In re Herald, Primeo and Thema Funds Securities Litigation

Filing 278

DECLARATION of Timothy J. Burke in Opposition re: #234 MOTION to Approve Approval of Partial Settlement.. Document filed by Repex Ventures S.A. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4)(Burke, Timothy)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

______________________________________
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In re HERALD, PRIMEO and THEMA FUND )
SECURITIES LITIGATION,
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______________________________________ )
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This Document Relates To:
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NEVILLE SEYMOUR DAVIS,
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Plaintiff,
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vs.
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ALBERTO BENBASSAT et al.,
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Defendants.
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______________________________________ )

Civil Action No. 09 CIV 289 (RMB)(HBP)
(Consolidated with 09 CIV 2032 and
09 CIV 2558)
ECF Case
Class Action

Case No. 09 Civ. 2558 (RMB)
Class Action

DECLARATION OF TIMOTHY J. BURKE IN SUPPORT OF LEAD PLAINTIFF
REPEX VENTURES, S.A.’s OPPOSITION TO LEAD PLAINTIFF
NEVILLE SEYMOUR DAVIS’S MOTION FOR PRELIMINARY APPROVAL OF
PARTIAL SETTLEMENT

I, Timothy J. Burke, hereby declare:
1.

I am an attorney at the law firm of Stull, Stull & Brody who is Lead Counsel for

Plaintiff Repex Ventures S.A. (“Repex Ventures”) in the above entitled action. I submit this
Declaration in support of Lead Plaintiffs’ Repex Ventures, S.A.’s Opposition to Lead Plaintiff
Neville Seymour Davis’s Motion for Preliminary Approval of Partial Settlement. I have
personal knowledge of the matters stated herein, and if called as a witness, I could and would
competently testify thereto.
2.

Attached hereto as Exhibit 1 is a true and correct copy of the June 21, 2011 Email

from Timothy J. Burke to Albert C. Chang.
3.

Attached hereto as Exhibit 2 is a true and correct copy of the June 21, 2011 Email

from Timothy J. Burke to Albert C. Chang and Evan A. Davis.
4.

Attached hereto as Exhibit 3 is a true and correct copy of the June 22, 2011 Email

from Timothy J. Burke to Albert C. Chang, Frank A. Bottini and Evan A. Davis.
5.

Attached hereto as Exhibit 4 is a true and correct copy of the June 22, 2011 Email

from Frank A. Bottini and June 24, 2011 from Evan A. Davis
I declare under penalty of perjury under the laws of the United States of America and the
State of California that the foregoing is true and correct.
Executed this 30th day of June 2011, at Los Angeles, California

/s/ Timothy J. Burke
Timothy J. Burke

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