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The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti) (Entered: 05/21/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464799667/","id":464799667,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479986144/","id":479986144,"tags":[],"absolute_url":"/docket/67923163/124/naclerio-v-docgo-inc/","date_created":"2026-05-21T08:08:16.617544-07:00","date_modified":"2026-05-21T08:08:16.636527-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"124","attachment_number":null,"pacer_doc_id":"127039655292","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Transcript","acms_document_guid":""}],"date_created":"2026-05-21T08:08:16.575192-07:00","date_modified":"2026-10-20T06:53:54.677906-07:00","date_filed":"2026-05-21","time_filed":"11:04:40","entry_number":124,"recap_sequence_number":"2026-05-21.001","pacer_sequence_number":414,"description":"TRANSCRIPT of Proceedings re: CONFERENCE held on 3/24/2026 before Judge Katherine Polk Failla. 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Release of Transcript Restriction set for 8/19/2026..(Moya, Goretti) (Entered: 05/21/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/458394595/","id":458394595,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/473397044/","id":473397044,"tags":[],"absolute_url":"/docket/67923163/121/naclerio-v-docgo-inc/","date_created":"2026-03-24T14:10:24.337147-07:00","date_modified":"2026-05-22T08:00:01.012300-07:00","sha1":"68ea9806367c91cfdbeab060a8442b8c8dc3bb59","page_count":2,"file_size":256052,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.121.0_1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.121.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 121 Filed 03/24/26 Page 1 of 2\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nGENESEE COUNTY EMPLOYEES\u2019\nRETIREMENT SYSTEM, Individually and\non Behalf of All Others Similarly Situated,\n 23 Civ. 9476 (KPF)\n Plaintiff,\n ORDER APPROVING\n -v.-\n PLAN OF ALLOCATION\n DOCGO INC. and ANTHONY CAPONE,\n\n Defendants.\n\nKATHERINE POLK FAILLA, District Judge:\n\n This matter having come before the Court on March 24, 2026, on Lead\n\nPlaintiff\u2019s motion for approval of the Plan of Allocation in the above-captioned\n\naction; the Court having considered all papers filed and proceedings had herein\n\nand otherwise being fully informed of the matter;\n\n IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that:\n\n 1. This Order incorporates by reference the definitions in the\n\nStipulation of Settlement dated November 12, 2025 (the \u201cStipulation\u201d), and all\n\ncapitalized terms used, but not defined herein, shall have the same meanings\n\nas set forth in the Stipulation.\n\n 2. This Court has jurisdiction to enter this Order, over the subject\n\nmatter of this Litigation, and over all of the Parties and all Class Members.\n\n 3. Pursuant to and in full compliance with Rule 23 of the Federal\n\nRules of Civil Procedure, this Court hereby finds and concludes that due and\n\nadequate notice was directed to all Persons who are Class Members who could\n\nbe identified with reasonable effort, advising them of the Plan of Allocation and\n\f Case 1:23-cv-09476-KPF Document 121 Filed 03/24/26 Page 2 of 2\n\n\n\n\nof their right to object thereto, and a full and fair opportunity was accorded to\n\nall Persons who are Class Members to be heard with respect to the Plan of\n\nAllocation.\n\n 4. The Court finds and concludes that the formula for the calculation\n\nof the claims of Authorized Claimants which is set forth in the Notice of\n\nPendency and Proposed Settlement of Class Action (the \u201cNotice\u201d) provided to\n\nClass Members provides a fair and reasonable basis upon which to allocate the\n\nproceeds of the Net Settlement Fund established pursuant to the Stipulation\n\namong the Class Members, with due consideration having been given to\n\nadministrative convenience and necessity.\n\n 5. This Court finds and concludes that the Plan of Allocation, as set\n\nforth in the Notice, is, in all respects, fair and reasonable and the Court\n\napproves the Plan of Allocation.\n\n SO ORDERED.\n\nDated: March 24, 2026\n New York, New York\n\n KATHERINE POLK FAILLA\n United States District Judge\n\n\n\n\n 2\n\f","ocr_status":2,"date_upload":"2026-05-19T18:19:04.098177-07:00","document_number":"121","attachment_number":null,"pacer_doc_id":"127039294265","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion for Settlement","acms_document_guid":""}],"date_created":"2026-03-24T14:10:24.297474-07:00","date_modified":"2026-10-20T06:53:54.590087-07:00","date_filed":"2026-03-24","time_filed":"15:05:45","entry_number":121,"recap_sequence_number":"2026-03-24.001","pacer_sequence_number":406,"description":"ORDER APPROVING PLAN OF ALLOCATION granting 108 Motion for Settlement. This matter having come before the Court on March 24, 2026, on Lead Plaintiff's motion for approval of the Plan of Allocation in the above-captioned action; the Court having considered all papers filed and proceedings had herein and otherwise being fully informed of the matter; IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that: This Order incorporates by reference the definitions in the Stipulation of Settlement dated November 12, 2025 (the \"Stipulation\"), and all capitalized terms used, but not defined herein, shall have the same meanings as set forth in the Stipulation. This Court has jurisdiction to enter this Order, over the subject matter of this Litigation, and over all of the Parties and all Class Members. Pursuant to and in full compliance with Rule 23 of the Federal Rules of Civil Procedure, this Court hereby finds and concludes that due and adequate notice was directed to all Persons who are Class Members who could be identified with reasonable effort, advising them of the Plan of Allocation and of their right to object thereto, and a full and fair opportunity was accorded to all Persons who are Class Members to be heard with respect to the Plan of Allocation. The Court finds and concludes that the formula for the calculation of the claims of Authorized Claimants which is set forth in the Notice of Pendency and Proposed Settlement of Class Action (the \"Notice\") provided to Class Members provides a fair and reasonable basis upon which to allocate the proceeds of the Net Settlement Fund established pursuant to the Stipulation among the Class Members, with due consideration having been given to administrative convenience and necessity. This Court finds and concludes that the Plan of Allocation, as set forth in the Notice, is, in all respects, fair and reasonable and the Court approves the Plan of Allocation. (Signed by Judge Katherine Polk Failla on 3/24/2026) (rro) (Entered: 03/24/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/458394556/","id":458394556,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/473397005/","id":473397005,"tags":[],"absolute_url":"/docket/67923163/122/naclerio-v-docgo-inc/","date_created":"2026-03-24T14:10:17.381252-07:00","date_modified":"2026-07-08T11:29:26.584521-07:00","sha1":"e41231cdadb067ccc8e00ffdcdef0268ba5e5a3f","page_count":4,"file_size":245603,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.122.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.122.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 122 Filed 03/24/26 Page 1 of 4\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nGENESEE COUNTY EMPLOYEES\u2019\nRETIREMENT SYSTEM, Individually and\non Behalf of All Others Similarly Situated,\n 23 Civ. 9476 (KPF)\n Plaintiff,\n ORDER AWARDING\n -v.- ATTORNEYS\u2019 FEES AND\n EXPENSES\nDOCGO INC. and ANTHONY CAPONE,\n\n Defendants.\n\nKATHERINE POLK FAILLA, District Judge:\n\n This matter having come before the Court on March 24, 2026, on the\n\nmotion of Lead Counsel for an award of attorneys\u2019 fees and expenses (the \u201cFee\n\nMotion\u201d), the Court, having considered all papers filed and proceedings\n\nconducted herein, having found the Settlement of this Litigation to be fair,\n\nreasonable and adequate, and otherwise being fully informed of the premises\n\nand good cause appearing therefore;\n\n IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that:\n\n 1. This Order incorporates by reference the definitions in the\n\nStipulation of Settlement dated November 12, 2025 (the \u201cStipulation\u201d), and all\n\ncapitalized terms used, but not defined herein, shall have the same meanings\n\nas set forth in the Stipulation.\n\n 2. This Court has jurisdiction to enter this Order, over the subject\n\nmatter of this Litigation, and over all of the Parties and all Class Members.\n\n 3. Notice of the Fee Motion was given to all Class Members who could\n\nbe located with reasonable effort. The form and method of notifying the Class\n\f Case 1:23-cv-09476-KPF Document 122 Filed 03/24/26 Page 2 of 4\n\n\n\n\nof the Fee Motion met the requirements of Rule 23 of the Federal Rules of Civil\n\nProcedure, the Private Securities Litigation Reform Act of 1995, due process,\n\nand any other applicable law; constituted the best notice practicable under the\n\ncircumstances; and constituted due and sufficient notice to all Persons entitled\n\nthereto.\n\n 4. Lead Counsel is hereby awarded attorneys\u2019 fees of 33% of the\n\nSettlement Amount, plus interest at the same rate earned by the Settlement\n\nFund. Lead Counsel is also awarded litigation expenses in the amount of\n\n$183,676.18, plus interest at the same rate earned by the Settlement Fund,\n\nwhich is payable to Lead Counsel upon entry of this Order and the Judgment.\n\nThe Court finds that the amount of fees awarded is fair, reasonable, and\n\nappropriate under the \u201cpercentage-of-recovery\u201d method.\n\n 5. In making this award of attorneys\u2019 fees and expenses to be paid\n\nfrom the Settlement Fund, the Court has analyzed the factors considered\n\nwithin the Second Circuit and found that:\n\n (a) the Settlement has created a fund of $12,500,000 in cash,\n\n pursuant to the terms of the Stipulation, and Class Members will benefit\n\n from the Settlement created by the efforts of Lead Counsel;\n\n (b) the fee sought by Lead Counsel has been reviewed and\n\n approved as reasonable by Lead Plaintiff, which oversaw the prosecution\n\n and resolution of the Litigation;\n\n (c) over 13,280 copies of the Postcard Notice were disseminated\n\n to potential Class Members indicating that Lead Counsel would move for\n\n 2\n\f Case 1:23-cv-09476-KPF Document 122 Filed 03/24/26 Page 3 of 4\n\n\n\n\n attorneys\u2019 fees in an amount not to exceed 33% of the Settlement\n\n Amount and for expenses in an amount not to exceed $250,000, plus\n\n interest on both amounts, and no objections to the fees or expenses were\n\n filed by Class Members;\n\n (d) Lead Counsel expended substantial time and effort pursuing\n\n the Litigation on behalf of the Class;\n\n (e) Lead Counsel pursued the Litigation on a contingent basis;\n\n (f) the claims against Defendants involve complex factual and\n\n legal issues and, in the absence of settlement, would involve lengthy\n\n proceedings whose resolution would be uncertain;\n\n (g) had Lead Counsel not achieved the Settlement, there would\n\n remain a significant risk that the Class may have recovered less or\n\n nothing from the Defendants;\n\n (h) Lead Counsel conducted the Litigation and achieved the\n\n Settlement with skill, perseverance, and diligent advocacy;\n\n (i) public policy concerns favor the award of reasonable\n\n attorneys\u2019 fees and expenses in securities class action litigation; and\n\n (j) the attorneys\u2019 fees and expenses awarded are fair and\n\n reasonable and consistent with awards in similar cases.\n\n 6. Any appeal or any challenge affecting this Court\u2019s approval\n\nregarding the Fee Motion shall in no way disturb or affect the finality of the\n\nJudgment entered with respect to the Settlement.\n\n\n\n\n 3\n\f Case 1:23-cv-09476-KPF Document 122 Filed 03/24/26 Page 4 of 4\n\n\n\n\n 7. In the event that the Settlement is terminated or does not become\n\nFinal or the Effective Date does not occur in accordance with the terms of the\n\nStipulation, this Order shall be rendered null and void to the extent provided in\n\nthe Stipulation and shall be vacated in accordance with the Stipulation..\n\n SO ORDERED.\n\nDated: March 24, 2026\n New York, New York\n\n KATHERINE POLK FAILLA\n United States District Judge\n\n\n\n\n 4\n\f","ocr_status":2,"date_upload":"2026-05-19T18:18:18.858587-07:00","document_number":"122","attachment_number":null,"pacer_doc_id":"127039294353","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Order on Motion for Attorney Fees","acms_document_guid":""}],"date_created":"2026-03-24T14:10:17.335022-07:00","date_modified":"2026-10-20T06:53:54.619754-07:00","date_filed":"2026-03-24","time_filed":"15:12:51","entry_number":122,"recap_sequence_number":"2026-03-24.002","pacer_sequence_number":408,"description":"ORDER AWARDING ATTORNEYS' FEES AND EXPENSES granting 110 Motion for Attorney Fees. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that: This Order incorporates by reference the definitions in the Stipulation of Settlement dated November 12, 2025 (the \"Stipulation\"), and all capitalized terms used, but not defined herein, shall have the same meanings as set forth in the Stipulation. This Court has jurisdiction to enter this Order, over the subject matter of this Litigation, and over all of the Parties and all Class Members. Notice of the Fee Motion was given to all Class Members who could be located with reasonable effort. The form and method of notifying the Class of the Fee Motion met the requirements of Rule 23 of the Federal Rules of Civil Procedure, the Private Securities Litigation Reform Act of 1995, due process, and any other applicable law; constituted the best notice practicable under the circumstances; and constituted due and sufficient notice to all Persons entitled thereto. Lead Counsel is hereby awarded attorneys' fees of 33% of the Settlement Amount, plus interest at the same rate earned by the Settlement Fund. Lead Counsel is also awarded litigation expenses in the amount of $183,676.18, plus interest at the same rate earned by the Settlement Fund, which is payable to Lead Counsel upon entry of this Order and the Judgment. The Court finds that the amount of fees awarded is fair, reasonable, and appropriate under the \"percentage-of-recovery\" method. In making this award of attorneys' fees and expenses to be paid from the Settlement Fund, the Court has analyzed the factors considered within the Second Circuit and found that:(a) the Settlement has created a fund of $12,500,000 in cash, pursuant to the terms of the Stipulation, and Class Members will benefit from the Settlement created by the efforts of Lead Counsel and further set forth in this Order.. (Signed by Judge Katherine Polk Failla on 3/24/2026) (rro) (Entered: 03/24/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/458394352/","id":458394352,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/473396800/","id":473396800,"tags":[],"absolute_url":"/docket/67923163/123/naclerio-v-docgo-inc/","date_created":"2026-03-24T14:10:01.550899-07:00","date_modified":"2026-07-08T11:29:26.376112-07:00","sha1":"e8cc6f82a629be46b1124bdc76a82794bb185858","page_count":9,"file_size":254677,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.123.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.123.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 1 of 9\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nGENESEE COUNTY EMPLOYEES\u2019\nRETIREMENT SYSTEM, Individually and\non Behalf of All Others Similarly Situated,\n 23 Civ. 9476 (KPF)\n Plaintiff,\n FINAL JUDGMENT AND ORDER\n -v.- OF DISMISSAL WITH\n PREJUDICE\nDOCGO INC. and ANTHONY CAPONE,\n\n Defendants.\n\nKATHERINE POLK FAILLA, District Judge:\n\n This matter came before the Court pursuant to the Order Preliminarily\n\nApproving Settlement and Providing for Notice (\u201cPreliminary Approval Order\u201d)\n\ndated November 18, 2025, on the application of Lead Plaintiff Genesee County\n\nEmployees\u2019 Retirement System for approval of the Settlement set forth in the\n\nStipulation of Settlement dated November 12, 2025 (the \u201cStipulation\u201d). Due\n\nand adequate notice having been given to the Class as required in said\n\nPreliminary Approval Order, and the Court having considered all papers filed\n\nand proceedings had herein and otherwise being fully informed in the premises\n\nand good cause appearing therefore, IT IS HEREBY ORDERED, ADJUDGED,\n\nAND DECREED that:\n\n 1. This Judgment incorporates by reference the definitions in the\n\nStipulation, and all capitalized terms used herein shall have the same\n\nmeanings as set forth in the Stipulation, unless otherwise set forth herein.\n\n 2. This Court has jurisdiction over the subject matter of the Litigation\n\nand over all parties to the Litigation, including all Members of the Class.\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 2 of 9\n\n\n\n\n 3. Pursuant to Rules 23(a) and (b)(3) of the Federal Rules of Civil\n\nProcedure, the Court hereby affirms its determination in the Preliminary\n\nApproval Order and finally certifies, for purposes of this Settlement only, this\n\nLitigation as a class action on behalf of all Persons who purchased DocGo Inc.\n\n(\u201cDocGo\u201d) publicly traded common stock between November 5, 2021, and\n\nSeptember 15, 2023, inclusive, and were damaged thereby. Excluded from the\n\nClass are: (i) Defendants and Former Defendants and members of their\n\nimmediate families; (ii) the officers and directors of DocGo during the Class\n\nPeriod, and members of their immediate families; (iii) the legal representatives,\n\nheirs, successors, or assigns of any of the foregoing; and (iv) any entity in\n\nwhich any Defendant or Former Defendant has or had a controlling interest.\n\nAlso excluded from the Class is any Person who properly excluded himself,\n\nherself, itself, or themselves from the Class by submitting a valid and timely\n\nrequest for exclusion, of which there were none.\n\n 4. The Court finds that for purposes of the Settlement only: (a) Class\n\nMembers are so numerous that joinder of all Class Members in the Class is\n\nimpracticable; (b) there are questions of law and fact common to the Class\n\nwhich predominate over any individual question; (c) the claims of Lead Plaintiff\n\nare typical of the claims of the Class; (d) Lead Plaintiff and its counsel have\n\nfairly and adequately represented and protected the Class Members; and (e) a\n\nclass action is superior to other available methods for the fair and efficient\n\nadjudication of the controversy, considering: (i) the interests of the Class\n\nMembers in individually controlling the prosecution with separate actions; (ii)\n\n 2\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 3 of 9\n\n\n\n\nthe extent and nature of any litigation concerning the controversy already\n\ncommenced by Class Members; (iii) the desirability or undesirability of\n\nconcentrating the litigation of these claims in this particular forum; and (iv) the\n\ndifficulties likely to be encountered in the management of the class action.\n\n 5. Pursuant to Federal Rule of Civil Procedure 23, the Court hereby\n\napproves the Settlement set forth in the Stipulation and finds that:\n\n (a) said Stipulation and the Settlement contained therein are, in\n\n all respects, fair, reasonable, and adequate and in the best interest of the\n\n Class;\n\n (b) there was no collusion in connection with the Stipulation;\n\n (c) the Stipulation was the product of informed, arm\u2019s-length\n\n negotiations among competent, able counsel; and\n\n (d) the record is sufficiently developed and complete to have\n\n enabled Lead Plaintiff and Defendants to have adequately evaluated and\n\n considered their respective positions.\n\n 6. Accordingly, the Court authorizes and directs implementation and\n\nperformance of all the terms and provisions of the Stipulation, as well as the\n\nterms and provisions hereof. The Court hereby dismisses the Litigation and all\n\nclaims asserted therein with prejudice. The Settling Parties are to bear their\n\nown costs, except as and to the extent provided in the Stipulation and herein.\n\n 7. The terms of the Stipulation and of this Judgment shall be forever\n\nbinding on the Released Defendant Parties, Lead Plaintiff, and all other Class\n\nMembers (regardless of whether or not any individual Class Member submits a\n\n 3\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 4 of 9\n\n\n\n\nProof of Claim or seeks or obtains a distribution from the Net Settlement Fund),\n\nas well as their respective successors and assigns.\n\n 8. Upon the Effective Date, and as provided in the Stipulation, Lead\n\nPlaintiff shall have, and each and every Releasing Plaintiff Party shall be\n\ndeemed to have, and by operation of this Judgment shall have, fully, finally,\n\nand forever waived, released, resolved, compromised, settled, relinquished,\n\ndischarged, and dismissed each and every one of the Released Plaintiff\u2019s Claims\n\n(including Unknown Claims) against each and every one of the Released\n\nDefendant Parties, whether or not such Class Member executes and delivers\n\nthe Proof of Claim or shares in the Net Settlement Fund. Claims to enforce the\n\nterms of the Stipulation or this Judgment are not released.\n\n 9. Upon the Effective Date, and as provided in the Stipulation, the\n\nReleasing Plaintiff Parties will be forever barred and enjoined from\n\ncommencing, instituting, maintaining, prosecuting, or continuing to prosecute\n\nany action or other proceeding in any forum (including, but not limited to, any\n\nstate or federal court of law or equity, arbitration tribunal, or administrative\n\nforum), asserting any of the Released Plaintiff\u2019s Claims against any of the\n\nReleased Defendant Parties.\n\n 10. Upon the Effective Date, the Releasing Plaintiff Parties shall be\n\ndeemed to have covenanted not to sue any Released Defendant Parties on the\n\nbasis of any Releasing Plaintiff\u2019s Claims or, unless compelled by operation of\n\nlaw, to assist any person in commencing or maintaining any suit relating to\n\nany Released Plaintiff\u2019s Claim against any Released Defendant Parties. The\n\n 4\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 5 of 9\n\n\n\n\nforegoing release is given regardless of whether Lead Plaintiff or any Class\n\nMember: (i) executed and delivered a Proof of Claim; (ii) received the Notice; (iii)\n\nparticipated in the Settlement Fund; (iv) filed an objection to the Settlement,\n\nthe proposed Plan of Allocation, or any application by Lead Plaintiff\u2019s Counsel\n\nfor attorneys\u2019 fees and expenses; or (v) had their claims approved or allowed.