in the united states district ... - altima cvt settlement · my firm's resume, which includes...

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION

CHRISTOPHER GANN, LEANDRE BISHOP, KEVIN BURKE, ELISA CABEBE, ISRAEL CHIA, KRISTA COSTA, HILLARY DICK, JURA GERALD, SEIJI SILER-HYATTE, JEANINE INGRASSIA, ARNIKA IRELAND, MONTELL JONES, MICHAEL KANZLER, ALEXANDRA MCCULLOUGH, TEREST MIRANDA, AUTUMN PIERCE, ROBERT H. WEINBERG, LASHANDRIKA WILLIAMS, AND LAURA WINDOM, individually and on behalf of all others similarly situated,

Plaintiffs,

v.

NISSAN NORTH AMERICA, INC., a California corporation,

Defendant.

I, Marc L. Godino, declare as follows:

CASE NO: 3:18-cv-00966

CLASS ACTION

DECLARATION OF MARC L. GODINO ON BEHALF OF GLANCY PRONGAY & MURRAY LLP IN SUPPORT OF PLAINTIFFS' MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AGREEMENT AND AWARD OF ATTORNEYS' FEES, COSTS, EXPENSES, AND REPRESENTATIVE PLAINTIFF SERVICE A WARDS

District Judge Eli Richardson Courtroom 874 Magistrate Judge Alistair E. Newbern Courtroom 77 4

JURY TRIAL DEMANDED

1. I am a partner at the firm of Glancy Prongay & Murray LLP (the "Firm"). I am an

attorney duly licensed to practice before all courts of the State of California and am admitted pro

hac vice to practice before this Court. I am one of Co-Lead Class Counsel, and counsel of record

in Cabebe v. Nissan North America, Inc., No. 3:18-cv-00144 (N.D. Cal., January 8, 2018),

brought on behalf of twelve of the nineteen representative plaintiffs in this Lawsuit. 1

1 Capitalized terms herein have the same meaning as set forth in the Settlement Agreement ("SA"), Docket No. 66-1.

511694. I NISSANAL TlMA TRANSMISSION

2. I have been practicing law for over 25 years. My firm has successfully

prosecuted some of the nation's largest class action lawsuits. Attached as Exhibit 3 is a copy of

my firm's resume, which includes my curriculum vitae and the qualifications of each attorney

from the Firm who worked on the litigation.

3. I submit this declaration in support of Plaintiffs' Motion for Final Approval of

Class Action Settlement Agreement and Award of Attorneys' Fees, Costs, Expenses, and

Representative Plaintiff Service Awards. I make this declaration based on personal knowledge. If

called as a witness, I could and would testify competently as to the matters stated herein.

4. The Firm undertook this matter solely on a contingency fee basis.

5. The Firm began investigating this matter approximately three years ago m

January of 201 7. At that time, Co-Lead Class Counsel Mark Greenstone was a partner with the

Firm and, along with me, the lead attorney on the case. In about April of 2018, Mr. Greenstone

founded his own firm, Greenstone Law APC. Mr. Greenstone subsequently filed a firm name

change with the Court and has remained the lead attorney on the case along with me, and has

been personally involved in every aspect of the work described in this Declaration. Danielle L.

Manning is an associate at the Firm who has also been personally involved in every aspect of the

work described in this Declaration and devotes much of her practice to automobile defect

litigation. The Firm and Mr. Greenstone and his firm are herein collectively referred to as

"Cabebe Counsel."

6. On September 22, 2017, after performing an extensive investigation into the facts

underlying problems with the continuously variable transmissions ("CVTs") in 2013-2016

Nissan Altima vehicles (the "Class Vehicles") manufactured by Nissan North America, Inc.'s

("Defendant" or "Nissan"), the Firm sent a pre-suit demand letter to Defendant pursuant to the

California Consumers Legal Remedies Act ("CLRA") on behalf of Elisa Cabebe (the "CLRA

Demand Letter").

7. Prior to sending the CLRA Demand Letter, Cabebe Counsel spent months

investigating the facts and underlying problems with the CVTs including by: (1) reviewing

2 511694.1 NISSANALTIMATRANSMISSION

publicly available complaints from Class Vehicle owners posted on the National Highway Safety

Administration's ("NHTSA") website and other public internet forums; (2) interviewing

potential putative class members and reviewing all of the documents and repair orders associated

with their vehicles including CarFax vehicle history reports; (3) researching the history of

Nissan's initial introduction of the CVTs into the Class Vehicles and its other models and all its

subsequent modifications and redesigns of the CVTs in these vehicles; (4) investigating the

mechanics of how CVTs are supposed to function through independent research and by

consulting with automotive experts; and (5) searching for and learning about any previously filed

or/or currently pending cases against Nissan for similar or related problems in the Class Vehicles

or other models.

8. On October 26, 2017, Cabebe Counsel spoke with Paul Cauley, Jr. from Drinker

Biddle & Reath LLP, counsel for Defendant, regarding the claims asserted in the CLRA demand

letter.

9. On November 21, 2017, Cabebe Counsel received a letter from Paul Cauley, Jr.

which formally responded to Ms. Cabebe's claims against Defendant.

10. After further communications with defense counsel, and based on the results of

my firm's extensive pre-litigation investigation, on January 8, 2018, Cabebe Counsel filed the

first California class action complaint on behalf of Ms. Cabebe and a nationwide class of all

persons who purchased or leased 2013 through 2015 Nissan Altima vehicles against Defendant

in the United States District Court for the Northern District of California alleging six causes of

action relating to alleged Nissan Altima transmission manufacturing defects. Specifically, the

complaint alleged: (1) Violations of the CLRA; (2) violations of California's Unfair Competition

Law; (3) Breach of Implied Warranty pursuant to the California Song-Beverly Consumer

Warranty Act and Cal. Comm. Code§ 2314; (4) Breach of Express Warranty Cal. Com. Code§

2313; (5) Violations of the Magnuson-Moss Warranty Act and (6) Fraudulent Omission.

11. Shortly after Plaintiff filed her complaint, Defendants' counsel requested a meet

and confer to discuss an extended briefing schedule for Defendant to respond to Plaintiffs

3 511694.1 NlSSANALTIMATRANSMISSION

complaint and to assess Plaintiffs view of the case. On January 16, 2018, the counsel for the

Parties met and conferred and agreed to file a stipulation to extend Defendant's time to respond

to Plaintiffs complaint and discussed their respective views of the case, including potential

resolution. During this time Cabebe Counsel continued to regularly interview putative class

members and potential class representatives and reviewed their documents, continued to monitor

complaints posted on NHTSA and elsewhere on the internet, and continued to investigate the

timeline of Nissan's actions regarding the CVTs in the Class Vehicles.

12. On March 7, 2018, Defendant filed a motion to dismiss Plaintiffs complaint and

Plaintiff began preparing to file an amended complaint in lieu of an opposition to Defendant's

motion.

13. In early April 2018, Cabebe Counsel was retained by Plaintiffs Hillary Dick,

Israel Chia, and Alexandra McCullough, and on April 19, 2018, we filed a First Amended Class

Action Complaint ("F AC") adding them as class representatives and including additional causes

of action under New York and Pennsylvania state law. In total the FAC alleged fourteen (14)

causes of action under three states' laws on behalf of Class Members in the states of California,

New York, and Pennsylvania.

14. On May 9, 2018, Defendant filed a motion to dismiss portions of the FAC.

Defendant's motion to dismiss challenged twelve (12) of Plaintiffs' claims, but did not challenge

Plaintiffs Cabebe and Dick's CLRA or California fraudulent omissions claims. On May 30,

2019, Cabebe Counsel filed their Opposition to Defendant's Motion to Dismiss Portions of

Plaintiffs ' First Amended Complaint and on June 13, 2018, Defendant filed its Reply In Support

of its Motion to Dismiss. On June 27, 2018, Danielle L. Manning of my firm our co-counsel

Mark S. Greenstone traveled to San Francisco for the hearing on Defendant's motion to dismiss

and a case management conference.

15. While Defendant's motion to dismiss was still pending, on August 9, 2018,

Plaintiff Cabebe served Defendant with comprehensive sets of special Interrogatories and thirty

nine Requests for Production concerning, inter alia, the history of the Class Vehicles and their

4 511694.1 NISSANAL TIMATRANSMISSION

CVTs; complaints received by Defendant concerning the Class Vehicles' CVTs; Defendants'

knowledge of CVT problems; any and all remedial efforts taken by Defendant to remedy

problems experienced by Class Members with their CVTs. On August 17, 2018, Defendant

served sets of special Interrogatories, and Requests for Production on Plaintiffs Cabebe, Dick,

Chia, and McCullough, to which Plaintiffs' counsel prepared comprehensive responses served to

Defendant on October 19, 2018. In addition, Cabebe Counsel reviewed over 20,000 pages of

documents produced by Nissan in August and September of 2018 and collected through

independent research, including thousands of pages of highly technical data and reports

generated by Nissan. Throughout this time, Cabebe Counsel continued to interview and

investigate the claims of potential class representatives.

16. On October 26, 2018, the Court issued its Order Granting in Part and Denying in

Part Defendant's Motion to Dismiss. Therein, the Court largely denied Nissan's motion to

dismiss, dismissing only Plaintiff Chia's New York General Business Law Section 349 claim,

and fraudulent omission claim under New York Law, and Plaintiff McCullough's Pennsylvania

fraudulent concealment claim.

17. Prior to and following the Court's order on Defendant's motion to dismiss, and in

preparation for drafting and filing a Second Amended Class Action Complaint ("SAC"), Cabebe

Counsel continued to interview and investigate the claims of potential class representatives as

part of an outreach effort that ultimately resulted in approximately 854 putative class members

reaching out to Cabebe Counsel,, and was retained by eight new class representatives from six

different states. Cabebe Counsel then thoroughly researched the new class representatives'

potential causes of action and how courts in these eight states have applied them prior to filing a

Second Amended Class Action Complaint. Cabebe Counsel's extensive ongoing investigation

helped to contextualize and verify information provided by NNA concerning the performance of

the Class Vehicles, countermeasures taken to address CVT issues, the cost of repairing their

CVTs and the like.

5 51 1694.1 NISSANALTIMATRANSMISSION

18. On December 14, 2018, Plaintiffs filed a Second Amended Class Action

Complaint adding plaintiffs Montell Jones, Kevin Burke, Arnika Ireland, Jeanine Ingrassia, Seiji

Siler-Hyatte, Lashandrika Williams, Laura Windom and Michael Kanzler, and alleging twenty

eight causes of action under Alabama, Arizona, California, Florida, Illinois, New Jersey, New

York, Pennsylvania and Texas state law.

19. On March 1, 2019, Defendant filed a Motion to Dismiss Portions of Plaintiffs'

Second Amended Complaint. Defendant's motion did not challenge Plaintiff Lashandrika

Williams's New Jersey Consumer Fraud Act Claim nor any of Plaintiffs' express or implied

warranty claims. Shortly thereafter, Cabebe Counsel began briefing an opposition to

Defendant's motion to dismiss which was completed about the time the parties began seriously

discussing settlement.

20. My firm also spoke with a technical consultant who has expertise in CVT and

automatic transmission design, repair, and aftermarket modification ..

21. On April 16, 2019, the parties attended an all-day mediation with mediator Hunter

Hughes in Atlanta, Georgia. I and Mark S. Greenstone attended on behalf of Plaintiffs. At the

end of the day, an agreement in principle was reached and over the next several weeks the parties

finalized a term sheet and formal settlement agreement. On May 3, 2019, the parties executed a

Memorandum of Understanding.

22. Thereafter, the parties spent weeks negotiating the language of the Settlement

Agreement and related documents-a process involving the exchange of numerous drafts and

dozens of conversations and emails regarding the language of the Settlement Agreement, notice

documents and other related matters-prior to executing the Settlement Agreement.

23. The negotiations resulted in significant relief to Plaintiffs and the Class. Notably,

three thousand and five hundred dollars ($3,500) is the average cost to repair or replace the most

common CVT defects. Since the inception of the lawsuits, my firm has spoken with many

individuals who simply could not afford to have their vehicle's transmission repaired.


Accordingly, we fought to ensure such persons' claims were covered under the terms of the

Settlement.

24. In addition, during the course of settlement negotiations, Plaintiffs' Counsel

pursued informal discovery from Defendant that was appropriately targeted as information

relevant to the Settlement Agreement. Specifically, my firm assisted with providing Nissan with

a list of topics, specific questions, and document requests. Nissan produced the requested data

and information, including almost 1 million lines of warranty claim-related information for the

Class Vehicles, which Co-Lead Class Counsel reviewed and then developed follow-up questions

to be answered by Nissan. These questions and other areas of inquiry were then addressed by

Co-Lead Class Counsel in a face-to-face interview with a Nissan engineer. Prior to the interview,

Co-Lead Class Counsel provided written questions and topics of inquiry so the engineer could

prepare and so the question and answer session would be as productive as possible.

25. The terms of the Settlement Agreement provided extensive relief to class

members and Cabebe Counsel believe the settlement, which was negotiated at arm's length, is

fair, reasonable and adequate. For example, the provision relating to proposed attorneys' fees,

costs and expenses was not agreed upon until after the parties had agreed on all material terms of

the Settlement Agreement,

26. On May 31, 2019, Plaintiffs filed a Consolidated Second Amended Class Action

Complaint with the Court. The amended complaint consolidates Plaintiffs' claims in the Gann,

Weinberg, Costa, and Cabebe cases and alleges a nationwide class of current and former owners

of Class Vehicles who purchased or leased the vehicle in the United States or its territories,

including Puerto Rico. Following entry of the Preliminary Approval Order, the plaintiffs in the

Weinberg, Costa, and Cabebe cases moved to stay their cases pending resolution of the

settlement approval process.

