Anwar et al v. Fairfield Greenwich Limited et al

Filing 1044

MEMORANDUM OF LAW in Opposition re: #1032 MOTION for Settlement Notice of Motion for Final Approval of the Proposed Partial Settlement and Plan of Allocation. PwC Defendants' Limited Objections to Plaintiffs' Motion. Document filed by Pricewaterhouse Coopers Accountants N.V., Pricewaterhousecoopers L.L.P.. (Attachments: #1 Exhibit A (Part 1), #2 Exhibit A (Part 2), #3 Exhibit B)(Duffy, Timothy)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ANWAR, et al.,
Plaintiffs,
Master File No. 09-cv-118 (VM)
- vFAIRFIELD GREENWICH LIMITED, et al.,
Defendants.
This Document Related To: All Actions

PWC DEFENDANTS’ LIMITED OBJECTIONS TO
PLAINTIFFS’ MOTION FOR FINAL SETTLEMENT APPROVAL
Defendants PricewaterhouseCoopers LLP (“PwC Canada”) and PricewaterhouseCoopers
Accountants N.V. (“PwC Netherlands”) (together, “the PwC Defendants”) oppose Plaintiffs’
Motion for Final Settlement Approval on two grounds.1
First, the Court’s Preliminary Approval Order and the Notice distributed to Settlement
Class Members (and presumably the final approval order that will be sought by the Settling
Parties), improperly purports to allow Settlement Class Members to purposely avail themselves
of the benefits and protections of this proceeding without submitting to the jurisdiction of this
Court for all matters arising from or related to this case. This attempted limitation on the Court’s
jurisdiction prejudices the rights of the PwC Defendants to assert that the affirmative conduct of
Settlement Class Members bars, limits, or otherwise impacts their claims against the PwC
Defendants in other fora. This Court should not allow Settlement Class Members to act in this
proceeding, whether by partaking of the benefits of the Proposed Settlement or by affirmatively
1

Defendant GlobeOp Financial Services LLC (“GlobeOp”) joins in one of the PwC Defendants’ objections as noted
below.

exempting themselves from it, and nevertheless permit them to argue that they are not subject to
the Court’s jurisdiction with regard to all matters arising from or related to this case.
Second, the Preliminary Approval Order (and presumably the final order as well)
improperly allow members of the Settlement Class Members to participate in the Proposed
Settlement (by making claims or excluding themselves from the Settlement Class) anonymously.
This prejudices the PwC Defendants’ right to determine whether such persons and entities have
in fact purposefully availed themselves of the benefits and protections of this proceeding, and
thus whether their claims against the PwC Defendants in other fora should be barred, limited, or
otherwise impacted.

The PwC Defendants are entitled to know who the Settlement Class

Members are, and whether they are participating in, or exempting themselves from, the proposed
Settlement so that the PwC Defendants can know who is, and who is not, bound by the Court’s
orders and judgments. This objection can easily be remedied by providing the parties to the
litigation access to the exclusion and claim information provided by the members of the
proposed Settlement Class under the terms of the stipulated Confidentiality Order already in
place.
BACKGROUND
There are two provisions of the Court’s Preliminary Approval Order, which the Settling
Parties will presumably propose be included in the Court’s Final Approval Order,2 relevant to the
PwC Defendants’ objections.
The first provision is Paragraph 17 of the Preliminary Approval Order, which provides:
Any Settlement Class Member who submits a Request for Exclusion shall not be
deemed to have submitted to the jurisdiction of any Court in the United States for
any matter on account of such submission, and any Settlement Class Member who
2

As of the deadline for filing this objection, February 15, 2013, none of the Settling Parties has proffered a Final
Approval Order for consideration by the parties or the Court.