\n\nNothing contained herein shall bar any action or claim to enforce the terms of\n\nthe Stipulation or this Judgment.\n\n 11. Upon the Effective Date, and as provided in the Stipulation, each of\n\nthe Released Defendant Parties shall be deemed to have, and by operation of\n\nthis Judgment shall have, fully, finally, and forever released, resolved,\n\ncompromised, settled, relinquished, and discharged each and every one of\n\nReleased Defendants\u2019 Claims (including Unknown Claims) against the\n\nReleasing Plaintiff Parties. Claims to enforce the terms of the Stipulation or\n\nthis Judgment are not released.\n\n 12. The Court finds and concludes that the Settling Parties and their\n\nrespective counsel have complied in all respects with the requirements of Rule\n\n11 of the Federal Rules of Civil Procedure in connection with the institution,\n\nprosecution, defense, and settlement of the Litigation.\n\n 13. Neither this Judgment nor the Stipulation (whether or not\n\nconsummated), including the exhibits thereto and the Plan of Allocation\n\ncontained therein (or any other plan of allocation that may be approved by the\n\nCourt), the negotiations leading to the execution of the Stipulation, nor any\n\nproceedings taken pursuant to or in connection with the Stipulation, and/or\n\n 5\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 6 of 9\n\n\n\n\napproval of the Settlement (including any arguments proffered in connection\n\ntherewith) shall be offered against the Released Defendant Parties or the\n\nReleasing Plaintiff Parties as evidence of, or construed as, or deemed to be\n\nevidence of any presumption, concession, or admission by any of the parties as\n\nto the truth of any facts alleged, validity, merit, or deficiency of any claim or\n\ndefense that was or could have been asserted in this Litigation, that damages\n\nrecoverable under the Complaint would not have exceeded the Settlement\n\nAmount, or with respect to any liability, fault, or wrongdoing of any kind, or in\n\nany way referred to for any other reason as against any of the parties, in any\n\ncivil, criminal or administrative action or proceeding, other than such\n\nproceedings as may be necessary to effectuate the provisions of the Stipulation.\n\n 14. The notice of the pendency and proposed Settlement of the\n\nLitigation given to the Class was the best notice practicable under the\n\ncircumstances, including the individual notice to all Members of the Class who\n\ncould be identified through reasonable effort. Said notice provided the best\n\nnotice practicable under the circumstances of those proceedings and of the\n\nmatters set forth therein, including the proposed Settlement set forth in the\n\nStipulation, to all Persons entitled to such notice, and said notice fully satisfied\n\nthe requirements of Federal Rule of Civil Procedure 23 and the requirements of\n\ndue process. No Class Member is relieved from the terms of the Settlement,\n\nincluding the Releases provided for therein, based upon the contention or proof\n\nthat such Class Member failed to receive actual or adequate notice. A full\n\nopportunity has been offered to Class Members to object to the proposed\n\n 6\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 7 of 9\n\n\n\n\nSettlement and to participate in the hearing thereon. The Court further finds\n\nthat the notice provisions of the Class Action Fairness Act, 28 U.S.C. \u00a71715,\n\nwere fully discharged and that the statutory waiting period has elapsed. Thus,\n\nthe Court hereby determines that all Class Members are bound by this\n\nJudgment.\n\n 15. The Escrow Agent shall maintain the Settlement Fund in\n\naccordance with the requirements set forth in the Stipulation. No Released\n\nDefendant Party shall have any liability, obligation, or responsibility\n\nwhatsoever for the administration of the Settlement or disbursement of the Net\n\nSettlement Fund.\n\n 16. Any Plan of Allocation submitted by Lead Counsel or any order\n\nentered regarding any attorneys\u2019 fee and expense application shall in no way\n\ndisturb or affect this Judgment and shall be considered separate from this\n\nJudgment.\n\n 17. Neither the Stipulation nor the Settlement contained therein, nor\n\nany act performed or document executed pursuant to or in furtherance of the\n\nStipulation or the Settlement: (a) is, or may be deemed to be, or may be used as\n\nan admission of, or evidence of, the validity of any Released Plaintiff\u2019s Claim, or\n\nof any wrongdoing or liability of the Defendants or Defendants\u2019 Released\n\nPersons; (b) is, or shall be deemed to be, or shall be used as an admission of\n\nany fault or omission of any Released Defendant Party in any statement,\n\nrelease, or written documents issued, filed, or made; or (c) is, or may be\n\ndeemed to be, or may be used as an admission of, or evidence of, any fault or\n\n 7\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 8 of 9\n\n\n\n\nomission of any of the Defendants, Former Defendants, or Defendants\u2019\n\nReleased Persons in any civil, criminal, or administrative proceeding in any\n\ncourt, administrative agency, or other tribunal. Released Defendant Parties\n\nmay file the Stipulation and/or this Judgment from this Litigation in any other\n\naction that may be brought against them in order to support a defense or\n\ncounterclaim based on principles of res judicata, collateral estoppel, release,\n\ngood faith settlement, judgment bar or reduction, or any theory of claim\n\npreclusion or issue preclusion or similar defense or counterclaim.\n\n 18. Without affecting the finality of this Judgment in any way, this\n\nCourt hereby retains continuing jurisdiction over: (a) implementation of this\n\nSettlement and any award or distribution of the Settlement Fund, including\n\ninterest earned thereon; (b) disposition of the Settlement Fund; (c) hearing and\n\ndetermining applications for attorneys\u2019 fees, expenses, and interest in the\n\nLitigation; and (d) hearing and determining applications for approval of the\n\nPlan of Allocation; and (e) all parties herein for the purpose of construing,\n\nenforcing, and administering the Stipulation.\n\n 19. Separate orders shall be entered regarding approval of a plan of\n\nallocation and the motion of Lead Counsel for an award of attorneys\u2019 fees and\n\nlitigation expenses. Such orders shall in no way affect or delay the finality of\n\nthis Judgment and shall not affect or delay the Effective Date of the Settlement.\n\n 20. The Court\u2019s orders entered during the course of the Litigation\n\nrelating to the confidentiality of information shall survive this Settlement.\n\n\n\n\n 8\n\f Case 1:23-cv-09476-KPF Document 123 Filed 03/24/26 Page 9 of 9\n\n\n\n\n 21. In the event that the Settlement does not become effective in\n\naccordance with the terms of the Stipulation, or the Effective Date does not\n\noccur, or in the event that the Settlement Fund, or any portion thereof, is\n\nreturned to Defendants or their insurers, then this Judgment shall be rendered\n\nnull and void to the extent provided by and in accordance with the Stipulation\n\nand shall be vacated and, in such event, all orders entered and Releases\n\ndelivered in connection herewith shall be null and void to the extent provided\n\nby and in accordance with the Stipulation, and the Settling Parties shall revert\n\nto their respective positions in the Litigation as of October 1, 2025, as provided\n\nin the Stipulation.\n\n 22. Without further order of the Court, the Settling Parties may agree\n\nto reasonable extensions of time to carry out any of the provisions of the\n\nStipulation.\n\n 23. The Court directs immediate entry of this Judgment by the Clerk of\n\nthe Court.\n\n 24. The Clerk of Court is directed to terminate all pending motions,\n\nadjourn all remaining dates, and close this case.\n\nDated: March 24, 2026\n New York, New York\n\n KATHERINE POLK FAILLA\n United States District Judge\n\n\n\n\n 9\n\f","ocr_status":2,"date_upload":"2026-05-19T18:15:28.259431-07:00","document_number":"123","attachment_number":null,"pacer_doc_id":"127039294557","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Judgment","acms_document_guid":""}],"date_created":"2026-03-24T14:10:01.490995-07:00","date_modified":"2026-10-20T06:53:54.646479-07:00","date_filed":"2026-03-24","time_filed":"15:25:29","entry_number":123,"recap_sequence_number":"2026-03-24.003","pacer_sequence_number":410,"description":"FINAL JUDGMENT AND ORDER OF DISMISSAL WITH PREJUDICE: IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that: This Judgment incorporates by reference the definitions in the Stipulation, and all capitalized terms used herein shall have the same meanings as set forth in the Stipulation, unless otherwise set forth herein. This Court has jurisdiction over the subject matter of the Litigation and over all parties to the Litigation, including all Members of the Class. The Court finds that for purposes of the Settlement only: (a) Class Members are so numerous that joinder of all Class Members in the Class is impracticable; (b) there are questions of law and fact common to the Class which predominate over any individual question; (c) the claims of Lead Plaintiff are typical of the claims of the Class; (d) Lead Plaintiff and its counsel have fairly and adequately represented and protected the Class Members; and (e) a class action is superior to other available methods for the fair and efficient adjudication of the controversy, considering: (i) the interests of the Class Members in individually controlling the prosecution with separate actions; (ii) the extent and nature of any litigation concerning the controversy already commenced by Class Members; (iii) the desirability or undesirability of concentrating the litigation of these claims in this particular forum; and (iv) the difficulties likely to be encountered in the management of the class action. Accordingly, the Court authorizes and directs implementation and performance of all the terms and provisions of the Stipulation, as well as the terms and provisions hereof. The Court hereby dismisses the Litigation and all claims asserted therein with prejudice. The Settling Parties are to bear their own costs, except as and to the extent provided in the Stipulation and herein. The Court directs immediate entry of this Judgment by the Clerk of the Court. The Clerk of Court is directed to terminate all pending motions, adjourn all remaining dates, and close this case. (Signed by Judge Katherine Polk Failla on 3/24/2026) (rro) (Entered: 03/24/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/457515017/","id":457515017,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/472500407/","id":472500407,"tags":[],"absolute_url":"","date_created":"2026-03-17T14:12:00.590512-07:00","date_modified":"2026-03-17T14:12:00.597365-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice to Court Regarding Proposed Order","acms_document_guid":""}],"date_created":"2026-03-17T14:12:00.575044-07:00","date_modified":"2026-03-17T14:12:00.575057-07:00","date_filed":"2026-03-17","time_filed":"16:33:51","entry_number":null,"recap_sequence_number":"2026-03-17.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/457476695/","id":457476695,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/472461493/","id":472461493,"tags":[],"absolute_url":"/docket/67923163/116/naclerio-v-docgo-inc/","date_created":"2026-03-17T12:13:06.321264-07:00","date_modified":"2026-06-23T06:03:29.628861-07:00","sha1":"054f35ea253408ec43dbd704ea4beaf5294e3943","page_count":8,"file_size":163997,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 1 of 8\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : LEAD PLAINTIFF\u2019S REPLY\n : MEMORANDUM OF LAW IN FURTHER\n vs. : SUPPORT OF MOTIONS FOR: (I) FINAL\n : APPROVAL OF CLASS ACTION\nDOCGO INC. and ANTHONY CAPONE, : SETTLEMENT AND APPROVAL OF PLAN\n : OF ALLOCATION; AND (II) AN AWARD\n Defendants. OF ATTORNEYS\u2019 FEES AND EXPENSES\n :\n x\n\n\n\n\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 2 of 8\n\n\n\n\n Lead Plaintiff Genesee County Employees\u2019 Retirement System and Lead Counsel\n\nrespectfully submit this reply memorandum of law in further support of: (i) Lead Plaintiff\u2019s Motion\n\nfor Final Approval of Class Action Settlement and Approval of Plan of Allocation; and (ii) Lead\n\nCounsel\u2019s Motion for an Award of Attorneys\u2019 Fees and Expenses. ECF 108-115.1\n\nI. PRELIMINARY STATEMENT\n\n The March 3, 2026 deadline for objections and requests for exclusion has passed and Lead\n\nPlaintiff is pleased to inform the Court that the Class\u2019 reaction to the Settlement, Plan of Allocation,\n\nand Lead Counsel\u2019s fee and expense application has been entirely positive. As detailed in the\n\nopening declaration of Ross D. Murray (ECF 114) and the accompanying Supplemental Declaration\n\nof Ross D. Murray Regarding: (A) Continued Notice Dissemination; (B) Update on Call Center\n\nServices and Website; and (C) Requests for Exclusion Received to Date (\u201cSuppl. Murray Decl.\u201d),\n\nthe Claims Administrator disseminated over 13,280 Postcard Notices to potential Class Members\n\nand nominees. See ECF 114, \u00b611; Suppl. Murray Decl., \u00b6\u00b63-4. Notice was also published in The\n\nWall Street Journal, transmitted over Business Wire, and posted on the settlement website\n\nestablished by the Claims Administrator, www.DocGoSecuritiesSettlement.com. ECF 114, \u00b6\u00b612,\n\n14; see also Suppl. Murray Decl., \u00b66. There have been no objections to the Settlement or Plan of\n\nAllocation. Moreover, no Class Member has sought exclusion from the Class. Suppl. Murray Decl.,\n\n\u00b6\u00b68-9.\n\n\n\n\n1\n Unless otherwise noted, capitalized terms have the meanings ascribed to them in the\nStipulation of Settlement dated November 12, 2025 (ECF 101-1) (the \u201cStipulation\u201d) or in the\nDeclaration of Christopher M. Wood in Support of: (I) Lead Plaintiff\u2019s Motion for Final Approval of\nClass Action Settlement and Approval of Plan of Allocation; and (II) Lead Counsel\u2019s Motion for an\nAward of Attorneys\u2019 Fees and Expenses (ECF 112). Unless otherwise noted, citations are omitted\nand emphasis is added.\n\n -1-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 3 of 8\n\n\n\n\n The Class\u2019 favorable response supports a finding that the Settlement, Plan of Allocation, and\n\nLead Counsel\u2019s fee and expense application, are fair, reasonable, and adequate.\n\nII. ARGUMENT\n\n A. The Reaction of the Class Strongly Supports Approval of the\n Settlement and Plan of Allocation\n\n As detailed in Lead Plaintiff\u2019s opening brief in support of approval of the Settlement, Lead\n\nCounsel achieved an outstanding $12.5 million settlement, recovering over 20% of reasonably\n\nrecoverable damages. ECF 109 at 13. The Class agrees. Not a single Class Member has objected to\n\nthe Settlement or Plan of Allocation. Likewise, no Class Member has sought to be excluded from\n\nthe Class. See Suppl. Murray Decl., \u00b6\u00b68-9. This favorable reaction \u201cis perhaps the most significant\n\nfactor\u201d in determining the fairness and adequacy of the proposed Settlement, and strongly supports\n\napproval here. Wal-Mart Stores, Inc. v. Visa U.S.A., Inc., 396 F.3d 96, 119 (2d Cir. 2005),\n\nsuperseded by rule as stated in Moses v. New York Times Co., 79 F.4th 235 (2d Cir. 2023); see also\n\nContant v. Bank of Am. Corp., 2020 WL 13689631, at *3 (S.D.N.Y. Nov. 19, 2020) (approving\n\nsettlement with no objections finding \u201cClass Members\u2019 reaction to the Settlement [is] entitled to\n\ngreat weight\u201d); In re Signet Jewelers Ltd. Sec. Litig., 2020 WL 4196468, at *6 (S.D.N.Y. July 21,\n\n2020) (alteration in original) (\u201c\u2018[T]he favorable reaction of the overwhelming majority of class\n\nmembers to the Settlement is perhaps the most significant factor in [the] Grinnell inquiry\u2019 into the\n\nfairness and adequacy of the Settlement.\u201d); In re Hi-Crush Partners L.P. Sec. Litig., 2014 WL\n\n7323417, at *6 (S.D.N.Y. Dec. 19, 2014) (\u201cThe reaction of the . . . Class to the Settlement is a\n\nsignificant factor in assessing its fairness and adequacy.\u201d); Maley v. Del Glob. Techs. Corp., 186 F.\n\nSupp. 2d 358, 362 (S.D.N.Y. 2002) (\u201c[T]he reaction of the class to the settlement is perhaps the most\n\nsignificant factor to be weighed in considering its adequacy.\u201d).\n\n\n\n -2-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 4 of 8\n\n\n\n\n The Class\u2019 positive reaction to the Settlement therefore weighs in favor of final approval of\n\nthe Settlement. See ECF 109 at \u00a7III.B.6; see also Signet, 2020 WL 4196468, at *6 (\u201cThe absence of\n\nany objections and the small number of requests for exclusion support a finding that the Settlement\n\nis fair, reasonable, and adequate.\u201d); Guevoura Fund Ltd. v. Sillerman, 2019 WL 6889901, at *7\n\n(S.D.N.Y. Dec. 18, 2019) (\u201cTo date, not a single Class Member has objected or sought exclusion.\n\nThe absence of negative feedback from Class Members evidences an overall favorable response of\n\nthe Class Members to the Settlement. Thus, this factor strongly supports approval of the\n\nSettlement.\u201d); In re Facebook, Inc., IPO Sec. & Deriv. Litig., 343 F. Supp. 3d 394, 410 (S.D.N.Y.\n\n2018) (\u201cThe overwhelmingly positive reaction \u2013 or absence of a negative reaction \u2013 weighs strongly\n\nin favor of confirming the Proposed Settlement.\u201d), aff\u2019d, 822 F. App\u2019x 40 (2d Cir. 2020); Yuzary v.\n\nHSBC Bank USA, N.A., 2013 WL 5492998, at *6 (S.D.N.Y. Oct. 2, 2013) (\u201cNo Class Member\n\nobjected to the settlement[.] This favorable response demonstrates that the class approves of the\n\nsettlement and supports final approval.\u201d); In re FLAG Telecom Holdings, Ltd. Sec. Litig., 2010 WL\n\n4537550, at *16 (S.D.N.Y. Nov. 8, 2010) (\u201cThe absence of objections to the Settlement supports the\n\ninference that it is fair, reasonable and adequate.\u201d).\n\n Moreover, the absence of objections from institutional investors provides further support for\n\nfinal approval of the proposed Settlement. See, e.g., In re Citigroup Inc. Bond Litig., 296 F.R.D.\n\n147, 156 (S.D.N.Y. 2013) (\u201c[N]ot one of the objections or requests for exclusion was submitted by\n\nan institutional investor. Therefore . . . \u2018the class\u2019s reaction weighs heavily in favor of approval.\u2019\u201d).\n\n The Class\u2019 favorable response to the Plan of Allocation likewise supports approval of the\n\nPlan of Allocation. See, e.g., In re Romeo Power Inc. Sec. Litig., 2024 U.S. Dist. LEXIS 237134, at\n\n*3-*4 (S.D.N.Y. Aug. 1, 2024) (approving plan of allocation where no objections were submitted);\n\nSignet, 2020 WL 4196468, at *6 (\u201cThe reaction of the Class also supports approval of the Plan of\n\n -3-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 5 of 8\n\n\n\n\nAllocation.\u201d); In re Veeco Instruments Inc. Sec. Litig., 2007 WL 4115809, at *14 (S.D.N.Y. Nov. 7,\n\n2007) (\u201c[N]ot one class member has objected to the Plan of Allocation which was fully explained in\n\nthe Notice of Settlement sent to all Class Members. This favorable reaction of the Class supports\n\napproval of the Plan of Allocation.\u201d); In re XL Fleet Corp. Sec. Litig., No. 1:21-cv-02002-JLR, ECF\n\n200 (S.D.N.Y. Apr. 30, 2024) (approving plan of allocation and noting that there were no objections\n\nto the proposed plan) (attached hereto as Ex. A); In re Wells Fargo & Co. Sec. Litig., No. 1:20-cv-\n\n04494-JLR-SN, ECF 205 (S.D.N.Y. Sept. 8, 2023) (approving plan of allocation and noting that\n\nthere were no objections to the proposed plan) (attached hereto as Ex. B).\n\n B. The Reaction of the Class Strongly Supports Approval of Lead\n Counsel\u2019s Fee and Expense Application\n\n As set forth more fully in Lead Counsel\u2019s opening brief in support of an award of attorneys\u2019\n\nfees and expenses, Lead Counsel\u2019s fee request of 33% of the Settlement Amount is supported by\n\nLead Plaintiff, consistent with awards in complex class action litigation, and fair and reasonable\n\nunder the relevant factors, including the fact that it does not result in a windfall to Lead Counsel.\n\nECF 111; see also In re Grab Holdings Ltd. Sec. Litig., 2025 WL 1413515, at *5 (S.D.N.Y. May 15,\n\n2025) (awarding 33-1/3% of $80 million settlement, representing recovery of between 8.9% and\n\n13.4% of estimated recoverable damages). The recovery here far exceeds, on a percentage basis, the\n\nmedian settlement for cases of this size. See Laarni Bulan and Eric Tam, Securities Class Action\n\nSettlements \u2013 2025 Review & Analysis (Cornerstone Research 2026) at 7, fig. 8. Since the Claims\n\nAdministrator disseminated the Court-approved notice, no objections have been raised to any aspect\n\nof Lead Counsel\u2019s application for awards of attorneys\u2019 fees and expenses.\n\n \u201cThe absence of any objections to [Lead Counsel\u2019s] requested attorneys\u2019 fees and Litigation\n\nExpenses supports a finding that the request is fair and reasonable.\u201d Signet, 2020 WL 4196468, at\n\n*21; see also Guevoura Fund, 2019 WL 6889901, at *22 (\u201cTo date, no object[ion] to the fee request\n -4-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 6 of 8\n\n\n\n\nhas been received. The lack of objections, in this day and age, is not only remarkable, but militates\n\nin favor of approval of the Fees as requested.\u201d); In re Veeco Instruments Inc. Sec. Litig., 2007 WL\n\n4115808, at *10 (S.D.N.Y. Nov. 7, 2007) (\u201cNo member of the Class has objected to either the\n\nSettlement or to Plaintiffs\u2019 Counsel\u2019s request for an award of attorneys\u2019 fees. This response suggests\n\nthat the fee request is fair and reasonable.\u201d).\n\nIII. CONCLUSION\n\n The $12.5 million Settlement \u2013 the byproduct of extensive litigation and arm\u2019s-length\n\nnegotiations by experienced counsel overseen by a skilled mediator \u2013 represents an outstanding\n\nrecovery for the Class. For these reasons and those set forth in their opening papers, ECF 108-115,\n\nLead Plaintiff and Lead Counsel respectfully request that the Court: (i) approve the proposed\n\nSettlement and Plan of Allocation as fair, reasonable, adequate, and in the best interest of the Class;\n\nand (ii) award attorneys\u2019 fees to Lead Counsel in the amount of 33% of the Settlement Amount, plus\n\nlitigation expenses in the amount of $183,676.18, plus the interest earned on both amounts.\n\nProposed orders are submitted herewith.