27. Following preliminary approval, the Firm participated in overseeing all aspects of

the case including implementing the dissemination of the Class Notice. This included finalizing

the long form, publication and post-card notices and the claim form, drafting the content for the

7 511694.1 NISSANALTIMATRANSM!SSION

settlement website and the questions and answers links, and reviewing and revising the IVR

script.

28. In addition, after the Court granted preliminarily approval of the settlement, the

Firm participated in regularly scheduled phone calls with Nissan's counsel, Plaintiffs' Counsel,

and the claims administrator.

29. Throughout this litigation the Firm provided updates to our class representatives

to keep them informed on the status of the litigation and answer any questions they may have.

30. Shortly after preliminary approval, and even before Class Notice was mailed, the

Firm began receiving telephone calls and emails from dozens of Class Members. Attorneys

familiar with the terms of the Settlement and questions Class Members were likely to have,

responded to every email and telephone call, often spending considerable time on the phone with

the Class Member answering their questions about the Settlement, the settlement benefits and the

claim process. To date, the Firm along with Greenstone Law APC has spoken with over 100

people regarding the settlement. This work will continue throughout the settlement

implementation process.

31. Along with my Co-Lead Class Counsel, the Firm has worked closely with

Plaintiffs' valuation expert Lee Bowron, whose declaration and report as to the value of the

Warranty Extension has been submitted along with Plaintiffs' final approval briefing. The Firm

participated extensively in the drafting of Plaintiffs' final approval and fee briefs and related

documentation, and will remain equally involved through the conclusion of this matter.

32. The information in this declaration regarding the Firm's time and expenses is

taken from time and expense printouts and supporting documentation prepared and maintained

by the Firm in the ordinary course of business.

33. The Firm has engaged in this matter on a fully contingent basis. The Firm has

received no compensation of any kind for my firm's work on this matter.

34. I am the person in the Firm who oversaw and conducted the day-to-day activities

of the Firm in the litigation, and I reviewed printouts (and supporting documentation where

8 511694.1 N!SSANALTIMATRANSMISS!ON

necessary and appropriate) in connection with the preparation of this declaration. The purpose of

this review was to confirm both the accuracy of the entries on the printouts as well as the

necessity for, and reasonableness of, the time and expenses committed to the litigation. I believe

that the time reflected in the Firm's lodestar calculation and the expenses for which payment is

sought as set forth herein are reasonable and were necessary for the effective and efficient

prosecution and resolution of the litigation. I also believe the time and expenses are of the type

that would normally be charged to a fee-paying client in the private legal marketplace.

35. Attached hereto as Exhibit 1 is a summary of the Firm's lodestar. The summary

includes the names of attorneys and professional support staff who worked on this case and each

timekeeper's respective hours and lodestar at current rates. The hourly rates shown in Exhibit 1

are the usual and customary rates set by the Firm for each individual. The Firm has expended

1,399.80 hours working on this case and the total lodestar is $729,107.50.

36. The backgrounds and qualifications of the attorneys who worked on the matter are

set forth in the Firm Resume. A true and correct copy of the Firm's Resume is attached hereto as

Exhibit 3.

3 7. Fee awards supported by my hourly rates and corresponding lodestar have been

regularly approved in class action settlements that I have overseen including the following:

Reniger, et al., v. Hyundai Motor America, et. al, No. 14-03612 (N.D. Cal.) Docket No. 104,

using the lodestar-multiplier approach; Shin, et al., v. BMW of North America, No. 09-00398,

(C.D. Cal.) Docket No. 72 (same); In re Zappos Security Breach Litigation, No. 12-00325 (D.

NV) Docket No. 418 using a lodestar and benefit conferred analysis; Peterson v. CJ America,

Inc., No. 14-2570 (S.D. Cal.), Docket No. 60, using a percentage of the common fund with a

lodestar cross-check; Sciortino, et al., v. Pepsico, Inc., No. 14-0478 (N.D. Cal.), Docket No. 163,

using a lodestar cross-check; Sateriale, et al., v. R.J Reynolds Tobacco Co., No. 09-08394 (C.D.

Cal.), Docket No. 233, using the lodestar-multiplier approach; Pappas v. Naked Juice Co., No.

l 1-cv-08276 (C.D. Cal.), Docket No. 184, awarded fees using the lodestar-multiplier approach;

Lilly v. Jamba Juice Company, et al., No. 13-cv-02998 (N.D. Cal.), Docket No. 75 (same); In re


Hovnanian Enterprises, Inc. Securities Litigation, No. 08-00999, (D.N.J.) Docket No. 101

(same).

38. Further, based on my knowledge of the class action plaintiffs bar nationwide, the

rates charged by the Firm are in line with the rates charged by other firms that handle class

actions of similar size and complexity. Each of the Firm's attorneys that have worked on this

case have practiced for the following number of years: Mr. Godino - 25 years; Mr. Greenstone -

20 years2; Ms. Wright - 7 years; and Ms. Manning - 3 years. Based on the years of experience of

each of the Firm's attorneys that worked on this case, I believe the hourly rates of $400.00 to

$850.00 are reasonable.

39. The hours and lodestar incurred by the Firm will increase because, the Firm,

along with other Co-Lead Class Counsel, is responsible for any further briefing in this case and

in particular responding to objectors, obtaining any needed discovery or deposition testimony

from objectors, attending the final approval hearing, and the significant post hearing work, which

includes years of claims administration and settlement implementation. If appeals are filed, Co

Lead Class Counsel will handle the appeals. On an ongoing basis, the Firm will continue to be in

regular contact with Class Members who contact us regarding the Settlement and its claims

process, as well as the Settlement Administrator regarding the same, and will continue to oversee

the inspection and repair/replacement programs, the claim process and will continue to regularly

review and act on the reports provided by the Settlement Administrator, as well as address any

issues as they arise. However, no additional fees will be paid for this work.

40. The Firm's lodestar figures are based upon the Firm's billing rates, which rates do

not include charges for expense items. Expense items are billed separately, and such charges are

not duplicated in the Firm's billing rates.

2 Mr. Greenstone was a Partner at the Firm at the commencement of the Litigation through April, 2018 at which time he formed his own law firm, Greenstone Law APC, Co-Lead Class Counsel.

10 511694.1 NISSANAL TIMATRANSMISSION

41. The Firm has expended $22,935.41 in costs and expenses on this case. Those

costs and expenses are summarized by category in Exhibit 3. The costs and expenses pertaining

to this case are reflected in the books and records of the Firm. These books and records are

prepared form receipts, expense vouchers, check records, and other documents and are an

accurate record of the costs and expenses.

42. The following is additional information regarding these expenses:

(a) Court Filing Fees: $429.50. This includes the filing and attorney admission

fees required by courts in the Litigation.

(b) M ediation Fees: $6,350.00. These costs relate to my Firm's contribution to the

full day mediation session with Hunter Hughes. The other portion was paid by Nissan and

other Plaintiffs' counsel.

(c) Expert Fees: $8,939.02. The Firm retained an expert who specialized in CVT

Transmissions to assist in evaluating the documents provided by Nissan and to assist in the

technical analysis related to the claims in this case. The Firm also retained an expert who

specializes in pricing and valuing extended service contracts and warranty extensions.

(d) Cow-ier & peciaJ Postage: $1,036.68. Postage and courier fees were incurred

in mailing information and correspondence to Plaintiffs and experts/consultants.

(e) Online Research: $200.00 This was paid to Westlaw for legal research and to

the Administrative Office of the United States Courts for PACER research of federal court

filings. Westlaw is used to obtain access to legal research, factual databases, and for cite

checking of briefs. The expense amount detailed herein represents the out-of-pocket costs

incurred by the Firm in connection with use of these services in connection with this

litigation. The Firm has a flat-rate contract with Westlaw for use of its services. When the

Firm utilizes Westlaw services, a billing code is entered for the specific case being

researched. At the end of each billing period in which a service is used, the Firm's costs for

such services are allocated to specific cases based on the percentage of use in connection

with that specific case in the billing period. As a result of the contract negotiated by the Firm,

11 511694. I NISSAN AL TIMATRANSMISSION

the Settlement Class enjoys substantial savings in comparison with the "market rate" for a la

carte use of online legal research services, which some law firms pass on to their clients.

43. Travel. Hotels Parking & Meals: $5,127.13. These out-of-town travel costs are in

connection with traveling from Los Angeles, California to Atlanta, Georgia to participate in a

full day mediation with Nissan with the highly experienced mediator, Hunter R. Hughes. The

travelling attorney was Marc Godino. It also includes travel to Nashville, Tennessee to obtain

information from Nissan engineers. The traveling attorney was Ms. Manning.

44. The out-of-pocket litigation expenses incurred by the Firm in this case are

reasonable in amount and were necessary for the effective and efficient prosecution of the

Litigation. In addition, I believe the expenses are of a type that would normally be charged to a

fee-paying client in the private legal marketplace and have been charged by the Firm to fee

paying clients. They are also the categories of expenses that have been awarded to the Firm and

other plaintiffs counsel in other class action settlements, including in the following cases:

Reniger, et al., v. Hyundai Motor America, et. al, No. 14-03612 (N.D. Cal.) Docket No. 104,

using the lodestar-multiplier approach; Shin, et al., v. BMW of North America, No. 09-00398,

(C.D. Cal.) Docket No. 72 (same); In re Zappos Security Breach Litigation, No. 12-00325 (D.

NV) Docket No. 418 using a lodestar and benefit conferred analysis; Peterson v. CJ America,

Inc., No. 14-2570 (S.D. Cal.), Docket No. 60, using a percentage of the common fund with a

lodestar cross-check; Sciortino, et al., v. Pepsico, Inc., No. 14-0478 (N.D. Cal.), Docket No. 163,

using a lodestar cross-check; Sateriale, et al., v. R.J Reynolds Tobacco Co., No. 09-08394 (C.D.

Cal.), Docket No. 233, using the lodestar-multiplier approach; Pappas v. Naked Juice Co., No.

11-cv-08276 (C.D. Cal.), Docket No. 184, awarded fees using the lodestar-multiplier approach;

Lilly v. Jamba Juice Company, et al., No. 13-cv-02998 (N.D. Cal.), Docket No. 75 (same); In re

Hovnanian Enterprises, Inc. Securities Litigation, No. 08-00999, (D.N.J.) Docket No. 101

(same).

45. Nissan also agreed to pay incentive awards of $5,000 to each of the nineteen

Plaintiffs named in the Lawsuits. SA, ~ 115. These will be paid separately and will not reduce


Settlement benefits to Class Members. Id. These amounts are based on time and efforts Plaintiffs

expended and their commitment to the Lawsuits. Each of the Plaintiffs stepped forward to file

the various lawsuits and represent other Altima purchasers knowing that they could be subject to

discovery, that the litigation could take years, that they were obligated to testify at trial, and that,

in the end, their efforts might not be successful. Nonetheless, Plaintiffs were willing to and did

do everything required and without them these cases would not have been brought and the

settlement obtained. For instance, the Cabebe Plaintiffs communicated with attorneys at the Firm

regarding all aspects of the Lawsuits, including via phone and email. They provided valuable

information necessary for drafting the initial complaint and amended complaints. In addition,

those that still possessed their vehicles were willing to produce their vehicles for inspection and

testing by Nissan. Plaintiffs in all of the Lawsuits, Leandre Bishop, Kevin Burke, Israel Chia,

Krista Costa, Hillary Dick, Jura Gerald, Seiji Siler-Hyatte, Jeanine Ingrassia, Arnika Ireland,

Montell Jones, Michael Kanzler, Alexandra McCullough, Terese Miranda, Autumn Pierce,

Robert H. Weinberg, Lashandrika Williams, and Laura Windom, spent time reviewing court

filings, and consulting for mediation and settlement as represented in the declarations of these

Plaintiffs' counsel.

46. Plaintiffs' counsel and based on my knowledge of the work and contributions

made by the Plaintiffs in the Lawsuits. The modest service awards are fair and reasonable.

I declare under penalty of perjury that the foregoing is true and correct to the best of my

knowledge.

Executed this 24th day of January, 2020, at Los Angeles, California.

Marc L. Godino

13 511694.1 NISSAN AL T!MA TRANSMISSION

TIMEKEEPER/CASE

ATTORNEYS:

Mark Greenstone

Marc Godino

Danielle Manning

Melissa Wright

TOTAL ATTORNEY

PARALEGALS:

Harry Kharadjian

Paul Harrigan

Emily Oswald

TOTAL PARALEGAL

TOTAL LODESTAR

GLANCY PRONGAY MURRAY LLP

FIRM LODESTAR REPORT FROM INCEPTION

EXHIBIT 1

IN RE NISSAN ALTIMA TRANSMISSION LITIGATION

INCEPTION THROUGH JANUARY 21, 2020

STATUS HOURS RATE

Partner 103.10 800.00

Partner 273.50 850.00

Associate 828.70 400.00

Associate 118.00 525.00

TOTAL 1,323.30

Senior Paralegal 40.25 290.00

Senior Paralegal 13.75 290.00

Paralegal 22.50 225.00

TOTAL 76.50

TOTAL 1,399.80

LODESTAR

82,480.00

232,475.00

331,480.00

61,950.00

708,385.00

11,672.50

3,987.50

5,062.50

20,722.50

729,107.50

NISSANALTIMATRANSMISSION OPERATIVE LODESTAR AND TIME ENTRIES RUN 1242020.XLSX - SUBMISSION

CHART - Page 1 of 1

GLANCY PRONGAY MURRAY LLP

FIRM EXPENSES REPORT

EXHIBIT2

IN RE NISSAN ALTIMA TRANSMISSION LITIGATION

INCEPTION THROUGH JANUARY 22, 2020

CATEGORY OF GLANCY EXPENSE

COURIER & SPECIAL POSTAGE

COURT FILING FEES

EXPERTS

MEDIATION

ONLINE RESEARCH

PHOTOIMAGING

SERVICE OF PROCESS

TRAVEL AIRFARE

TRAVEL AUTO

TRAVEL HOTEL

TRAVEL MEALS

TRAVEL PARKING

GRAND TOTAL

511406_1.xlsx - CASE EXPENSES CHART Page 1of1

AMOUNT

1,096.33

429.50

8,939.02

6,350.00

200.00

26.40

767.03

2,875.17

455.36

1,438.41

275.32

82.87

22,935.41

482505.7 OFFICE Page 1

FIRM RESUME

Glancy Prongay & Murray LLP (the “Firm”) has represented investors, consumers and employees for over 25 years. Based in Los Angeles, with offices in New York City and Berkeley, the Firm has successfully prosecuted class action cases and complex litigation in federal and state courts throughout the country. As Lead Counsel, Co-Lead Counsel, or as a member of Plaintiffs’ Counsel Executive Committees, the Firm’s attorneys have recovered billions of dollars for parties wronged by corporate fraud, antitrust violations and malfeasance. Indeed, the Institutional Shareholder Services unit of RiskMetrics Group has recognized the Firm as one of the top plaintiffs’ law firms in the United States in its Securities Class Action Services report for every year since the inception of the report in 2003. The Firm’s efforts have been publicized in major newspapers such as the Wall Street Journal, the New York Times, and the Los Angeles Times.