2

submits a Proof of Claim thereby submits to the jurisdiction of this Court with
respect only to the subject matter of such Proof of Claim and all determinations
made by this Court thereon and shall not be deemed to have submitted to the
jurisdiction of this Court or of any court in the United States for any other matter
on account of such submission.
(Dkt. No. 1008 ¶ 17) The second provision is Paragraph 21 of the Preliminary Approval Order:
Except where a Settlement Class Member who submits a Request for Exclusion
commences or otherwise prosecutes a Released Claim against a Released Party,
all information submitted by a Settlement Class Member in a Request for
Exclusion or a Proof of Claim shall be treated as confidential protected
information and may not be disclosed by the Claims Administrator, its affiliates
or the Settling Parties to any third party absent a further order of this Court upon a
showing of necessity, and any such information that is submitted to the Court
shall be filed under seal.
(Dkt. No. 1008 ¶ 21)
The Preliminary Approval Order originally submitted some three weeks prior to the
hearing contained a much more customary version of Paragraph 17 that simply said: “Any
Settlement Class Member who submits a Request for Exclusion or a Proof of Claim thereby
submits to the jurisdiction of the Court with respect to the subject matter thereof and all
determinations made by the Court thereon” (Dkt. No. 996-1 ¶ 17), and it contained no provision
with regard to the confidentiality of class or exclusion information. The “somewhat unusual”
provisions (to use Plaintiffs’ counsel’s words, see Preliminary Approval Tr. at 27 (11/30/2012)),
of the revised Paragraph 17 and new Paragraph 21, were added at the eleventh hour for the
express purpose of protecting beneficial owners of investments in the funds from suits by Irving
Picard, the SIPC Trustee for Bernard L. Madoff Investment Securities, LLC, and the courtappointed Liquidator of Fairfield Sentry Ltd. for monies that Settlement Class Members may
have directly or indirectly received from the Madoff Ponzi scheme. Id. at 25-26.
As the Court is well aware, the vast majority of the members of the proposed Settlement
Class are foreign entities and individuals. Investors in Fairfield Sentry Ltd., Fairfield Sigma

3

Ltd., and Fairfield Lambda Ltd., all of which were so-called “off shore” investment funds – the
number of which dwarfs the number of investors in the so-called domestic funds, Greenwich
Sentry and Greenwich Sentry Partners – were required to represent that they were not subject to
United States taxation. Plaintiffs themselves have estimated that there are only about 200
members of the proposed Settlement Class in the United States and that these class members
account for less than 10% of the likely claims. (See, e.g.¸ Ex. A to Declaration of Jeffrey L.
Roether (Dkt. No. 1031) at 4-5) And, as demonstrated in the parties’ briefs on the certification
of a litigation class, it is very much an open question as to whether this Court has jurisdiction
over the foreign investors in the proposed litigation class, and whether the orders and judgments
of this Court would be enforceable against the members of the proposed litigation class, which is
largely coextensive with the Proposed Settlement Class.
The enforceability of this Court’s orders and judgments against members of the proposed
Settlement Class (and the proposed litigation class for that matter) is not a theoretical question.
The PwC Defendants are currently facing claims from members of the proposed Settlement
Class and are asserting defenses the success of which may very well depend on the claimants’
ability to argue whether this Court’s orders and judgments (beyond those related to claim
determinations) will apply to them.
The PwC Defendants have been named as defendants in a complaint filed by a number of
purported Fairfield Sentry investors in the Netherlands; namely, Colima International Limited
and Stichting Fairfield Compensation Foundation3 (“the Colima Litigation”). (A translation of
the Colima Litigation complaint is attached as Exhibit A) Assuming, for purposes of this

3

A foundation established under Dutch law “to recover losses suffered by investors on their investments in the
Sentry and/or Sigma and/or Lambda investment funds,” the “participants” in which are such investors. (See Ex. A at
¶ 2.8)

4

objection, the truth of the allegations that the Colima Litigation plaintiffs (or the individuals and
entities they represent) experienced a net loss on investments in Fairfield Sentry, Sigma, or
Lambda, they are Settlement Class Members.4
PwC Canada has recently filed a motion in the Colima Litigation arguing that the Dutch
court should dismiss the claims against PwC Canada on various grounds, including that the
Dutch court has no jurisdiction to adjudicate claims against PwC Canada, that several of the
plaintiffs in that case are also named plaintiffs in this case, that the pendency of this case
precludes or at least makes inappropriate a parallel Dutch proceeding, and that if a settlement
class is certified in this case, some or all of the Colima Litigation plaintiffs will likely submit to
this Court’s jurisdiction for all related matters by either making claims under the proposed
settlement or requesting exclusion from the Settlement Class, thus demonstrating the availability,
adequacy, and primacy of this litigation as opposed to the Colima litigation. (A translation of
PwC Canada’s Motion to Dismiss in the Colima Litigation is attached as Exhibit B)
ARGUMENT
I.