\n\nDATED: March 17, 2026 Respectfully submitted,\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n 200 31st Avenue North\n Nashville, TN 37203\n Telephone: 615/244-2203\n 615/252-3798 (fax)\n cwood@rgrdlaw.com\n\n\n\n\n -5-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 7 of 8\n\n\n\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n SAMUEL H. RUDMAN\n DAVID A. ROSENFELD\n 58 South Service Road, Suite 200\n Melville, NY 11747\n Telephone: 631/367-7100\n 631/367-1173 (fax)\n srudman@rgrdlaw.com\n drosenfeld@rgrdlaw.com\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n ELLEN GUSIKOFF STEWART (admitted pro hac vice)\n ERIC I. NIEHAUS (admitted pro hac vice)\n JOSEPH J. TULL (admitted pro hac vice)\n 655 West Broadway, Suite 1900\n San Diego, CA 92101\n Telephone: 619/231-1058\n 619/231-7423 (fax)\n elleng@rgrdlaw.com\n ericn@rgrdlaw.com\n jtull@rgrdlaw.com\n\n Lead Counsel for Lead Plaintiff\n\n VANOVERBEKE, MICHAUD\n & TIMMONY, P.C.\n THOMAS C. MICHAUD\n 79 Alfred Street\n Detroit, MI 48201\n Telephone: 313/578-1200\n 313/578-1201 (fax)\n tmichaud@vmtlaw.com\n\n Additional Counsel\n\n\n\n\n -6-\n4899-9413-9288.v1\n\f Case 1:23-cv-09476-KPF Document 116 Filed 03/17/26 Page 8 of 8\n\n\n\n\n CERTIFICATION PURSUANT TO LOCAL RULE 7.1(c)\n\n I, Christopher M. Wood, hereby declare that this document contains 1,516 words, and\n\ncomplies with the word-count limitation provided by Local Rule 7.1(c).\n\nDATED: March 17, 2026 ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n\n -7-\n4899-9413-9288.v1\n\f","ocr_status":2,"date_upload":"2026-06-22T23:04:38.172934-07:00","document_number":"116","attachment_number":null,"pacer_doc_id":"127039252236","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Reply Memorandum of Law in Support of Motion","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663615/","id":483663615,"tags":[],"absolute_url":"/docket/67923163/116/1/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:04:24.492480-07:00","date_modified":"2026-06-23T06:03:29.829656-07:00","sha1":"036eb0609017bb2bf9a32af3fbd3c876d1507782","page_count":1,"file_size":110242,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 116-1 Filed 03/17/26 Page 1 of 1\n\n\n\n\nINDEX OF EXHIBITS TO LEAD PLAINTIFF\u2019S REPLY MEMORANDUM OF LAW IN\n FURTHER SUPPORT OF MOTIONS FOR: (I) FINAL APPROVAL OF CLASS\nACTION SETTLEMENT AND APPROVAL OF PLAN OF ALLOCATION; AND (II) AN\n AWARD OF ATTORNEYS\u2019 FEES AND EXPENSES\n\n\n DOCUMENT EXHIBIT\nIn re XL Fleet Corp. Sec. Litig., A\n No. 1:21-cv-02002-JLR, ECF 200 (S.D.N.Y.\n Apr. 30, 2024)\nIn re Wells Fargo & Co. Sec. Litig., B\n No. 1:20-cv-04494-JLR-SN, ECF 205\n (S.D.N.Y. Sept. 8, 2023)\n\f","ocr_status":2,"date_upload":"2026-06-22T23:05:03.094617-07:00","document_number":"116","attachment_number":1,"pacer_doc_id":"127039252237","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Appendix (Index of Exhibits)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663616/","id":483663616,"tags":[],"absolute_url":"/docket/67923163/116/2/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:04:24.507591-07:00","date_modified":"2026-06-23T05:41:01.886481-07:00","sha1":"4fbc0bf88891b567a80f9e9e31a3ee397663770b","page_count":4,"file_size":252357,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 116-2 Filed 03/17/26 Page 1 of 4\n\n\n\n\n EXHIBIT A\n\f Case\n Case\n 1:23-cv-09476-KPF\n 1:21-cv-02002-JLR Document\n Document116-2\n 200 Filed\n Filed\n 04/30/24\n 03/17/26Page\n Page\n 1 of23of 4\n\n\n\n\n UNITED STATES DISTRICT COURT\n SOUTHERN DISTRICT OF NEW YORK\n\n\n IN RE XL FLEET CORP. SECURITIES Case No. 1:21-cv-02002-JLR\n LITIGATION\n\n\n\n\n ORDER APPROVING\n PLAN OF ALLOCATION OF NET SETTLEMENT FUND\n\n This matter came on for hearing on April 30, 2024 (the \u201cSettlement Hearing\u201d) on\n\nPlaintiffs\u2019 motion to determine whether the proposed plan of allocation of the Net Settlement\n\nFund (\u201cPlan of Allocation\u201d) created by the Settlement achieved in the above-captioned class\n\naction (the \u201cAction\u201d) should be approved. The Court having considered all matters submitted to\n\nit at the Settlement Hearing and otherwise; and it appearing that notice of the Settlement Hearing\n\nsubstantially in the form approved by the Court was mailed or emailed to all Settlement Class\n\nMembers who or which could be identified with reasonable effort, and that a summary notice of\n\nthe hearing substantially in the form approved by the Court was published in Investor\u2019s Business\n\nDaily and was transmitted over the PR Newswire pursuant to the specifications of the Court; and\n\nthe Court having considered and determined the fairness and reasonableness of the\n\nproposed Plan of Allocation; and for the reasons set forth on the record on April 30, 2024;\n\n NOW, THEREFORE, IT IS HEREBY ORDERED THAT:\n\n 1. This Order approving the proposed Plan of Allocation incorporates by reference\n\nthe definitions in the Stipulation and Agreement of Settlement dated December 6, 2023 (the\n\n\u201cStipulation\u201d; ECF No. 182-1) and all capitalized terms not otherwise defined herein shall have\n\nthe same meanings as set forth in the Stipulation.\n\f Case\n Case\n 1:23-cv-09476-KPF\n 1:21-cv-02002-JLR Document\n Document116-2\n 200 Filed\n Filed\n 04/30/24\n 03/17/26Page\n Page\n 2 of33of 4\n\n\n\n\n 2. The Court has jurisdiction to enter this Order approving the proposed Plan of\n\nAllocation, and over the subject matter of the Action and all parties to the Action, including all\n\nSettlement Class Members.\n\n 3. Notice of Plaintiffs\u2019 motion for approval of the proposed Plan of Allocation was\n\ngiven to all Settlement Class Members who could be identified with reasonable effort. The form\n\nand method of notifying the Settlement Class of the motion for approval of the proposed Plan of\n\nAllocation satisfied the requirements of Rule 23 of the Federal Rules of Civil Procedure, the\n\nPrivate Securities Litigation Reform Act of 1995 (15 U.S.C. \u00a7 78u-4(a)(7)), due process, and all\n\nother applicable law and rules, constituted the best notice practicable under the circumstances,\n\nand constituted due and sufficient notice to all persons and entities entitled thereto.\n\n 4. The Notice, which included the Plan of Allocation, was available to potential\n\nSettlement Class Members and nominees on the Settlement Website and no objections to the\n\nproposed plan were submitted.\n\n 5. The Court hereby finds and concludes that the formula for the calculation of the\n\nclaims of Claimants as set forth in the Plan of Allocation mailed to Settlement Class Members\n\nprovides a fair and reasonable basis upon which to allocate the proceeds of the Net Settlement\n\nFund among Settlement Class Members with due consideration having been given to\n\nadministrative convenience and necessity.\n\n 6. The Court hereby finds and concludes that the Plan of Allocation is, in all\n\nrespects, fair and reasonable to the Settlement Class.\n\n 7. There is no just reason for delay in the entry of this Order, and immediate entry\n\nby the Clerk of the Court is expressly directed.\n\n\n\n\n 2\n\fCase\n Case\n 1:23-cv-09476-KPF\n 1:21-cv-02002-JLR Document\n Document116-2\n 200 Filed\n Filed\n 04/30/24\n 03/17/26Page\n Page\n 3 of43of 4\n\n\n\n 30th day of ______________,\n SO ORDERED this _______ April 2024.\n\n\n\n ________________________________________\n The Honorable Jennifer L. Rochon\n United States District Judge\n\n\n\n\n 3\n\f","ocr_status":2,"date_upload":"2026-06-22T23:05:19.218968-07:00","document_number":"116","attachment_number":2,"pacer_doc_id":"127039252238","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit A (In re XL Fleet)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663617/","id":483663617,"tags":[],"absolute_url":"/docket/67923163/116/3/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:04:24.519791-07:00","date_modified":"2026-06-23T05:40:56.719224-07:00","sha1":"5cc59e809d803daab35c0504db5a77d212bb2806","page_count":4,"file_size":170433,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.116.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 116-3 Filed 03/17/26 Page 1 of 4\n\n\n\n\n EXHIBIT B\n\f Case\n Case1:23-cv-09476-KPF\n 1:20-cv-04494-JLR-SN\n Document\n Document\n 116-3\n 205 Filed 03/17/26\n 09/08/23 Page\n Page12ofof34\n\n\n\n\n UNITED STATES DISTRICT COURT\n SOUTHERN DISTRICT OF NEW YORK\n\n\nIN RE WELLS FARGO & COMPANY\nSECURITIES LITIGATION Case No. 1:20-cv-04494-JLR-SN\n\n\n\n\n ORDER APPROVING\n PLAN OF ALLOCATION OF NET SETTLEMENT FUND\n\n This matter came on for hearing on September 8, 2023 (the \u201cSettlement Hearing\u201d) on Lead\n\nPlaintiffs\u2019 motion to approve the proposed plan of allocation (\u201cPlan of Allocation\u201d) of the Net\n\nSettlement Fund created under the Settlement in the above-captioned class action (the \u201cAction\u201d).\n\nThe Court having considered all matters submitted to it at the Settlement Hearing and otherwise;\n\nit appearing that: (i) the Notice of the Settlement Hearing (which included a summary of the\n\nSettlement as well as the full text of the proposed Plan of Allocation) (the \u201cNotice\u201d) was mailed\n\nto all Settlement Class Members who or which could be identified with reasonable effort\n\nsubstantially in the form approved by the Court and (ii) a summary notice of the hearing\n\nsubstantially in the form approved by the Court was published in The Wall Street Journal and\n\nInvestor\u2019s Business Daily and released over PR Newswire pursuant to the specifications of the\n\nCourt; and the Court having considered and determined the fairness and reasonableness of the\n\nproposed Plan of Allocation; and, for the reasons set forth on the record during the Settlement\n\nHearing,\n\n NOW, THEREFORE, IT IS HEREBY ORDERED THAT:\n\n 1. This Order approving the proposed Plan of Allocation incorporates by reference the\n\ndefinitions in the Stipulation and Agreement of Settlement dated May 8, 2023 (Doc. 178-1), and\n\f Case\n Case1:23-cv-09476-KPF\n 1:20-cv-04494-JLR-SN\n Document\n Document\n 116-3\n 205 Filed 03/17/26\n 09/08/23 Page\n Page23ofof34\n\n\n\n\nas amended on August 31, 2023 (the \u201cStipulation\u201d) and all terms not otherwise defined herein shall\n\nhave the same meanings as set forth in the Stipulation.\n\n 2. The Court has jurisdiction to enter this Order approving the proposed Plan of\n\nAllocation, and over the subject matter of the Action and all Parties to the Action, including all\n\nSettlement Class Members.\n\n 3. Notice of Lead Plaintiffs\u2019 motion for approval of the proposed Plan of Allocation\n\nwas given to all Settlement Class Members who or which could be identified with reasonable\n\neffort. The form and method of notifying the Settlement Class of the motion for approval of the\n\nproposed Plan of Allocation satisfied the requirements of Rule 23 of the Federal Rules of Civil\n\nProcedure, the United States Constitution (including the Due Process Clause), and the Private\n\nSecurities Litigation Reform Act of 1995, 15 U.S.C. \u00a7 78u-4, as amended; constituted the best\n\nnotice practicable under the circumstances; and constituted due and sufficient notice to all persons\n\nand entities entitled thereto.\n\n 4. Copies of the Notice, which included the Plan of Allocation, were mailed to over\n\n1,835,000 potential Settlement Class Members and nominees, and no objections to the Plan of\n\nAllocation have been received.\n\n 5. The Court hereby finds and concludes that the formula for the calculation of the\n\nclaims of Claimants as set forth in the Plan of Allocation mailed to Settlement Class Members\n\nprovides a fair and reasonable basis upon which to allocate the proceeds of the Net Settlement\n\nFund among Settlement Class Members with due consideration having been given to\n\nadministrative convenience and necessity.\n\n\n\n\n 2\n\f Case\n Case1:23-cv-09476-KPF\n 1:20-cv-04494-JLR-SN\n Document\n Document\n 116-3\n 205 Filed 03/17/26\n 09/08/23 Page\n Page34ofof34\n\n\n\n\n 6. The Court hereby finds and concludes that the Plan of Allocation is, in all respects,\n\nfair and reasonable to the Settlement Class. Accordingly, the Court hereby approves the Plan of\n\nAllocation proposed by Lead Plaintiffs.\n\n 7. Any appeal or any challenge affecting this Order approving the Plan of Allocation\n\nshall in no way disturb or affect the finality of the Judgment.\n\n 8. There is no just reason for delay in the entry of this Order, and immediate entry by\n\nthe Clerk of the Court is expressly directed.\n\n SO ORDERED this __8_____\n th September ___ 2023.\n day of ___________\n\n\n\n ________________________________________\n The Honorable Jennifer L. Rochon\n United States District Judge\n\n\n\n\n 3\n\f","ocr_status":2,"date_upload":"2026-06-22T23:05:19.895389-07:00","document_number":"116","attachment_number":3,"pacer_doc_id":"127039252239","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit B (In re Wells Fargo)","acms_document_guid":""}],"date_created":"2026-03-17T12:13:06.297112-07:00","date_modified":"2026-10-20T06:53:54.450481-07:00","date_filed":"2026-03-17","time_filed":"13:40:38","entry_number":116,"recap_sequence_number":"2026-03-17.001","pacer_sequence_number":388,"description":"REPLY MEMORANDUM OF LAW in Support re: 110 MOTION for Attorney Fees and Expenses., 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation. . Document filed by Genesee County Employees' Retirement System. (Attachments: # 1 Appendix (Index of Exhibits), # 2 Exhibit A (In re XL Fleet), # 3 Exhibit B (In re Wells Fargo)).(Wood, Christopher) (Entered: 03/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/457476691/","id":457476691,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/472461489/","id":472461489,"tags":[],"absolute_url":"/docket/67923163/117/naclerio-v-docgo-inc/","date_created":"2026-03-17T12:13:05.110066-07:00","date_modified":"2026-06-23T05:40:43.217293-07:00","sha1":"916ec893db952b618b74c71f4e0c1a7008046f74","page_count":4,"file_size":109855,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.117.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.117.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 117 Filed 03/17/26 Page 1 of 4\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : SUPPLEMENTAL DECLARATION OF\n : ROSS D. MURRAY REGARDING: (A)\n vs. : CONTINUED NOTICE DISSEMINATION;\n : (B) UPDATE ON CALL CENTER\nDOCGO INC. and ANTHONY CAPONE, : SERVICES AND WEBSITE; AND (C)\n : REQUESTS FOR EXCLUSION RECEIVED\n Defendants. TO DATE\n :\n x\n\f Case 1:23-cv-09476-KPF Document 117 Filed 03/17/26 Page 2 of 4\n\n\n\n\n I, ROSS D. MURRAY, declare and state as follows:\n\n 1. I am employed as a Vice President of Securities by Verita Global (\u201cVerita\u201d),\n\nlocated at 1 McInnis Parkway, Suite 250, San Rafael, California. Pursuant to this Court\u2019s\n\nNovember 18, 2025 Order Preliminarily Approving Settlement and Providing for Notice (ECF\n\n106) (the \u201cNotice Order\u201d), Verita was appointed as the Claims Administrator in connection with\n\nthe proposed Settlement of the above-captioned litigation (the \u201cLitigation\u201d).1 I oversaw the notice\n\nservices that Verita provided in accordance with the Notice Order.\n\n 2. I submit this declaration as a supplement to my previously filed declaration, the\n\nDeclaration of Ross D. Murray Regarding: (A) Notice Dissemination; (B) Publication; (C)\nEstablishment of Call Center Services and Website; and (D) Requests for Exclusion Received to\n\nDate (ECF 114) (the \u201cInitial Mailing Declaration\u201d). The following statements are based on my\n\npersonal knowledge and information provided to me by other Verita employees, and, if called as\n\na witness, I could and would testify competently thereto.\n\n CONTINUED DISSEMINATION OF NOTICE\n\n 3. As more fully detailed in the Initial Mailing Declaration, as of February 12, 2026,\n\nVerita had mailed or emailed a total of 13,280 Postcard Notices and four copies of the Notice of\n\nPendency and Proposed Settlement of Class Action (the \u201cNotice\u201d) and Proof of Claim and Release\n\nform (the \u201cProof of Claim\u201d) (collectively, the \u201cClaim Package\u201d) to potential Class Members and\ntheir nominees. In addition, one institution reported that they anticipated sending Postcard Notices\n\nvia email to 9,972 potential Class Members. See Initial Mailing Declaration, \u00b611.\n\n 4. Since February 12, 2026, Verita has mailed two Claim Packages in response to\n\nrequests from potential Class Members, brokers, and nominees and as a result of mail returned as\n\n\n\n\n1\n Any capitalized terms used that are not otherwise defined herein shall have the meanings ascribed\nto them in the Stipulation of Settlement, dated November 12, 2025 (ECF 101-1) (the\n\u201cStipulation\u201d), which is available on the website established for the Settlement at\nwww.DocGoSecuritiesSettlement.com.\nSUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED\nNOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)\nREQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -1-\n\f Case 1:23-cv-09476-KPF Document 117 Filed 03/17/26 Page 3 of 4\n\n\n\n\nundeliverable for which new addresses were identified and re-mailed to those new addresses.2\n\nTherefore, as of March 13, 2026, Verita has mailed or emailed a total of 13,280 Postcard Notices\n\nand six Claim Packages to potential Class Members and nominees.\n\n UPDATE ON CALL CENTER SERVICES AND SETTLEMENT WEBSITE\n\n 5. Verita continues to maintain the toll-free telephone number (1-888-808-8947) to\n\naccommodate inquiries about the Settlement from potential Class Members. Verita also monitors\n\nthe case-dedicated e-mail address, info@DocGoSecuritiesSettlement.com. Verita endeavors to\n\nrespond timely to each telephone and e-mail inquiry and will continue to respond to Class Member\n\ninquiries via the toll-free telephone number and case dedicated e-mail address until the conclusion\nof the administration.\n\n 6. Verita also continues to maintain the website dedicated to the Settlement,\n\nwww.DocGoSecuritiesSettlement.com (the \u201cSettlement Website\u201d), to assist potential Class\n\nMembers. Following Lead Counsel\u2019s filing of their briefing in support of the Settlement on\n\nFebruary 17, 2026, Verita posted to the Settlement Website copies of the papers in support of the\n\nMotion for Final Approval of Class Action Settlement and Approval of Plan of Allocation and the\n\nMotion for an Award of Attorneys\u2019 Fees and Expenses. Verita will continue operating,\n\nmaintaining and, as appropriate, updating the Settlement Website until the conclusion of the\n\nadministration of this Settlement.\n REQUESTS FOR EXCLUSION AND OBJECTIONS RECEIVED TO DATE\n\n 7. Pursuant to the Notice Order, the Notice and Settlement Website informed potential\n\nClass Members that written requests for exclusion from the Class were to be mailed to Verita,\n\npostmarked or received no later than March 3, 2026. At the time of the Initial Mailing Declaration,\n\nVerita reported that it had not received any requests for exclusion. See Initial Mailing Declaration,\n\n\u00b616.\n\n\n\n2\n Verita has re-mailed a total of one Postcard Notice to persons whose original mailings were\nreturned by the United States Postal Service (\u201cUSPS\u201d) and for whom updated addresses were\nprovided to Verita by the USPS or were obtained through other means.\nSUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED\nNOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)\nREQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -2-\n\f Case 1:23-cv-09476-KPF Document 117 Filed 03/17/26 Page 4 of 4\n\n\n\n\n 8. Since the Initial Mailing Declaration was executed, and as of the date of this\n\ndeclaration, Verita has not received any requests for exclusion.\n\n 9. Although the Notice Order (and the Notice) provides that Class Members who wish\n\nto file objections must file them with the Court and copy them to relevant counsel (rather than to\n\nVerita), I also note for the sake of completeness that as of the date of this declaration Verita has\n\nnot received any objections.\n\n I declare under penalty of perjury that the foregoing is true and correct and that this\n\ndeclaration was executed this 13th day of March, 2026, at San Rafael, California.\n\n\n\n\n ROSS D. MURRAY\n\n\n\n\nSUPPLEMENTAL DECLARATION OF ROSS D. MURRAY REGARDING: (A) CONTINUED\nNOTICE DISSEMINATION; (B) UPDATE ON CALL CENTER SERVICES AND WEBSITE; AND (C)\nREQUESTS FOR EXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -3-\n\f","ocr_status":2,"date_upload":"2026-06-22T23:04:37.069076-07:00","document_number":"117","attachment_number":null,"pacer_doc_id":"127039252253","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Declaration in Support of Motion","acms_document_guid":""}],"date_created":"2026-03-17T12:13:05.080941-07:00","date_modified":"2026-10-20T06:53:54.518217-07:00","date_filed":"2026-03-17","time_filed":"13:42:14","entry_number":117,"recap_sequence_number":"2026-03-17.002","pacer_sequence_number":392,"description":"DECLARATION of Ross D. Murray [Supplemental] in Support re: 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation., 110 MOTION for Attorney Fees and Expenses.. Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 03/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/457476683/","id":457476683,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/472461481/","id":472461481,"tags":[],"absolute_url":"/docket/67923163/118/naclerio-v-docgo-inc/","date_created":"2026-03-17T12:13:02.297454-07:00","date_modified":"2026-03-17T12:13:02.306865-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"118","attachment_number":null,"pacer_doc_id":"127039252276","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Proposed Judgment","acms_document_guid":""}],"date_created":"2026-03-17T12:13:02.229708-07:00","date_modified":"2026-10-20T06:53:54.547134-07:00","date_filed":"2026-03-17","time_filed":"13:43:52","entry_number":118,"recap_sequence_number":"2026-03-17.003","pacer_sequence_number":396,"description":"PROPOSED JUDGMENT. 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Document filed by Genesee County Employees' Retirement System. Related Document Number: 108 ..(Wood, Christopher) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 03/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/457476672/","id":457476672,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/472461470/","id":472461470,"tags":[],"absolute_url":"/docket/67923163/120/naclerio-v-docgo-inc/","date_created":"2026-03-17T12:12:58.805374-07:00","date_modified":"2026-03-17T12:12:58.811927-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"120","attachment_number":null,"pacer_doc_id":"127039252317","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Proposed Order","acms_document_guid":""}],"date_created":"2026-03-17T12:12:58.760188-07:00","date_modified":"2026-10-20T06:53:54.575745-07:00","date_filed":"2026-03-17","time_filed":"13:46:03","entry_number":120,"recap_sequence_number":"2026-03-17.005","pacer_sequence_number":400,"description":"PROPOSED ORDER. Document filed by Genesee County Employees' Retirement System. Related Document Number: 110 ..