Anwar et al v. Fairfield Greenwich Limited et al

Filing 135

DECLARATION of James A. Harrod in Support re: (133 in 1:09-cv-00118-VM-THK, 133 in 1:09-cv-00118-VM-THK, 28 in 1:09-cv-02269-VM, 28 in 1:09-cv-02269-VM) MOTION to Appoint Securities & Investment Company Bahrain, Harel Insurance Company Ltd., AXA Private Management, St. Stephens School, and Pacific West Health Medical Inc., Employees Retirement Trust to serve as lead plaintiff(s). MOTION to Appoint Counsel. MOTION to Appoint Securities & Investment Company Bahrain, Harel Insurance Company Ltd., AXA Private Management, St. Stephens School, and Pacific West Health Medical Inc., Employees Retirement Trust to serve as lead plaintiff(s). MOTION to Appoint Securities & Investment Company Bahrain, Harel Insurance Company Ltd., AXA Private Management, St. Stephens School, and Pacific West Health Medical Inc., Employees Retirement Trust to serve as lead plaintiff(s).. Document filed by AXA Private Management, St. Stephen's School, Pacific West Health Medical Center Inc. Employees Retirement Trust(On behalf of Itself), Harel Investment and Financial Services Ltd.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)Filed In Associated Cases: 1:09-cv-00118-VM-THK, 1:09-cv-02269-VM(Harrod, James)

Anwar et al v. Fairfield Greenwich Limited et al

Doc. 135

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ANWAR, et al., Plaintiffs, -againstFAIRFIELD GREENWICH LIMITED, et al., Defendants. This Document Relates To: The Knight Services Holdings Limited et al v. Fairfield Sentry Limited et al, 1:09-cv-02269 (VM) Master File No. 09-cv-118 (VM)

Dated: May 11, 2009

DECLARATION OF JAMES A. HARROD IN SUPPORT OF MOTION OF THE ANWAR PLAINTIFFS FOR APPOINTMENTAS LEAD PLAINTIFFS AND FOR APPROVAL OF THEIR SELECTION OF LEAD COUNSEL

David Boies BOIES, SCHILLER & FLEXNER LLP 333 Main Street Armonk, NY 10504 Telephone: [phone] David A. Barrett BOIES, SCHILLER & FLEXNER LLP 575 Lexington Avenue New York, NY 10022 Telephone: [phone] Stuart H. Singer Sashi Bach Boruchow BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, #1200 Ft. Lauderdale, Florida 33301 Telephone: [phone]

Robert C. Finkel Carl L. Stine James A. Harrod E. Elizabeth Robinson WOLF POPPER LLP 845 Third Avenue New York, NY 10022 Telephone: [phone] Christopher Lovell Victor E. Stewart LOVELL STEWART HALEBIAN LLP 61 Broadway New York, NY 10006 Telephone: [phone] Interim Co-Lead Counsel for Plaintiffs And Co-Counsel for Anwar Plaintiffs

Dockets.Justia.com

I, James A. Harrod, declare as follows: 1. I am a member of the law firm of Wolf Popper LLP, counsel for the Anwar

Plaintiffs in the above-captioned action. I submit this Declaration in support of the motion of the Anwar Plaintiffs ("Movants") to be appointed as Lead Plaintiffs, and for approval of Lead Plaintiffs' selection of Lead Counsel. 2. Attached as Exhibit 1 are true and correct copies of the signed Certification of

Najla Al Shirawi, on behalf of Securities & Investment Company Bahrain, including Securities & Investment Company Bahrain's trading in Fairfield Sentry Limited ("Fairfield Sentry"), pursuant to the Private Securities Litigation Reform Act of 1995 ("PSLRA"), 15 U.S.C. § 78u4(a)(2), during the period March 11, 2004 through December 11, 2009, inclusive (the "Class Period"). 3. Attached as Exhibit 2 is a true and correct copy of the signed Certification of

Hanan Friedman, on behalf of Harel Insurance Company Ltd., including Harel Insurance Company Ltd.'s trading in Fairfield Sentry, pursuant to the PSLRA during the Class Period. 4. Attached as Exhibit 3 is a true and correct copy of the signed Certification of

Duncan Pollock, on behalf of St. Stephen's School, including St. Stephen's School's trading in Fairfield Sigma Limited, pursuant to the PSLRA during the Class Period. 5. Attached as Exhibit 4 is a true and correct copy of the signed Certification of Dr.

Laurence Wiener, on behalf of Pacific West Health Medical Center, Inc. Employees' Retirement Trust, including Pacific West Health Medical Center, Inc. Employees' Retirement Trust's trading in Fairfield Sentry, pursuant to the PSLRA during the Class Period.

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6.

Attached as Exhibit 5 is a true and correct copy of the initial notice to class

members that was published on March 11, 2009, on Business Wire, advising the public of the pendency of a class action filed on behalf of investors in Fairfield Sentry. 7. Attached as Exhibit 6 is a true and correct copy of a chart of Movants'

transactions in Fairfield Sentry and Fairfield Sigma and their aggregate investments on purchases made during the Class Period. I hereby declare under penalty of perjury under the laws of the United States and the laws of the State of New York that the foregoing is true and correct to the best of my knowledge, information, and belief. Executed on May 11, 2009, at New York, New York.

_____s/ James A. Harrod____ James A. Harrod

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