U.S. District Court California Northern District (San...

US District Court Civil Docket as of September 14, 2009Retrieved from the court on September 21, 2009

U.S. District CourtCalifornia Northern District (San Francisco)

CIVIL DOCKET FOR CASE #: 3:09-cv-01001-SI

Petzschke v. Century Aluminum Company et al Date Filed: 03/09/2009

Assigned to: Hon. Susan Illston Jury Demand: None

Member case: (View Member Case) Nature of Suit: 850 Securities/Commodities

Cause: 15:77 Securities Fraud Jurisdiction: Federal Question

Plaintiff

Eric Petzschke represented by Lionel Z. Glancy

Individually and on Behalf of All Others Glancy & Binkow LLP

Similarly Situated 1801 Avenue of The Stars

Suite 311

Los Angeles, CA 90067

310-201-9150

Fax: 310-201-9160

Email: [email protected]

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Michael M. Goldberg

Glancy & Binkow LLP

1801 Avenue of the Stars, Suite 311

Los Angeles, CA 90067

310/201-9150

Fax: (310) 201-9160


LEAD ATTORNEY


Plaintiff

Stuart Wexler represented by Betsy Carol Manifold

Lead plaintiff for the Security Act claims Wolf Haldenstein Adler Freeman & Herz

Symphony Towers

750 B Street Suite 2770

San Diego, CA 92101

619-239-4599



Francis M. Gregorek

Wolf Haldenstein Adler Freeman & Herz LLP

Symphony Towers

750 B Street

Suite 2770

San Diego, CA 92101

619-239-4599



Rachele R. Rickert

Wolf Haldenstein Adler Freeman & Herz LLP

Symphony Towers

750 B Street

Suite 2770

San Diego, CA 92101

619-239-4599

Fax: 619-234-4599



V.

Defendant

Century Aluminum Company represented by Bruce A. Ericson

Pillsbury Winthrop Shaw Pittman LLP

50 Fremont St.

Post Office Box 7880

San Francisco, CA 94120-7880

(415) 983-1000

Fax: (415) 983-1200


LEAD ATTORNEY


Defendant

Logan W. Kruger represented by Bruce A. Ericson

(See above for address)

LEAD ATTORNEY


Defendant

Michael A. Bless represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Steve Schneider represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

John C. Fontaine represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Jack E. Thompson represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Peter C. Jone represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

John P. O'Brien represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Willy R. Strothotte represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Jarl Berntzen represented by Bruce A. Ericson


LEAD ATTORNEY


Defendant

Credit Suisse Securities (USA) LLC represented by Robert P. Varian

Orrick Herrington & Sutcliffe LLP

405 Howard Street

San Francisco, CA 94105

415-773-5700

Fax: 415-773-5759


LEAD ATTORNEY


Defendant

Morgan Stanley & Co. Incorporated represented by Robert P. Varian


LEAD ATTORNEY


V.

Movant

Peter Abrams represented by Betsy Carol Manifold



Francis M. Gregorek



Rachele R. Rickert



Movant

Waterford Township General Employees represented by Christopher Paul Seefer

Retirement System Coughlin Stoia Geller Rudman & Robbins LLP

100 Pine Street, Suite 2600

San Francisco, CA 94111

415-288-4545

Fax: 415-288-4534



Darren Jay Robbins

Coughlin Stoia Geller Rudman & Robbins LLP

655 West Broadway

Suite 1900

San Diego, CA 92101

619-231-1058

Fax: 619-231-7423



Erik David Peterson

Coughlin Stoia Geller Rudman & Robbins

655 West Broadway

Suite 1900

San Diego, CA 92101

619-231-1058



Date Filed # Docket Text

03/09/2009 1 COMPLAINT (summons issued); against all defendants( Filing fee $ 350, receipt number

34611029737.). Filed byEric Petzschke. (ys, COURT STAFF) (Filed on 3/9/2009) (Additional

attachment(s) added on 3/25/2009: # 1 Civil Cover Sheet) (ys, COURT STAFF). (Entered:

03/10/2009)