The PwC Defendants Have Standing to Make These Objections.
The PwC Defendants are mindful of the general rule that a non-settling defendant usually

lacks standing to object to a settlement “because a nonsettling defendant is ordinarily not
affected by such a settlement.” Zupnick v. Fogel, 989 F.2d 93, 98 (2d Cir. 1993). In this case,
however, the PwC Defendants qualify for the “recognized exception to this general rule which
permit[s] a non-settling defendant to object where it can demonstrate that it will sustain some
formal legal prejudice as a result of the settlement.” Id. (internal quotations omitted).
4

They are, of course, likely to be members of the proposed litigation class as well. As the Court is aware, in
contrast to their arguments with respect to several other jurisdictions, Defendants did not take issue with the
Plaintiffs’ contention that a Dutch court would likely give preclusive effect to a class action judgment of this Court.
(See Defendants’ Mem. Opposing Class Certification (Dkt. No. 788) at 33 n.81)

5

There can be no question that under well-established law that Settlement Class Members
not already subject to the general jurisdiction of this Court who act in this proceeding will
become subject to the specific jurisdiction of this Court for all matters arising from this case. See
N.Y. CPLR § 302(a)(1) (McKinney’s 2008) (courts have jurisdiction over any non-domiciliary
who “in person or through an agent … transacts any business within the state”); see also PDK
Labs, Inc. v. Friedlander, 103 F.3d 1105, 1109-11 (2d Cir. 1997) (finding assertion of legal
rights in New York met business-transaction test).
A final approval order that purports to limit this Court’s jurisdiction over Settlement
Class Members to only the Proofs of Claim they submit, and not to any other claims related
thereto, will therefore purport to limit the Court’s jurisdiction, which will prejudice the PwC
Defendants’ right to assert the orders and judgments of this Court that are not limited to the
Proofs of Claim against the Settlement Class Members in related proceedings.
In addition, allowing Settlement Class Members to act anonymously in this proceeding
will exacerbate the prejudice to the PwC Defendants’ right to assert the orders and judgments of
this Court against the Settlement Class Members, for the simple reason that the PwC Defendants
will be unable to identify the Settlement Class Members who have taken action and recovered on
their claims (and thereby subjected themselves to the jurisdiction of the Court).5
In these circumstances, the PwC Defendants have standing to challenge these specific
provisions of Court’s approval orders. Phillips Petroleum Co. v. Shutts, 472 U.S. 797, 805
(1985) (finding class-action defendant had standing to challenge trial court’s assertion of
jurisdiction over absent class members on the basis of the defendant’s assertion that “it would be

5

GlobeOp has standing to join in this objection as noted below on these same grounds.

6

obviously and immediately injured if this class-action judgment against it became final without
binding the plaintiff class”).
II.

The Court Should Not Purport to Limit Its Personal Jurisdiction Over Settlement
Class Members.
It is beyond dispute that a federal court has the power to assert jurisdiction over absent

class members, provided appropriate notice and the opportunity to “opt out” are given to class
members. Id. at 811-812. Assuming that the Court certifies the proposed Settlement Class, it
will necessarily have concluded that it has personal jurisdiction over the members of the
Settlement Class.6 Id. at 805 (“[A] judgment issued without proper personal jurisdiction over an
absent party is not entitled to full faith and credit elsewhere and thus has no res judicata effect as
to that party.”). And, for absent class members not otherwise subject to the Court’s general
jurisdiction, the scope of the Court’s specific jurisdiction extends to any claims that arise from
the class member’s participation in this case. See, e.g., N.Y. CPLR § 302(a)(1). Indeed, the
Settling Parties themselves seek the Court’s imprimatur over a settlement that purports to release
claims that “arise out of or relate in any manner to” a long list of circumstances that may be
safely summarizes as anything related to the Fairfield Greenwich funds or Madoff.

