Anwar et al v. Fairfield Greenwich Limited et al

Filing 1566

REPLY AFFIDAVIT of JASON RABE in Support re: #1559 MOTION for Attorney Fees AND FOR FINAL APPROVAL OF PROPOSED PWC SETTLEMENT AND PLAN OF ALLOCATION AND AWARD OF ATTORNEYS FEES AND REIMBURSEMENT OF EXPENSES.. 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. (Barrett, David)

Download PDF
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK PASHA S. ANWAR, et al., Plaintiffs, Master File No. 09-cv-118 (VM) (FM) v. FAIRFIELD GREENWICH LIMITED, et al., Defendants. SUPPLEMENTAL AFFIDAVIT OF JASON RABE WITH RESPECT TO CLASS NOTICE AND ADMINISTRATION OF THE PWC SETTLEMENT STATE OF MINNESOTA COUNTY OF HENNEPIN ) ) ss: ) JASON RABE, being first duly sworn, deposes and says: 1. I submit this supplemental affidavit to provide the Court with updated information regarding, among other things, the mailing of the Notice of Proposed Settlement of Class Action and Settlement Fairness Hearing, and Motion for Attorneys’ Fees and Reimbursement of Expenses (the “PwC Notice”) and Proof of Claim and Release Form (the “PwC Proof of Claim”) (together, the “PwC Notice Packet”) and the receipt of requests for exclusion from the Settlement Class. I am a Program Manager for Rust Consulting, Inc. (“Rust”), the Courtappointed Claims Administrator. I am over 21 years of age and am not a party to this Action. I have personal knowledge of the facts set forth herein and, if called as a witness, could and would testify competently thereto. 2. On March 17, 2016, I executed my original affidavit (the “Initial Affidavit”) that was filed with the Court on March 18, 2016 [Dkt No. 1562], attesting, among other things, to the 1   mailing of the PwC Notice Packet and the publication of the Summary Notice once each in the international editions of The Wall Street Journal and the dissemination of the Summary Notice for worldwide distribution, including North America, over PR Newswire. 3. As more fully stated in my Initial Affidavit (at ¶10), as of March 16, 2016, Rust had mailed a total of 5,158 PwC Notice Packets to potential Class Members. Since my Initial Affidavit was executed, during the period from March 17, 2016 through April 21, 2016, inclusive, in response to correspondence or inquiries from potential Class Members, financial institutions, brokers, nominees or record owners, Rust has mailed an additional 24 PwC Notice Packets to potential Class Members. Accordingly, as of close of business April 21, 2016, we have mailed a total of 5,182 PwC Notice Packets to potential Class Members. 4. As stated in my Initial Affidavit (at ¶13), on January 22, 2016, Rust posted the PwC Notice, PwC Proof of Claim, and important Court documents including the Preliminary Approval Order, PwC Stipulation of Settlement and decisions and orders of the Court, on a website dedicated to the PwC Settlement and to the Anwar litigation ( From January 22, 2016 through April 21, 2016, the Website has had 6,828 total hits. 5. Rust operates a toll-free telephone hotline (1-855-263-3450), and a direct dial line for international callers (1-612-359-7949), with an Interactive Voice Response System (“IVR”) and live operators to assist potential Class Members with questions about the Settlement, as stated in my Initial Affidavit (at ¶14). From January 22, 2016, the date of initial mailing of the PwC Notice Packet, through April 21, 2016, Rust has received 182 calls on these lines, of which 120 callers requested and spoke with a live operator for assistance. 2  

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?