(Wood, Christopher) Proposed Order to be reviewed by Clerk's Office staff. (Entered: 03/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454111546/","id":454111546,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469020195/","id":469020195,"tags":[],"absolute_url":"/docket/67923163/113/naclerio-v-docgo-inc/","date_created":"2026-02-17T13:09:09.260645-08:00","date_modified":"2026-06-23T03:25:30.566598-07:00","sha1":"5953b29ad1b7989b7a2713245ef26f51e567c376","page_count":3,"file_size":832423,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.113.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.113.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 113 Filed 02/17/26 Page 1 of 3\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n- -- - -- - - -- - - - -- X\nGENESEE COUNTY EMPLOYEES' Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, CLASS ACTION\n\n Plaintiff, DECLARATION OF TRACY KHAN IN\n SUPPORT OF LEAD PLAINTIFF'S\n vs. MOTION FOR FINAL APPROVAL OF\n SETTLEMENT AND AW ARD OF\nDOCGO INC. and ANTHONY CAPONE, ATTORNEYS' FEES AND EXPENSES\n\n Defendants.\n- - -- - - -- -- - - -- - X\n\f Case 1:23-cv-09476-KPF Document 113 Filed 02/17/26 Page 2 of 3\n\n\n\n\n I, Tracy Khan, declare as follows:\n\n 1. I am a trustee of Genesee County Employees' Retirement System (\"GCERS\"), and\n\nam authorized to make this declaration on behalf of GCERS. I previously served as the Vice Chair\n\nof GCERS and I have been responsible for overseeing this litigation on behalf of GCERS.\n\n 2. I respectfully submit this declaration in support of final approval of the $12.5\n\nmillion settlement (\"Settlement\"). I have personal knowledge of the statements herein and, if\n\ncalled upon as a witness, could and would competently testify thereto.\n\n 3. GCERS is a public pension fund organized for current and former employees of the\n\nCounty of Genesee in Flint, Michigan. With over $250 million in assets, GCERS provides services\n\nand benefits to over 1,000 members.\n\n 4. GCERS understands that the Private Securities Litigation Reform Act of 1995 was\n\nintended to encourage institutional investors to direct securities class actions. As Lead Plaintiff,\n\nGCERS has monitored the progress of this Litigation and the active participation of Lead Counsel\n\nRobbins Geller Rudman & Dowd LLP (\"Robbins Geller\") in its prosecution. In fulfillment of its\n\nresponsibilities on behalf of all members of the Class, GCERS: (i) engaged in numerous meetings,\n\nphone conferences, and correspondence with Lead Counsel; (ii) participated in the Litigation and\n\nprovided input into the prosecution of the case; (iii) searched for and provided documents and\n\ninformation responsive to Defendants' discovery requests; (iv) kept informed regarding case\n\nstatus; (v) reviewed documents filed in this action and opinions of the Court; (vi) consulted with\n\ncounsel and provided input regarding litigation and settlement strategy; (vii) participated in and\n\nwas kept informed about mediation and settlement negotiations; and (viii) considered and\n\napproved the proposed Settlement.\n\n\n\n\n - 1-\n\f Case 1:23-cv-09476-KPF Document 113 Filed 02/17/26 Page 3 of 3\n\n\n\n\n 5. GCERS authorized Lead Counsel to settle this action for $12.5 million. In making\n\nits determination that the $12.5 million Settlement represented a fair, reasonable, and adequate\n\namount for the Class, GCERS weighed the substantial benefits to the Class against the significant\n\nrisks and uncertainties of continued litigation. After doing so, GCERS believes that the Settlement\n\nrepresents an excellent recovery for the Class and a recovery that would not have been possible\n\nwithout the diligent efforts of Lead Counsel. GCERS believes the Settlement represents a fair,\n\nreasonable, and adequate recovery on behalf of the Class and that its approval is in the best interest\n\nof the Class.\n\n 6. While I recognize that any determination of attorneys' fees is left to the Court,\n\nGCERS believes the fee application for 33% of the Settlement Amount and expenses in an amount\n\nnot to exceed $200,000 is fair, reasonable, and appropriate given the facts and circumstances of\n\nthis case, Lead Counsel's high quality representation and its diligence in prosecuting this\n\nLitigation, and fees awarded in similar cases.\n\n I declare, under penalty of perjury, that the foregoing is true and correct. Executed this\n\n_j__ day of February, 2026, at J ~ fll\u00b7~\n\n\n TRUSTEE OF GENESEE COUNTY\n EMPLOYEES' RETIREMENT SYSTEM\n\n\n\n\n -2-\n\f","ocr_status":2,"date_upload":"2026-06-22T23:06:20.667733-07:00","document_number":"113","attachment_number":null,"pacer_doc_id":"127039079601","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Declaration in Support of Motion","acms_document_guid":""}],"date_created":"2026-02-17T13:09:09.238255-08:00","date_modified":"2026-02-20T12:05:41.019824-08:00","date_filed":"2026-02-17","time_filed":"14:05:07","entry_number":113,"recap_sequence_number":"2026-02-17.006","pacer_sequence_number":377,"description":"DECLARATION of Tracy Khan in Support re: 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation., 110 MOTION for Attorney Fees and Expenses.. Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454111537/","id":454111537,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469020183/","id":469020183,"tags":[],"absolute_url":"/docket/67923163/114/naclerio-v-docgo-inc/","date_created":"2026-02-17T13:09:07.834196-08:00","date_modified":"2026-06-23T03:25:28.203954-07:00","sha1":"35c815905e82756f8617c358cf0257e6e3717958","page_count":6,"file_size":126946,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 1 of 6\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : DECLARATION OF ROSS D. MURRAY\n : REGARDING: (A) NOTICE\n vs. : DISSEMINATION; (B) PUBLICATION; (C)\n : ESTABLISHMENT OF CALL CENTER\nDOCGO INC. and ANTHONY CAPONE, : SERVICES AND WEBSITE; AND (D)\n : REQUESTS FOR EXCLUSION RECEIVED\n Defendants. TO DATE\n :\n x\n\f Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 2 of 6\n\n\n\n\n I, ROSS D. MURRAY, declare and state as follows:\n\n 1. I am employed as a Vice President of Securities by Verita Global (\u201cVerita\u201d),\n\nlocated at 1 McInnis Parkway, Suite 250, San Rafael, California. The following statements are\n\nbased on my personal knowledge and information provided to me by others and if called to testify\n\nI could and would do so competently.\n\n 2. Pursuant to the Court\u2019s November 18, 2025 Order Preliminarily Approving\n\nSettlement and Providing for Notice (ECF 106) (the \u201cNotice Order\u201d), Verita was appointed as the\n\nClaims Administrator in connection with the proposed Settlement of the above-captioned litigation\n\n(the \u201cLitigation\u201d).1 I oversaw the notice services that Verita provided in accordance with the\nNotice Order.\n\n 3. I submit this declaration in order to provide the Court and the parties to the\n\nLitigation with information regarding: (i) mailing and emailing of the Court-approved Postcard\n\nNotice (attached hereto as Exhibit A) and, if requested by potential Class Members, mailing of the\n\nNotice of Pendency and Proposed Settlement of Class Action (the \u201cNotice\u201d) and Proof of Claim\n\nand Release form (the \u201cProof of Claim\u201d) (collectively, the \u201cClaim Package,\u201d attached hereto as\n\nExhibit B); (ii) publication of the Summary Notice of Pendency and Proposed Settlement of Class\n\nAction (the \u201cSummary Notice\u201d); (iii) establishment of the website and toll-free telephone number\n\ndedicated to this Settlement; and (iv) the number of requests for exclusion from the Class received\nto date by Verita.\n\n DISSEMINATION OF NOTICE\n\n 4. Pursuant to the Notice Order, Verita is responsible for disseminating notice of the\n\nSettlement to potential Class Members. The Class consists of all Persons who purchased DocGo\n\nInc. (\u201cDocGo\u201d) publicly traded common stock between November 5, 2021, and September 15,\n\n\n\n1\n Any capitalized terms used that are not otherwise defined herein shall have the meanings ascribed\nto them in the Stipulation of Settlement dated November 12, 2025 (ECF 101-1) (the \u201cStipulation\u201d),\nwhich is available on the website established for the Litigation at\nwww.DocGoSecuritiesSettlement.com.\n\nDECLARATION OF ROSS D. MURRAY REGARDING NOTICE DISSEMINATION, PUBLICATION,\nESTABLISHMENT OF CALL CENTER SERVICES AND WEBSITE, AND REQUESTS FOR\nEXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -1-\n\f Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 3 of 6\n\n\n\n\n2023, inclusive, and were damaged thereby. Excluded from the Class are: (i) Defendants and\n\nFormer Defendants and members of their immediate families; (ii) the officers and directors of\n\nDocGo during the Class Period and members of their immediate families; (iii) the legal\n\nrepresentatives, heirs, successors, or assigns of any of the foregoing; and (iv) any entity in which\n\nany Defendant or Former Defendant has or had a controlling interest. Also excluded from the\n\nClass is any Person who properly excludes himself, herself, itself, or themselves from the Class\n\nby submitting a valid and timely request for exclusion.\n\n 5. Verita received a file via email from DocGo\u2019s transfer agent, which contained the\n\nnames and addresses of potential Class Members. The list was reviewed to identify and eliminate\nduplicate entries and incomplete data, resulting in a usable mailing list of 93 unique names and\n\naddresses, and 22 email addresses. Verita had the unique name and address data printed onto\n\nPostcard Notices, posted the Postcard Notices for First-Class Mail, postage prepaid, and delivered\n\n93 Postcard Notices on December 9, 2025, to the United States Post Office for mailing.\n\nAdditionally, Verita emailed 22 Postcard Notices to potential Class Members with valid email\n\naddresses.\n\n 6. On December 9, 2025, as part of its normal mailing procedures, Verita mailed, by\n\nFirst-Class Mail, Postcard Notices and cover letters to 256 brokerages, custodial banks, and other\n\ninstitutions (\u201cNominee Holders\u201d) that hold securities in \u201cstreet name\u201d as nominees for the benefit\nof their customers who are the beneficial owners of the securities. The Nominee Holders also\n\ninclude a group of filers/institutions who have requested notification of every securities case.\n\nThese Nominee Holders are included in a proprietary database created and maintained by Verita.\n\nIn our experience, the Nominee Holders included in this proprietary database represent a\n\nsignificant majority of the beneficial holders of securities. The cover letter accompanying the\n\nPostcard Notices advised the Nominee Holders of the proposed Settlement and requested their\n\ncooperation in forwarding the Postcard Notices to potential Class Members. In the more than four\n\ndecades that we have been providing notice and claims administration services in securities class\n\nactions, we have found the majority of potential class members hold their securities in street name\n\nDECLARATION OF ROSS D. MURRAY REGARDING NOTICE DISSEMINATION, PUBLICATION,\nESTABLISHMENT OF CALL CENTER SERVICES AND WEBSITE, AND REQUESTS FOR\nEXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -2-\n\f Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 4 of 6\n\n\n\n\nand are notified through the Nominee Holders. Verita also mailed Postcard Notices and cover\n\nletters to 4,413 institutions included on the U.S. Securities and Exchange Commission\u2019s (\u201cSEC\u201d)\n\nlist of active brokers and dealers at the time of mailing. A sample of the cover letter mailed to\n\nNominee Holders and the institutions included on the SEC\u2019s list of active brokers and dealers is\n\nattached hereto as Exhibit C.\n\n 7. On December 9, 2025, Verita also delivered electronic copies of the Postcard\n\nNotice to 333 registered electronic filers who are qualified to submit electronic claims. These\n\nfilers are primarily institutions and third-party filers who typically file numerous claims on behalf\n\nof beneficial owners for whom they act as trustees or fiduciaries.\n 8. As part of the notice program for this Settlement, on December 9, 2025, Verita also\n\ncaused electronic copies of the Claim Package and Postcard Notice to be published by the\n\nDepository Trust Company (\u201cDTC\u201d) on the DTC Legal Notice System (\u201cLENS\u201d). LENS enables\n\nthe participating bank and broker nominees to review the Claim Package and Postcard Notice and\n\ncontact Verita for copies of the Postcard Notice for their beneficial holders.\n\n 9. Verita has acted as a repository for shareholder and nominee inquiries and\n\ncommunications received in this Settlement. In this regard, Verita has forwarded the Postcard\n\nNotice on request to nominees who purchased DocGo publicly traded common stock during the\n\nClass Period for the beneficial interest of other persons. Verita Global has also forwarded the\nPostcard Notice directly to beneficial owners upon receipt of the names and addresses from such\n\nbeneficial owners or nominees.\n\n 10. Following the initial mailing, Verita received seven responses to the outreach\n\nefforts described above, which included computer files containing a total of 1,448 names and\n\naddresses and 19 email addresses of potential Class Members. In addition, 28 institutions\n\nrequested that Verita send them a total of 6,695 Postcard Notices for forwarding directly to their\n\nclients. Verita has also mailed one Postcard Notice as a result of returned mail for which a new\n\naddress was identified for re-mailing to that potential Class Member. Verita also received four\n\n\n\nDECLARATION OF ROSS D. MURRAY REGARDING NOTICE DISSEMINATION, PUBLICATION,\nESTABLISHMENT OF CALL CENTER SERVICES AND WEBSITE, AND REQUESTS FOR\nEXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -3-\n\f Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 5 of 6\n\n\n\n\nrequests for Claim Packages from potential Class Members. Each of these requests has been\n\ncompleted in a timely manner.\n\n 11. As of February 12, 2026, Verita has mailed or emailed a total of 13,280 Postcard\n\nNotices and four Claim Packages to potential Class Members and nominees. In addition, one\n\ninstitution reported that they anticipated sending Postcard Notices via email to 9,972 potential\n\nClass Members.\n\n PUBLICATION OF THE SUMMARY NOTICE\n\n 12. In accordance with the Notice Order, on December 16, 2025, Verita caused the\n\nSummary Notice to be published in the national edition of The Wall Street Journal and transmitted\nover Business Wire, as shown in the confirmations of publication attached hereto as Exhibit D.\n\n ESTABLISHMENT OF CALL CENTER SERVICES AND SETTLEMENT WEBSITE\n\n 13. On December 9, 2025, Verita established and continues to maintain a case-specific,\n\ntoll-free telephone number, 1-888-808-8947, to accommodate potential Class Member inquiries.\n\nThe toll-free telephone number is set forth in the Notice, Proof of Claim, Postcard Notice,\n\nSummary Notice, and on the case website. Verita has been and will continue to promptly respond\n\nto all inquiries to the toll-free telephone helpline.\n\n 14. On December 9, 2025, Verita established and continues to maintain a website\n\ndedicated to this Settlement (www.DocGoSecuritiesSettlement.com) to provide additional\ninformation to Class Members and to provide answers to frequently asked questions. The web\n\naddress is set forth in the Notice, Proof of Claim, Postcard Notice, and Summary Notice. The\n\nwebsite includes information regarding the Litigation and the Settlement, including the exclusion,\n\nobjection, and claim filing deadlines, and details about the Court\u2019s Settlement Hearing. Copies of\n\nthe Notice, Proof of Claim, Stipulation, and Notice Order are posted on the website and are\n\navailable for downloading. In addition, the website provides Class Members with the ability to\n\nsubmit their Proofs of Claim online.\n\n\n\n\nDECLARATION OF ROSS D. MURRAY REGARDING NOTICE DISSEMINATION, PUBLICATION,\nESTABLISHMENT OF CALL CENTER SERVICES AND WEBSITE, AND REQUESTS FOR\nEXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -4-\n\f Case 1:23-cv-09476-KPF Document 114 Filed 02/17/26 Page 6 of 6\n\n\n\n\n REQUESTS FOR EXCLUSION RECEIVED TO DATE\n\n 15. The Notice informs potential Class Members that written requests for exclusion\n\nfrom the Class are to be sent to Verita, such that they are postmarked no later than March 3, 2026.\n\n 16. The Notice also sets forth the information that must be included in each request for\n\nexclusion. As of the date of this declaration, Verita has not received any requests for exclusion.\n\n 17. Although the Notice Order (and the Notice) provides that Class Members who wish\n\nto file objections must file them with the Court and copy them to relevant counsel (rather than to\n\nVerita), I also note for the sake of completeness that as of the date of this declaration Verita has\n\nnot received any objections.\n I declare under penalty of perjury that the foregoing is true and correct and that this\n\ndeclaration was executed this 12th day of February, 2026, at San Rafael, California.\n\n\n\n\n ROSS D. MURRAY\n\n\n\n\nDECLARATION OF ROSS D. MURRAY REGARDING NOTICE DISSEMINATION, PUBLICATION,\nESTABLISHMENT OF CALL CENTER SERVICES AND WEBSITE, AND REQUESTS FOR\nEXCLUSION RECEIVED TO DATE - 1:23-cv-09476-KPF -5-\n\f","ocr_status":2,"date_upload":"2026-06-22T23:05:37.854342-07:00","document_number":"114","attachment_number":null,"pacer_doc_id":"127039079635","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Declaration in Support of Motion","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663618/","id":483663618,"tags":[],"absolute_url":"/docket/67923163/114/1/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:05:29.235141-07:00","date_modified":"2026-06-23T06:03:33.933458-07:00","sha1":"cea333c4c0286cd8ec6414727b7aa18510f4e569","page_count":3,"file_size":192207,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 114-1 Filed 02/17/26 Page 1 of 3\n\n\n\n\n EXHIBIT A\n\fCase\n DocGo1:23-cv-09476-KPF\n Securities Settlement Document 114-1 Filed 02/17/26 Page 2 of 3\n Claims Administrator\n c/o Verita Global\n P.O. Box 301171\n Los Angeles, CA 90030-1171\n\n\n\n\n LEGAL NOTICE <>\n Genesee County Employees\u2019 Retirement Postal Service: Please Do Not Mark Barcode\n System v. DocGo Inc., et al.,\n No. 1:23-cv-09476-KPF DCGO - \u00abClaim8\u00bb-\u00abCkDig\u00bb\n www.DocGoSecuritiesSettlement.com\n \u00abFirstNAME\u00bb \u00abLastNAME\u00bb\n Court-Ordered Legal Notice\n (Forwarding Service Requested)\n \u00abName1\u00bb\n \u00abName2\u00bb\n This notice contains important information about a\n securities class action settlement. \u00abName3\u00bb\n You may be entitled to a payment.\n \u00abName4\u00bb\n This notice may affect your legal rights. \u00abAddr1\u00bb \u00abAddr2\u00bb\n Please read this notice carefully. \u00abCity\u00bb, \u00abState\u00bb\u00abFProv\u00bb \u00abZip\u00bb\u00abFZip\u00bb\n \u00abFCountry\u00bb\n\n DCGO\n\fCase 1:23-cv-09476-KPF Document 114-1 Filed 02/17/26 Page 3 of 3\n\n THIS POSTCARD PROVIDES ONLY LIMITED INFORMATION ABOUT THE SETTLEMENT.\n VISIT WWW.DOCGOSECURITIESSETTLEMENT.COM OR CALL 1-888-808-8947 FOR MORE INFORMATION.\n\n If you purchased DocGo Inc. (\u201cDocGo\u201d) publicly traded common stock between November 5, 2021, and September 15, 2023, inclusive, you could be entitled to\n a payment from a proposed settlement (\u201cSettlement\u201d) reached in the above-captioned action (\u201cLitigation\u201d). Your rights may be affected by this Litigation and the\n Settlement. A hearing will be held on March 24, 2026, at 10:00 a.m., at the United States District Court, Southern District of New York, Thurgood Marshall United\n States Courthouse, 40 Foley Square, Courtroom 618, New York, NY 10007 (\u201cSettlement Hearing\u201d), before the Honorable Katherine Polk Failla, to determine\n whether the proposed Settlement of the Litigation against Defendants DocGo and Anthony Capone for $12.5 million in cash and the Plan of Allocation should be\n approved as fair, reasonable, and adequate; whether the Litigation should be dismissed with prejudice against Defendants, as set forth in the Stipulation of Settlement\n (\u201cStipulation\u201d) filed with the Court; and whether Lead Counsel\u2019s application for an award of attorneys\u2019 fees of up to 33% of the Settlement Amount, and expenses not\n to exceed $250,000, plus interest on both amounts, should be granted.\n If approved, the Settlement will resolve a putative class action lawsuit alleging that, in violation of the U.S. federal securities laws, the Defendants misled investors\n by making materially false and misleading statements and failing to disclose material information, which caused DocGo\u2019s common stock to trade at artificially\n inflated prices until the nature of the alleged wrongdoing was revealed, causing DocGo\u2019s common stock price to fall. Defendants deny the allegations and any\n liability or wrongdoing of any kind. For a full description of the proposed Settlement and your rights, and to make a claim, you may obtain the Stipulation,\n long-form Notice of Pendency and Proposed Settlement of Class Action (\u201cNotice\u201d), and the Proof of Claim and Release form (\u201cClaim Form\u201d) by visiting the website:\n www.DocGoSecuritiesSettlement.com (\u201cWebsite\u201d) or you may request copies of the documents from the Claims Administrator by: (i) mail: DocGo Securities\n Settlement, Claims Administrator, c/o Verita Global, P.O. Box 301171, Los Angeles, CA 90030-1171; or (ii) toll-free call: 1-888-808-8947.\n To qualify for a payment from the Settlement, you must submit a valid Claim Form, with supporting documentation, postmarked or submitted online no later than\n March 9, 2026. Your pro rata share of the Settlement will depend on the number of valid claims, and the number, size, and timing of your transactions in DocGo\n publicly traded common stock. The estimated average distribution per share of DocGo publicly traded common stock is approximately $0.12, before deducting any\n Court-approved fees and expenses. Your actual share of the Settlement will be determined pursuant to the proposed Plan of Allocation set forth in the Notice, or other\n plan approved by the Court.