Glancy Prongay & Murray’s commitment to high quality and excellent personalized services has boosted its national reputation, and we are now recognized as one of the premier plaintiffs’ firms in the country. The Firm works tenaciously on behalf of clients to produce significant results and generate lasting corporate reform.

The Firm’s integrity and success originate from our attorneys, who are among the brightest and most experienced in the field. Our distinguished litigators have an unparalleled track record of investigating and prosecuting corporate wrongdoing. The Firm is respected for both the zealous advocacy with which we represent our clients’ interests as well as the highly-professional and ethical manner by which we achieve results. We are ideally positioned to pursue securities, antitrust, consumer, and derivative litigation on behalf of our clients. The Firm’s outstanding accomplishments are the direct result of the exceptional talents of our attorneys and employees.

SECURITIES CLASS ACTION SETTLEMENTS Appointed as Lead or Co-Lead Counsel by judges throughout the United States, Glancy Prongay & Murray has achieved significant recoveries for class members in numerous securities class actions, including: In re Mercury Interactive Corporation Securities Litigation, USDC Northern District of California, Case No. 05-3395-JF, in which the Firm served as Co-Lead Counsel and achieved a settlement valued at over $117 million. In re Real Estate Associates Limited Partnership Litigation, USDC Central District of California, Case No. 98-7035-DDP, in which the Firm served as local counsel and

1925 Century Park East, Suite 2100 Los Angeles, CA 90067

T: 310.201.9150


plaintiffs achieved a $184 million jury verdict after a complex six week trial in Los Angeles, California and later settled the case for $83 million. In Re Yahoo! Inc. Securities Litigation, USDC Northern District of California, Case No. 5:17-cv-00373-LHK, in which the Firm served as Co-Lead Counsel and achieved an $80 million settlement. The City of Farmington Hills Employees Retirement System v. Wells Fargo Bank, N.A., USDC District of Minnesota, Case No. 10-cv-04372-DWF/JJG, in which the Firm served as Co-Lead Counsel and achieved a settlement valued at $62.5 million. Schleicher v. Wendt, (Conseco Securities Litigation), USDC Southern District of Indiana, Case No. 02-1332-SEB, a securities fraud class action in which the Firm served as Lead Counsel for the Class and achieved a settlement of over $41 million. Robb v. Fitbit, Inc., USDC Northern District of California, Case No. 3:16-cv-00151, a securities fraud class action in which the Firm served as Lead Counsel for the Class and achieved a settlement of $33 million. Yaldo v. Airtouch Communications, State of Michigan, Wayne County, Case No. 99-909694-CP, in which the Firm served as Co-Lead Counsel and achieved a settlement valued at over $32 million for defrauded consumers. Lapin v. Goldman Sachs, USDC Southern District of New York, Case No. 03-0850-KJD, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of $29 million. In re Heritage Bond Litigation, USDC Central District of California, Case No. 02-ML-1475-DT, where as Co-Lead Counsel, the Firm recovered in excess of $28 million for defrauded investors and continues to pursue additional defendants. In re Livent, Inc. Noteholders Litigation, USDC Southern District of New York, Case No. 99 Civ 9425-VM, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of over $27 million. In re ECI Telecom Ltd. Securities Litigation, USDC Eastern District of Virginia, Case No. 01-913-A, in which the Firm served as sole Lead Counsel and recovered almost $22 million for defrauded ECI investors. Senn v. Sealed Air Corporation, USDC New Jersey, Case No. 03-cv-4372-DMC, a securities fraud class action, in which the Firm acted as co-lead counsel for the Class and achieved a settlement of $20 million. In re Gilat Satellite Networks, Ltd. Securities Litigation, USDC Eastern District of New York, Case No. 02-1510-CPS, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of $20 million.


In re Lumenis, Ltd. Securities Litigation, USDC Southern District of New York, Case No.02-CV-1989-DAB, in which the Firm served as Co-Lead Counsel and achieved a settlement valued at over $20 million. In re Infonet Services Corporation Securities Litigation, USDC Central District of California, Case No. CV 01-10456-NM, in which as Co-Lead Counsel, the Firm achieved a settlement of $18 million. In re ESC Medical Systems, Ltd. Securities Litigation, USDC Southern District of New York, Case No. 98 Civ. 7530-NRB, a securities fraud class action in which the Firm served as sole Lead Counsel for the Class and achieved a settlement valued in excess of $17 million. In re Musicmaker.com Securities Litigation, USDC Central District of California, Case No. 00-02018-CAS, a securities fraud class action in which the Firm was sole Lead Counsel for the Class and recovered in excess of $13 million. In re Lason, Inc. Securities Litigation, USDC Eastern District of Michigan, Case No. 99 76079-AJT, in which the Firm was Co-Lead Counsel and recovered almost $13 million for defrauded Lason stockholders. In re Inso Corp. Securities Litigation, USDC District of Massachusetts, Case No. 99 10193-WGY, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement valued in excess of $12 million. In re National TechTeam Securities Litigation, USDC Eastern District of Michigan, Case No. 97-74587-AC, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement valued in excess of $11 million. Taft v. Ackermans (KPNQwest Securities Litigation), USDC Southern District of New York, Case No. 02-CV-07951-PKL, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement worth $11 million. Jenson v. First Trust Corporation, USDC Central District of California, Case No. 05-cv-3124-ABC, in which the Firm was appointed sole lead counsel and achieved an $8.5 million settlement in a very difficult case involving a trustee’s potential liability for losses incurred by investors in a Ponzi scheme. Kevin Ruf of the Firm also successfully defended in the 9th Circuit Court of Appeals the trial court’s granting of class certification in this case. In re Ramp Networks, Inc. Securities Litigation, USDC Northern District of California, Case No. C-00-3645-JCS, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of nearly $7 million. Capri v. Comerica, Inc., USDC Eastern District of Michigan, Case No. 02-CV-60211-MOB, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of $6.0 million.


Plumbing Solutions Inc. v. Plug Power, Inc., USDC Eastern District of New York, Case No. CV 00 5553-ERK, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of over $5 million. Ree v. Procom Technologies, Inc., USDC Southern District of New York, Case No. 02-CV-7613-JGK, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of $2.7 million. Tatz v. Nanophase Technologies Corp., USDC Northern District of Illinois, Case No. 01-C-8440-MCA, a securities fraud class action in which the Firm served as Co-Lead Counsel for the Class and achieved a settlement of $2.5 million. In re F & M Distributors Securities Litigation, USDC Eastern District of Michigan, Case No. 95 CV 71778-DT, a securities fraud class action in which the Firm served on the Executive Committee and helped secure a $20.25 million settlement.

ANTITRUST PRACTICE GROUP AND ACHIEVEMENTS Glancy Prongay & Murray’s Antitrust Practice Group focuses on representing individuals and entities that have been victimized by unlawful monopolization, price-fixing, market allocation, and other anti-competitive conduct. The Firm has prosecuted significant antitrust cases and has helped individuals and businesses recover billions of dollars. Prosecuting civil antitrust cases under federal and state laws throughout the country, the Firm’s Antitrust Practice Group represents consumers, businesses, and Health and Welfare Funds and seeks injunctive relief and damages for violations of antitrust and commodities laws. The Firm has served, or is currently serving, as Lead Counsel, Co-Lead Counsel or Class Counsel in a substantial number of antitrust class actions, including: In re Nasdaq Market-Makers Antitrust Litigation, USDC Southern District of New York, Case No. 94 C 3996-RWS, MDL Docket No. 1023, a landmark antitrust lawsuit in which the Firm filed the first complaint against all of the major NASDAQ market makers and served on Plaintiffs’ Counsel’s Executive Committee in a case that recovered $900 million for investors. Sullivan v. DB Investments, USDC District of New Jersey, Case No. No. 04-cv-2819, where the Firm served as Co-Lead Settlement Counsel in an antitrust case against DeBeers relate to the pricing of diamonds that settled for $295 million. In re Korean Air Lines Antitrust Litig., USDC Central District of California, Master File No. CV 07-05107 SJO(AGRx), MDL No. 07-0189, where the Firm served as Co-Lead Counsel in a case related to fixing of prices for airline tickets to Korea that settled for $86 million.


In re Urethane Chemical Antitrust Litig., USDC District of Kansas, Case No. MDL 1616, where the Firm served as Co-Lead counsel in an antitrust price fixing case that settled $33 million. In re Western States Wholesale Natural Gas Litig., USDC District of Nevada, Case No. MDL 1566, where the Firm served as Class Counsel in an antitrust price fixing case that settled $25 million. In re Aggrenox Antitrust Litig., USDC District of Connecticut, Case No. 14-cv-2516, where the Firm played a major role in achieving a settlement of $54,000,000. In re Solodyn Antitrust Litig., USDC District of Massachusetts, Case No. MDL 2503, where the Firm played a major role in achieving a settlement of $43,000,000. In re Generic Pharmaceuticals Pricing Antitrust Litig., USDC Eastern District of Pennsylvania, Case No. 16-md-2427, where the Firm is representing a major Health and Welfare Fund in a case against a number of generic drug manufacturers for price fixing generic drugs. In re Actos End Payor Antitrust Litig., USDC Southern District of New York, Case No. 13-cv-9244, where the Firm is serving on Plaintiffs’ Executive Committee. In re Heating Control Panel Direct Purchaser Action, USDC Eastern District of Michigan, Case No. 12-md-02311, representing a recreational vehicle manufacturer in a price-fixing class action involving direct purchasers of heating control panels. In re Instrument Panel Clusters Direct Purchaser Action, USDC Eastern District of Michigan, Case No. 12-md-02311, representing a recreational vehicle manufacturer in a price-fixing class action involving direct purchasers of instrument panel clusters. In addition, the Firm is currently involved in the prosecution of many market manipulation cases relating to violations of antitrust and commodities laws, including Sullivan v. Barclays PLC (manipulation of Euribor rate), In re Foreign Exchange Benchmark Rates Antitrust Litig., In re LIBOR-Based Financial Instruments Antitrust Litig., In re Gold Futures & Options Trading Litig., In re Platinum & Palladium Antitrust Litig., Sonterra Cap. Master Fund v. Credit Suisse Group AG (Swiss Libor rate manipulation), Twin City Iron Pension Fund v. Bank of Nova Scotia (manipulation of treasury securities), and Ploss v. Kraft Foods Group (manipulation of wheat prices). Glancy Prongay & Murray has been responsible for obtaining favorable appellate opinions which have broken new ground in the class action or securities fields, or which have promoted shareholder rights in prosecuting these actions. The Firm successfully argued the appeals in a number of cases: In Smith v. L’Oreal, 39 Cal.4th 77 (2006), Firm partner Kevin Ruf established ground-breaking law when the California Supreme Court agreed with the Firm’s position that


waiting penalties under the California Labor Code are available to any employee after termination of employment, regardless of the reason for that termination.

