Anwar et al v. Fairfield Greenwich Limited et al

Filing 1533

SETTLEMENT AGREEMENT with PwC Defendants. Document filed by Harel Insurance Company, Ltd., Pacific West Health Medical Center, Inc. Employee's Retirement Trust, Securities & Investment Company Bahrain, St. Stephen's School. (Attachments: #1 Exhibit A, #2 Exhibit A-1, #3 Exhibit A-2, #4 Exhibit A-3, #5 Exhibit B)(Barrett, David)

EXHIBIT A-2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
PASHA ANWAR, et al.,
Plaintiffs,
v.

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

FAIRFIELD GREENWICH LIMITED,
et al.,
Defendants.
SUMMARY NOTICE
TO: All beneficial owners of shares or limited partnership interests in Fairfield
Sentry Limited, Fairfield Sigma Limited, Fairfield Lambda Limited,
Greenwich Sentry, L.P. and Greenwich Sentry Partners, L.P. (collectively,
the “Funds”) as of December 10, 2008 (whether as holders of record or
traceable to a shareholder or limited partner account of record) (“Beneficial
Owners”), who suffered a Net Loss of principal invested in the Funds
(collectively, the “Settlement Class”). If you meet the above class
definition, you could get a payment from a class action settlement.
A federal court authorized this Notice. This is not a solicitation from a lawyer.
YOU ARE HEREBY NOTIFIED, pursuant to an Order of the United States
District Court for the Southern District of New York, that a hearing will be held on
_________________, 2016, at ______.m., before The Honorable Victor Marrero, at
the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York,
New York (the “Court”), for the purpose of determining (1) whether the proposed
settlement of claims against the PwC Defendants (PwC Canada, PwC Netherlands,

and PwC International) in the above-captioned Action for consideration of the sum of
$55,000,000 in cash, should be approved by the Court as fair, reasonable and
adequate; (2) whether this Action should be dismissed with prejudice as to the PwC
Defendants pursuant to the terms and conditions set forth in the Stipulation dated as of
January ____, 2016; (3) whether the proposed plan to distribute the settlement
proceeds (the “Plan of Allocation”) is fair, reasonable and adequate and therefore
should be approved; and (4) whether the application of Plaintiffs’ Lead Counsel for
the payment of attorneys’ fees and expenses incurred in connection with this Action
should be approved.
If you were a Beneficial Owner of shares or limited partnership interests in one
or more of the Funds as of December 10, 2008 and suffered a Net Loss in principal on
your investment in those shares or limited partnership interests, your rights may be
affected by this Settlement, including the release and extinguishment of claims you
may possess relating to your ownership interest in the Funds. Net Loss means the
total cash investment made by a Beneficial Owner in a Fund, directly or indirectly
through one or more intermediaries, less the total amount of any redemptions or
withdrawals or recoveries from any source by that Beneficial Owner from or with
respect to the same Fund.

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If you are a member of the Settlement Class, in order to share in the distribution
of the Net Settlement Fund, you must submit a Proof of Claim and Release form that
is received no later than _______, 2016, establishing that you are entitled to recovery.
If you desire to be excluded from the Settlement Class, you must submit a
request for exclusion that is received by _____________, 2016. Any objection to any
aspect of the Settlement must be filed with the Court no later than ___________,
2016.
If you wish to receive a detailed Notice concerning the terms of the Settlement
or the Proof of Claim and Release form, you may obtain copies by writing to Rust
Consulting, Inc., P.O. Box 2874, Faribault, MN 55021-8674, or by visiting:
[e-mail]
www.FairfieldGreenwichLitigation.com
DO NOT TELEPHONE THE COURT, THE CLERK’S OFFICE OR ANY OF
THE DEFENDANTS OR COUNSEL FOR THE DEFENDANTS REGARDING
THIS NOTICE.
DATED: _________, 2016

BY ORDER OF THE COURT
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

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