\n You will be bound by any judgment or order entered in the Litigation, regardless of whether you submit a Claim Form, unless you timely and validly exclude yourself\n from the Class. If you exclude yourself from the Class, you cannot get money from this Settlement. If you are a Class Member and do not exclude yourself from\n the Class, you may object to the proposed Settlement, Plan of Allocation, and/or request for award of attorneys\u2019 fees and expenses no later than March 3, 2026. The\n long-form Notice and the Website explain how to exclude yourself from the Class or how to object.\n Lead Plaintiff and the Class are represented by Lead Counsel: Ellen Gusikoff Stewart, Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San\n Diego, CA 92101, 1-800-449-4900, settlementinfo@rgrdlaw.com. You may, but do not have to, attend the Settlement Hearing to be heard. The Court reserves the right\n to hold the Settlement Hearing telephonically or by other virtual means and/or change its date and/or time. Please check the Website for updates.\n\f","ocr_status":1,"date_upload":"2026-06-22T23:05:59.359051-07:00","document_number":"114","attachment_number":1,"pacer_doc_id":"127039079636","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit A (Postcard Notice)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663619/","id":483663619,"tags":[],"absolute_url":"/docket/67923163/114/2/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:05:29.251156-07:00","date_modified":"2026-06-23T05:58:16.807236-07:00","sha1":"bb93baefaf1859dc83826af122cce4171de0f986","page_count":27,"file_size":532788,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 1 of 27\n\n\n\n\n EXHIBIT B\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 2 of 27\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n x\nGENESEE COUNTY EMPLOYEES\u2019 RETIREMENT : Civil Action No. 1:23-cv-09476-KPF\nSYSTEM, Individually and on Behalf of All Others :\n CLASS ACTION\nSimilarly Situated, :\n :\n Plaintiff,\n :\n vs. :\n :\nDOCGO INC. and ANTHONY CAPONE, :\n Defendants. :\n x\n\n NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION\nTO: ALL PERSONS OR ENTITIES WHO PURCHASED DOCGO INC. (\u201cDocGo\u201d) PUBLICLY TRADED COMMON\nSTOCK BETWEEN NOVEMBER 5, 2021, AND SEPTEMBER 15, 2023, INCLUSIVE (THE \u201cCLASS PERIOD\u201d)\nPLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. YOUR RIGHTS MAY BE AFFECTED BY\nPROCEEDINGS IN THIS LITIGATION. PLEASE NOTE THAT IF YOU ARE A CLASS MEMBER, YOU MAY BE ENTITLED\nTO SHARE IN THE PROCEEDS OF THE SETTLEMENT DESCRIBED IN THIS NOTICE. TO CLAIM YOUR SHARE OF\nTHE SETTLEMENT PROCEEDS, YOU MUST SUBMIT A VALID PROOF OF CLAIM AND RELEASE FORM (\u201cPROOF OF\nCLAIM\u201d) POSTMARKED OR SUBMITTED ONLINE (AT WWW.DOCGOSECURITIESSETTLEMENT.COM) ON OR\nBEFORE MARCH 9, 2026.\n THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION.\n This Notice of Pendency and Proposed Settlement of Class Action (\u201cNotice\u201d) has been issued pursuant to Rule\n23 of the Federal Rules of Civil Procedure and an Order of the United States District Court for the Southern District of\nNew York (the \u201cCourt\u201d). The purpose of this Notice is to inform you of: (i) the pendency of this class action (the \u201cLitigation\u201d)\nbetween Genesee County Employees\u2019 Retirement System (\u201cLead Plaintiff\u201d) and DocGo and Anthony Capone\n(\u201cDefendants\u201d); (ii) the proposed $12.5 million cash settlement reached therein (the \u201cSettlement\u201d); and (iii) the hearing\n(the \u201cSettlement Hearing\u201d) to be held by the Court to consider the fairness, reasonableness, and adequacy of the\nSettlement, as set forth in the Stipulation of Settlement, dated November 12, 2025 (the \u201cStipulation\u201d), by and between\nLead Plaintiff and Defendants (the \u201cParties\u201d or \u201cSettling Parties\u201d). This Notice describes what steps you may take in\nrelation to the Settlement and this class action. 1\nThis Notice is not intended to be, and should not be construed as, an expression of any opinion by the Court with respect\nto the truth of the allegations in the Litigation as to any of the Defendants or the merits of the claims or defenses asserted\nby or against the Defendants. This Notice is solely to advise you of the pendency of the Litigation, the proposed Settlement\nof the Litigation, and your rights in connection therewith.\n\n\n\n\n1\n All capitalized terms used in this Notice that are not otherwise defined herein shall have the meanings provided in the Stipulation, which is available\non the website www.DocGoSecuritiesSettlement.com.\n\n 1\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 3 of 27\n\n YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT\n SUBMIT A PROOF The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must\n OF CLAIM be postmarked or submitted online on or before March 9, 2026.\n Get no payment. This is the only option that potentially allows you to ever be part of any other\n lawsuit against the Defendants or any other Released Defendant Parties about the legal claims\n being resolved by this Settlement. Should you elect to exclude yourself from the Class you\n EXCLUDE\n should understand that Defendants and the other Released Defendant Parties will have the\n YOURSELF FROM\n right to assert any and all defenses they may have to any claims that you may seek to assert,\n THE CLASS\n including, without limitation, the defense that any such claims are untimely under applicable\n statutes of limitations and statutes of repose. Requests for exclusion must be postmarked\n on or before March 3, 2026.\n Write to the Court about why you do not like the Settlement, the Plan of Allocation, and/or the\n request for attorneys\u2019 fees and expenses. You will still be a Member of the Class. Objections\n OBJECT\n must be received by the Court and counsel on or before March 3, 2026. If you submit a\n written objection, you may (but do not have to) attend the Settlement Hearing.\n GO TO THE\n SETTLEMENT Ask to speak in Court about the fairness of the Settlement, the Plan of Allocation, and/or the\n HEARING ON request for attorneys\u2019 fees and expenses. Requests to speak at the Settlement Hearing\n MARCH 24, 2026 AT must be received by the Court and counsel on or before March 3, 2026.\n 10:00 A.M.\n Receive no payment. You will, however, still be a Member of the Class, which means that you\n give up your right to ever be part of any other lawsuit against the Defendants or any other\n DO NOTHING\n Released Defendant Parties about the legal claims being resolved by this Settlement and you\n will be bound by any judgments or orders entered by the Court in the Litigation.\n SUMMARY OF THIS NOTICE\nStatement of Class Recovery\n Pursuant to the Settlement described herein, a $12.5 million cash settlement fund has been established. Based\non Lead Plaintiff\u2019s estimate of the number of allegedly damaged shares eligible to recover under the Settlement, the\naverage distribution per share of DocGo common stock under the Plan of Allocation is approximately $0.12, before\ndeduction of any taxes on the income earned on the Settlement Amount, notice and administration costs, and the\nattorneys\u2019 fees and expenses as determined by the Court. Class Members should note, however, that this is only an\nestimate. A Class Member\u2019s actual recovery will be a proportion of the Net Settlement Fund determined by that claimant\u2019s\nclaim as compared to the total claims of all Class Members who submit acceptable Proofs of Claim. An individual Class\nMember may receive more or less than this estimated average distribution amount. Please see the Plan of Allocation set\nforth and discussed at pages 9 through 13 below for more information on the calculation of your claim.\nStatement of Potential Outcome of Case\n The Settling Parties disagree on both liability and damages and do not agree on the amount of damages that\nwould be recoverable if the Class prevailed on each or any claim alleged. Defendants deny that they are liable to the\nClass and deny that the Class has suffered any damages. The issues on which the Settling Parties disagree are many,\nbut include: (1) whether Defendants engaged in conduct that would give rise to any liability to the Class under the federal\nsecurities laws; (2) whether Defendants have valid defenses to any such claims of liability; (3) the appropriate economic\nmodel for determining the amount by which the price of DocGo common stock was allegedly artificially inflated (if at all)\nduring the relevant period; and (4) the amount, if any, by which the price of DocGo common stock was allegedly artificially\ninflated (if at all) during the relevant period.\nStatement of Attorneys\u2019 Fees and Expenses Sought\n Since the Litigation\u2019s inception, Lead Plaintiff\u2019s Counsel have expended considerable time and effort in the\nprosecution of this Litigation on a wholly contingent basis and have advanced the expenses of the Litigation in the\nexpectation that if they were successful in obtaining a recovery for the Class, they would be paid from such recovery.\nLead Counsel will apply to the Court, on behalf of all Lead Plaintiff\u2019s Counsel, for an award of attorneys\u2019 fees not to exceed\n33% of the Settlement Amount, plus expenses not to exceed $250,000, plus interest earned on both amounts at the same\nrate as earned by the Settlement Fund. 2 If the amounts requested are approved by the Court, the average cost per DocGo\ncommon share will be approximately $0.04.\n\n\n\n\n2\n Lead Plaintiff\u2019s Counsel refers to Lead Counsel, Robbins Geller Rudman & Dowd LLP, and additional counsel Vanoverbeke, Michaud & Timmony, P.C.\n\n 2\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 4 of 27\n\nFurther Information\n For further information regarding the Litigation, this Notice, or to review the Stipulation, please contact the Claims\nAdministrator toll-free at 1-888-808-8947, or visit the website, www.DocGoSecuritiesSettlement.com.\n You may also contact a representative of counsel for the Class: Greg Wood, Shareholder Relations, Robbins\nGeller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, 1-800-449-4900,\nsettlementinfo@rgrdlaw.com.\n Please Do Not Call the Court or Defendants with Questions About the Settlement.\nReasons for the Settlement\n Lead Plaintiff\u2019s principal reason for entering into the Settlement is the benefit to the Class now, without further\nrisk or the delays inherent in continued litigation. The cash benefit under the Settlement must be considered against the\nsignificant risk that a smaller recovery \u2013 or, indeed, no recovery at all \u2013 might be achieved after contested motions, trial,\nand likely appeals, a process that could last several years into the future. For Defendants, who have denied and continue\nto deny all allegations of liability, fault, or wrongdoing whatsoever, the principal reason for entering into the Settlement is\nto eliminate the uncertainty, risk, costs, and burdens inherent in any litigation, especially in complex cases such as this\nLitigation. Defendants have concluded that further conduct of this Litigation could be protracted and distracting.\n BASIC INFORMATION\n1. What is the purpose of this Notice?\n The Court has directed the issuance of this Notice to inform potential Class Members about the Litigation and the\nproposed Settlement and their options in connection therewith before the Court rules on the Settlement. Additionally,\nClass Members have the right to understand how this class action lawsuit may generally affect their legal rights.\n This Notice explains the class action lawsuit, the Settlement, Class Members\u2019 legal rights in connection with the\nSettlement, what benefits are available, who is eligible for them, and how to get them.\n The Court in charge of the Litigation is the United States District Court for the Southern District of New York, and\nthe case is known as Genesee County Employees\u2019 Retirement System v. DocGo Inc., et al., No. 1:23-cv-09476-KPF. The\ncase has been assigned to the Honorable Katherine Polk Failla. The entity representing the Class is the \u201cLead Plaintiff,\u201d\nand the company and individual it sued and who have now settled are called the \u201cDefendants.\u201d\n The issuance of this Notice is not an expression of any opinion by the Court concerning the merits of any claim\nin the Litigation, and the Court still has to decide whether to approve the Settlement. If the Court approves the Settlement\nand a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after\nthe completion of all claims processing. Please be patient, as this process can take some time to complete.\n2. What is this lawsuit about?\n The Litigation is currently pending before Judge Katherine Polk Failla in the United States District Court for the\nSouthern District of New York (the \u201cCourt\u201d). The initial complaint in the Litigation was filed on October 27, 2023. On\nJanuary 17, 2024, the Court appointed Genesee County Employees\u2019 Retirement System as Lead Plaintiff and Robbins\nGeller Rudman & Dowd LLP as Lead Counsel.\n On March 20, 2024, Lead Plaintiff filed the Amended Complaint for Violations of the Federal Securities Laws (the\n\u201cComplaint\u201d) alleging violations of \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934 (the \u201cExchange Act\u201d). Lead\nPlaintiff alleged that throughout the Class Period Defendants made materially false or misleading statements and/or failed\nto disclose (i) DocGo\u2019s Chief Executive Officer, defendant Anthony Capone, fabricated his educational background in\ncomputational learning theory, a subset of AI; and (ii) contrary to Capone\u2019s representations to investors, DocGo did not sign\nasylum seekers up for New York Medicaid and could not leverage signups into future business in DocGo\u2019s payer vertical.\nWhen the truth regarding Defendants\u2019 allegedly false and misleading statements was publicly disclosed, the price of DocGo\ncommon stock declined, causing damage to Class Members. Defendants deny Lead Plaintiff\u2019s allegations. On\nJune 21, 2024, Defendants and former defendants Stan Vashovsky and Andre Oberholzer (the \u201cFormer Defendants\u201d) moved\nto dismiss the Complaint. Lead Plaintiff filed its opposition to the motion on August 20, 2024, and Defendants and the Former\nDefendants filed their replies on September 19, 2024. On March 28, 2025, the Court granted in part and denied in part the\nmotion to dismiss. The Court upheld certain of Lead Plaintiff\u2019s claims against Defendants DocGo and Capone, and dismissed\nall of its claims against the Former Defendants. Defendants answered the Complaint on April 25, 2025.\n On May 2, 2025, Lead Plaintiff and Defendants filed their joint proposed Stipulated Protective Order and their\njoint proposed Civil Case Management Plan and Scheduling Order, which were both so ordered on May 5, 2025.\n Beginning in June 2025, the Parties exchanged discovery requests and served subpoenas on a number of third parties.\n\n\n\n 3\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 5 of 27\n\n On July 21, 2025, Lead Plaintiff filed its motion for class certification, supported by an expert report. On\nAugust 18, 2025, the Court granted the Parties\u2019 request for a 30-day extension of the deadlines in the previously-entered\nscheduling order.\n Lead Plaintiff and Defendants participated in a voluntary confidential mediation session with Miles Ruthberg (of\nPhillips ADR), an experienced mediator, on September 9, 2025. The mediation session was preceded by the submission\nand exchange of mediation statements by both Lead Plaintiff and Defendants. The Parties engaged in good-faith\nnegotiations, but did not reach a settlement at the mediation session. Following additional settlement discussions with Mr.\nRuthberg, on September 26, 2025, the Parties accepted a mediator\u2019s proposal to settle the Litigation in return for a cash\npayment of $12.5 million to be paid by or on behalf of Defendants for the benefit of the Class, subject to the negotiation\nof the terms of a stipulation of settlement and approval by the Court. The Stipulation (together with the Exhibits thereto)\nreflects the final and binding agreement among the Settling Parties.\n3. Why is there a settlement?\n The Court has not decided in favor of Defendants or Lead Plaintiff. Instead, both sides agreed to the Settlement\nto avoid the distraction, costs, and risks of further litigation, and Lead Plaintiff agreed to the Settlement in order to ensure\nthat Class Members will receive compensation.\n If there were no Settlement and Lead Plaintiff failed to establish any essential legal or factual element of remaining\nclaims against the remaining Defendants, neither Lead Plaintiff nor the other Members of the Class would recover\nanything from Defendants. Also, if Defendants proved any of their defenses at summary judgment, trial, or on appeal, the\nClass could recover substantially less than the amount provided in the Settlement, or nothing at all.\n WHO IS IN THE SETTLEMENT\n4. How do I know if I am a Member of the Class?\n The Court directed that everyone who fits this description is a Class Member: All Persons who purchased DocGo\npublicly traded common stock between November 5, 2021, and September 15, 2023, inclusive, and were damaged\nthereby. Excluded from the Class are: (i) Defendants and Former Defendants and members of their immediate families;\n(ii) the officers and directors of DocGo during the Class Period and members of their immediate families; (iii) the legal\nrepresentatives, heirs, successors, or assigns of any of the foregoing; and (iv) any entity in which any Defendant or Former\nDefendant has or had a controlling interest. Also excluded from the Class is any Person who properly excludes himself,\nherself, itself, or themselves from the Class by submitting a valid and timely request for exclusion.\n Please Note: Receipt of this Notice or the Postcard Notice does not mean that you are a Class Member or that\nyou will be entitled to receive a payment from the Settlement. If you are a Class Member and you wish to be eligible to\nparticipate in the distribution of the proceeds from the Settlement, you are required to submit a Proof of Claim and the\nrequired supporting documentation as set forth therein postmarked or submitted online on or before March 9, 2026.\n5. What if I am still not sure if l am included in the Class?\n If you are still not sure whether you are included in the Class, you can ask for free help. You can contact the\nClaims Administrator toll-free at 1-888-808-8947, or you can fill out and return the Proof of Claim to see if you qualify.\n THE SETTLEMENT BENEFITS \u2013 WHAT YOU GET\n6. What does the Settlement provide?\n The Settlement provides that, in exchange for the release of the Released Plaintiff\u2019s Claims (defined below) and\ndismissal of the Litigation, Defendants have agreed to pay or cause to be paid $12.5 million in cash to be distributed after\nTaxes, Tax Expenses, Notice and Administration Expenses, and Court-approved attorneys\u2019 fees and expenses, pro rata,\nto Class Members who send in a valid Proof of Claim pursuant to the Court-approved Plan of Allocation and who would\nreceive at least $10.00. The Plan of Allocation is described in more detail at the end of this Notice.\n7. How much will my payment be?\n Your share of the Net Settlement Fund will depend on several things, including the total dollar amount of claims\nrepresented by the valid Proofs of Claim that Class Members submit, compared to the dollar amount of your claim, all as\ncalculated under the Plan of Allocation discussed below.\n\n\n\n\n 4\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 6 of 27\n\n HOW YOU GET A PAYMENT \u2013 SUBMITTING A PROOF OF CLAIM\n8. How can I get a payment?\n To be eligible to receive a payment from the Settlement, you must submit a Proof of Claim. A Proof of Claim may\nbe downloaded at www.DocGoSecuritiesSettlement.com. Read the instructions contained in the Proof of Claim carefully,\nfill out the Proof of Claim, include all the documents the form asks for, sign it, and mail (to DocGo Securities Settlement,\nClaims Administrator, c/o Verita Global, P.O. Box 301171, Los Angeles, CA 90030-1171) or submit it online at\nwww.DocGoSecuritiesSettlement.com so that it is postmarked or received no later than March 9, 2026.\n9. When will I get my payment?\n The Court will hold a Settlement Hearing on March 24, 2026, at 10:00 a.m., to decide whether to approve the\nSettlement. If the Court approves the Settlement, there might be appeals. It is always uncertain whether appeals can be\nresolved, and if so, how long it will take to resolve them. It also takes time for all the Proofs of Claim to be processed.\nPlease be patient.\n10. What am I giving up to get a payment or to stay in the Class?\n If you are a Class Member, unless you timely and validly exclude yourself from the Class, you will remain a Class\nMember, and that means you cannot sue, continue to sue, or be part of any other lawsuit against Defendants or the\nReleased Defendant Parties about the Released Plaintiff\u2019s Claims (as defined below) in this Litigation. It also means that\nall of the Court\u2019s orders will apply to you and legally bind you. If you remain a Class Member, and if the Settlement is\napproved, you will give up all \u201cReleased Plaintiff\u2019s Claims\u201d (as defined below), including \u201cUnknown Claims\u201d (as defined\nbelow), against the \u201cDefendants\u2019 Released Persons\u201d (as defined below):\n \u2022 \u201cReleased Plaintiff\u2019s Claims\u201d means any and all claims and causes of action of every nature and\n description, whether known or unknown, including Unknown Claims (as defined below), demands, losses,\n and rights, whether arising under federal, state, local, common, statutory, administrative or foreign law,\n or any other law, rule or regulation, at law or in equity, whether class or individual in nature, whether\n accrued or unaccrued, whether liquidated or unliquidated, whether matured or unmatured, that Lead\n Plaintiff or any other Class Member has or could have asserted in any court or forum, based on, arising\n out of, or in connection with: (i) any purchase or acquisition of publicly traded DocGo common stock\n during the period between November 5, 2021, and September 15, 2023, inclusive; and (ii) the conduct,\n allegations, acts, facts, matters, occurrences, transactions, disclosures, filings, representations,\n statements, or omissions that were or could have been alleged by Lead Plaintiff or any other Member of\n the Class in the Litigation. Released Plaintiff\u2019s Claims do not include: (i) any claims related to the\n enforcement of the Settlement; (ii) any derivative claims; (iii) any claims arising out of ERISA; or (iv) any\n claims of any Person who or which submits a timely and valid request for exclusion from the Class that\n is accepted by the Court.