OTHER NOTABLE ACHIEVEMENTS Other notable Firm cases are: Silber v. Mabon I, 957 F.2d 697 (9th Cir. 1992) and Silber v. Mabon II, 18 F.3d 1449 (9th Cir. 1994), which are the leading decisions in the Ninth Circuit regarding the rights of opt-outs in class action settlements. In Rothman v. Gregor, 220 F.3d 81 (2d Cir. 2000), the Firm won a seminal victory for investors before the Second Circuit Court of Appeals, which adopted a more favorable pleading standard for investors in reversing the District Court’s dismissal of the investors’ complaint. After this successful appeal, the Firm then recovered millions of dollars for defrauded investors of the GT Interactive Corporation. The Firm also argued Falkowski v. Imation Corp., 309 F.3d 1123 (9th Cir. 2002), as amended, 320 F.3d 905 (9th Cir. 2003), and favorably obtained the substantial reversal of a lower court’s dismissal of a cutting edge, complex class action initiated to seek redress for a group of employees whose stock options were improperly forfeited by a giant corporation in the course of its sale of the subsidiary at which they worked. The Firm is also involved in the representation of individual investors in court proceedings throughout the United States and in arbitrations before the American Arbitration Association, National Association of Securities Dealers, New York Stock Exchange, and Pacific Stock Exchange. Mr. Glancy has successfully represented litigants in proceedings against such major securities firms and insurance companies as A.G. Edwards & Sons, Bear Stearns, Merrill Lynch & Co., Morgan Stanley, PaineWebber, Prudential, and Shearson Lehman Brothers. One of the Firm’s unique skills is the use of “group litigation” - the representation of groups of individuals who have been collectively victimized or defrauded by large institutions. This type of litigation brought on behalf of individuals who have been similarly damaged often provides an efficient and effective economic remedy that frequently has advantages over the class action or individual action devices. The Firm has successfully achieved results for groups of individuals in cases against major corporations such as Metropolitan Life Insurance Company, and Occidental Petroleum Corporation. Glancy Prongay & Murray LLP currently consists of the following attorneys:

PARTNERS

LEE ALBERT, a partner, was admitted to the bars of the Commonwealth of Pennsylvania, the State of New Jersey, and the United States District Courts for the Eastern District of Pennsylvania and the District of New Jersey in 1986. He received his B.S. and M.S. degrees from Temple University and Arcadia University in 1975 and 1980, respectively, and received his J.D. degree from Widener University School of Law in 1986. Upon graduation from law school, Mr. Albert spent several years working as a


civil litigator in Philadelphia, PA. Mr. Albert has extensive litigation and appellate practice experience having argued before the Supreme and Superior Courts of Pennsylvania and has over fifteen years of trial experience in both jury and non-jury cases and arbitrations. Mr. Albert has represented a national health care provider at trial obtaining injunctive relief in federal court to enforce a five-year contract not to compete on behalf of a national health care provider and injunctive relief on behalf of an undergraduate university. Currently, Mr. Albert represents clients in all types of complex litigation including matters concerning violations of federal and state antitrust and securities laws, mass tort/product liability and unfair and deceptive trade practices. Some of Mr. Albert’s current major cases include In Re Automotive Wire Harness Systems Antitrust Litigation (E.D. Mich.); In Re Heater Control Panels Antitrust Litigation (E.D. Mich.); Kleen Products, et al. v. Packaging Corp. of America (N.D. Ill.); and In re Class 8 Transmission Indirect Purchaser Antitrust Litigation (D. Del.). Previously, Mr. Albert had a significant role in Marine Products Antitrust Litigation (C.D. Cal.); Baby Products Antitrust Litigation (E.D. Pa.); In re ATM Fee Litigation (N.D. Cal.); In re Canadian Car Antitrust Litigation (D. Me.); In re Broadcom Securities Litigation (C.D. Cal.); and has worked on In re Avandia Marketing, Sales Practices and Products Liability Litigation (E.D. Pa.); In re Ortho Evra Birth Control Patch Litigation (N.J. Super. Ct., Middlesex County); In re AOL Time Warner, Inc. Securities Litigation (S.D.N.Y.); In re WorldCom, Inc. Securities Litigation (S.D.N.Y.); and In re Microsoft Corporation Massachusetts Consumer Protection Litigation (Mass. Super. Ct.). PETER A. BINKOW has prosecuted lawsuits on behalf of consumers and investors in state and federal courts throughout the United States. He served as Lead or Co-Lead Counsel in many class action cases, including: In re Mercury Interactive Securities Litigation ($117.5 million recovery); The City of Farmington Hills Retirement System v Wells Fargo ($62.5 million recovery); Schleicher v Wendt (Conseco Securities litigation - $41.5 million recovery); Lapin v Goldman Sachs ($29 million recovery); In re Heritage Bond Litigation ($28 million recovery); In re National Techteam Securities Litigation ($11 million recovery for investors); In re Lason Inc. Securities Litigation ($12.68 million recovery), In re ESC Medical Systems, Ltd. Securities Litigation ($17 million recovery); and many others. In Schleicher v Wendt, Mr. Binkow successfully argued the seminal Seventh Circuit case on class certification, in an opinion authored by Chief Judge Frank Easterbrook. He has argued and/or prepared appeals before the Ninth Circuit, Seventh Circuit, Sixth Circuit and Second Circuit Courts of Appeals. Mr. Binkow joined the Firm in 1994. He was born on August 16, 1965 in Detroit, Michigan. Mr. Binkow obtained a Bachelor of Arts degree from the University of Michigan in 1988 and a Juris Doctor degree from the University of Southern California in 1994. JOSEPH D. COHEN has extensive complex civil litigation experience, and currently oversees the firm’s settlement department, negotiating, documenting and obtaining court approval of the firm’s securities, merger and derivative settlements.


Prior to joining the firm, Mr. Cohen successfully prosecuted numerous securities fraud, consumer fraud, antitrust and constitutional law cases in federal and state courts throughout the country. Cases in which Mr. Cohen took a lead role include: Jordan v. California Dep’t of Motor Vehicles, 100 Cal. App. 4th 431 (2002) (complex action in which the California Court of Appeal held that California’s Non-Resident Vehicle $300 Smog Impact Fee violated the Commerce Clause of the United States Constitution, paving the way for the creation of a $665 million fund and full refunds, with interest, to 1.7 million motorists); In re Geodyne Res., Inc. Sec. Litig. (Harris Cty. Tex.) (settlement of securities fraud class action, including related litigation, totaling over $200 million); In re Cmty. Psychiatric Centers Sec. Litig. (C.D. Cal.) (settlement of $55.5 million was obtained from the company and its auditors, Ernst & Young, LLP); In re McLeodUSA Inc., Sec. Litig. (N.D. Iowa) ($30 million settlement); In re Arakis Energy Corp. Sec. Litig. (E.D.N.Y.) ($24 million settlement); In re Metris Cos., Inc., Sec. Litig. (D. Minn.) ($7.5 million settlement); In re Landry’s Seafood Rest., Inc. Sec. Litig. (S.D. Tex.) ($6 million settlement); and Freedman v. Maspeth Fed. Loan and Savings Ass’n, (E.D.N.Y) (favorable resolution of issue of first impression under RESPA resulting in full recovery of improperly assessed late fees). Mr. Cohen was also a member of the teams that obtained substantial recoveries in the following cases: In re: Foreign Exchange Benchmark Rates Antitrust Litig. (S.D.N.Y.) (partial settlements of approximately $2 billion); In re Washington Mutual Mortgage-Backed Sec. Litig. (W.D. Wash.) (settlement of $26 million); Mylan Pharm., Inc. v. Warner Chilcott Public Ltd. Co. (E.D. Pa.) ($8 million recovery in antitrust action on behalf of class of indirect purchasers of the prescription drug Doryx); City of Omaha Police and Fire Ret. Sys. v. LHC Group, Inc. (W.D. La.) (securities class action settlement of $7.85 million); and In re Pacific Biosciences of Cal., Inc. Sec. Litig. (Cal. Super. Ct.) ($7.6 million recovery). In addition, Mr. Cohen was previously the head of the settlement department at Bernstein Litowitz Berger & Grossmann LLP. While at BLB&G, Mr. Cohen had primary responsibility for overseeing the team working on the following settlements, among others: In Re Merck & Co., Inc. Sec., Deriv. & “ERISA” Litig. (D.N.J.) ($1.062 billion securities class action settlement); New York State Teachers’ Ret. Sys. v. General Motors Co. (E.D. Mich.) ($300 million securities class action settlement); In re JPMorgan Chase & Co. Sec. Litig. (S.D.N.Y.) ($150 million settlement); Dep’t of the Treasury of the State of New Jersey and its Division of Inv. v. Cliffs Natural Res. Inc., et al. (N.D. Ohio) ($84 million securities class action settlement); In re Penn West Petroleum Ltd. Sec. Litig. (S.D.N.Y.) ($19.76 million settlement); and In re BioScrip, Inc. Sec. Litig. ($10.9 million settlement). JOSHUA L. CROWELL, a partner in the firm’s Los Angeles office, concentrates his practice on prosecuting complex securities cases on behalf of investors.

Recently, he was co-lead counsel in In re Yahoo! Inc. Securities Litigation, No. 17-CV-00373-LHK (N.D. Cal.), which resulted in an $80 million settlement for the class. He also led the prosecution of In re Akorn, Inc. Securities Litigation, No. 1:15-cv-01944 (N.D. Ill.), achieving a $24 million class settlement.


Prior to joining Glancy Prongay & Murray LLP, Joshua was an Associate at Labaton Sucharow LLP in New York, where he substantially contributed to some of the firm’s biggest successes. There he helped secure several large federal securities class settlements, including:

• In re Countrywide Financial Corp. Securities Litigation, No. CV 07-05295 MRP (MANx) (C.D. Cal.) – $624 million

• In re Schering-Plough Corp. / ENHANCE Securities Litigation, No. 08-397 (DMC) (JAD) (D.N.J.) – $473 million

• In re Broadcom Corp. Class Action Litigation, No. CV-06-5036-R (CWx) (C.D. Cal.) – $173.5 million

• In re Fannie Mae 2008 Securities Litigation, No. 08-civ-7831-PAC (S.D.N.Y.) – $170 million

• Oppenheimer Champion Fund and Core Bond Fund actions, Nos. 09-cv-525-JLK-KMT and 09-cv-1186-JLK-KMT (D. Colo.) – $100 million combined

He began his legal career as an Associate at Paul, Hastings, Janofsky & Walker LLP in New York, primarily representing financial services clients in commercial litigation.

Super Lawyers has selected Joshua as a Rising Star in the area of Securities Litigation from 2015 through 2017.

Prior to attending law school, Mr. Joshua was a Senior Economics Consultant at Ernst & Young LLP, where he priced intercompany transactions and calculated the value of intellectual property. Joshua received a J.D., cum laude, from The George Washington University Law School. During law school, he was a member of The George Washington Law Review and the Mock Trial Board. He was also a law intern for Chief Judge Edward J. Damich of the United States Court of Federal Claims. Joshua earned a B.A. in International Relations from Carleton College. LIONEL Z. GLANCY, a graduate of University of Michigan Law School, is the founding partner of the Firm. After serving as a law clerk for United States District Judge Howard McKibben, he began his career as an associate at a New York law firm concentrating in securities litigation. Thereafter, he started a boutique law firm specializing in securities litigation, and other complex litigation, from the Plaintiff’s perspective. Mr. Glancy has established a distinguished career in the field of securities litigation over the last thirty years, having appeared and been appointed lead counsel on behalf of aggrieved investors in securities class action cases throughout the country. He has appeared and argued before dozens of district courts and a number of appellate courts. His efforts have resulted in the recovery of hundreds of millions of dollars in settlement proceeds for huge classes of shareholders. Well known in securities law, he has lectured on its developments and practice, including having lectured before Continuing Legal Education seminars and law schools. Mr. Glancy was born in Windsor, Canada, on April 4, 1962. Mr. Glancy earned his undergraduate degree in political science in 1984 and his Juris Doctor degree in 1986,


both from the University of Michigan. He was admitted to practice in California in 1988, and in Nevada and before the U.S. Court of Appeals, Ninth Circuit, in 1989. MARC L. GODINO has extensive experience successfully litigating complex, class action lawsuits as a plaintiffs’ lawyer. Since joining the firm in 2005, Mr. Godino has played a primary role in cases resulting in settlements of more than $100 million. He has prosecuted securities, derivative, merger & acquisition, and consumer cases throughout the country in both state and federal court, as well as represented defrauded investors at FINRA arbitrations. Mr. Godino manages the Firm’s consumer class action department. While a senior associate with Stull Stull & Brody, Mr. Godino was one of the two primary attorneys involved in Small v. Fritz Co., 30 Cal. 4th 167 (April 7, 2003), in which the California Supreme Court created new law in the State of California for shareholders that held shares in detrimental reliance on false statements made by corporate officers. The decision was widely covered by national media including The National Law Journal, the Los Angeles Times, the New York Times, and the New York Law Journal, among others, and was heralded as a significant victory for shareholders. Mr. Godino’s successes with Glancy Prongay & Murray LLP include: Good Morning To You Productions Corp., et al., v. Warner/Chappell Music, Inc., et al., Case No. 13-04460 (C.D. Cal.) (In this highly publicized case that attracted world-wide attention, Plaintiffs prevailed on their claim that the song “Happy Birthday” should be in the public domain and achieved a $14,000,000 settlement to class members who paid a licensing fee for the song); Ord v. First National Bank of Pennsylvania, Case No. 12-766 (W. D. Pa.) ($3,000,000 settlement plus injunctive relief); Pappas v. Naked Juice Co. of Glendora, Inc., Case No. 11-08276 (C.D. Cal.) ($9,000,000 settlement plus injunctive relief);Astiana v. Kashi Company, Case No. 11-1967 (S.D. Cal.) ($5,000,000 settlement); In re Magma Design Automation, Inc. Securities Litigation, Case No. 05-2394 (N.D. Cal.) ($13,500,000 settlement); In re Hovnanian Enterprises, Inc. Securities Litigation, Case No. 08-cv-0099 (D.N.J.) ($4,000,000 settlement); In re Skilled Healthcare Group, Inc. Securities Litigation, Case No. 09-5416 (C.D. Cal.) ($3,000,000 settlement); Kelly v. Phiten USA, Inc., Case No. 11-67 (S.D. Iowa) ($3,200,000 settlement plus injunctive relief); (Shin et al., v. BMW of North America, 2009 WL 2163509 (C.D. Cal. July 16, 2009) (after defeating a motion to dismiss, the case settled on very favorable terms for class members including free replacement of cracked wheels); Payday Advance Plus, Inc. v. MIVA, Inc., Case No. 06-1923 (S.D.N.Y.) ($3,936,812 settlement); Esslinger, et al. v. HSBC Bank Nevada, N.A., Case No. 10-03213 (E.D. Pa.) ($23,500,000 settlement); In re Discover Payment Protection Plan Marketing and Sales Practices Litigation, Case No. 10-06994 ($10,500,000 settlement ); In Re: Bank of America Credit Protection Marketing and Sales Practices Litigation, Case No. 11-md-02269 (N.D. Cal.) ($20,000,000 settlement). Mr. Godino was also the principal attorney in the following published decisions: In re Zappos.com, Inc., Customer Data Sec. Breach Litigation, 714 Fed Appx. 761 (9th Cir. 2018) (reversing order dismissing class action complaint); Small et al., v. University Medical Center of Southern Nevada, et al., 2017 WL 3461364 (D. Nev. Aug. 10, 2017)


