 . Diane Weisburgh, et al . v. United Telecommunications, Inc .,C.A. No. 90-2259-v, (D. Ka . )

76. Jerome Block v . Knowled eware Inc .,1 :91-CV-2390, (N .D. Ga . )

77 . Boardwalk Marketplace Securities Liti ag tion ,MDL 712 (WWE) (D . Conn.)

78 . In re Crazy Eddie Securities Litigation,C.A . No. 87 CIV 0033 (EHN) (E .D. N.Y . )

79. First Jersey Securities Litigation,MDL 681 (E.D. Pa.)

80. Coated Sales Inc . Securities Liti ation,C .A. No . 88-2458 (WGB) (D. N.J . )

81 . Genetech, Inc . securities Litigation ,

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Master File No. C88-4038 DLJ (N .D . Ca . )

82. City Fed Financial Corp. Securities Litigation,C.A. No. 89-4345 (D . N.J . )

83. Scott Paper Company Securities Litigation ,Master File No. 90-6192 (E.D. Pa . )

84. United Telecommunication Securities Litigation,C.A. No. 9-2251-0 (D . Ks. )

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