Anwar et al v. Fairfield Greenwich Limited et al

Filing 127

MOTION to Appoint Fairfield Investor Group to serve as lead plaintiff(s)., MOTION to Appoint Counsel. Document filed by Fairfield Investor Group.(Torell, Catherine)

Anwar et al v. Fairfield Greenwich Limited et al

Doc. 127

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ANWAR, et al., Plaintiffs, v. FAIRFIELD GREENWICH LIMITED, et al., Defendants. MOTION OF THE FAIRFIELD INVESTOR GROUP FOR APPOINTMENT AS LEAD PLAINTIFF AND APPOINTMENT OF LEAD COUNSEL TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD PLEASE TAKE NOTICE THAT Madanes Investment & Enterprise Ltd., Carling Investment Ltd., Shimon Laor, and Arie and Dafna Gruber (collectively, the "Fairfield Investor Group" or "Movant") respectfully move this Court, pursuant to Section 21D(a)(3)(B) of the Securities and Exchange Act of 1934 (the "Exchange Act"), as amended by the Private Securities Litigation Reform Act of 1995 (the "PSLRA"), 15 U.S.C. § 78u-4(a)(3)(B), for entry of an Order appointing Movant as Lead Plaintiff on behalf of itself and all others similarly situated who, between March 11, 2004 and December 10, 2008, inclusive (the "Class Period"), acquired shares of Fairfield Sentry Limited and incurred damages as a result of the Defendants' violations of the federal securities laws; and appointing the law firm of Cohen Milstein Sellers & Toll PLLC ("Cohen Milstein") to serve as Lead Counsel. This motion is supported by the accompanying Memorandum of Law, the Declaration of Catherine A. Torell and the exhibits annexed thereto, all of the prior pleadings and proceedings herein, and such other written or oral argument as may be permitted by the Court. WHEREFORE, Movant respectfully requests that the Court: (i) appoint Movant as Lead Plaintiff pursuant to Section 21D(a)(3)(B) of the Exchange Act; (ii) appoint Cohen Milstein as Lead Counsel for the class; and (iii) grant such other and further relief as the Court may deem just and proper. Master File No. 09-CV-118-VM This Document Relates To: 09-CV-2269-VM (Knight Action)

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Dated: New York, New York May 11, 2009

Respectfully submitted, COHEN MILSTEIN SELLERS & TOLL PLLC

By:

/s/ Catherine A. Torell Catherine A. Torell (CAT-0905) 150 East 52nd Street, 30th Floor New York, New York 10022 Tel.: [phone] Fax: [phone] -andSteven J. Toll Daniel S. Sommers S. Douglas Bunch 1100 New York Avenue, N.W. Suite 500, West Tower Washington, D.C. 20005 Tel.: [phone] Fax: [phone]

Proposed Lead Counsel for Movant Of Counsel: Jacob Sabo, Esq. The Tower # 3 Daniel Frisch St. Tel Aviv Israel Tel: [phone] Fax: [phone]

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