03/09/2009 2 Certification of Attorney Lionel Glancy pursuant to Northern District Civil Local Rule 3-7(d)

by Eric Petzschke. (ys, COURT STAFF) (Filed on 3/9/2009) (ys, COURT STAFF). (Entered:

03/10/2009)

03/09/2009 3 ADR SCHEDULING ORDER: Case Management Statement due by 6/5/2009. Case

Management Conference set for 6/12/2009 02:30 PM. (Attachments: # 1 standing orders

and cmc order)(ys, COURT STAFF) (Filed on 3/9/2009) (Entered: 03/10/2009)

03/09/2009 4 Summons Issued as to Peter C. Jone, John P. O'Brien, Willy R. Strothotte, Jarl Berntzen,

Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. Incorporated, Century Aluminum

Company, Logan W. Kruger, Michael A. Bless, Steve Schneider, John C. Fontaine, Jack E.

Thompson. (ys, COURT STAFF) (Filed on 3/9/2009) (Entered: 03/10/2009)

03/09/2009 CASE DESIGNATED for Electronic Filing. (ys, COURT STAFF) (Filed on 3/9/2009) (Entered:

03/10/2009)

03/25/2009 5 CLERKS NOTICE re: Failure to E-File documents #1 and #2 by plaintiff's counsel. (ys, COURT

STAFF) (Filed on 3/25/2009) (Entered: 03/25/2009)

04/01/2009 6 MOTION to Relate Case Motion for Administrative Relief to Consider Whether Cases Should

be Related Pursuant to L.R. 3-12 09-1103-PJH filed by Peter Abrams. (Manifold, Betsy) (Filed

on 4/1/2009) Modified on 4/2/2009 (ys, COURT STAFF). (Entered: 04/01/2009)

04/01/2009 7 Declaration of Betsy C. Manifold in Support of 6 MOTION to Relate Case Motion for

Administrative Relief to Consider Whether Cases Should be Related Pursuant to L.R. 3-12

filed byPeter Abrams. (Related document(s) 6) (Manifold, Betsy) (Filed on 4/1/2009)

(Entered: 04/01/2009)

04/01/2009 8 Proposed Order re 6 MOTION to Relate Case Motion for Administrative Relief to Consider

Whether Cases Should be Related Pursuant to L.R. 3-12 by Peter Abrams. (Manifold, Betsy)

(Filed on 4/1/2009) (Entered: 04/01/2009)

04/01/2009 9 CERTIFICATE OF SERVICE by Peter Abrams re 6 MOTION to Relate Case Motion for

Administrative Relief to Consider Whether Cases Should be Related Pursuant to L.R. 3-12, 7

Declaration in Support, 8 Proposed Order Declaration of Service (Manifold, Betsy) (Filed on

4/1/2009) (Entered: 04/01/2009)

04/03/2009 10 Certificate of Interested Entities by Peter C. Jone, John P. O'Brien, Willy R. Strothotte, Jarl

Berntzen, Century Aluminum Company, Logan W. Kruger, Michael A. Bless, Steve

Schneider, John C. Fontaine, Jack E. Thompson Pursuant to Fed. R. Civ. P. 7.1 and Civil L.R. 3-

12 (Ericson, Bruce) (Filed on 4/3/2009) (Entered: 04/03/2009)

04/03/2009 11 Response of Defendants to 6 Motion for Administrative Relief to Consider Whether Cases

Should be Related Pursuant to L.R. 3-12 filed byPeter C. Jone, John P. O'Brien, Willy R.

Strothotte, Jarl Berntzen, Century Aluminum Company, Logan W. Kruger, Michael A. Bless,

Steve Schneider, John C. Fontaine, Jack E. Thompson. (Ericson, Bruce) (Filed on 4/3/2009)

Modified on 4/6/2009 (ys, COURT STAFF). (Entered: 04/03/2009)

04/03/2009 12 CERTIFICATE OF SERVICE by Peter C. Jone, John P. O'Brien, Willy R. Strothotte, Jarl


Schneider, John C. Fontaine, Jack E. Thompson re 11 Response in Support, 10 Certificate of

Interested Entities, (Ericson, Bruce) (Filed on 4/3/2009) (Entered: 04/03/2009)

04/15/2009 13 ORDER RELATING CASE to 09-1103, 09-1162, 09-1205. Signed by Judge Illston on 4/8/09.