(denying motion to dismiss); Sciortino v. Pepsico, Inc., 108 F.Supp. 3d 780 (N.D. Cal.. June 5, 2015) (motion to dismiss denied); Peterson v. CJ America, Inc., 2015 WL 11582832 (S.D. Cal. May 15, 2015) (motion to dismiss denied); Lilly v. Jamba Juice Company, 2014 WL 4652283 (N. D. Cal. Sep 18, 2014) (class certification granted in part); Kramer v. Toyota Motor Corp., 705 F. 3d 1122 (9th Cir. 2013) (affirming denial of Defendant’s motion to compel arbitration); Sateriale, et al. v. R.J. Reynolds Tobacco Co., 697 F. 3d 777 (9th Cir. 2012) (reversing order dismissing class action complaint); Shin v. BMW of North America, 2009 WL 2163509 (C.D. Cal. July 16, 2009) (motion to dismiss denied); In re 2TheMart.com Securities Litigation, 114 F. Supp. 2d 955 (C.D. Cal. 2002) (motion to dismiss denied); In re Irvine Sensors Securities Litigation, 2003 U.S. Dist. LEXIS 18397 (C.D. Cal. 2003) (motion to dismiss denied). The following represent just a few of the cases Mr. Godino is currently litigating in a leadership position: Small v. University Medical Center of Southern Nevada, Case No. 13-00298 (D. Nev.); Courtright, et al., v. O’Reilly Automotive Stores, Inc., et al., Case No. 14-334 (W.D. Mo); Keskinen v. Edgewell Personal Care Co., et al., Case No. 17-07721 (C.D. CA); Ryan v. Rodan & Fields, LLC, Case No. 18-02505 (N.D. Cal) MATTHEW M. HOUSTON, a partner in the firm’s New York office, graduated from Boston University School of Law in 1988. Mr. Houston is an active member of the Bar of the State of New York and an inactive member of the bar for the Commonwealth of Massachusetts. Mr. Houston is also admitted to the United States District Courts for the Southern and Eastern Districts of New York and the District of Massachusetts, and the Second, Seventh, Ninth, and Eleventh Circuit Court of Appeals of the United States. Mr. Houston repeatedly has been selected as a New York Metro Super Lawyer. Mr. Houston has substantial courtroom experience involving complex actions in federal and state courts throughout the country. Mr. Houston was co-lead trial counsel in one the few ERISA class action cases taken to trial asserting breach of fiduciary duty claims against plan fiduciaries, Brieger et al. v. Tellabs, Inc., No. 06-CV-01882 (N.D. Ill.), and has successfully prosecuted many ERISA actions, including In re Royal Ahold N.V. Securities and ERISA Litigation, Civil Action No. 1:03-md-01539. Mr. Houston has been one of the principal attorneys litigating claims in multi-district litigation concerning employment classification of pickup and delivery drivers and primarily responsible for prosecuting ERISA class claims resulting in a $242,000,000 settlement; In re FedEx Ground Package Inc. Employment Practices Litigation, No. 3:05-MD-527 (MDL 1700). Mr. Houston recently presented argument before the Eleventh Circuit Court of Appeals on behalf of a class of Florida pickup and delivery drivers obtaining a reversal of the lower court’s grant of summary judgment. Mr. Houston represented the interests of Nevada and Arkansas drivers employed by FedEx Ground obtaining significant recoveries on their behalf. Mr. Houston also served as lead counsel in multi-district class litigation seeking to modify insurance claims handling practices; In re UnumProvident Corp. ERISA Benefits Denial Actions, No. 1:03-cv-1000 (MDL 1552). Mr. Houston has played a principal role in numerous derivative and class actions wherein substantial benefits were conferred upon plaintiffs: In re: Groupon Derivative Litigation, No. 12-cv-5300 (N.D. Ill. 2012) (settlement of consolidated derivative action


resulting in sweeping corporate governance reform estimated at $159 million) Bangari v. Lesnik, et al., No. 11 CH 41973 (Illinois Circuit Court, County of Cook) (settlement of claim resulting in payment of $20 million to Career Education Corporation and implementation of extensive corporate governance reform); In re Diamond Foods, Inc. Shareholder Litigation, No. CGC-11-515895 (California Superior Court, County of San Francisco) ($10.4 million in monetary relief including a $5.4 million clawback of executive compensation and significant corporate governance reform); Pace American Shareholder Litigation, 94-92 TUC-RMB (securities fraud class action settlement resulting in a recovery of $3.75 million); In re Bay Financial Securities Litigation, Master File No. 89-2377-DPW, (D. Mass.) (J. Woodlock) (settlement of action based upon federal securities law claims resulting in class recovery in excess of $3.9 million); Goldsmith v. Technology Solutions Company, 92 C 4374 (N.D. Ill. 1992) (J. Manning) (recovery of $4.6 million as a result of action alleging false and misleading statements regarding revenue recognition). In addition to numerous employment and derivative cases, Mr. Houston has litigated actions asserting breach of fiduciary duty in the context of mergers and acquisitions. Mr. Houston has been responsible for securing millions of dollars in additional compensation and structural benefits for shareholders of target companies: In re Instinet Group, Inc. Shareholders Litigation, C.A. No. 1289 (Delaware Court of Chancery); Jasinover v. The Rouse Company, Case No. 13-C-04-59594 (Maryland Circuit Court); McLaughlin v. Household International, Inc., Case No. 02 CH 20683 (Illinois Circuit Court); Sebesta v. The Quizno’s Corporation, Case No. 2001 CV 6281 (Colorado District Court); Crandon Capital Partners v. Sanford M. Kimmel, C.A. No. 14998 (Del. Ch.); and Crandon Capital Partners v. Kimmel, C.A. No. 14998 (Del. Ch. 1996) (J. Chandler) (settlement of an action on behalf of shareholders of Transnational Reinsurance Co. whereby acquiring company provided an additional $10.4 million in merger consideration). JASON L. KRAJCER is a partner in the firm’s Los Angeles office. He specializes in complex securities cases and has extensive experience in all phases of litigation (fact investigation, pre-trial motion practice, discovery, trial, appeal). Prior to joining Glancy Prongay & Murray LLP, Mr. Krajcer was an Associate at Goodwin Procter LLP where he represented issuers, officers and directors in multi-hundred million and billion dollar securities cases. He began his legal career at Orrick, Herrington & Sutcliffe LLP, where he represented issuers, officers and directors in securities class actions, shareholder derivative actions, and matters before the U.S. Securities & Exchange Commission. Mr. Krajcer is admitted to the State Bar of California, the Bar of the District of Columbia, the United States Supreme Court, the Ninth Circuit Court of Appeals, and the United States District Courts for the Central and Southern Districts of California. SUSAN G. KUPFER is the founding partner of the Firm’s Berkeley office. Ms Kupfer joined the Firm in 2003. She is a native of New York City, and received her A.B. degree from Mount Holyoke College in 1969 and her Juris Doctor degree from Boston


University School of Law in 1973. She did graduate work at Harvard Law School and, in 1977, was named Assistant Dean and Director of Clinical Programs at Harvard, supervising and teaching in that program of legal practice and related academic components. For much of her legal career, Ms. Kupfer has been a professor of law. Her areas of academic expertise are Civil Procedure, Federal Courts, Conflict of Laws, Constitutional Law, Legal Ethics, and Jurisprudence. She has taught at Harvard Law School, Hastings College of the Law, Boston University School of Law, Golden Gate University School of Law, and Northeastern University School of Law. From 1991 through 2002, she was a lecturer on law at the University of California, Berkeley, Boalt Hall, teaching Civil Procedure and Conflict of Laws. Her publications include articles on federal civil rights litigation, legal ethics, and jurisprudence. She has also taught various aspects of practical legal and ethical training, including trial advocacy, negotiation and legal ethics, to both law students and practicing attorneys. Ms. Kupfer previously served as corporate counsel to The Architects Collaborative in Cambridge and San Francisco, and was the Executive Director of the Massachusetts Commission on Judicial Conduct. She returned to the practice of law in San Francisco with Morgenstein & Jubelirer and Berman DeValerio LLP before joining the Firm. Ms. Kupfer’s practice is concentrated in complex antitrust litigation. She currently serves, or has served, as Co-Lead Counsel in several multidistrict antitrust cases: In re Photochromic Lens Antitrust Litig. (MDL 2173, M.D. Fla. 2010); In re Fresh and Process Potatoes Antitrust Litig. (D. ID. 2011); In re Korean Air Lines Antitrust Litig. (MDL No. 1891, C.D. Cal. 2007); In re Urethane Antitrust Litigation (MDL 1616, D. Kan. 2004); In re Western States Wholesale Natural Gas Litigation (MDL 1566, D. Nev. 2005); and Sullivan et al v. DB Investments et al (D. N.J. 2004). She has been a member of the lead counsel teams that achieved significant settlements in: In re Sorbates Antitrust Litigation ($96.5 million settlement); In re Pillar Point Partners Antitrust Litigation ($50 million settlement); and In re Critical Path Securities Litigation ($17.5 million settlement). Ms. Kupfer is a member of the bar of Massachusetts and California, and is admitted to practice before the United States District Courts for the Northern, Central, Eastern and Southern Districts of California, the District of Massachusetts, the Courts of Appeals for the First and Ninth Circuits, and the U.S. Supreme Court. GREGORY B. LINKH works out of the New York office, where he litigates antitrust, securities, shareholder derivative, and consumer cases. Greg graduated from the State University of New York at Binghamton in 1996 and from the University of Michigan Law School in 1999. While in law school, Greg externed with United States District Judge Gerald E. Rosen of the Eastern District of Michigan. Greg was previously associated with the law firms Dewey Ballantine LLP, Pomerantz Haudek Block Grossman & Gross LLP, and Murray Frank LLP.

Previously, Greg had significant roles in In re Merrill Lynch & Co., Inc. Research Reports Securities Litigation (settled for $125 million); In re Crompton Corp. Securities Litigation (settled $11 million); Lowry v. Andrx Corp. (settled for $8 million); In re


Xybernaut Corp. Securities MDL Litigation (settled for $6.3 million); and In re EIS Int’l Inc. Securities Litigation (settled for $3.8 million). Greg also represented the West Virginia Investment Management Board (“WVIMB”) in WVIMB v. Residential Accredited Loans, Inc., et al., relating to the WVIMB's investment in residential mortgage-backed securities.

Currently, Greg is litigating various antitrust and securities cases, including In re Korean Ramen Antitrust Litigation, In re Automotive Parts Antitrust Litigation, and In re Horsehead Holding Corp. Securities Litigation.

Greg is the co-author of Inherent Risk In Securities Cases In The Second Circuit, NEW YORK LAW JOURNAL (Aug. 26, 2004); and Staying Derivative Action Pursuant to PSLRA and SLUSA, NEW YORK LAW JOURNAL, P. 4, COL. 4 (Oct. 21, 2005).

BRIAN MURRAY is the managing partner of the Firm's New York Park Avenue office and the head of the Firm's Antitrust Practice Group. He received Bachelor of Arts and Master of Arts degrees from the University of Notre Dame in 1983 and 1986, respectively. He received a Juris Doctor degree, cum laude, from St. John’s University School of Law in 1990. At St. John’s, he was the Articles Editor of the ST. JOHN’S LAW REVIEW. Mr. Murray co-wrote: Jurisdição Estrangeira Tem Papel Relevante Na De Fiesa De Investidores Brasileiros, ESPAÇA JURÍDICO BOVESPA (August 2008); The Proportionate Trading Model: Real Science or Junk Science?, 52 CLEVELAND ST. L. REV. 391 (2004-05); The Accident of Efficiency: Foreign Exchanges, American Depository Receipts, and Space Arbitrage, 51 BUFFALO L. REV. 383 (2003); You Shouldn’t Be Required To Plead More Than You Have To Prove, 53 BAYLOR L. REV. 783 (2001); He Lies, You Die: Criminal Trials, Truth, Perjury, and Fairness, 27 NEW ENGLAND J. ON CIVIL AND CRIMINAL CONFINEMENT 1 (2001); Subject Matter Jurisdiction Under the Federal Securities Laws: The State of Affairs After Itoba, 20 MARYLAND J. OF INT’L L. AND TRADE 235 (1996); Determining Excessive Trading in Option Accounts: A Synthetic Valuation Approach, 23 U. DAYTON L. REV. 316 (1997); Loss Causation Pleading Standard, NEW YORK LAW JOURNAL (Feb. 25, 2005); The PSLRA ‘Automatic Stay’ of Discovery, NEW YORK LAW JOURNAL (March 3, 2003); and Inherent Risk In Securities Cases In The Second Circuit, NEW YORK LAW JOURNAL (Aug. 26, 2004). He also authored Protecting The Rights of International Clients in U.S. Securities Class Action Litigation, INTERNATIONAL LITIGATION NEWS (Sept. 2007); Lifting the PSLRA “Automatic Stay” of Discovery, 80 N. DAK. L. REV. 405 (2004); Aftermarket Purchaser Standing Under § 11 of the Securities Act of 1933, 73 ST. JOHN’S L. REV.633 (1999); Recent Rulings Allow Section 11 Suits By Aftermarket Securities Purchasers, NEW YORK LAW JOURNAL (Sept. 24, 1998); and Comment, Weissmann v. Freeman: The Second Circuit Errs in its Analysis of Derivative Copy-rights by Joint Authors, 63 ST. JOHN’S L. REV. 771 (1989). Mr. Murray was on the trial team that prosecuted a securities fraud case under Section 10(b) of the Securities Exchange Act of 1934 against Microdyne Corporation in the Eastern District of Virginia and he was also on the trial team that presented a claim under Section 14 of the Securities Exchange Act of 1934 against Artek Systems Corporation and Dynatach Group which settled midway through the trial.