(See

Stipulation of Settlement at 15-16 (defining “Released Claims”)). Surely the Court’s jurisdiction
cannot be narrower than the scope of the release enforceable against Settlement Class members.
Given that the Court will have necessarily found it is has jurisdiction over the members
of the proposed settlement class if it approves the proposed Settlement, class members will
(unless they opt out) release all claims arising out of this case, and those class members who
submit opt-out requests in this proceeding will retain the right to pursue claims notwithstanding
6

The issue of this Court’s jurisdiction over absent class members is distinct from the issue in dispute with regard to
Plaintiffs’ pending motion for certification of a litigation class of whether a foreign court would enforce this Court’s
orders against the class member.

7

the settlement. At the same time, however, an order that includes a provision along the lines of
Paragraph 17 would – illogically and improperly – purport to limit the Court’s jurisdiction over
class members (whether they opt out or claim) to their claims or requests for exclusion and invite
them to disavow this Court’s jurisdiction over other claims related to this case. Any such
provision would be irreconcilable with the basis for asserting jurisdiction over the class, and with
the releases and bars to be imposed under the proposed Settlement; more specifically, it would
deprive the PwC Defendants (and potentially others) of the right to assert their conduct and the
Court’s jurisdiction, orders, and judgments, in related matters.
The Settling Parties proposed scheme boils down to this: Class members should be free
to partake of the benefits of, or exempt themselves from the binding effects of, the proposed
Settlement without any effect on their status with regard to any claims or potential claims against
the PwC Defendants whether in this case or elsewhere. Class members cannot have their cake
and eat it too. If they want the benefits and protection of the Court, whether for purposes of
making a claim and receiving settlement proceeds or protection against assertion of the class
orders and judgments against them, they must accept that they will have established sufficient
minimum contacts to subject them to the personal jurisdiction of this Court for all matters arising
out of this case, which may very well have an impact on what they can and cannot claim both in
litigation and in other proceedings in foreign jurisdictions.
This is not an attempt by the PwC Defendants to expand their rights, but simply to
prevent class members from simultaneously acknowledging that this Court that it has jurisdiction
over their claims on the one hand while denying it on the other. There is no such thing as
“cafeteria” jurisdiction, where a litigant gets to pick and choose among related matters to be
heard by the court. Class members may not participate in or affirmatively exclude themselves

8

from the proposed settlement and also be heard to argue positions that they either never had or
have waived, including, but not limited to, that this proceeding is insufficient to address their
claims or protect their rights, that they are not bound by the order the Court may have issued or
may issue concerning matters beyond the scope of the settlement (e.g., that they have claims that
have been dismissed, or may in the future be dismissed, by this Court), and that they are not
bound by future class certification orders or judgments of this Court.
This is not a hypothetical concern. Members of the proposed settlement class (and
proposed litigation class) are suing the PwC Defendants in the Netherlands right now. (See Ex.
A) PwC Canada has argued that the pendency of this action, and especially any participation
therein by the Colima Litigation plaintiffs, bars or at least recommends dismissal of their claims
in the Netherlands. (See Ex. B) If this Court enters an order asserting jurisdiction over these
plaintiffs, and making it clear that if they participate in the case they are, in fact, subject to this
Court’s jurisdiction for all related matters, the PwC Defendants will be able to argue to the Dutch
court, for example, that these plaintiffs are improperly pursuing the same claims in two different
fora at the same time and that they have acknowledged the adequacy of New York as an
appropriate forum in which to bring their claims. If, however, the Court enters an order than
purports to limit its jurisdiction over these plaintiffs, these class members will be able to argue –
and may well appear to the Dutch court – that they are only participating in this case for purposes
of the proposed settlement and should be free to pursue their related claims against the PwC
Defendants in the Netherlands. This would deprive the PwC Defendants of their rights under
U.S. (and likely other jurisdictions’) law.7 See Bersch v. Drexel Firestone, Inc., 519 F.2d 974,

7

This objection is not, as was argued by plaintiffs at the preliminary approval hearing (Tr. at 23-24), inconsistent
with the PwC Defendants’ position that the Court should not certify a litigation class in this case. The PwC
Defendants maintain that certification of the proposed litigation class would be inappropriate because, among other
reasons, the Court does not have jurisdiction over the vast majority of foreign class members and cannot conclude

9

996 (2d Cir. 1975), abrogated on other grounds by Morrison v. National Australia Bank Ltd.,
130 S.Ct. 2869 (2010) (“If defendants prevail against a class they are entitled to a victory no less
broad than a defeat would have been.”).
III.