(ts, COURT STAFF) (Filed on 4/15/2009) Modified on 4/16/2009 (ys, COURT STAFF).

(Entered: 04/15/2009)

04/15/2009 14 CLERKS NOTICE Case Management Conference set for 7/10/2009 02:30 PM. (Attachments:

# 1 Standing Order) (ts, COURT STAFF) (Filed on 4/15/2009) (Entered: 04/15/2009)

05/08/2009 15 MOTION to Consolidate Cases Notice of Motion and Motion for Consolidation of Cases,

MOTION to Appoint Lead Plaintiff and Lead Counsel Notice of Motion and Motion for

Appointment of Stuart Wexler, Mark Panasuk, and Peter Abrams as Lead Plaintiffs Pursuant

to 15 U.S.C. § 77z-1 and Approval of Lead Plaintiffs' Choice of Counsel filed by Peter Abrams.

Motion Hearing set for 6/19/2009 09:00 AM in Courtroom 10, 19th Floor, San Francisco.

(Attachments: # 1 Proposed Order [Proposed] Order Consolidating Cases, Appointing Stuart

Wexler, Mark Panasuk, and Peter Abrams as Lead Plaintiffs Pursuant to 15 U.S.C. § 77z-1

And Approving Lead Plaintiffs' Choice of Counsel)(Rickert, Rachele) (Filed on 5/8/2009)

(Entered: 05/08/2009)

05/08/2009 16 Brief re 15 MOTION to Consolidate Cases Notice of Motion and Motion for Consolidation of

Cases MOTION to Appoint Lead Plaintiff and Lead Counsel Notice of Motion and Motion for

Appointment of Stuart Wexler, Mark Panasuk, and Peter Abrams as Lead Plaintiffs Pursuant

to 15 U.S.C. § 77z-1 and Approval of Lead Plaintiffs' Choice of Cou Memorandum of Points

and Authorities in Support of Motion for Consolidation of Cases, Appointment of Stuart

Wexler, Mark Panasuk, and Peter Abrams as Lead Plaintiffs Pursuant to 15 U.S.C. § 77z-1

and Approval of Lead Plaintiffs' Choice of Counsel filed byPeter Abrams. (Related

document(s)15 ) (Rickert, Rachele) (Filed on 5/8/2009) (Entered: 05/08/2009)

05/08/2009 17 Declaration of Rachele R. Rickert in Support of 15 MOTION to Consolidate Cases Notice of

Motion and Motion for Consolidation of Cases MOTION to Appoint Lead Plaintiff and Lead

Counsel Notice of Motion and Motion for Appointment of Stuart Wexler, Mark Panasuk,

and Peter Abrams as Lead Plaintiffs Pursuant to 15 U.S.C. § 77z-1 and Approval of Lead

Plaintiffs' Choice of Cou, 16 Brief,, filed byPeter Abrams. (Related document(s) 15, 16)

(Rickert, Rachele) (Filed on 5/8/2009) (Entered: 05/08/2009)

05/08/2009 18 CERTIFICATE OF SERVICE by Peter Abrams re 17 Declaration in Support,, 15 MOTION to

Consolidate Cases Notice of Motion and Motion for Consolidation of Cases MOTION to

Appoint Lead Plaintiff and Lead Counsel Notice of Motion and Motion for Appointment of

Stuart Wexler, Mark Panasuk, and Peter Abrams as Lead Plaintiffs Pursuant to 15 U.S.C. §

77z-1 and Approval of Lead Plaintiffs' Choice of Cou, 16 Brief,, Declaration of Service

(Rickert, Rachele) (Filed on 5/8/2009) (Entered: 05/08/2009)

05/08/2009 19 MOTION to Consolidate Cases, MOTION to Appoint Lead Plaintiff and Lead Counsel

;Memorandum of Points and Authorities in Support Thereof filed by Waterford Township

General Employees Retirement System. Motion Hearing set for 6/19/2009 09:00 AM in

Courtroom 10, 19th Floor, San Francisco. (Attachments: # 1 Proposed Order)(Peterson, Erik)

(Filed on 5/8/2009) (Entered: 05/08/2009)