Mr. Murray’s major cases include In re Horsehead Holding Corp. Sec. Litig., No. 16-cv-292, 2018 WL 4838234 (D. Del. Oct. 4, 2018) (recommending denial of motion to dismiss securities fraud claims where company’s generic cautionary statements failed to adequately warn of known problems); In re Deutsche Bank Sec. Litig., --- F.R.D. ---, 2018 WL 4771525 (S.D.N.Y. Oct. 2, 2018) (granting class certification for Securities Act claims and rejecting defendants’ argument that class representatives’ trading profits made them atypical class members); Robb v. Fitbit Inc., 216 F. Supp. 3d 1017 (N.D. Cal. 2016) (denying motion to dismiss securities fraud claims where confidential witness statements sufficiently established scienter); In re Eagle Bldg. Tech. Sec. Litig., 221 F.R.D. 582 (S.D. Fla. 2004), 319 F. Supp. 2d 1318 (S.D. Fla. 2004) (complaint against auditor sustained due to magnitude and nature of fraud; no allegations of a “tip-off” were necessary); In re Turkcell Iletisim A.S. Sec. Litig., 209 F.R.D. 353 (S.D.N.Y. 2002) (defining standards by which investment advisors have standing to sue); In re Turkcell Iletisim A.S. Sec. Litig., 202 F. Supp. 2d 8 (S.D.N.Y. 2001) (liability found for false statements in prospectus concerning churn rates); Feiner v. SS&C Tech., Inc., 11 F. Supp. 2d 204 (D. Conn. 1998) (qualified independent underwriters held liable for pricing of offering); Malone v. Microdyne Corp., 26 F.3d 471 (4th Cir. 1994) (reversal of directed verdict for defendants); and Adair v. Bristol Tech. Systems, Inc., 179 F.R.D. 126 (S.D.N.Y. 1998) (aftermarket purchasers have standing under section 11 of the Securities Act of 1933). Mr. Murray also prevailed on an issue of first impression in the Superior Court of Massachusetts, in Cambridge Biotech Corp. v. Deloitte and Touche LLP, in which the court applied the doctrine of continuous representation for statute of limitations purposes to accountants for the first time in Massachusetts. 6 Mass. L. Rptr. 367 (Mass. Super. Jan. 28, 1997). In addition, in Adair v. Microfield Graphics, Inc. (D. Or.), Mr. Murray settled the case for 47% of estimated damages. In the Qiao Xing Universal Telephone case, claimants received 120% of their recognized losses. Among his current cases, Mr. Murray represents a class of investors in a securities litigation involving preferred shares of Deutsche Bank and is lead counsel in a securities class action against Horsehead Holdings, Inc. in the District of Delaware. Mr. Murray served as a Trustee of the Incorporated Village of Garden City (2000-2002); Commissioner of Police for Garden City (2000-2001); Co-Chairman, Derivative Suits Subcommittee, American Bar Association Class Action and Derivative Suits Committee, (2007-2010); Member, Sports Law Committee, Association of the Bar for the City of New York, 1994-1997; Member, Litigation Committee, Association of the Bar for the City of New York, 2003-2007; Member, New York State Bar Association Committee on Federal Constitution and Legislation, 2005-2008; Member, Federal Bar Council, Second Circuit Committee, 2007-present. Mr. Murray has been a panelist at CLEs sponsored by the Federal Bar Council and the Institute for Law and Economic Policy, at the German-American Lawyers Association Annual Meeting in Frankfurt, Germany, and is a frequent lecturer before institutional investors in Europe and South America on the topic of class actions.

ROBERT V. PRONGAY is a partner in the Firm’s Los Angeles office where he focuses on the investigation, initiation, and prosecution of complex securities cases on behalf of


institutional and individual investors. Mr. Prongay’s practice concentrates on actions to recover investment losses resulting from violations of the federal securities laws and various actions to vindicate shareholder rights in response to corporate and fiduciary misconduct.

Mr. Prongay has extensive experience litigating complex cases in state and federal courts nationwide. Since joining the Firm, Mr. Prongay has successfully recovered millions of dollars for investors victimized by securities fraud and has negotiated the implementation of significant corporate governance reforms aimed at preventing the recurrence of corporate wrongdoing.

Mr. Prongay was recently recognized as one of thirty lawyers included in the Daily Journal’s list of Top Plaintiffs Lawyers in California for 2017. Several of Mr. Prongay’s cases have received national and regional press coverage. Mr. Prongay has been interviewed by journalists and writers for national and industry publications, ranging from The Wall Street Journal to the Los Angeles Daily Journal. Mr. Prongay has appeared as a guest on Bloomberg Television where he was interviewed about the securities litigation stemming from the high-profile initial public offering of Facebook, Inc.

Mr. Prongay received his Bachelor of Arts degree in Economics from the University of Southern California and his Juris Doctor degree from Seton Hall University School of Law. Mr. Prongay is also an alumnus of the Lawrenceville School.

DANIELLA QUITT, a partner in the firm’s New York office, graduated from Fordham University School of Law in 1988, is a member of the Bar of the State of New York, and is also admitted to the United States District Courts for the Southern and Eastern Districts of New York, the United States Court of Appeals for the Second, Fifth, and Ninth Circuits, and the United States Supreme Court.

Ms. Quitt has extensive experience in successfully litigating complex class actions from inception to trial and has played a significant role in numerous actions wherein substantial benefits were conferred upon plaintiff shareholders, such as In re Safety-Kleen Corp. Stockholders Litigation, (D.S.C.) (settlement fund of $44.5 million); In re Laidlaw Stockholders Litigation, (D.S.C.) (settlement fund of $24 million); In re UNUMProvident Corp. Securities Litigation, (D. Me.) (settlement fund of $45 million); In re Harnischfeger Industries (E.D. Wisc.) (settlement fund of $10.1 million); In re Oxford Health Plans, Inc. Derivative Litigation, (S.D.N.Y.) (settlement benefit of $13.7 million and corporate therapeutics); In re JWP Inc. Securities Litigation, (S.D.N.Y.) (settlement fund of $37 million); In re Home Shopping Network, Inc., Derivative Litigation, (S.D. Fla.) (settlement benefit in excess of $20 million); In re Graham-Field Health Products, Inc. Securities Litigation, (S.D.N.Y.) (settlement fund of $5.65 million); Benjamin v. Carusona, (E.D.N.Y.) (prosecuted action on behalf of minority shareholders which resulted in a change of control from majority-controlled management at Gurney’s Inn Resort & Spa Ltd.); In re Rexel Shareholder Litigation, (Sup. Ct. N.Y. County) (settlement benefit in excess of $38 million); and Croyden Assoc. v. Tesoro Petroleum Corp., et al., (Del. Ch.) (settlement benefit of $19.2 million).


In connection with the settlement of Alessi v. Beracha, (Del. Ch.), a class action brought on behalf of the former minority shareholders of Earthgrains, Chancellor Chandler commented: “I give credit where credit is due, Ms. Quitt. You did a good job and got a good result, and you should be proud of it.”@

Ms. Quitt has focused her practice on shareholder rights and ERISA class actions but also handles general commercial and consumer litigation. Ms. Quitt serves as a member of the S.D.N.Y. ADR Panel and has been consistently selected as a New York Metro Super Lawyer.

JONATHAN M. ROTTER leads the Firm’s intellectual property litigation practice. He recently served for three years as the first Patent Pilot Program Law Clerk at the United States District Court for the Central District of California, both in Los Angeles and Orange County. There, he assisted the Honorable S. James Otero, Andrew J. Guilford, George H. Wu, John A. Kronstadt, and Beverly Reid O’Connell with hundreds of patent cases in every major field of technology, from complaint to post-trial motions. Mr. Rotter also served as a law clerk for the Honorable Milan D. Smith, Jr. on the United States Court of Appeals for the Ninth Circuit.

Before his service to the court, Mr. Rotter practiced at an international law firm, where he argued appeals at the Federal Circuit, Ninth Circuit, and California Court of Appeal, tried cases, argued motions, and managed all aspects of complex litigation. He also served as a volunteer criminal prosecutor for the Los Angeles City Attorney’s Office. His cases have involved diverse technologies in both “wet” and “dry” disciplines, and he excels at the critical skill of translating complex subject matter into a coherent story that can be digested by judges and juries.

In addition to intellectual property matters, Mr. Rotter litigates consumer protection, healthcare, antitrust, and securities class actions. Mr. Rotter handles cases on contingency, partial contingency, and hourly bases. He works collaboratively with other lawyers and law firms across the country.

Mr. Rotter graduated with honors from Harvard Law School in 2004. He served as an editor of the Harvard Journal of Law & Technology, and was a Fellow in Law and Economics at the John M. Olin Center for Law, Economics, and Business, and a Fellow in Justice, Welfare, and Economics at the Weatherhead Center For International Affairs. He graduated with honors from the University of California, San Diego in 2000 with a B.S. in molecular biology and a B.A. in music.

Mr. Rotter serves on the Merit Selection Panel for Magistrate Judges in the Central District of California, and the Model Patent Jury Instructions and Model Patent Local Rules subcommittees of the American Intellectual Property Law Association. He has written extensively on intellectual property issues, and has been honored for his work with legal service organizations. He is admitted to practice before the United States Patent & Trademark Office, the United States Courts of Appeals for the Second, Ninth and Federal Circuits, and the United States District Courts for the Northern, Central, and Southern Districts of California.


KEVIN F. RUF graduated from the University of California at Berkeley with a Bachelor of Arts in Economics and earned his Juris Doctor degree from the University of Michigan. He was an associate at the Los Angeles firm Manatt Phelps and Phillips from 1988 until 1992, where he specialized in commercial litigation. In 1993, he joined the firm Corbin & Fitzgerald (with future federal district court Judge Michael Fitzgerald) specializing in white collar criminal defense work. Kevin joined the Glancy firm in 2001 and is the head of the firm’s Labor practice. Kevin has successfully argued a number of important appeals, including in the 9th Circuit Court of Appeals. He has twice argued cases before the California Supreme Court – winning both. In Smith v. L'Oreal (2006), the California Supreme Court established a fundamental right of all California workers to immediate payment of all earnings at the conclusion of their employment. The second California Supreme Court case, Lee v. Dynamex (2018), has been called a “blockbuster” and “bombshell” as it altered 30 years of California law and established a new definition of employment that brings more workers within the protections of California’s Labor Code. Kevin has been named one of California’s “Top 75 Employment Lawyers” by the Daily Journal. He has consistently been named a “Super Lawyer.” Since 2014, Kevin has been an elected member of the Ojai Unified School District Board of Trustees. Kevin was also a Main Company Member of the world-famous Groundlings improv and sketch comedy troupe – “where everyone else got famous.” BENJAMIN I. SACHS-MICHAELS, a partner in the firm’s New York office, graduated from Benjamin N. Cardozo School of Law in 2011. His practice focuses on shareholder derivative litigation and class actions on behalf of shareholders and consumers. While in law school, Mr. Sachs-Michaels served as a judicial intern to Senior United States District Judge Thomas J. McAvoy in the United States District Court for the Northern District of New York and was a member of the Cardozo Journal of Conflict Resolution. Mr. Sachs-Michaels is a member of the Bar of the State of New York. He is also admitted to the United States District Courts for the Southern and Eastern Districts of New York and the United States Court of Appeals for the Second Circuit. CASEY E. SADLER is a native of New York, New York. After graduating from the University of Southern California, Gould School of Law, Mr. Sadler joined the Firm in 2010. While attending law school, Mr. Sadler externed for the Enforcement Division of the Securities and Exchange Commission, spent a summer working for P.H. Parekh & Co. – one of the leading appellate law firms in New Delhi, India – and was a member of USC's Hale Moot Court Honors Program. Mr. Sadler’s practice focuses on securities and consumer litigation. A partner in the Firm’s Los Angeles office, Mr. Sadler is admitted to the State Bar of California and the


United States District Courts for the Northern, Southern, and Central Districts of California. EX KANO S. SAMS II earned his Bachelor of Arts degree in Political Science from the University of California Los Angeles. Mr. Sams earned his Juris Doctor degree from the University of California Los Angeles School of Law, where he served as a member of the UCLA Law Review. After law school, Mr. Sams practiced class action civil rights litigation on behalf of plaintiffs. Subsequently, Mr. Sams was a partner at Coughlin Stoia Geller Rudman & Robbins LLP (currently Robbins Geller Rudman & Dowd LLP), where his practice focused on securities and consumer class actions on behalf of investors and consumers. During his career, Mr. Sams has served as lead counsel in dozens of securities class actions and complex-litigation cases throughout the United States. Mr. Sams was one of the counsel for respondents in Cyan, Inc. v. Beaver Cty. Employees Ret. Fund, No. 15-1439, 2018 WL 1384564 (U.S. Mar. 20, 2018), 583 U.S. ___ (2018), in which the United States Supreme Court ruled unanimously in favor of respondents, holding that: (1) the Securities Litigation Uniform Standards Act of 1998 (“SLUSA”) does not strip state courts of jurisdiction over class actions alleging violations of only the Securities Act of 1933; and (2) SLUSA does not empower defendants to remove such actions from state to federal court. Mr. Sams also participated in a successful appeal before a Fifth Circuit panel that included former United States Supreme Court Justice Sandra Day O’Connor sitting by designation, in which the court unanimously vacated the lower court’s denial of class certification, reversed the lower court’s grant of summary judgment, and issued an important decision on the issue of loss causation in securities litigation: Alaska Electrical Pension Fund v. Flowserve Corp., 572 F.3d 221 (5th Cir. 2009). The case settled for $55 million. Mr. Sams has also obtained other significant results. Notable examples include: In re King Digital Entm’t plc S’holder Litig., No. CGC-15-544770 (San Francisco Superior Court) (case settled for $18.5 million); In re Castlight Health, Inc. S’holder Litig., Lead Case No. CIV533203 (California Superior Court, County of San Mateo) (case settled for $9.5 million); Wiley v. Envivio, Inc., Master File No. CIV517185 (California Superior Court, County of San Mateo) (case settled for $8.5 million); In re CafePress Inc. S’holder Litig., Master File No. CIV522744 (California Superior Court, County of San Mateo) (case settled for $8 million); Robinson v. Audience, Inc., Case No. 1:12-cv-232227 (California Superior Court, County of Santa Clara) (case settled for $6,050,000); Estate of Gardner v. Continental Casualty Co., No. 3:13-cv-1918 (JBA), 2016 WL 806823 (D. Conn. Mar. 1, 2016) (granting class certification); Forbush v. Goodale, No. 33538/2011, 2013 WL 582255 (N.Y. Sup. Feb. 4, 2013) (denying motions to dismiss in a shareholder derivative action); Curry v. Hansen Med., Inc., No. C 09-5094 CW, 2012 WL 3242447 (N.D. Cal. Aug. 10, 2012) (upholding securities fraud complaint; case settled for $8.5 million); Wilkof v. Caraco Pharm. Labs., Ltd., 280 F.R.D. 332 (E.D. Mich. 2012) (granting class certification); Puskala v. Koss Corp., 799 F. Supp. 2d 941 (E.D. Wis. 2011) (upholding securities fraud complaint); Mishkin v. Zynex Inc., Civil Action No. 09-cv-00780-REB-KLM, 2011 WL 1158715 (D. Colo. Mar. 30, 2011) (denying defendants’ motion to dismiss securities fraud complaint); and Tsirekidze v. Syntax-


Brillian Corp., No. CV-07-02204-PHX-FJM, 2009 WL 2151838 (D. Ariz. July 17, 2009) (granting class certification; case settled for $10 million).