The Court Should Allow the PwC Defendants Access to all Available Information
Regarding Settlement Class Members.8
Regardless of whether the Court sustains the PwC Defendants’ objection to a provision

that purports to limit the scope of the Court’s jurisdiction over Settlement Class Members, it
cannot be disputed that the PwC Defendants will be entitled to assert both the provisions of any
final approval order and the receipt of settlement proceeds as may be necessary to bar, limit, or
off-set other claims made by Settlement Class Members. In order to do so, however, the PwC
Defendants must be able to determine whether their adversaries in other proceedings are class
members, have made claims, have been paid under the proposed Settlement, or opted out of the
proposed Settlement. This is basic information to which all litigants in the case are obviously
entitled in order to protect themselves against barred claims, double recoveries, or the assertion
of inconsistent positions in different proceedings. Paragraph 21, however, of the Preliminary
Approval Order – and any similar provision that may be included in the final approval order –
would unfairly and improperly prevent the PwC Defendants from gaining access to this
information.9

that its judgments are likely to be enforced against class members in most (but not all – the Netherlands possibly
being one of the exceptions) of the relevant foreign jurisdictions. The PwC Defendants’ objections to the proposed
settlement are premised on the assumption that the Court’s approves the proposed Settlement Class (or litigation
class), notwithstanding these arguments. The PwC Defendants are entitled to argue that if the Court,
notwithstanding the PwC Defendants’ class certification arguments, concludes it has jurisdiction over the class, it
cannot restrict that jurisdiction to allow class members to avoid the effects of submitting to the Court’s personal
jurisdiction.
8

GlobeOp joins the PwC Defendants’ objection to the provision of confidential status to Requests for Exclusion or
Proofs of Claim in the Final Approval Order.
9

Claim information is not only important for the purpose of protecting the PwC Defendants’ rights vis-à-vis
Settlement Class Members in other proceedings; it is also directly relevant to the claims pending against the PwC

10

Only two justifications have been offered to date for restricting access to this information.
Neither has merit. First is the suggestion that record owners may be required to treat the
beneficial owners’ information as confidential. Record owners, however, are perfectly capable
of securing the permission of the beneficial owners to make available whatever information the
Court requires to make a claim at the same time they seek instructions with regard to the
Settlement, so any such technical restrictions can easily be addressed. And, more broadly,
claimants can be afforded the protections of the Confidentiality Order already in place in the case
(or some equivalent order) to protect against the dissemination of their information beyond the
scope mandated by the settlement and claims process as it concerns the PwC Defendants or
others who may seek access to the information.
The second justification is that without the ability to act anonymously for purposes of the
proposed Settlement, class members may choose not to participate, thus undermining the
proposed Settlement. This is, of course, speculation, and even if it turns out to be well-founded
speculation, would not justify keeping this information secret from the PwC Defendants. No
doubt the concern is the same that admittedly motivated the Settling Parties to ask the Court to
limit its jurisdiction over Settlement Class Members – a fear that claimants will be subjected to
claims by the SIPC Trustee, the Fairfield Sentry Liquidator, or others – presumably including
judgment creditors, the IRS, or others. The fact that a plaintiff class member may be subject to a
claim by a third party is no justification for hiding his or her identity and other relevant

Defendants in this case. As Plaintiffs’ counsel explained to the Court, in many cases, the members of the proposed
Settlement Class are beneficial, but not record, owners of investments in the Fairfield Greenwich funds. (Tr. at 1617) Indeed, it is very difficult, if not impossible, to determine the identities of members of the purported class by
examining the financial records produced in discovery by various parties. This makes it quite difficult to determine
the existence and amount of potential individual claims, and thus also the aggregate value of such claims. This is
particularly true with regard to the PwC Defendants given the limited time frames of their respective audit work
with regard to the funds and the restrictions on claims for initial, as opposed to subsequent, investments already
imposed by the Court.

11

information about his or her claim from a defendant in litigation against whom he or she also
seeks to recover.