05/08/2009 20 Declaration of Erik D. Peterson in Support of 19 MOTION to Consolidate Cases MOTION to

Appoint Lead Plaintiff and Lead Counsel ;Memorandum of Points and Authorities in Support

Thereof filed byWaterford Township General Employees Retirement System. (Attachments:

# 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Related document(s) 19 ) (Peterson,

Erik) (Filed on 5/8/2009) (Entered: 05/08/2009)

05/08/2009 21 Certificate of Interested Entities by Waterford Township General Employees Retirement

System Pursuant to Local Rule 3-7(d) (Peterson, Erik) (Filed on 5/8/2009) (Entered:

05/08/2009)


System Pursuant to Local Rule 3-7(d) (Robbins, Darren) (Filed on 5/8/2009) (Entered:

05/08/2009)


System Pursuant to Local Rule 3-7(d) (Seefer, Christopher) (Filed on 5/8/2009) (Entered:

05/08/2009)

05/11/2009 24 CERTIFICATE of Counsel re 18 Certificate of Service,, 17 Declaration in Support,, 15 MOTION

to Consolidate Cases Notice of Motion and Motion for Consolidation of Cases MOTION to



77z-1 and Approval of Lead Plaintiffs' Choice of Cou, 16 Brief,, Certification by Lawyer

Seeking to Serve as Class Counsel [Local Rule 3-7(d)] by Betsy Carol Manifold on behalf of

Peter Abrams (Attachments: # 1 Declaration of Service)(Manifold, Betsy) (Filed on

5/11/2009) (Entered: 05/11/2009)





77z-1 and Approval of Lead Plaintiffs' Choice of Cou, 16 Brief,, 24 Certificate of Counsel,,

Certification by Lawyer Seeking to Serve as Class Counsel [Local Rule 3-7(d)] by Rachele R.

Rickert on behalf of Peter Abrams (Attachments: # 1 Declaration of Service)(Rickert,

Rachele) (Filed on 5/11/2009) (Entered: 05/11/2009)





77z-1 and Approval of Lead Plaintiffs' Choice of Cou, 16 Brief,, 24 Certificate of Counsel,, 25

Certificate of Counsel,, Certification by Lawyer Seeking to Serve as Class Counsel [Local Rule

3-7(d)] by Francis M. Gregorek on behalf of Peter Abrams (Attachments: # 1 Declaration of

Service)(Gregorek, Francis) (Filed on 5/12/2009) (Entered: 05/12/2009)

05/15/2009 27 MOTION to Consolidate Cases DEFENDANTS' MOTION TO CONSOLIDATE RELATED CASES

filed by Peter C. Jone, John P. O'Brien, Willy R. Strothotte, Jarl Berntzen, Century Aluminum

Company, Logan W. Kruger, Michael A. Bless, Steve Schneider, John C. Fontaine, Jack E.

Thompson. Motion Hearing set for 6/19/2009 09:00 AM in Courtroom 10, 19th Floor, San

Francisco. (Ericson, Bruce) (Filed on 5/15/2009) (Entered: 05/15/2009)



Schneider, John C. Fontaine, Jack E. Thompson re 27 MOTION to Consolidate Cases

DEFENDANTS' MOTION TO CONSOLIDATE RELATED CASES (Ericson, Bruce) (Filed on

5/18/2009) (Entered: 05/18/2009)

05/18/2009 29 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME TO PLEAD AND

REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE by Peter C. Jone, John P.

O'Brien, Willy R. Strothotte, Jarl Berntzen, Century Aluminum Company, Logan W. Kruger,

Michael A. Bless, Steve Schneider, John C. Fontaine, Jack E. Thompson. (Ericson, Bruce)

(Filed on 5/18/2009) (Entered: 05/18/2009)



Schneider, John C. Fontaine, Jack E. Thompson re 29 Stipulation, and Proposed Order

Regarding Extension of Time To Plead and Request to Continue Case Management

Conference (Ericson, Bruce) (Filed on 5/19/2009) (Entered: 05/19/2009)

05/20/2009 31 ORDER granting request for extension; Case Management Conference set for 9/11/2009