Additionally, Mr. Sams has successfully represented consumers in class action litigation. Mr. Sams worked on nationwide litigation and a trial against major tobacco companies, and in statewide tobacco litigation that resulted in a $12.5 billion recovery for California cities and counties in a landmark settlement. He also was a principal attorney in a consumer class action against one of the largest banks in the country that resulted in a substantial recovery and a change in the company’s business practices. Mr. Sams also participated in settlement negotiations on behalf of environmental organizations along with the United States Department of Justice and the Ohio Attorney General’s Office that resulted in a consent decree requiring a company to perform remediation measures to address the effects of air and water pollution. Additionally, Mr. Sams has been an author or co-author of several articles in major legal publications, including “9th Circuit Decision Clarifies Securities Fraud Loss Causation Rule” published in the February 8, 2018 issue of the Daily Journal, and “Market Efficiency in the World of High-Frequency Trading” published in the December 26, 2017 issue of the Daily Journal.

KARA M. WOLKE is a partner in the firm’s Los Angeles office. Ms. Wolke specializes in complex litigation, including the prosecution of securities fraud, derivative, consumer, and wage and hour class actions. She has extensive experience in written appellate advocacy in both State and Federal Circuit Courts of Appeals, and has successfully argued before the Court of Appeals for the State of California. With over a decade of experience in financial class action litigation, Ms. Wolke has helped to recover hundreds of millions of dollars for injured investors, consumers, and employees. Notable cases include: Farmington Hills Employees’ Retirement System v. Wells Fargo Bank, Case No. 10-4372 (D. Minn.) ($62.5 million settlement on behalf of participants in Wells Fargo’s securities lending program. The settlement was reached on the eve of trial and ranked among the largest recoveries achieved in a securities lending class action stemming from the 2008 financial crisis.); Schleicher, et al. v. Wendt, et al. (Conseco), Case No. 02-cv-1332 (S.D. Ind.) ($41.5 million securities class action settlement); Lapin v. Goldman Sachs, Case No. 03-850 (S.D.N.Y.) ($29 million securities class action settlement); In Re: Mannkind Corporation Securities Litigation, Case No. 11-929 (C.D. Cal) (approximately $22 million settlement - $16 million in cash plus stock); Jenson v. First Trust Corp., Case No. 05-3124 (C.D. Cal.) ($8.5 million settlement of action alleging breach of fiduciary duty and breach of contract against trust company on behalf of a class of elderly investors); and Pappas v. Naked Juice Co., Case No. 11-08276 (C.D. Cal.) ($9 million settlement in consumer class action alleging misleading labeling of juice products as “All Natural”). With a background in intellectual property, Ms. Wolke was a part of the team of lawyers who successfully challenged the claim of copyright ownership to the song “Happy Birthday to You” on behalf of artists and filmmakers who had been forced to pay hefty licensing fees to publicly sing the world’s most famous song. In the resolution of that action, the defendant music publishing company funded a settlement of $14 million and,


significantly, agreed to relinquish the song to the public domain. Previously, Ms. Wolke penned an article regarding the failure of U.S. Copyright Law to provide an important public performance right in sound recordings, 7 Vand. J. Ent. L. & Prac. 411, which was nationally recognized and received an award by the American Bar Association and the Grammy® Foundation. Committed to the provision of legal services to the poor, disadvantaged, and other vulnerable or disenfranchised individuals and groups, Ms. Wolke also oversees the Firm’s pro bono practice. Ms. Wolke currently serves as a volunteer attorney for KIND (Kids In Need of Defense), representing unaccompanied immigrant and refugee children in custody and deportation proceedings, and helping them to secure legal permanent residency status in the U.S. Ms. Wolke graduated summa cum laude with a Bachelor of Science in Economics from The Ohio State University in 2001. She subsequently earned her J.D. (with honors) from Ohio State, where she was active in Moot Court and received the Dean’s Award for Excellence during each of her three years. Ms. Wolke is admitted to the State Bar of California, the Ninth Circuit Court of Appeals, as well as the United States District Courts for the Northern, Southern, and Central Districts of California. She lives with her husband and two sons in Los Angeles.

OF COUNSEL BRIAN D. BROOKS joined the New York office of Glancy Prongay & Murray LLP in 2019, specializing in antitrust, consumer, and securities litigation. His current cases include In re Zetia Antitrust Litigation, No. 18-md-2836 (E.D. Va.); Staley, et al. v. Gilead Sciences, Inc., et al., No. 3:19-cv-02573-EMC (N.D. Cal.); and In re: Seroquel XR (Extended Release Quetiapine Fumarate) Litigation, No. 1:19-cv-08296-CM (S.D.N.Y.). Prior to joining the firm, Mr. Brooks was an associate at Murray, Frank & Sailer, LLP in New York, where his practice was focused on antitrust, consumer, and securities matters, and later a partner at Smith, Segura & Raphael, LLP, in New York and Louisiana. During his tenure at Smith Segura & Raphael, LLP, Mr. Brooks represented direct purchasers in numerous antitrust matters, including In re: Suboxone (Buprenorphine Hydrochloride and Naloxone) Antitrust Litigation, No. 2:13-md-02445 (E.D. Pa.), In re: Niaspan Antitrust Litigation, No. 2:13-md-02460 (E.D. Pa.), and In re: Novartis & Par Antitrust Litigation (Exforge), No. 18-cv-4361 (S.D.N.Y.), and was an active member of the trial team for the class in In re: Nexium (Esomeprazole) Antitrust Litigation, No. 12-md-2409 (D. Mass.), the first post-Actavis reverse-payment case to be tried to verdict. He was also an active member of the litigation teams in the King Drug Company of Florence, Inc. et al. v. Cephalon, Inc., et al. (Provigil), No. 2:06-cv-1797 (E.D. Pa.); In re: Prograf Antitrust Litigation, No. 1:11-md-2242 (D. Mass.) and In re: Miralax antitrust matters, which collectively settled for more than $600 million, and a member of the litigation teams in In re: Relafen Antitrust Litigation, No. 01-cv-12239 (D. Mass.); In re: Buspirone Antitrust Litigaiton, MDL Dkt. No. 1410 (S.D.N.Y.); In re: Remeron Antitrust Litigation, No. 02-2007 (D.N.J.); In re: Terazosin Hydrochloride


Antitrust Litigation, No. 99-MDL-1317 (S.D. Fla.); and In re K-Dur Antitrust Litigation, No. 10-cv-1652 (D.N.J.). Mr. Brooks received his B.A. from Northwestern State University of Louisiana in 1998 and his J.D. from Washington and Lee School of Law in 2002, where he was a staff writer for the Environmental Law Digest and clerked for the Alderson Legal Assistance Program, handling legal matters for inmates of the Federal Detention Center in Alderson, West Virginia. He is admitted to practice in all state courts in New York and Louisiana, as well as the United States District Courts for the Southern and Eastern Districts of New York and the Eastern and Western Districts of Louisiana. MARK S. GREENSTONE specializes in consumer, financial fraud and employment-related class actions. Possessing significant law and motion and trial experience, Mr. Greenstone has represented clients in multi-million dollar disputes in California state and federal courts, as well as the Court of Federal Claims in Washington, D.C. Mr. Greenstone received his training as an associate at Sheppard, Mullin, Richter & Hampton LLP where he specialized in complex business litigation relating to investment management, government contracts and real estate. Upon leaving Sheppard Mullin, Mr. Greenstone founded an internet-based company offering retail items on multiple platforms nationwide. He thereafter returned to law bringing a combination of business and legal skills to his practice. Mr. Greenstone graduated Order of the Coif from the UCLA School of Law. He also received his undergraduate degree in Political Science from UCLA, where he graduated Magna Cum Laude and was inducted into the Phi Beta Kappa honor society. Mr. Greenstone is a member of the Consumer Attorneys Association of Los Angeles, the Santa Monica Bar Association and the Beverly Hills Bar Association. He is admitted to practice in state and federal courts throughout California. ROBERT I. HARWOOD, Of Counsel to the firm, graduated from William and Mary Law School in 1971, and has specialized in securities law and securities litigation since beginning his career in 1972 at the Enforcement Division of the New York Stock Exchange. Mr. Harwood was a founding member of Harwood Feffer LLP. He has prosecuted numerous securities, class, derivative, and ERISA actions. He is a member of the Trial Lawyers’ Section of the New York State Bar Association and has served as a guest lecturer at trial advocacy programs sponsored by the Practicing Law Institute. In a statewide survey of his legal peers published by Super Lawyers Magazine, Mr. Harwood has been consistently selected as a “New York Metro Super Lawyer.” Super Lawyers are the top five percent of attorneys in New York, as chosen by their peers and through the independent research. He is also a Member of the Board of Directors of the MFY Legal Services Inc., which provides free legal representation in civil matters to the poor and the mentally ill in New York City. Since 1999, Mr. Harwood has also served as a Village Justice for the Village of Dobbs Ferry, New York.


Commenting on Mr. Harwood’s abilities, in In re Royal Dutch/Shell Transport ERISA Litigation, (D.N.J.), Judge Bissell stated:

the Court knows the attorneys in the firms involved in this matter and they are highly experienced and highly skilled in matters of this kind. Moreover, in this case it showed. Those efforts were vigorous, imaginative and prompt in reaching the settlement of this matter with a minimal amount of discovery . . . . So both skill and efficiency were brought to the table here by counsel, no doubt about that.

Likewise, Judge Hurley stated in connection with In re Olsten Corporation Securities Litigation, No. 97 CV-5056 (E.D.N.Y. Aug. 31, 2001), wherein a settlement fund of $24.1 million was created: “The quality of representation here I think has been excellent.” Mr. Harwood was lead attorney in Meritt v. Eckerd, No. 86 Civ. 1222 (E.D.N.Y. May 30, 1986), where then Chief Judge Weinstein observed that counsel conducted the litigation with “speed and skill” resulting in a settlement having a value “in the order of $20 Million Dollars.” Mr. Harwood prosecuted the Hoeniger v. Aylsworth class action litigation in the United States District Court for the Western District of Texas (No. SA-86-CA-939), which resulted in a settlement fund of $18 million and received favorable comment in the August 14, 1989 edition of The Wall Street Journal (“Prospector Fund Finds Golden Touch in Class Action Suit” p. 18, col. 1). Mr. Harwood served as co-lead counsel in In Re Interco Incorporated Shareholders Litigation, Consolidated C.A. No. 10111 (Delaware Chancery Court) (May 25, 1990), resulting in a settlement of $18.5 million, where V.C. Berger found, “This is a case that has an extensive record that establishes it was very hard fought. There were intense efforts made by plaintiffs’ attorneys and those efforts bore very significant fruit in the face of serious questions as to ultimate success on the merits.” Mr. Harwood served as lead counsel in Morse v. McWhorter (Columbia/HCA Healthcare Securities Litigation), (M.D. Tenn.), in which a settlement fund of $49.5 million was created for the benefit of the Class, as well as In re Bank One Securities Litigation, (N.D. Ill.), which resulted in the creation of a $45 million settlement fund. Mr. Harwood also served as co-lead counsel in In re Safety-Kleen Corp. Stockholders Litigation, (D.S.C.), which resulted in a settlement fund of $44.5 million; In re Laidlaw Stockholders Litigation, (D.S.C.), which resulted in a settlement fund of $24 million; In re AIG ERISA Litigation, (S.D.N.Y.), which resulted in a settlement fund of $24.2 million; In re JWP Inc. Securities Litigation, (S.D.N.Y.), which resulted in a $37 million settlement fund; In re Oxford Health Plans, Inc. Derivative Litigation, (S.D.N.Y.), which resulted in a settlement benefit of $13.7 million and corporate therapeutics; and In re UNUMProvident Corp. Securities Litigation, (D. Me.), which resulted in the creation of settlement fund of $45 million. Mr. Harwood has also been one of the lead attorneys in litigating claims in In re FedEx Ground Package Inc. Employment Practices Litigation, No. 3:05-MD-527 (MDL 1700), a multi-district litigation concerning employment classification of pickup and delivery drivers which resulted in a $242,000,000 settlement. LEANNE HEINE SOLISH is a partner in GPM’s Los Angeles office. Her practice focuses on complex securities litigation.