At best, concealing this information hampers the litigation; at worst, it

encourages attempts by class members to achieve double recoveries and avoid potentially
legitimate claims against their assets under applicable U.S. law.
CONCLUSION
The PwC Defendants (and GlobeOp to the extent noted above) respectfully request that
any Order issued by the Court approving the Proposed Settlement not contain provisions similar
to Paragraphs 17 or 21 of its Preliminary Approval Order.

/s/ Timothy A. Duffy ________

Dated: February 15, 2013

Andrew M. Genser
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, New York 10022
Telephone: [phone]
Emily Nicklin, P.C.
Timothy A. Duffy, P.C.
KIRKLAND & ELLIS LLP
300 North LaSalle
Chicago, Illinois 60654
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendant
PricewaterhouseCoopers LLP

/s/ William R. Maguire_______
William R. Maguire
Sarah L. Cave
Gabrielle S. Marshall

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HUGHES HUBBARD & REED LLP
One Battery Park Plaza
New York, New York 10004
[phone]
Attorneys for PricewaterhouseCoopers
Accountants N.V.

/s/ David H. McGill____________
David H. McGill
KOBRE & KIM
800 Third Avenue
New York, New York 10022
[phone]
Attorneys for GlobeOp Financial Services
LLC

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CERTIFICATE OF SERVICE
I, Timothy A. Duffy, hereby certify that I electronically filed the foregoing by using the
CM/ECF system, which generated notices to the following:
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Michael Jules Aguirre
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Robert James Anello
[e-mail]
Allan J. Arffa
[e-mail]
Bruce Allen Baird
[e-mail],[e-mail]
Jeffrey Edward Baldwin
[e-mail]
David A. Barrett
[e-mail],[e-mail],[e-mail]
Demet Basar
[e-mail]
Timothy D. Battin
[e-mail]
Daniel R. Benson
[e-mail],[e-mail]
Patrick Barrett Berarducci
s&[e-mail],[e-mail]
Sashi Bach Boruchow
[e-mail],[e-mail],[e-mail],emaults
[e-mail],[e-mail],[e-mail]
Richard E. Brodsky
[e-mail]
Kent Andrew Bronson
[e-mail]
Lewis Nathan Brown
[e-mail]
Gustavo Fabian Bruckner
[e-mail]
Allison Caffarone
[e-mail],s&[e-mail]
Helen Virginia Cantwell
[e-mail],[e-mail]
Sarah Loomis Cave
[e-mail]
Matthew W. Cheney
[e-mail]
Michael Joseph Chepiga
[e-mail],[e-mail]

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Joshua Daniel Clark
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Joseph Clay Coates , III
[e-mail]
Jonathan David Cogan
[e-mail]
Amy E. Crawford
[e-mail]
Mark Geoffrey Cunha
[e-mail],[e-mail]
Laurence Edward Curran , III
[e-mail]
Paul Edouard Dans
[e-mail]
Adam S. Deckinger
[e-mail]
Joshua Seth Devore
[e-mail],[e-mail]
Timothy A. Duffy
[e-mail],[e-mail]
Matthew Fitzgerald Dunn
[e-mail]
EFG Capital International Corp.
[e-mail]
Lawrence P. Eagel
[e-mail]
Leslie Gordon Fagen
[e-mail]
Dyanne Eyce Feinberg
[e-mail],[e-mail]
Daniel J. Fetterman
[e-mail],[e-mail]
Robert Craig Finkel
[e-mail],[e-mail],[e-mail],TSH
[e-mail]
Paige Elizabeth Fleming
[e-mail]
David Alan Gehn
[e-mail]
Andrew M. Genser
[e-mail],[e-mail]
Eli Justin Glasser
[e-mail]
Ricardo Alejandro Gonzalez
[e-mail],[e-mail],[e-mail]

