Anwar et al v. Fairfield Greenwich Limited et al

Filing 1183

MOTION for Settlement Preliminary Approval, Preliminary Certification of the Class for Purposes of Settlement, Approval of Notice to the Class, and Scheduling of a Settlement Hearing. Document filed by Pacific West Health Medical Center, Inc. Employee's Retirement Trust. Return Date set for 9/23/2013 at 10:00 AM.(Finkel, Robert)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

PASHA S. ANWAR, et al.,
Plaintiffs,
v.
FAIRFIELD GREENWICH LIMITED, et al.,

Master File No. 09-cv-118 (VM)

Defendants.
This Document Relates To: 09-cv-118 (VM)

NOTICE OF MOTION FOR (I) PRELIMINARY APPROVAL OF THE PARTIAL
GLOBEOP CLASS ACTION SETTLEMENT, (II) PRELIMINARY CERTIFICATION
OF THE CLASS FOR PURPOSES OF SETTLEMENT, (III) APPROVAL OF
NOTICE TO THE CLASS, AND (IV) SCHEDULING OF A SETTLEMENT HEARING
PLEASE TAKE NOTICE that the Representatative Plaintiffs,1 on their own behalf and on
behalf of the GlobeOp Settlement Class, through counsel, hereby move this Court before the
Honorable Victor Marrero, for an order pursuant to Rule 23 of the Federal Rules of Civil Procedure:
preliminarily approving the proposed partial class action settlement; preliminarily certifying the
GlobeOp Settlement Class for settlement purposes only; approving the proposed forms of the
Notice of Proposed Partial Settlement of Class Action and Settlement Fairness Hearing and Motion
for Attorneys’ Fees and Reimbursement of Expenses, and the Summary Notice of Proposed Partial
Settlement; approving the proposed methods of disseminating notice; approving Rust Consulting as

1

All capitalized terms not otherwise defined herein have the same meanings as set forth in the Stipulation of
Settlement dated as of August 27, 2013 (the “Stipulation”), filed herewith.

Claims Administrator; setting a date for the Settlement Hearing; and such other and further relief as
the Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that in support of this motion, Representatative
Plaintiffs submit herewith: Plaintiffs’ Memorandum of Law in Support of their Motion for (i)
Preliminary Approval of Partial GlobeOp Settlement, (ii) Preliminary Certification of the Class for
Purposes of Settlement, (iii) Approval of Notice to the Class, and (iv) Scheduling of a Settlement
Hearing; and the accompanying Stipulation of Settlement dated as of August 27, 2013, with exhibits
appended thereto, including the Proposed Order Preliminarily Approving Settlement and Providing
for Notice of Proposed Settlement.
Dated: August 29, 2013

Respectfully submitted,
By:/s/ Robert C. Finkel
Robert C. Finkel

David A. Barrett
Howard L. Vickery, II
BOIES, SCHILLER & FLEXNER LLP
575 Lexington Avenue
New York, NY 10022
[phone]

Robert C. Finkel
James A. Harrod
WOLF POPPER LLP
845 Third Avenue
New York, NY 10022
[phone]

Stuart H. Singer
Carlos Sires
Sashi Bach Boruchow
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., #1200
Ft. Lauderdale, Florida 33301
[phone]

Christopher Lovell
Victor E. Stewart
LOVELL STEWART HALEBIAN
JACOBSON LLP
61 Broadway, Suite 501
New York, NY 10006
[phone]

Co-Lead Counsel for Plaintiffs and
Counsel for PSLRA Plaintiffs in the Action

174893-1

CERTIFICATE OF SERVICE
I hereby certify that on August 29, 2013, I caused true and correct copies of the
foregoing to be served by ECF on all parties registered with the Court's ECF system under
docket number 09-CV-118 (VM).
/s/ Natalie M. Mackiel
Natalie M. Mackiel

174893-1