Ms. Solish has extensive experience litigating complex cases in federal courts nationwide. Since joining GPM in 2012, Ms. Solish has helped secure several large class action settlements for injured investors, including: The City of Farmington Hills Employees Retirement System v. Wells Fargo Bank, Case No. 10-4372--DWF/JJG (D. Minn.) ($62.5 million settlement on behalf of participants in Wells Fargo’s securities lending program. The settlement was reached on the eve of trial and ranked among the largest recoveries achieved in a securities lending class action stemming from the 2008 financial crisis.); Mild v. PPG Industries, Inc. et al., Case No. 2:18-cv-04231 (C.D. Cal.) ($25 million settlement); In re Penn West Petroleum Ltd. Securities Litigation, Case No. 1:14-cv-06046-JGK (S.D.N.Y.) ($19 million settlement for the U.S. shareholder class as part of a $39 million global settlement); In re ITT Educational Services, Inc. Securities Litigation (Indiana), Case No. 1:14-cv-01599-TWP-DML ($12.5375 million settlement); In re Doral Financial Corporation Securities Litigation, Case No. 3:14-cv-01393-GAG (D.P.R.) ($7 million settlement); Larson v. Insys Therapeutics Incorporated, et al., Lead Case No. 14-cv-01043-PHX-GMS (D. Ariz.) ($6.125 million settlement); In re Unilife Corporation Securities Litigation, Case No. 1:16-cv-03976-RA ($4.4 million settlement); and In re K12 Inc. Securities Litigation, Case No. 4:16-cv-04069-PJH (N.D. Cal.) ($3.5 million settlement). Super Lawyers Magazine has selected Ms. Solish as a “Rising Star” in the area of Securities Litigation for the past four consecutive years, 2016 through 2019. Ms. Solish graduated summa cum laude with a B.S.M. in Accounting and Finance from Tulane University, where she was a member of the Beta Alpha Psi honors accounting organization and was inducted into the Beta Gamma Sigma Business Honors Society. Ms. Solish subsequently earned her J.D. from the University of Texas School of Law. Ms. Solish is admitted to the State Bar of California, the Ninth Circuit Court of Appeals, and the United States District Courts for the Central, Northern, and Southern Districts of California. Ms. Solish is also a Registered Certified Public Accountant in Illinois. STAN KARAS of counsel in the Los Angeles office, is an experienced class action attorney, who works on every stage of such cases from pleading challenges to class certification proceedings to trial and appeal. He is also an experienced trial lawyer, including as first chair. Among other successes, he obtained a $3 million jury verdict for a client, along with a finding that the defendant was liable for punitive damages. In another trial, the court granted non-suit in favor of Stan’s client after he delivered the opening argument. Mr. Karas started his legal career at Paul Hastings Janofsky and Walker, where he handled complex commercial and real estate litigation. Subsequently, he joined Quinn Emanuel Urquhart & Sullivan, where he specialized in class actions, both on the plaintiff and the defense side, as well as intellectual property litigation. Mr. Karas then worked at a plaintiff-side class action firm where he obtained tens of millions of dollars in settlements on behalf of his clients.


Mr. Karas is a graduate of Stanford University, where he received a degree in History and Literature and was elected to Phi Beta Kappa. He graduated from Boalt Hall School of Law at UC Berkeley. In law school, Mr. Karas served as Articles Editor of the California Law Review and Notes and Comments Editor of the Berkeley Technology Law Journal. Mr. Karas has published on class action and privacy law issues including Privacy, Identity, Databases, 52 Am. U. L. Rev. 393 (2002) and The Role of Fluid Recovery in Consumer Protection Litigation, 90 Cal. L. Rev. 959 (2002).

ASSOCIATES GRAHAM CLEGG received his LLB in 1988 from the Manchester University School of Law in England, with Honors. He was admitted to the New York State Bar in 2002. Mr. Clegg has significant experience in the prosecution of class claims, including In re Bristol-Myers Squibb Securities Litigation, which settled for $185 million. CHRISTOPHER FALLON focuses on securities, consumer, and anti-trust litigation. Prior to joining the firm, Mr. Fallon was a contract attorney with O'Melveny & Myers LLP working on anti-trust and business litigation disputes. He is a Certified E-Discovery Specialist through the Association of Certified E-Discovery Specialists (ACEDS). Mr. Fallon earned his J.D. and a Certificate in Dispute Resolution from Pepperdine Law School in 2004. While attending law school, Christopher worked at the Pepperdine Special Education Advocacy Clinic and interned with the Rhode Island Office of the Attorney General. Prior to attending law school, he graduated from Boston College with a Bachelor of Arts in Economics and a minor in Irish Studies, then served as Deputy Campaign Finance Director on a U.S. Senate campaign. MEHRDAUD JAFARNIA received his J.D. in 2001 from Southwestern University School of Law, having earlier earned a B.A. in Political Science/International Relations from the University of California at Los Angeles (UC Regents Merit Scholarship Award and the Vance Burch Scholarship). Mr. Jafarnia served as a Staff Attorney for the 9th Circuit Court of Appeals and has represented financial institutions in adversary and evidentiary proceedings in the Bankruptcy Courts. THOMAS J. KENNEDY works out of the New York office, where he focuses on securities, antitrust, mass torts, and consumer litigation. He received a Juris Doctor degree from St. John’s University School of Law in 1995. At St. John’s, he was a member of the ST. JOHN’S JOURNAL OF LEGAL COMMENTARY. Mr. Kennedy graduated from Miami University in 1992 with a Bachelor of Science degree in Accounting and has passed the CPA exam. Mr. Kennedy was previously associated with the law firm Murray Frank LLP. JENNIFER M. LEINBACH served for nearly five years as a judicial law clerk for a number of judges in the Central District of California. As a judicial law clerk, Ms. Leinbach was responsible for assisting these judges with case management, preparing for hearings and trial, and drafting rulings. Ms. Leinbach worked on a variety of different cases, including cases involving financial fraud, insolvency and complex civil litigation.


Ms. Leinbach was also responsible for assisting those judges, sitting by designation, on appellate cases. Ms. Leinbach graduated magna cum laude from Vermont Law School and was a member of Vermont Law Review, where she focused on environmental law issues. During law school, Ms. Leinbach served as a judicial extern in the District of Vermont. She obtained her undergraduate degree cum laude from Pepperdine University. CHARLES H. LINEHAN graduated summa cum laude from the University of California, Los Angeles with a Bachelor of Arts degree in Philosophy and a minor in Mathematics. Mr. Linehan received his Juris Doctor degree from the UCLA School of Law, where he was a member of the UCLA Moot Court Honors Board. While attending law school, Mr. Linehan participated in the school’s First Amendment Amicus Brief Clinic (now the Scott & Cyan Banister First Amendment Clinic) where he worked with nationally recognized scholars and civil rights organizations to draft amicus briefs on various Free Speech issues. DANIELLE L. MANNING is a litigation associate in the firm’s Los Angeles office. Ms. Manning specializes in prosecuting complex class action lawsuits in state and federal courts nationwide, including consumer and securities fraud class actions. She has particular experience litigating automobile defect and Telephone Consumer Protection Act (“TCPA”) cases and excels at managing multiple significant matters at once. Ms. Manning has experience in all phases of pre-trial litigation, including conducting fact investigation, drafting pleadings, researching and drafting briefs in the context of law and motion practice, drafting and responding to discovery requests, assisting with deposition preparation, and preparing for and negotiating settlements. Ms. Manning is admitted to the State Bar of California, the Ninth Circuit Court of Appeals, United States District Courts for the Central and Northern Districts of California, and the Eastern District of Michigan.

A few of the matters Ms. Manning is currently taking an active role in are: Gann et. al. v. Nissan North America, Case No. 3:18-cv-00966 (M.D. Tenn.) (preliminary approval granted July 16, 2019); Salcedo v. Häagen-Dazs Shoppe Company Inc., Case No. 5:17-cv-03504 (N.D. Cal.); Andre Damico et. al. v. Hyundai Motor America Inc., Case No. 30-2018-01008552-CU-BC-CXC (Cal. Super. Ct.) (demurrer overruled); Elaine Hall et al. v. General Motors LLC, Case No. 4:19-cv-10186 (E.D. Mich.) (motion to dismiss pending); Mark Mina v. Red Robin International Inc., et al., Case No. 2:18-cv-09472 (C.D. Cal.)(motion to dismiss pending) and Kohna et al. v. Subaru of America Inc., Case No. 1:19-cv-09323 (D.N.J). Ms. Manning received her Juris Doctor degree from the University of California Los Angeles School of Law, where she served as Chief Managing Editor of the Journal of Environmental Law and Policy. While attending law school, Ms. Manning externed for the Honorable Laurie D. Zelon in the California Court of Appeal and interned for the California Department of Justice, Office of the Attorney General. Ms. Manning received her Bachelor of Arts degree with honors in Environmental Analysis from Claremont McKenna College.


VAHE MESROPYAN joined the firm in 2018 and focuses his practice on litigating securities class actions. Immediately prior to joining the firm, Mr. Mesropyan served as a judicial law clerk for multiple judges in the U.S. District Court for the Central District of California. Prior to his clerkship, Mr. Mesropyan was an associate at Crowell & Moring LLP, where he represented Fortune 500 companies in complex antitrust matters. Mr. Mesropyan received his J.D. from the University of California, Irvine School of Law as a Dean’s Merit Scholarship recipient. While in law school, he clerked for the Federal Trade Commission, Consumer Protection Unit and served as an extern for the Internal Revenue Service, Office of Chief Counsel. NATALIE S. PANG is an associate in the firm's Los Angeles office. Ms. Pang has advocated on behalf of thousands of consumers during her career. Ms. Pang has extensive experience in case management and all facets of litigation: from a case’s inception through the discovery process--including taking and defending depositions and preparing witnesses for depositions and trial--mediation and settlement negotiations, pretrial motion work, trial and post-trial motion work. Prior to joining the firm, Ms. Pang lead the mass torts department of her last firm, where she managed the cases of over two thousand individual clients. There, Ms. Pang worked on a wide variety of complex state and federal matters which included cases involving pharmaceutical drugs, medical devices, auto defects, toxic torts, false advertising, and uninhabitable conditions. Ms. Pang was also trial counsel in the notable case, Celestino Acosta et al. v. City of Long Beach et al. (BC591412) which was brought on behalf of residents of a mobile home park built on a former trash dump and resulted in a $39.5 million verdict after an eleven-week jury trial in Los Angeles Superior Court. Ms. Pang received her J.D. from Loyola Law School. While in law school, Ms. Pang received a Top 10 Brief Award as a Scott Moot Court competitor, was chosen to be a member of the Scott Moot Court Honor's Board, and competed as a member of the National Moot Court Team. Ms. Pang was also a Staffer and subsequently an Editor for Loyola's Entertainment Law Review as well as a Loyola Writing Tutor. During law school, Ms. Pang served as an extern for: the Hon. Rolf Treu (Los Angeles Superior Court), the Los Angeles City Attorney's Office, and the Federal Public Defender's Office. Ms. Pang obtained her undergraduate degree from the University of Southern California and worked in the healthcare industry prior to pursuing her career in law. JARED F. PITT focuses on securities, consumer, and anti-trust litigation. Prior to joining the firm, Mr. Pitt was an associate at Willoughby Doyle LLP and was a senior financial statement auditor for KMPG LLP where he earned his CPA license. Mr. Pitt earned his J.D. from Loyola Law School in 2010. Prior to attending law school he graduated with honors from both the University of Michigan’s Ross School of Business and USC’s Marshall School of Business where he received a Masters of Accounting.


PAVITHRA RAJESH is an associate in the firm’s Los Angeles office. Ms. Rajesh graduated from University of California, Santa Barbara with a Bachelor of Science degree in Mathematics and a Bachelor of Arts degree in Psychology. She received her Juris Doctor degree from UCLA School of Law. Ms. Rajesh has unique writing experience from her judicial externship for the Patent Pilot Program in the United States District Court for the Central District of California, where she worked closely with the Clerk and judges in the program on patent cases. While in law school, Ms. Rajesh was an Associate Editor for the UCLA Law Review. NOREEN R. SCOTT received her J.D. in 2002 from Tulane Law School and earned a B.A. in Economics from Emory University in 1999. She served as a law clerk to the Hon. Charles R. Jones on the Louisiana State Court of Appeal, and has extensive experience prosecuting complex class action cases. GARTH A. SPENCER is based in the New York office. His work includes securities, antitrust, and consumer litigation. Mr. Spencer also works on whistleblower matters. Mr. Spencer received his B.A. in Mathematics from Grinnell College in 2006. He received his J.D. in 2011 from Duke University School of Law, where he was a staff editor on the Duke Law Journal. From 2011 until 2014 he worked in the tax group of a large, international law firm. Since 2014 he has worked on tax whistleblower matters. Mr. Spencer received his LL.M. in Taxation from New York University in 2016 immediately prior to joining the firm. DANA K. VINCENT received her J.D. in 2002 from Georgetown University Law Center in Washington D.C. and her B.A. cum laude from Spellman College in 1995. Dana also earned an M.A. in Economics from the New School in 1999, where she was the Aaron Diamond Fellow. Ms. Vincent has served as a Law Clerk to the Hon. Sterling Johnson, Jr. of Brooklyn, NY, and has significant experience in the New York Office of the Attorney General where she served as an Assistant Attorney General from 2003-2006. She was a consultant to the Marshall Project, an online journalism organization focusing on U.S. Criminal Justice issues. MELISSA WRIGHT is a litigation associate in the firm’s Los Angeles office. Ms. Wright specializes in complex litigation, including the prosecution of securities fraud and consumer class actions. She has particular expertise in all aspects of the discovery phase of litigation, including drafting and responding to discovery requests, negotiating protocols for the production of Electronically Stored Information (ESI) and all facets of ESI discovery, and assisting in deposition preparation. She has managed multiple document production and review projects, including the development of ESI search terms, overseeing numerous attorneys reviewing large document productions, drafting meet and confer correspondence and motions to compel where necessary, and coordinating the analysis of information procured during the discovery phase for utilization in substantive motions or settlement negotiations. Ms. Wright received her J.D. from the UC Davis School of Law in 2012, where she was a board member of Tax Law Society and externed for the California Board of


Equalization’s Tax Appeals Assistance Program focusing on consumer use tax issues. Ms. Wright also graduated from NYU School of Law, where she received her LL.M. in Taxation in 2013.

in the united states district ... - altima cvt settlement · my firm's resume, which includes...

Documents