\n \u2022 \u201cReleased Defendants\u2019 Claims\u201d means any and all claims and causes of action of every nature and\n description whatsoever, including both known claims and Unknown Claims (as defined below), whether\n arising under federal, state, common, or foreign law, against the Releasing Plaintiff Parties (as defined\n below) that arise out of or relate in any way to the institution, prosecution, or settlement of the claims against\n Defendants or the Former Defendants in the Litigation. Released Defendants\u2019 Claims do not include: (i) any\n claims relating to the enforcement of the Settlement; or (ii) any claims against any Person who or which\n submits a timely and valid request for exclusion from the Class that is accepted by the Court.\n \u2022 \u201cReleased Defendant Party\u201d or \u201cReleased Defendant Parties\u201d or \u201cDefendants\u2019 Released Persons\u201d mean\n any or all of Defendants and the Former Defendants and/or any or all of their current, former, or future\n parents, affiliates, subsidiaries, business units, divisions, or controlling shareholders; and each and all of\n their and Defendants\u2019 and the Former Defendants\u2019 respective current, former, or future officers, directors,\n employees, members, managers, partners, principals, controlling shareholders, joint ventures, related\n entities, agents, advisors, accountants, auditors, insurers, reinsurers, and attorneys; and the\n predecessors, successors, estates, assigns, assignees, immediate family members, spouses, heirs,\n executors, trusts, trustees, administrators, agents, legal or personal representatives of each of them, in\n their capacities as such, and any entity in which any Defendant has or had a controlling interest. The\n Released Defendant Parties other than the Defendants themselves, including the Former Defendants,\n are intended as third party beneficiaries of this Settlement with respect to the release of the Released\n Plaintiff\u2019s Claims.\n\n\n\n\n 5\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 7 of 27\n\n\u2022 \u201cReleasing Plaintiff Party\u201d or \u201cReleasing Plaintiff Parties\u201d mean Lead Plaintiff, all other plaintiffs in the\n Litigation, their respective attorneys, and all other Class Members, and each and all of their respective\n current, former, or future parents, affiliates, subsidiaries, business units, divisions, or controlling\n shareholders; each and all of their respective current, former, or future officers, directors, employees,\n members, managers, partners, principals, controlling shareholders, agents, advisors, accountants, auditors,\n insurers, reinsurers, related entities and attorneys; and the predecessors, successors, estates, estate\n managers, assigns, assignees, immediate family members, spouses, heirs, executors, trusts, trustees,\n administrators, agents, legal or personal representative of each of them, in their capacities as such.\n\u2022 \u201cUnknown Claims\u201d means: (a) any and all Released Plaintiff\u2019s Claims that any of the Releasing Plaintiff\n Parties do not know or suspect to exist in his, her, or its favor at the time of the release of such claims;\n and (b) any and all Released Defendants\u2019 Claims that any of the Released Defendant Parties do not\n know or suspect to exist in his, her, or its favor at the time of the release of such claims, and including,\n without limitation, those that, if known by him, her, or it, might have affected his, her, or its decision(s)\n with respect to this Settlement. Unknown Claims include, without limitation, those claims in which some\n or all of the facts composing the claim may be unsuspected, undisclosed, concealed, or hidden. With\n respect to: (a) any and all Released Plaintiff\u2019s Claims against the Released Defendant Parties; and\n (b) any and all Released Defendants\u2019 Claims against the Releasing Plaintiff Parties, the Settling Parties\n stipulate and agree that, upon the Effective Date, the Settling Parties shall expressly waive, and each\n Releasing Plaintiff Party and Released Defendant Party shall be deemed to have, and by operation of\n the Judgment shall have expressly waived, any and all provisions, rights, and benefits conferred by any\n law of any state or territory of the United States or principle of common law or foreign law, that is similar,\n comparable, or equivalent to California Civil Code \u00a71542, which provides:\n A general release does not extend to claims that the creditor or releasing party\n does not know or suspect to exist in his or her favor at the time of executing the release\n and that, if known by him or her, would have materially affected his or her settlement with\n the debtor or released party.\n The Settling Parties shall fully, finally, and forever expressly waive any and all provisions, rights, and\n benefits conferred by any law of any state or territory of the United States or any other jurisdiction, or\n principle of common law, which is similar, comparable, or equivalent to California Civil Code \u00a71542. The\n Releasing Plaintiff Parties and Released Defendant Parties acknowledge that they may hereafter\n discover facts, legal theories, or authorities in addition to or different from those which he, she, it, or their\n counsel now knows or believes to be true with respect to the subject matter of the Released Plaintiff\u2019s\n Claims or Released Defendants\u2019 Claims, but: (a) the Releasing Plaintiff Parties shall expressly, fully,\n finally, and forever waive, compromise, settle, discharge, extinguish, and release, and each Releasing\n Plaintiff Party shall be deemed to have waived, compromised, settled, discharged, extinguished, and\n released, and upon the Effective Date, and by operation of the Judgment shall have waived,\n compromised, settled, discharged, extinguished, and released, fully, finally, and forever, any and all\n Released Plaintiff\u2019s Claims against the Released Defendant Parties, known or unknown, suspected or\n unsuspected, contingent or non-contingent, accrued or unaccrued, whether or not concealed or hidden,\n which now exist, or heretofore have existed, or may hereafter exist, upon any theory of law or equity now\n existing or coming into existence in the future, including, but not limited to, conduct which is negligent,\n intentional, with or without malice, or a breach of any duty, law, or rule, without regard to the subsequent\n discovery or existence of such different or additional facts, legal theories, or authorities; and (b) the\n Released Defendant Parties shall expressly, fully, finally, and forever waive, compromise, settle,\n discharge, extinguish, and release, and each Released Defendant Party shall be deemed to have waived,\n compromised, settled, discharged, extinguished, and released, and upon the Effective Date, and by\n operation of the Judgment shall have waived, compromised, settled, discharged, extinguished, and\n released, fully, finally, and forever, any and all Released Defendants\u2019 Claims against Lead Plaintiff, the\n Class, and Lead Plaintiff\u2019s Counsel, known or unknown, suspected or unsuspected, contingent or\n non-contingent, whether or not concealed or hidden, which now exist, or heretofore have existed, upon\n any theory of law or equity now existing or coming into existence in the future, including, but not limited\n to, conduct which is negligent, intentional, with or without malice, or a breach of any duty, law or rule,\n without regard to the subsequent discovery or existence of such different or additional facts, legal\n theories, or authorities. The Settling Parties acknowledge, and the Releasing Plaintiff Parties and\n Released Defendant Parties shall be deemed by operation of law to have acknowledged, that the\n foregoing waiver was separately bargained for and is a key element of the Settlement of which this\n release is a part.\n\n\n\n\n 6\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 8 of 27\n\n EXCLUDING YOURSELF FROM THE CLASS\n If you do not want to participate in this Settlement, and you want to keep the right to potentially sue Defendants\nand the other Released Defendant Parties, on your own, about the claims being released by the Settlement, then you\nmust take steps to remove yourself from the Class. This is called excluding yourself \u2013 or is sometimes referred to as\n\u201copting out.\u201d If you are requesting exclusion from the Class because you want to bring your own lawsuit based on the\nmatters alleged in this Litigation, you may want to consult an attorney and discuss whether any individual claim that you\nmay wish to pursue would be time-barred by the applicable statutes of limitation or repose. If timely and valid requests for\nexclusion exceed a certain amount, as set forth in a separate confidential agreement between the Settling Parties, DocGo\nshall have, in its discretion, the option to terminate the Settlement in accordance with the procedures set forth in the\nSupplemental Agreement.\n11. How do I get out of the Class and the proposed Settlement?\n To exclude yourself from the Class and the Settlement, you must send a letter by First-Class Mail stating that you\n\u201crequest exclusion from the Class in the DocGo Securities Settlement.\u201d Your letter must include your purchases and sales\nof DocGo common stock during the Class Period, including the dates and number of shares of DocGo common stock you\npurchased and sold, and the price paid for each such purchase and received for each such sale. In addition, you must\ninclude your name, address, email address, telephone number, and your signature. You must mail your exclusion request\nso that it is postmarked no later than March 3, 2026 to:\n DocGo Securities Settlement\n Claims Administrator\n c/o Verita Global\n EXCLUSIONS\n P.O. Box 5100\n Larkspur, CA 94977-5100\n If you properly exclude yourself, you will not get any payment from the Settlement, and you cannot object to the\nSettlement. You will not be legally bound by anything that happens in this lawsuit, and you may be able to sue the\nDefendants and the other Released Defendant Parties about the Released Plaintiff\u2019s Claims in the future, if such claims\nare not time-barred.\n12. If I do not exclude myself, can I sue the Defendants and the other Released Defendant Parties for the\n same thing later?\n No. Unless you exclude yourself from the Class, you give up any rights you may potentially have to sue the\nDefendants and the other Released Defendant Parties for any and all Released Plaintiff\u2019s Claims. If you have a pending\nlawsuit against any of the Released Defendant Parties, speak to your lawyer in that case immediately. You must exclude\nyourself from the Class in this Litigation to continue your own lawsuit. Remember, the exclusion deadline is March 3, 2026.\n13. If I exclude myself, can I get money from the proposed Settlement?\n No. If you exclude yourself from the Class, you should not send in a Proof of Claim to ask for any money from the\nSettlement. But you may have the right to potentially sue or be part of a different lawsuit against the Defendants and/or\nthe other Released Defendant Parties.\n THE LAWYERS REPRESENTING YOU\n14. Do I have a lawyer in this case?\n The Court ordered that the law firm of Robbins Geller Rudman & Dowd LLP represents the Class Members,\nincluding you. These lawyers are called Lead Counsel. If you want to be represented by your own lawyer, you may hire\none at your own expense.\n15. How will the lawyers be paid?\n Lead Counsel, on behalf of Lead Plaintiff\u2019s Counsel, will apply to the Court for an award of attorneys\u2019 fees not to\nexceed 33% of the Settlement Amount and for expenses, costs, and charges in an amount not to exceed $250,000 in\nconnection with the Litigation, plus interest on such fees and expenses at the same rate as earned by the Settlement\nFund. Such sums as may be approved by the Court will be paid from the Settlement Fund.\n\n\n\n\n 7\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 9 of 27\n\n OBJECTING TO THE SETTLEMENT\n You can tell the Court that you do not agree with the Settlement or any part of it.\n16. How do I tell the Court that I object to the proposed Settlement?\n If you are a Class Member, you can comment on or object to the proposed Settlement, the proposed Plan of\nAllocation, and/or Lead Counsel\u2019s fee and expense application. You can write to the Court setting out your comment or\nobjection. The Court will consider your views. To comment or object, you must send a signed letter saying that you wish\nto comment on or object to the proposed Settlement in the DocGo Securities Settlement. Include your name, address,\nemail address, telephone number, and your signature (even if you are represented by counsel), identify the date(s),\nprice(s), and number of shares of DocGo common stock purchased or sold during the Class Period, and state with\nspecificity your comments or the reasons why you object to the Settlement, Plan of Allocation, and/or fee and expense\napplication, including any legal and evidentiary support for such objection. Any objection must state whether it applies\nonly to the objector, to a specific subset of the Class, or to the entire Class. In addition, the objector must identify all class\naction settlements to which the objector or his, her, or its counsel have previously objected. You must also include copies\nof documents demonstrating your purchases and/or sales of DocGo common stock during the Class Period. Your\ncomment or objection must be filed with the Court and mailed or delivered to each of the following addresses such that it\nis received no later than March 3, 2026:\n COURT LEAD COUNSEL DEFENDANTS\u2019 COUNSEL\n CLERK OF THE COURT ROBBINS GELLER RUDMAN GIBSON, DUNN\n UNITED STATES DISTRICT COURT & DOWD LLP & CRUTCHER LLP\n SOUTHERN DISTRICT OF NEW YORK Attn: Ellen Gusikoff Stewart Attn: Lissa M. Percopo\n 500 Pearl Street 655 West Broadway, Suite 1900 1700 M Street, N.W.\n New York, NY 10007 San Diego, CA 92101 Washington, DC 20036\n17. What is the difference between objecting and excluding?\n Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if\nyou stay in the Class.\n Excluding yourself is telling the Court that you do not want to be paid and do not want to release any claims you\nthink you may have against the Defendants and the other Released Defendant Parties. If you exclude yourself from the\nClass, you cannot object to the Settlement because it does not affect you.\n THE COURT\u2019S SETTLEMENT HEARING\n The Court will hold a hearing to decide whether to approve the proposed Settlement. You may attend the hearing\nand speak, but you do not have to.\n18. When and where will the Court decide whether to approve the proposed Settlement?\n The Court will hold a Settlement Hearing at 10:00 a.m., on March 24, 2026, before the Honorable Katherine Polk\nFailla, at the United States District Court for the Southern District of New York, Thurgood Marshall United States\nCourthouse, 40 Foley Square, Courtroom 618, New York, NY 10007. At the hearing, the Court will consider whether the\nSettlement and the Plan of Allocation are fair, reasonable, and adequate. If there are objections, the Court will consider\nthem, even if the objectors do not ask to speak at the hearing. The Court will listen to people who have asked to speak at\nthe hearing. The Court may also decide the amount of attorneys\u2019 fees and expenses to award Lead Counsel. At or after\nthe Settlement Hearing, the Court will decide whether to approve the Settlement and the Plan of Allocation. We do not\nknow how long these decisions will take. You should be aware that the Court may change the date, time, and location of\nthe Settlement Hearing without another notice being sent to Class Members.\n There exists the possibility that the Court may decide to conduct the Settlement Hearing by video or telephonic\nconference, or otherwise allow Class Members to appear at the hearing by telephone or video conference, without further\nwritten notice to the Class. In order to determine whether the date and time of the Settlement Hearing have changed, or\nwhether Class Members (who wish to attend the hearing) must or may participate by telephone or video, it is important\nthat you monitor the Court\u2019s docket or the website, www.DocGoSecuritiesSettlement.com, before making any plans to\nattend the Settlement Hearing. Any updates regarding the Settlement Hearing, including any changes to the date and\ntime of the hearing or updates regarding in-person or remote appearances at the hearing, will be posted to the Settlement\nwebsite. Also, if the Court requires or allows Class Members to participate in the Settlement Hearing by telephone or\nvideo conference, the information for accessing the hearing will be posted to the Settlement website. Accordingly, please\ncontinue to check the Settlement website for important updates.\n\n\n\n\n 8\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 10 of 27\n\n19. Do I have to come to the Settlement Hearing?\n No. Lead Counsel will answer any questions the Court may have. But you are welcome to come at your own\nexpense. If you are a Class Member and send an objection, you do not have to come to Court to talk about it. As long as\nyou are a Class Member and mailed your complete written objection on time, the Court will consider it. You may also pay\nyour own lawyer to attend the hearing, but it is not necessary. Class Members do not need to appear at the hearing or\ntake any other action to indicate their approval.\n20. May I speak at the Settlement Hearing?\n If you object to the Settlement, the Plan of Allocation, and/or the fee and expense application, you may ask the\nCourt for permission to speak at the Settlement Hearing. To do so, you must include with your objection (see question 16\nabove) a statement saying that it is your \u201cNotice of Intention to Appear in the DocGo Securities Settlement.\u201d Persons who\nintend to object to the Settlement, the Plan of Allocation, and/or any attorneys\u2019 fees and expenses to be awarded to Lead\nPlaintiff\u2019s Counsel and desire to present evidence at the Settlement Hearing must include in their written objections the\nidentity of any witnesses they may call to testify and any exhibits they intend to introduce into evidence at the Settlement\nHearing. Your notice of intention to appear must be received no later than March 3, 2026, and addressed to the Clerk\nof Court, Lead Counsel, and Defendants\u2019 Counsel, at the addresses listed above in question 16.\n You cannot speak at the hearing if you exclude yourself from the Class.\n IF YOU DO NOTHING\n21. What happens if I do nothing?\n If you do nothing, you will not receive any money from this Settlement. In addition, unless you exclude yourself\nfrom the Class, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the\nDefendants and the other Released Defendant Parties about the Released Plaintiff\u2019s Claims in this case.\n GETTING MORE INFORMATION\n22. How do I get more information?\n For even more detailed information concerning the matters involved in this Litigation, you can obtain answers to\ncommon questions regarding the proposed Settlement by contacting the Claims Administrator toll-free at 1-888-808-8947\nor by email at info@DocGoSecuritiesSettlement.com. Reference is also made to the Stipulation, to the pleadings in\nsupport of the Settlement, to the Orders entered by the Court, and to the other settlement-related papers filed in the\nLitigation, which are posted on the Settlement website at www.DocGoSecuritiesSettlement.com, and which may be\ninspected at the Office of the Clerk of the United States District Court for the Southern District of New York, during regular\nbusiness hours. For a fee, all papers filed in this Litigation are available at www.pacer.gov.\n THE PROPOSED PLAN OF ALLOCATION OF NET\n SETTLEMENT FUND AMONG CLASS MEMBERS\n23. How will my claim be calculated?\n As discussed above, the Settlement provides $12.5 million in cash for the benefit of the Class. The Settlement\nAmount and any interest it earns constitute the \u201cSettlement Fund.\u201d The Settlement Fund, after deduction of Court-\napproved attorneys\u2019 fees and expenses, Notice and Administration Expenses, Taxes, and any other fees, expenses, or\namounts approved by the Court, is the \u201cNet Settlement Fund.\u201d If the Settlement is approved by the Court, the Net\nSettlement Fund will be distributed to eligible Authorized Claimants \u2013 i.e., Members of the Class who timely submit valid\nProofs of Claim that are accepted for payment by the Court \u2013 in accordance with this proposed Plan of Allocation (\u201cPlan\nof Allocation\u201d or \u201cPlan\u201d) or such other plan of allocation as the Court may approve. Class Members who do not timely\nsubmit valid Proofs of Claim will not share in the Net Settlement Fund but will otherwise be bound by the Settlement. The\nCourt may approve this proposed Plan of Allocation, or modify it, without additional notice to the Class. Any order\nmodifying the Plan of Allocation will be posted on the Settlement website, www.DocGoSecuritiesSettlement.com.\n 1. The objective of the Plan of Allocation is to equitably distribute the Net Settlement Fund among Members\nof the Class who submit acceptable Proofs of Claim (\u201cAuthorized Claimants\u201d) based on their respective alleged economic\nlosses resulting from violations of the federal securities laws alleged in this Litigation. The Plan of Allocation reflects Lead\nPlaintiff\u2019s damages expert\u2019s analysis undertaken to that end, including a review of publicly available information regarding\nDocGo and statistical analysis of the price movements of DocGo common stock and the price performance of relevant\nmarket and peer indices during the Class Period. The Plan of Allocation, however, is not a formal damages analysis.\n\n\n\n\n 9\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 11 of 27\n\n 2. The calculations made pursuant to this Plan of Allocation are not intended to be estimates of, or indicative\nof, the amounts that Class Members might have been able to recover after a trial. Nor are the calculations pursuant to the\nPlan of Allocation intended to be estimates of the amounts that will be paid to Authorized Claimants pursuant to the\nSettlement. The computations under the Plan of Allocation are only a method to weigh the claims of Authorized Claimants\nagainst one another for the purposes of making equitable allocations of the Net Settlement Fund.