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Mark P. Goodman
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Andrew Garry Gordon
[e-mail]
Brian Dale Graifman
[e-mail]
Adam K. Grant
[e-mail],[e-mail]
James Abram Harrod , III
[e-mail],[e-mail],[e-mail]
David Scott Hoffner
[e-mail],[e-mail]
Fraser Lee Hunter , Jr
[e-mail]
Elizabeth A. Izquierdo
[e-mail],[e-mail],[e-mail],bsim
[e-mail],[e-mail],[e-mail],jgarcia@bhlawpa.c
om,[e-mail],[e-mail],[e-mail],ddorn@bhlaw
pa.com,[e-mail],[e-mail]
Jon Andrew Jacobson
[e-mail]
Gaytri D. Kachroo
[e-mail],[e-mail],[e-mail]
Brad Scott Karp
[e-mail]
Marc E. Kasowitz
[e-mail],[e-mail]
Peter Eric Kazanoff
[e-mail],[e-mail]
Michael Sangyun Kim
[e-mail]
Stephanie Elizabeth Kirwan
[e-mail]
Brad Eric Konstandt
[e-mail]
Daniel W. Krasner
[e-mail]
Jennie Boehm Krasner
[e-mail]
Jody Krisiloff
[e-mail]
Glenn Kurtz
[e-mail],[e-mail],[e-mail],jgreen@whit
ecase.com
Eliot Lauer
[e-mail],[e-mail],[e-mail]

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Andrew J. Levander
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Brandon R. Levitt
[e-mail]
Christopher Lovell
[e-mail],[e-mail]
Natalie Marie MacKiel
[e-mail]
Joel Steven Magolnick
[e-mail]
William R. Maguire
[e-mail]
Gabrielle Sean Marshall
[e-mail]
Timothy Neil McCabe
[e-mail]
David Harrison McGill
[e-mail]
Diane Lee McGimsey
[e-mail],s&[e-mail]
Kristi Stahnke McGregor
[e-mail]
Amanda Mcgovern
[e-mail]
Jorge Alejandro Mestre
[e-mail],[e-mail],[e-mail],evonder
[e-mail],[e-mail],[e-mail],ar
[e-mail],[e-mail]
Philip A. Mirrer-Singer
[e-mail]
David J. Molton
[e-mail],[e-mail],acondon@brownrudnic
k.com,[e-mail],[e-mail],ebowers@brownrudnic
k.com,[e-mail]
Michael Joseph Moscato
[e-mail],[e-mail]
Terence Michael Mullen
[e-mail]
Sharon L. Nelles
[e-mail],s&[e-mail]
Gregory Mark Nespole
[e-mail]
Joseph Emanuel Neuhaus
[e-mail],s&[e-mail]

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Emily Nicklin
[e-mail]
William M. O'Connor
[e-mail]
Jonathan Edgar Pollard
[e-mail]
John H. Ray , III
[e-mail]
Sara Ann Ricciardi
[e-mail]
Jeffrey Lawrence Roether
[e-mail]
Brenton Rogers
[e-mail]
Claudio Godinez RoumainOchoa
[e-mail]
Bradley H. Samuels
[e-mail]
Robert S. Schachter
[e-mail],[e-mail],[e-mail],[e-mail]
Mark Jackson Schirmer
[e-mail],[e-mail]
Howard M. Shapiro
[e-mail]
Martin S. Siegel
[e-mail],[e-mail]
Stuart Harold Singer
[e-mail],[e-mail],[e-mail],[e-mail]
Paul Jacob Sirkis
[e-mail]
Bradley Paul Smith
[e-mail],s&[e-mail]
Louis Smith
[e-mail],[e-mail]
Hillary Sobel
[e-mail]
Patrick James Somers
[e-mail]
Daniel Stephen Sommers
[e-mail]
Richard A Speirs
[e-mail]
Edward M. Spiro
[e-mail]
Victor E. Stewart
[e-mail]

5

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Carl Lester Stine
[e-mail]
David S. Stone
[e-mail],[e-mail],aalberts@stonemagnalaw
.com
Anisley Tarragona
[e-mail]
Steven Jeffrey Toll
[e-mail],[e-mail]
Catherine A. Torell
[e-mail]
Annette Urena
[e-mail]
Howard L. Vickery , II
[e-mail],[e-mail],[e-mail]
Chet Barry Waldman
[e-mail]
Robert Alan Wallner
[e-mail]
Stephen Lee Weinstein
[e-mail]
Lauren Whetstone
[e-mail]
Catherine Whitfield
[e-mail]
Kenneth A. Zitter
[e-mail]
Jeffrey Charles Zwerling
[e-mail]
_/s/ Timothy A. Duffy

6