02:30 PM.. Signed by Judge Illston on 5/19/09. (ts, COURT STAFF) (Filed on 5/20/2009)

(Entered: 05/20/2009)

05/29/2009 32 Memorandum in Opposition Proposed Lead Plaintiffs Stuart Wexler, Peter Abrams and

Marc Panasuk's Memorandum of Points and Authorities in: 1) Opposition to Waterford

Township General Employees Retirement System's Motion for Consolidation of Related

Actions, Appointment of Lead Plaintiff and for Approval of Selection of Lead Counsel; 2)

Opposition to Defendants' Motion to Consolidate Related Actions; and 3) Further Support of

Proposed Lead Plaintiffs' Motion for Consolidation and Appointment of Lead Plaintiff and

Lead Plaintiffs' Selection of Counsel filed byPeter Abrams. (Manifold, Betsy) (Filed on

5/29/2009) (Entered: 05/29/2009)

05/29/2009 33 Statement of Non-Opposition CENTURY DEFENDANTS RESPONSE TO MOTIONS TO

CONSOLIDATE CASES AND TO APPOINT LEAD PLAINTIFFS AND LEAD PLAINTIFFS COUNSEL

[Dkt. 15-21] filed byPeter C. Jone, John P. O'Brien, Willy R. Strothotte, Jarl Berntzen,

Century Aluminum Company, Logan W. Kruger, Michael A. Bless, Steve Schneider, John C.

Fontaine, Jack E. Thompson. (Ericson, Bruce) (Filed on 5/29/2009) (Entered: 05/29/2009)

05/29/2009 34 RESPONSE in Support re 19 MOTION to Consolidate Cases MOTION to Appoint Lead

Plaintiff and Lead Counsel ;Memorandum of Points and Authorities in Support Thereof filed

byWaterford Township General Employees Retirement System. (Seefer, Christopher) (Filed

on 5/29/2009) (Entered: 05/29/2009)

06/05/2009 35 Reply Memorandum Proposed Lead Plaintiffs Stuart Wexler, Peter Abrams and Marc

Panasuk's Reply in: 1) Opposition to Waterford Township General Employees Retirement

System's Motion for Consolidation of Related Actions, Appointment of Lead Plaintiff and for

Approval of Selection of Lead Counsel; 2) Opposition to Defendants' Motion to Consolidate

Related Actions; and 3) Further Support of Proposed Lead Plaintiffs' Motion for

Consolidation and Appointment of Lead Plaintiff and Lead Plaintiffs' Selection of Counsel

filed byPeter Abrams. (Manifold, Betsy) (Filed on 6/5/2009) (Entered: 06/05/2009)

06/05/2009 36 DECLARATION of Stuart Wexler Declaration of [Proposed] Lead Plaintiff Stuart Wexler in: 1)

Opposition to Waterford Township General Employees Retirement System's Motion for

Consolidation of Related Actions, Appointment of Lead Plaintiff and for Approval of

Selection of Lead Counsel; 2) Opposition to Defendants' Motion to Consolidate Related

Actions; and 3) Further Support of Proposed Lead Plaintiffs' Motion for Consolidation and

Appointment of Lead Plaintiff and Lead Plaintiffs' Selection of Counsel filed byPeter Abrams.

(Manifold, Betsy) (Filed on 6/5/2009) (Entered: 06/05/2009)

06/05/2009 37 DECLARATION of Peter Abrams Declaration of [Proposed] Lead Plaintiff Peter Abrams in: 1)

Opposition to Waterford Township General Employees Retirement System's Motion for

Consolidation of Related Actions, Appointment of Lead Plaintiff and for Approval of

Selection of Lead Counsel; 2) Opposition to Defendants' Motion to Consolidate Related

Actions; and 3) Further Support of Proposed Lead Plaintiffs' Motion for Consolidation and

Appointment of Lead Plaintiff and Lead Plaintiffs' Selection of Counsel filed byPeter Abrams.