\n 3. All purchases of DocGo common stock during the Class Period (November 5, 2021, through\nSeptember 15, 2023, both dates inclusive) are potentially eligible for compensation based on claims asserted under the\nExchange Act. 3\n 4. A \u201cRecognized Loss Amount\u201d will be calculated as set forth below for each purchase of DocGo common\nstock during the Class Period that is listed in the Proof of Claim and for which adequate documentation is provided. To the\nextent that the calculation of a Recognized Loss Amount results in a negative number, that number shall be set to zero.\n 5. As detailed below, the Net Settlement Fund will be allocated on a pro rata basis to Authorized Claimants.\n Recognized Loss Amount Calculations on DocGo Common Stock\n 6. In this case, Lead Plaintiff alleges that Defendants made false statements and omitted material facts during\nthe Class Period, which had the effect of artificially inflating the trading price of DocGo common stock. Lead Plaintiff further\nalleges that corrective information released to the market removed alleged artificial inflation from the share prices of DocGo\ncommon stock on September 10, 2023, September 14, 2023, and September 15, 2023 (the \u201ccorrective disclosures\u201d).\n 7. Recognized Loss Amounts are based on the difference in the amount of alleged artificial inflation in the\nprices of DocGo common stock at the time of purchase and at the time of sale.\n 8. For each share of DocGo common stock purchased from November 5, 2021, through and including\nSeptember 15, 2023, and:\n (a) Sold before September 11, 2023, the Recognized Loss Amount will be $0.00.\n (b) Sold from September 11, 2023, through and including the close of trading on\nSeptember 15, 2023, the Recognized Loss Amount will be the lesser of: (i) the amount of artificial inflation per share on\nthe date of purchase as stated in Table A below minus the amount of artificial inflation per share on the date of sale as\nstated in Table A below; or (ii) the purchase price minus the sale price.\n (c) Sold from September 16, 2023, through and including the close of trading on December 15, 2023,\nthe Recognized Loss Amount will be the least of: (i) the amount of artificial inflation per share on the date of purchase\nas stated in Table A below; (ii) the purchase price minus the average closing price between September 18, 2023 and the\ndate of sale as stated in Table B below; and (iii) the purchase price minus the sale price.\n (d) Held as of the close of trading on December 15, 2023, the Recognized Loss Amount will be the\nlesser of: (i) the amount of artificial inflation per share on the date of purchase as stated in Table A below; or (ii) the\npurchase price minus $5.70. 4\n (e) Notwithstanding the foregoing, for shares of DocGo common stock purchased during the period\nfrom November 5, 2021, through and including April 28, 2022, the Recognized Loss Amount calculated pursuant to\nsubparagraphs (a) through (d) above shall be reduced by ninety percent (90%). This reduction applies only to those\nspecific purchases made during this period and does not affect Recognized Loss Amounts attributable to shares\npurchased outside this timeframe.\n\n\n\n\n3\n Any transactions in DocGo common stock executed outside of regular trading hours for the U.S. financial markets shall be deemed to have occurred\nduring the next regular trading session.\n4\n Pursuant to Section 21D(e)(1) of the Exchange Act, \u201cin any private action arising under this title in which the plaintiff seeks to establish damages\nby reference to the market price of a security, the award of damages to the plaintiff shall not exceed the difference between the purchase or sale price\npaid or received, as appropriate, by the plaintiff for the subject security and the mean trading price of that security during the 90-day period beginning\non the date on which the information correcting the misstatement or omission that is the basis for the action is disseminated to the market.\u201d Consistent\nwith the requirements of the Exchange Act, Recognized Loss Amounts are reduced to an appropriate extent by taking into account the closing prices\nof DocGo common stock during the \u201c90-day look-back period,\u201d September 18, 2023, through and including December 15, 2023. The mean (average)\nclosing price for DocGo common stock during this 90-day look-back period was $5.70.\n\n 10\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 12 of 27\n\n Table A\n DocGo Inc. Common Stock Estimated Artificial Inflation Amount\n\n Date Range Artificial Inflation per Share\n\n November 5, 2021 - September 10, 2023 $1.19\n September 11, 2023 - September 14, 2023 $1.04\n September 15, 2023 $0.39\n\n Table B\n DocGo Inc. Common Stock Closing Price & Average Closing Price\n Average Closing Average Closing\n Closing Price Between Closing Price Between\n Date Date\n Price September 18, 2023 Price September 18, 2023\n and Date Shown and Date Shown\n09/18/2023 $5.29 $5.29 11/01/2023 $6.09 $5.71\n09/19/2023 $5.28 $5.29 11/02/2023 $6.07 $5.72\n09/20/2023 $5.12 $5.23 11/03/2023 $6.04 $5.73\n09/21/2023 $5.10 $5.20 11/06/2023 $5.80 $5.73\n09/22/2023 $5.10 $5.18 11/07/2023 $6.11 $5.74\n09/25/2023 $5.00 $5.15 11/08/2023 $5.94 $5.75\n09/26/2023 $5.07 $5.14 11/09/2023 $5.70 $5.74\n09/27/2023 $5.05 $5.13 11/10/2023 $5.72 $5.74\n09/28/2023 $5.27 $5.14 11/13/2023 $5.65 $5.74\n09/29/2023 $5.33 $5.16 11/14/2023 $6.19 $5.75\n10/02/2023 $5.33 $5.18 11/15/2023 $5.97 $5.76\n10/03/2023 $5.13 $5.17 11/16/2023 $5.88 $5.76\n10/04/2023 $5.76 $5.22 11/17/2023 $5.80 $5.76\n10/05/2023 $5.80 $5.26 11/20/2023 $5.77 $5.76\n10/06/2023 $6.00 $5.31 11/21/2023 $5.60 $5.76\n10/09/2023 $5.99 $5.35 11/22/2023 $5.75 $5.76\n10/10/2023 $5.84 $5.38 11/24/2023 $5.75 $5.76\n10/11/2023 $5.86 $5.41 11/27/2023 $5.69 $5.76\n10/12/2023 $5.61 $5.42 11/28/2023 $5.72 $5.76\n10/13/2023 $5.86 $5.44 11/29/2023 $5.52 $5.75\n10/16/2023 $6.00 $5.47 11/30/2023 $5.65 $5.75\n10/17/2023 $6.10 $5.50 12/01/2023 $6.01 $5.75\n10/18/2023 $6.04 $5.52 12/04/2023 $6.17 $5.76\n10/19/2023 $5.88 $5.53 12/05/2023 $5.56 $5.76\n10/20/2023 $6.06 $5.55 12/06/2023 $5.48 $5.75\n10/23/2023 $6.00 $5.57 12/07/2023 $5.37 $5.75\n10/24/2023 $6.75 $5.62 12/08/2023 $5.24 $5.74\n10/25/2023 $6.59 $5.65 12/11/2023 $5.29 $5.73\n10/26/2023 $6.12 $5.67 12/12/2023 $5.16 $5.72\n10/27/2023 $6.01 $5.68 12/13/2023 $5.39 $5.72\n10/30/2023 $6.01 $5.69 12/14/2023 $5.49 $5.71\n10/31/2023 $5.94 $5.70 12/15/2023 $4.99 $5.70\n\n\n\n\n 11\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 13 of 27\n\n ADDITIONAL PROVISIONS\n 9. Calculation of Claimant\u2019s \u201cRecognized Claim\u201d: A claimant\u2019s \u201cRecognized Claim\u201d will be the sum of\nhis, her, or its Recognized Loss Amounts as calculated above with respect to DocGo common stock. If a claimant had a\nmarket gain with respect to their overall transactions in DocGo common stock during the Class Period, the value of the\nclaimant\u2019s Recognized Claim will be zero. If a claimant suffered an overall market loss with respect to their overall\ntransactions in DocGo common stock during the Class Period, but that market loss was less than the claimant\u2019s total\nRecognized Claim, their Recognized Claim will be limited to the amount of the actual market loss. For purposes of\ndetermining whether a claimant had a market gain, or suffered a market loss, with respect to a claimant\u2019s overall\ntransactions of DocGo common stock during the Class Period, the Claims Administrator will determine the difference\nbetween, the claimant\u2019s (i) Total Purchase Amount 5 and (ii) the sum of the Total Sales Proceeds 6 and Holding Value. 7\n 10. FIFO Matching: If a Class Member made more than one purchase or sale of DocGo common stock\nduring the Class Period, all purchases and sales will be matched on a First-In, First-Out (\u201cFIFO\u201d) basis, beginning with\nthe earliest purchase of the security.\n 11. \u201cPurchase/Sale\u201d Prices: For the purposes of calculations under this Plan of Allocation, \u201cpurchase price\u201d\nmeans the actual price paid, excluding all fees, taxes, and commissions, and \u201csale price\u201d means the actual amount\nreceived, not deducting any fees, taxes, and commissions.\n 12. \u201cPurchase/Sale\u201d Dates: Purchases and sales of DocGo common stock will be deemed to have occurred\non the \u201ccontract\u201d or \u201ctrade\u201d date as opposed to the \u201csettlement\u201d or \u201cpayment\u201d date. The receipt or grant by gift, inheritance,\nor operation of law of DocGo common stock shall not be deemed a purchase or sale of DocGo common stock for the\ncalculation of a claimant\u2019s Recognized Loss Amount, nor shall the receipt or grant be deemed an assignment of any claim\nrelating to the purchase or sale of DocGo common stock unless (i) the donor or decedent purchased or sold those shares\nof DocGo common stock between November 5, 2021, and December 15, 2023 (both dates inclusive); (ii) the instrument\nof gift or assignment specifically provides that it is intended to transfer such rights; and (iii) no other duplicative Proof of\nClaim was submitted by or on behalf of the donor, on behalf of the decedent, or by anyone else with respect to such\nshares of DocGo common stock.\n 13. Short Sales: In accordance with the Plan of Allocation, the Recognized Loss Amount on any portion of\na transaction that matches against (or \u201ccovers\u201d) a \u201cshort sale\u201d is zero. The Recognized Loss Amount on a \u201cshort sale\u201d that\nis not covered is also zero.\n 14. In the event that a claimant establishes a short position during the Class Period, the earliest subsequent\nClass Period purchase shall be matched against such short position on a FIFO basis and will not be entitled to a recovery.\n 15. Common Stock Purchased/Sold Through the Exercise of Options: With respect to DocGo common\nstock purchased or sold via the exercise of an option, the purchase/sale date of the DocGo common stock is the exercise\ndate of the option and the purchase/sale price is the exercise price of the option.\n 16. Determination of Distribution Amount: If the sum total of Recognized Claims of all Authorized\nClaimants who are entitled to receive payment out of the Net Settlement Fund is greater than the Net Settlement Fund,\neach Authorized Claimant shall receive the claimants\u2019 authorized share of the Net Settlement Fund as provided by this\nPlan of Allocation. That share will be the Authorized Claimant\u2019s Recognized Claim divided by the total of Recognized\nClaims of all Authorized Claimants, multiplied by the total amount of the Net Settlement Fund.\n 17. If an Authorized Claimant\u2019s pro rata share of the Net Settlement Fund calculates to less than $10.00, no\ndistribution will be made to that Authorized Claimant.\n 18. Payment pursuant to the Plan of Allocation or such other plan as may be approved by the Court for this\nSettlement shall be conclusive against all Authorized Claimants. No person shall have any claim against Lead Plaintiff,\nLead Plaintiff\u2019s Counsel, Lead Plaintiff\u2019s damages expert, Defendants, Defendants\u2019 Counsel, any of the other Class\nMembers, the Claims Administrator, or other agent designated by Lead Plaintiff\u2019s Counsel arising from distributions made\nsubstantially in accordance with the Stipulation, the plan of allocation approved by the Court, or further orders of the Court.\n\n\n\n\n5\n The \u201cTotal Purchase Amount\u201d is the total amount the claimant paid (excluding commissions and other charges) for DocGo common stock\npurchased during the Class Period.\n6\n The Claims Administrator will match any sales of DocGo common stock from the start of the Class Period through and including the close of trading\non December 15, 2023, first against the claimant\u2019s opening position (the proceeds of those sales will not be considered for purposes of calculating\nmarket gains or losses). The total amount received (excluding commissions and other charges) for the remaining sales of DocGo common stock sold\nfrom the start of the Class Period through and including the close of trading on December 15, 2023 will be the \u201cTotal Sales Proceeds.\u201d\n7\n The Claims Administrator will ascribe a \u201cHolding Value\u201d for the securities equal to $4.99 (the closing price of DocGo common stock on December\n15, 2023) for each share of DocGo common stock purchased during the Class Period and still held as of the close of trading on December 15, 2023.\n\n 12\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 14 of 27\n\n 19. Class Members who do not submit acceptable Proofs of Claim will not share in the distribution of the Net\nSettlement Fund, however they will nevertheless be bound by the Settlement and the Order and Final Judgment of the\nCourt dismissing this Litigation unless they have timely and validly sought exclusion.\n 20. The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the claim of any\nClass Member or claimant.\n 21. Each claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to the\nclaimant\u2019s claim and Proof of Claim.\n SPECIAL NOTICE TO SECURITIES BROKERS AND OTHER NOMINEES\n Nominees who purchased DocGo publicly traded common stock during the Class Period for beneficial owners\nwho are Class Members are directed to: (i) request within seven (7) calendar days of receipt of the Postcard Notice\nsufficient copies of the Postcard Notice from the Claims Administrator to forward via First Class Mail to all such beneficial\nowners; or (ii) send a list of the names and addresses (including email addresses if available) of such beneficial owners\nto the Claims Administrator within seven (7) calendar days after receipt of the Postcard Notice. If a nominee elects to\nsend the Postcard Notice to beneficial owners, such nominee is directed to email or mail (where an email is unavailable)\nthe Postcard Notice within seven (7) calendar days of receipt of those documents from the Claims Administrator, and\nupon such emailing or mailing, the nominee shall send a statement to the Claims Administrator confirming that the\nemailing or mailing was made as directed, and the nominee shall retain the list of names and addresses for use in\nconnection with any possible future notice to the Class. Upon full compliance with these instructions, including the timely\nemailing or mailing of the Postcard Notice to beneficial owners, such nominees may seek reimbursement of their\nreasonable expenses actually incurred in complying with these instructions by providing the Claims Administrator with\nproper documentation supporting the expenses for which reimbursement is sought and reflecting compliance with these\ninstructions. Reasonable out-of-pocket expenses actually incurred in connection with the foregoing includes up to $0.03\nper record for providing names, addresses, and email addresses to the Claims Administrator; up to a maximum of $0.03\nper Postcard Notice mailed by you, plus postage at the rate used by the Claims Administrator; or $0.03 per Postcard\nNotice sent by email. Such properly documented expenses incurred by nominees in compliance with the terms of these\ninstructions will be paid from the Settlement Fund. All communications concerning the foregoing should be addressed to\nthe Claims Administrator at notifications@veritaglobal.com or:\n DocGo Securities Settlement\n Claims Administrator\n c/o Verita Global\n P.O. Box 301171\n Los Angeles, CA 90030-1171\nDATED: November 18, 2025 ____________________________________\n BY ORDER OF THE COURT\n UNITED STATES DISTRICT COURT\n SOUTHERN DISTRICT OF NEW YORK\n\n\n\n\n 13\n\fCase 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 15 of 27\n\n\n\n\n THIS PAGE INTENTIONALLY LEFT BLANK\n\n\n\n\n 14\n\fCase 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 16 of 27\n\n\n\n\n THIS PAGE INTENTIONALLY LEFT BLANK\n\n\n\n\n 15\n\fCase 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 17 of 27\n\n\n\n\n THIS PAGE INTENTIONALLY LEFT BLANK\n\n\n\n\n 16\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 18 of 27\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n x\nGENESEE COUNTY EMPLOYEES\u2019 RETIREMENT : Civil Action No. 1:23-cv-09476-KPF\nSYSTEM, Individually and on Behalf of All Others :\n CLASS ACTION\nSimilarly Situated, :\n :\n Plaintiff,\n :\n vs. :\n :\nDOCGO INC. and ANTHONY CAPONE, :\n Defendants. :\n x\n\n PROOF OF CLAIM AND RELEASE\n I. GENERAL INSTRUCTIONS\n 1. To recover as a Class Member based on the claims in the Litigation, 1 you must complete\nand, on page 9 hereof, sign this Proof of Claim. If you fail to submit a properly addressed (as set forth in\nparagraph 3 below) Proof of Claim, your claim may be rejected and you may be precluded from any\nrecovery from the Net Settlement Fund created in connection with the proposed Settlement.\n 2. Submission of this Proof of Claim, however, does not assure that you will share in the\nproceeds of the Settlement of the Litigation.\n 3. YOU MUST MAIL OR SUBMIT ONLINE YOUR COMPLETED AND SIGNED PROOF OF\nCLAIM, ACCOMPANIED BY COPIES OF THE DOCUMENTS REQUESTED HEREIN, ON OR BEFORE\nMARCH 9, 2026, ADDRESSED AS FOLLOWS:\n DocGo Securities Settlement\n Claims Administrator\n c/o Verita Global\n P.O. Box 301171\n Los Angeles, CA 90030-1171\n Online Submissions: www.DocGoSecuritiesSettlement.com\nIf you are NOT a Class Member, as defined in the Notice of Pendency and Proposed Settlement of Class\nAction (\u201cNotice\u201d), DO NOT submit a Proof of Claim.\n\n\n\n\n1\n This Proof of Claim and Release form (\u201cProof of Claim\u201d) incorporates by reference the definitions in the Stipulation of\nSettlement, dated November 12, 2025 (\u201cStipulation\u201d), which can be obtained at www.DocGoSecuritiesSettlement.com.\n\n\n\n\n 1\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 19 of 27\n\n\n\n 4. If you are a Class Member, you will be bound by the terms of any judgments or orders\nentered in the Litigation WHETHER OR NOT YOU SUBMIT A PROOF OF CLAIM, unless you submit a\ntimely and valid request for exclusion from the Class. Thus, if you are a Class Member, the Judgment will\nrelease the Released Defendant Parties from all Released Plaintiff\u2019s Claims, and you will be forever barred\nand enjoined from commencing, instituting, prosecuting, or continuing to prosecute any action or other\nproceeding in any court of law or equity, arbitration tribunal, or administrative forum asserting any of the\nReleased Plaintiff\u2019s Claims against any of the Released Defendant Parties.\n 5. You are eligible to participate in the distribution of the Net Settlement Fund only if you are\na Member of the Class and if you complete and return this form as specified below. If you fail to submit a\ntimely, properly addressed, and completed Proof of Claim with the required documentation, your claim may\nbe rejected and you may be precluded from receiving any distribution from the Net Settlement Fund.\n 6. Submission of this Proof of Claim does not guarantee that you will share in the proceeds\nof the Settlement. The distribution of the Net Settlement Fund will be governed by the Plan of Allocation set\nforth in the Notice, if it is approved by the Court, or by such other plan of allocation approved by the Court.\n II. CLAIMANT IDENTIFICATION\n You are a Member of the Class if you purchased DocGo Inc. (\u201cDocGo\u201d) publicly traded common stock\nbetween November 5, 2021, and September 15, 2023, inclusive (the \u201cClass Period\u201d), and are not otherwise\nexcluded from the Class.\n Use Part I of this form entitled \u201cClaimant Identification\u201d to identify each purchaser of record\n(\u201cnominee\u201d) of the DocGo common stock that forms the basis of this claim. THIS PROOF OF CLAIM MUST\nBE FILED BY THE ACTUAL BENEFICIAL PURCHASER(S) OR THE LEGAL REPRESENTATIVE OF\nSUCH PURCHASER(S) OF DOCGO PUBLICLY TRADED COMMON STOCK UPON WHICH THIS CLAIM\nIS BASED.\n All joint purchasers must sign this Proof of Claim. If you purchased DocGo publicly traded common\nstock during the Class Period and held the securities in your name, you are the beneficial owner as well as\nthe record owner and you must sign this Proof of Claim to participate in the Settlement. If, however, you\npurchased DocGo publicly traded common stock during the Class Period and the shares were registered\nin the name of a third party, such as a nominee or brokerage firm, you are the beneficial owner of these\nshares, but the third party is the record owner. The beneficial owner, not the record owner, must sign this\nProof of Claim.\n Executors, administrators, guardians, conservators, and trustees must complete and sign this Proof\nof Claim on behalf of Persons represented by them and their authority must accompany this claim and their\ntitles or capacities must be stated. Specifically, they must: (i) expressly state the capacity in which they are\nacting; (ii) identify the name, account number, last four digits of the Social Security Number (or full Taxpayer\nIdentification Number), address, and telephone number of the beneficial owner of (or other Person or entity\non whose behalf they are acting with respect to) the DocGo publicly traded common stock; and (iii) furnish\nherewith evidence of their authority to bind to the Proof of Claim the Person or entity on whose behalf they\nare acting. (Authority to complete and sign a Proof of Claim cannot be established by stockbrokers\ndemonstrating only that they have discretionary authority to trade stock in another Person\u2019s accounts.)\n\n\n\n\n 2\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 20 of 27\n\n\n\n The last four digits of the Social Security Number (or full Taxpayer Identification Number) and\ntelephone number of the beneficial owner may be used in verifying the claim. Failure to provide the\nforegoing information could delay verification of your claim or result in the rejection of the claim.\n You are required to submit genuine and sufficient documentation for all of your transactions and\nholdings in the DocGo common stock set forth in the \u201cSchedule of Transactions\u201d in Part II of this Proof of\nClaim. Documentation may consist of copies of brokerage confirmation slips or monthly brokerage account\nstatements, or an authorized statement from your broker containing the transactional and holding\ninformation found in a broker confirmation slip or account statement. Neither the Parties nor the Claims\nAdministrator independently have information about your investments in DocGo publicly traded common\nstock. IF SUCH DOCUMENTS ARE NOT IN YOUR POSSESSION, PLEASE OBTAIN COPIES OR\nEQUIVALENT CONTEMPORANEOUS DOCUMENTS FROM YOUR BROKER. FAILURE TO SUPPLY\nTHIS DOCUMENTATION MAY RESULT IN THE REJECTION OF YOUR CLAIM. DO NOT SEND\nORIGINAL DOCUMENTS. Please keep a copy of all documents that you send to the Claims Administrator.