06/05/2009 38 CERTIFICATE OF SERVICE by Peter Abrams re 35 Reply Memorandum,, 36 Declaration in

Opposition,, 37 Declaration in Opposition,, Declaration of Service (Manifold, Betsy) (Filed on

6/5/2009) (Entered: 06/05/2009)

06/05/2009 39 Reply Memorandum DEFENDANTS REPLY MEMORANDUM IN SUPPORT OF MOTION TO

CONSOLIDATE RELATEDACTIONS filed byPeter C. Jone, John P. O'Brien, Willy R. Strothotte,

Jarl Berntzen, Century Aluminum Company, Logan W. Kruger, Michael A. Bless, Steve

Schneider, John C. Fontaine, Jack E. Thompson. (Ericson, Bruce) (Filed on 6/5/2009)

(Entered: 06/05/2009)

06/05/2009 40 Reply Memorandum re 19 MOTION to Consolidate Cases MOTION to Appoint Lead Plaintiff

and Lead Counsel ;Memorandum of Points and Authorities in Support Thereof filed

byWaterford Township General Employees Retirement System. (Seefer, Christopher) (Filed

on 6/5/2009) (Entered: 06/05/2009)

06/24/2009 41 Minute Entry: Motion Hearing held on 6/19/2009 before Illston (Date Filed: 6/24/2009).

(Court Reporter B. Ball.) (ts, COURT STAFF) (Date Filed: 6/24/2009) (Entered: 06/24/2009)

06/25/2009 42 Transcript of Proceedings held on June 19, 2009, before Judge Susan Illston. Court

Reporter/Transcriber Belle Ball, CSR, RMR, CRR, Telephone number (415)373-2529,

[email protected]. Per General Order No. 59 and Judicial Conference policy,

this transcript may be viewed only at the Clerks Office public terminal or may be purchased

through the Court Reporter/Transcriber until the deadline for the Release of Transcript

Restriction.After that date it may be obtained through PACER. Any Notice of Intent to

Request Redaction, if required, is due no later than 5 business days from date of this filing.

Release of Transcript Restriction set for 9/21/2009. (Ball, Belle) (Filed on 6/25/2009)

(Entered: 06/25/2009)

06/26/2009 43 Brief re 19 MOTION to Consolidate Cases MOTION to Appoint Lead Plaintiff and Lead

Counsel ;Memorandum of Points and Authorities in Support Thereof Supplemental

Memorandum filed byWaterford Township General Employees Retirement System.

(Attachments: # 1 Exhibit A, # 2 Exhibit B)(Related document(s) 19 ) (Seefer, Christopher)

(Filed on 6/26/2009) (Entered: 06/26/2009)

09/02/2009 44 STIPULATION AND [PROPOSED] ORDER REGARDING SCHEDULE FOR CASE MANAGEMENT

CONFERENCE by Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. Incorporated.

(Varian, Robert) (Filed on 9/2/2009) (Entered: 09/02/2009)

09/08/2009 45 ORDER GRANTING MOTIONS TO CONSOLIDATE CASES; RE: MOTIONS TO APPOINT LEAD

PLAINTIFFS AND APPROVE SELECTION OF LEAD COUNSEL re 15, 19, 27. (SI, COURT STAFF)

(Filed on 9/8/2009) (Entered: 09/08/2009)

09/09/2009 46 ORDER CONTINUING CMC TO 9/18/09 (tf, COURT STAFF) (Filed on 9/9/2009) (Entered:

09/09/2009)

09/09/2009 47 CASE MANAGEMENT STATEMENT JOINT CASE MANAGEMENT STATEMENT, RULE 26(f)

REPORTAND [PROPOSED] ORDER filed by Jarl Berntzen, Michael A. Bless, Century

Aluminum Company, John C. Fontaine, Peter C. Jone, Logan W. Kruger, John P. O'Brien,

Steve Schneider, Willy R. Strothotte, Jack E. Thompson. (Ericson, Bruce) (Filed on 9/9/2009)

(Entered: 09/09/2009)

09/09/2009 Set Deadlines/Hearings: Case Management Conference set for 9/18/2009 02:30 PM. (ys,

COURT STAFF) (Filed on 9/9/2009) (Entered: 09/10/2009)

09/14/2009 48 Declaration of Stuart Wexler Declaration of Lead Plaintiff Stuart Wexler Requesting

Appointment as Sole Lead Plaintiff in the Consolidated Action filed byStuart Wexler.


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