\nAlso, please do not highlight any portion of the Proof of Claim or any supporting documents.\n A Proof of Claim should be submitted for each separate legal entity (e.g., a claim of joint owners\nshould not include separate transactions of just one of the joint owners, and an individual should not\ncombine his or her IRA transactions with transactions made solely in the individual\u2019s name). Conversely, a\nsingle Proof of Claim should be submitted on behalf of one legal entity including all transactions made by\nthat entity, no matter how many separate accounts that entity has (e.g., an institution with multiple\nbrokerage accounts that the entity has transacted in DocGo common stock during the Class Period).\n By submitting a signed Proof of Claim, you will be swearing that you: (i) own(ed) the DocGo publicly\ntraded common stock you have listed in the Proof of Claim; or (ii) are expressly authorized to act on behalf\nof the owner thereof.\n By submitting a signed Proof of Claim, you will be swearing to the truth of the statements contained\ntherein and the genuineness of the documents attached thereto, subject to penalties of perjury under the\nlaws of the United States of America. The making of false statements, or the submission of forged or\nfraudulent documentation, will result in the rejection of your claim and may subject you to civil liability or\ncriminal prosecution.\n If the Court approves the Settlement, payments to eligible Authorized Claimants pursuant to the\nPlan of Allocation (or such other plan of allocation as the Court approves) will be made after the completion\nof all claims processing. This could take substantial time. Please be patient.\nIf you have questions concerning the Proof of Claim, or need additional copies of the Proof of\nClaim or the Notice, you may contact the Claims Administrator, DocGo Securities Settlement, c/o\nVerita Global at P.O. Box 301171, Los Angeles, CA 90030-1171, or by email at\ninfo@DocGoSecuritiesSettlement.com, or by toll-free phone at 1-888-808-8947, or you may\ndownload the documents from the Settlement website, www.DocGoSecuritiesSettlement.com.\n\n\n\n\n 3\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 21 of 27\n\n\n\n III. CLAIM FORM\n Use Part II of this form entitled \u201cSchedule of Transactions in DocGo Publicly Traded Common\nStock\u201d to supply all required details of your transaction(s). If you need more space or additional schedules,\nattach separate sheets giving all of the required information in substantially the same form. Sign and print\nor type your name on each additional sheet.\n On the schedules, provide all of the requested information with respect to all of your purchases\nand sales of DocGo publicly traded common stock that took place between November 5, 2021, and\nDecember 15, 2023, inclusive, whether such transactions resulted in a profit or a loss. 2 You must also\nprovide all of the requested information with respect to the number of shares of DocGo publicly traded\ncommon stock you held at the close of trading on November 4, 2021, September 15, 2023, and\nDecember 15, 2023. Failure to report all such transactions may result in the rejection of your claim.\n List each transaction separately and in chronological order, by trade date, beginning with the\nearliest. You must accurately provide the month, day, and year of each transaction you list.\n The date of covering a \u201cshort sale\u201d is deemed to be the date of purchase of DocGo publicly traded\ncommon stock. The date of a \u201cshort sale\u201d is deemed to be the date of sale of DocGo publicly traded\ncommon stock.\n COPIES OF BROKER CONFIRMATIONS OR OTHER DOCUMENTATION OF YOUR\nTRANSACTIONS IN DocGo PUBLICLY TRADED COMMON STOCK SHOULD BE ATTACHED TO YOUR\nPROOF OF CLAIM. FAILURE TO PROVIDE THIS DOCUMENTATION COULD DELAY VERIFICATION\nOF YOUR CLAIM OR RESULT IN THE REJECTION OF YOUR CLAIM. THE PARTIES DO NOT HAVE\nINFORMATION ABOUT YOUR TRANSACTIONS IN DocGo COMMON STOCK.\n PLEASE NOTE: As set forth in the Plan of Allocation contained in the Notice, each Authorized\nClaimant shall receive his, her, its, or their pro rata share of the Net Settlement Fund. If the prorated payment\nto any Authorized Claimant calculates to less than $10.00, it will not be included in the calculation and no\ndistribution will be made to that Authorized Claimant.\n NOTICE REGARDING ELECTRONIC FILES: Certain claimants with large numbers of transactions\nmay request, or may be requested, to submit information regarding their transactions in electronic files. This\nis different from the online submission process that is available at www.DocGoSecuritiesSettlement.com. All\nclaimants MUST submit a manually signed paper Proof of Claim whether or not they also submit electronic\ncopies. If you have a large number of transactions and wish to file your claim electronically, you must contact\nthe Claims Administrator at edata@veritaglobal.com to obtain the required file layout. Any file not in\naccordance with the required electronic filing format will be subject to rejection. Only one claim should be\nsubmitted for each separate legal entity, and the complete name of the beneficial owner(s) of the common\nstock must be entered where called for. Distribution payments must be made by check or electronic payment\npayable to the Authorized Claimant (beneficial account owner). The third-party filer shall not be the payee of\nany distribution payment or electronic distribution payment. No electronic files will be considered to have been\nproperly submitted unless the Claims Administrator issues to the claimant a written acknowledgment of receipt\nand acceptance of electronically submitted data.\n\n\n\n\n2\n Information requested about your purchases on September 16, 2023 through and including the close of trading on\nDecember 15, 2023 is needed only for the Claims Administrator to confirm that you have reported all relevant transactions. Purchases\nduring this period are not eligible for a recovery because they are outside the Class Period.\n\n\n\n\n 4\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 22 of 27\n\n Must Be Postmarked (if Mailed)\n Official or Received (if Submitted Online)\n Office UNITED STATES DISTRICT COURT No Later Than March 9, 2026\n Use SOUTHERN DISTRICT OF NEW YORK\n Only\n Genesee County Employees\u2019 Retirement DCGO\n System v. DocGo Inc., et al.\n Please Type or Print in the Boxes Below\n No. 1:23-cv-09476-KPF\n Must use Black or Blue Ink or your\n PROOF OF CLAIM AND RELEASE claim may be deemed deficient.\nREMEMBER TO ATTACH COPIES OF BROKER CONFIRMATIONS OR OTHER DOCUMENTATION OF YOUR TRANSACTIONS\nIN DocGo PUBLICLY TRADED COMMON STOCK. FAILURE TO PROVIDE THIS DOCUMENTATION COULD DELAY\nVERIFICATION OF YOUR CLAIM OR RESULT IN THE REJECTION OF YOUR CLAIM.\n PART I. CLAIMANT IDENTIFICATION\n Last Name M.I. First Name\n\n\n Last Name (Co-Beneficial Owner) M.I. First Name (Co-Beneficial Owner)\n\n\n\n IRA Joint Tenancy Employee Individual Other\n Company Name (Beneficial Owner - If Claimant is not an Individual) or Custodian Name if an IRA (specify)\n\n\n Trustee/Asset Manager/Nominee/Record Owner\u2019s Name (If Different from Beneficial Owner Listed Above)\n\n\n Account#/Fund# (Not Necessary for Individual Filers)\n\n\n\n Social Security Number (Last 4 digits) Taxpayer Identification Number\n or \u2014\n Telephone Number (Primary Daytime) Telephone Number (Alternate)\n \u2014 \u2014 \u2014 \u2014\n Email Address\n\n\n\n MAILING INFORMATION\nAddress\n\n\nAddress (cont.)\n\n\nCity State ZIP Code\n\n\nForeign Province Foreign Postal Code Foreign Country Name/Abbreviation\n\n\n\n ATP BE FL OP\n\n / /\nFOR CLAIMS FOR CLAIMS\nPROCESSING OB CB KE DR ME RE PROCESSING\nONLY ICI EM ND SH ONLY\n\n\n\n\n *DCGOFIVE* 5\n\f Case II.1:23-cv-09476-KPF\n PART Document\n SCHEDULE OF TRANSACTIONS 114-2 PUBLICLY\n IN DocGo Filed 02/17/26 Page 23STOCK\n TRADED COMMON of 27\n\nA. Number of shares of DocGo publicly traded common stock held at the Proof Enclosed?\n close of trading on November 4, 2021. If none, write \u201c0\u201d or \u201czero.\u201d Y N\nB. Purchases of DocGo publicly traded common stock between November 5, 2021 and December 15, 2023, inclusive:\n PURCHASES\n\n Total Purchase Proof of\n or Acquisition Price Purchase/\n Trade Date(s) Number of Shares (Excluding commissions, Acquisition\n (List Chronologically) Purchased or Acquired taxes, and fees) Enclosed\n M M D D Y Y Y Y\n\n / / . 00\n Y\n 1. $ N\n\n / / . 00\n Y\n 2. $ N\n\n / / . 00\n Y\n 3. $ N\n\n / / . 00\n Y\n 4. $ N\n\n / / . 00\n Y\n 5. $ N\n\nIMPORTANT: (i) If any purchase listed covered a \u201cshort sale,\u201d please mark Yes: Yes\n(ii) If you received shares through an acquisition or merger, please identify the date, the share amount and the company acquired:\n M M D D Y Y Y Y Merger Shares: Company:\n\n\n\nC. Sales of DocGo publicly traded common stock between November 5, 2021 and December 15, 2023, inclusive:\n SALES\n\n\n Total Sales Price Proof of\n Trade Date(s) Number of (Excluding commissions, Sale\n (List Chronologically) Shares Sold taxes and fees) Enclosed?\n M M D D Y Y Y Y\n\n / / . 00\n Y\n 1. $ N\n\n / / . 00\n Y\n 2. $ N\n\n / / . 00\n Y\n 3. $ N\n\n / / . 00\n Y\n 4. $ N\n\n / / . 00\n Y\n 5. $ N\n\nD. Number of shares of DocGo publicly traded common stock held at the Proof Enclosed?\n close of trading on September 15, 2023. If none, write \u201c0\u201d or \u201czero.\u201d Y N\n\nE. Number of shares of DocGo publicly traded common stock held at the Proof Enclosed?\n close of trading on December 15, 2023. If none, write \u201c0\u201d or \u201czero.\u201d Y N\n If you require additional space, attach extra schedules in the same format as above. Sign and print your\n name and the last four digits of your Social Security/Taxpayer Identification Number on each additional page.\nYOU MUST READ THE RELEASE AND SIGN THE CERTIFICATION ON PAGE 9. FAILURE TO SIGN THE CERTIFICATION\n MAY RESULT IN A DELAY IN PROCESSING OR THE REJECTION OF YOUR CLAIM.\n\n *DCGOSIX* 6\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 24 of 27\n IV. SUBMISSION TO JURISDICTION OF COURT AND ACKNOWLEDGMENTS\n I (We) submit this Proof of Claim under the terms of the Stipulation described in the Notice. I (We) also submit to the\njurisdiction of the United States District Court for the Southern District of New York with respect to my (our) claim as a Class Member\nand for purposes of enforcing the release set forth herein. I (We) further acknowledge that I am (we are) bound by and subject to the\nterms of any judgment that may be entered in the Litigation. I (We) agree to furnish additional information to the Claims Administrator\nto support this claim if requested to do so. I (We) have not submitted any other claim covering the same purchases or sales of DocGo\npublicly traded common stock during the relevant period and know of no other Person having done so on my (our) behalf.\n V. RELEASE\n 1. I (We) hereby acknowledge full and complete satisfaction of, and do hereby fully, finally, and forever waive, release,\nrelinquish, discharge, and dismiss from the Released Plaintiff\u2019s Claims each and all of the \u201cReleased Defendant Parties,\u201d defined as\nany or all of Defendants and the Former Defendants and/or any or all of their current, former, or future parents, affiliates, subsidiaries,\nbusiness units, divisions, or controlling shareholders; and each and all of their and Defendants\u2019 and the Former Defendants\u2019 respective\ncurrent, former, or future officers, directors, employees, members, managers, partners, principals, controlling shareholders, joint\nventures, related entities, agents, advisors, accountants, auditors, insurers, reinsurers, and attorneys; and the predecessors, successors,\nestates, assigns, assignees, immediate family members, spouses, heirs, executors, trusts, trustees, administrators, agents, legal or\npersonal representatives of each of them, in their capacities as such, and any entity in which any Defendant has or had a controlling\ninterest. The Released Defendant Parties other than the Defendants themselves, including the Former Defendants, are intended as\nthird-party beneficiaries of this Settlement with respect to the release of the Released Plaintiff\u2019s Claims.\n 2. \u201cReleased Plaintiff\u2019s Claims\u201d means any and all claims and causes of action of every nature and description,\nwhether known or unknown, including Unknown Claims (as defined below), demands, losses, and rights, whether arising under\nfederal, state, local, common, statutory, administrative or foreign law, or any other law, rule or regulation, at law or in equity,\nwhether class or individual in nature, whether accrued or unaccrued, whether liquidated or unliquidated, whether matured or\nunmatured, that Lead Plaintiff or any other Class Member has or could have asserted in any court or forum, based on, arising\nout of, or in connection with: (i) any purchase or acquisition of publicly traded DocGo common stock during the period between\nNovember 5, 2021, and September 15, 2023, inclusive; and (ii) the conduct, allegations, acts, facts, matters, occurrences,\ntransactions, disclosures, filings, representations, statements, or omissions that were or could have been alleged by Lead Plaintiff or\nany other Member of the Class in the Litigation. Released Plaintiff\u2019s Claims do not include: (i) any claims related to the enforcement\nof the Settlement; (ii) any derivative claims; (iii) any claims arising out of ERISA; or (iv) any claims of any Person who or which\nsubmits a timely and valid request for exclusion from the Class that is accepted by the Court.\n 3. \u201cUnknown Claims\u201d means: (a) any and all Released Plaintiff\u2019s Claims that any of the Releasing Plaintiff Parties do\nnot know or suspect to exist in his, her, or its favor at the time of the release of such claims; and (b) any and all Released Defendants\u2019\nClaims that any of the Released Defendant Parties do not know or suspect to exist in his, her, or its favor at the time of the release\nof such claims, and including, without limitation, those that, if known by him, her, or it, might have affected his, her, or its decision(s)\nwith respect to this Settlement. Unknown Claims include, without limitation, those claims in which some or all of the facts composing\nthe claim may be unsuspected, undisclosed, concealed, or hidden. With respect to: (a) any and all Released Plaintiff\u2019s Claims\nagainst the Released Defendant Parties; and (b) any and all Released Defendants\u2019 Claims against the Releasing Plaintiff Parties,\nthe Settling Parties stipulate and agree that, upon the Effective Date, the Settling Parties shall expressly waive, and each Releasing\nPlaintiff Party and Released Defendant Party shall be deemed to have, and by operation of the Judgment shall have expressly\nwaived, any and all provisions, rights, and benefits conferred by any law of any state or territory of the United States, or principle of\ncommon law or foreign law, that is similar, comparable, or equivalent to California Civil Code \u00a71542, which provides:\n A general release does not extend to claims that the creditor or releasing party does not know or suspect to\n exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially\n affected his or her settlement with the debtor or released party.\nThe Settling Parties shall fully, finally, and forever expressly waive any and all provisions, rights, and benefits conferred by any law\nof any state or territory of the United States or any other jurisdiction, or principle of common law, which is similar, comparable, or\nequivalent to California Civil Code \u00a71542. The Releasing Plaintiff Parties and Released Defendant Parties acknowledge that they\nmay hereafter discover facts, legal theories, or authorities in addition to or different from those which he, she, it, or their counsel now\nknows or believes to be true with respect to the subject matter of the Released Plaintiff\u2019s Claims or Released Defendants\u2019 Claims,\nbut: (a) the Releasing Plaintiff Parties shall expressly, fully, finally, and forever waive, compromise, settle, discharge, extinguish,\nand release, and each Releasing Plaintiff Party shall be deemed to have waived, compromised, settled, discharged, extinguished,\nand released, and upon the Effective Date, and by operation of the Judgment shall have waived, compromised, settled, discharged,\nextinguished, and released, fully, finally, and forever, any and all Released Plaintiff\u2019s Claims against the Released Defendant Parties,\nknown or unknown, suspected or unsuspected, contingent or non-contingent, accrued or unaccrued, whether or not concealed or\nhidden, which now exist, or heretofore have existed, or may hereafter exist, upon any theory of law or equity now existing or coming\ninto existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a breach of\nany duty, law, or rule, without regard to the subsequent discovery or existence of such different or additional facts, legal theories, or\n\n\n *DCGOSEVEN* 7\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 25 of 27\n\nauthorities; and (b) the Released Defendant Parties shall expressly, fully, finally, and forever waive, compromise, settle, discharge,\nextinguish, and release, and each Released Defendant Party shall be deemed to have waived, compromised, settled, discharged,\nextinguished, and released, and upon the Effective Date, and by operation of the Judgment shall have waived, compromised,\nsettled, discharged, extinguished, and released, fully, finally, and forever, any and all Released Defendants\u2019 Claims against Lead\nPlaintiff, the Class, and Lead Plaintiff\u2019s Counsel, known or unknown, suspected or unsuspected, contingent or non-contingent,\nwhether or not concealed or hidden, which now exist, or heretofore have existed, upon any theory of law or equity now existing or\ncoming into existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a\nbreach of any duty, law or rule, without regard to the subsequent discovery or existence of such different or additional facts, legal\ntheories, or authorities. The Settling Parties acknowledge, and the Releasing Plaintiff Parties and Released Defendant Parties shall\nbe deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and is a key element\nof the Settlement of which this release is a part.\n 4. These Releases shall be of no force or effect unless and until the Court approves the Stipulation and the Settlement\nbecomes effective on the Effective Date.\n CERTIFICATION\n By signing and submitting this Proof of Claim, the claimant(s) or the Person(s) who represent(s) the claimant(s) certifies\n(certify), as follows:\n 1. that I (we) read and understand the contents of the Notice and this Proof of Claim, including the Releases provided\nfor in the Settlement and the terms of the Plan of Allocation;\n 2. that the claimant(s) is a (are) Class Member(s), as defined in the Notice and on page 2 of this Proof of Claim, and\nis (are) not excluded from the Class by definition or pursuant to request as set forth in the Notice;\n 3. that I (we) own(ed) the DocGo publicly traded common stock identified in the Proof of Claim and have not assigned\nthe claim against the Released Defendant Parties to another, or that, in signing and submitting this Proof of Claim, I (we) have the\nauthority to act on behalf of the owner(s) thereof;\n 4. that the claimant(s) has (have) not submitted any other claim covering the same purchases of DocGo publicly\ntraded common stock, and knows (know) of no other Person having done so on the claimant\u2019s (claimants\u2019) behalf;\n 5. that the claimant(s) submit(s) to the jurisdiction of the Court with respect to claimant\u2019s (claimants\u2019) claim and for\npurposes of enforcing the Releases set forth herein;\n 6. that I (we) agree to furnish such additional information with respect to this Proof of Claim as Lead Counsel, the\nClaims Administrator, or the Court may require;\n 7. that the claimant(s) waive(s) the right to trial by jury, to the extent it exists, and agree(s) to the Court\u2019s summary\ndisposition of the determination of the validity and amount of the claim made by means of this Proof of Claim;\n 8. that I (we) acknowledge that the claimant(s) will be bound by and subject to the terms of any judgment(s) that may\nbe entered in the Litigation; and\n 9. that the claimant(s) is (are) NOT subject to backup withholding under the provisions of Section 3406(a)(1)(C) of the\nInternal Revenue Code because: (i) the claimant(s) is (are) exempt from backup withholding; or (ii) the claimant(s) has (have) not\nbeen notified by the IRS that he/she/it is subject to backup withholding as a result of a failure to report all interest or dividends; or\n(iii) the IRS has notified the claimant(s) that he/she/it is no longer subject to backup withholding. If the IRS has notified the\nclaimant(s) that he, she, or it is subject to backup withholding, please strike out the language in the preceding sentence indicating\nthat the claim is not subject to backup withholding in the certification above.\n\n\n\n\n *DCGOEIGHT* 8\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 26 of 27\n\n\n UNDER THE PENALTIES OF PERJURY, I (WE) CERTIFY THAT ALL OF THE INFORMATION PROVIDED BY ME (US) ON\nTHIS PROOF OF CLAIM IS TRUE, CORRECT, AND COMPLETE, AND THAT THE DOCUMENTS SUBMITTED HEREWITH ARE\nTRUE AND CORRECT COPIES OF WHAT THEY PURPORT TO BE:\n\n\nExecuted this________________ day of __________________________ in ___________________________________________\n (Month/Year) (City/State/Country)\n\n_____________________________________________ _____________________________________________\n(Sign your name here) (Sign your name here)\n\n\n_____________________________________________ _____________________________________________\n(Type or print your name here) (Type or print your name here)\n\n\n_____________________________________________ _____________________________________________\n(Capacity of person(s) signing, e.g., (Capacity of person(s) signing, e.g.,\nBeneficial Purchaser or Acquirer, Executor or Administrator) Beneficial Purchaser or Acquirer, Executor or Administrator)\n\n\n ACCURATE CLAIMS PROCESSING TAKES A SIGNIFICANT AMOUNT OF TIME.\n THANK YOU FOR YOUR PATIENCE.\n\n\nReminder Checklist:\n1. Please sign the above release and acknowledgment. 5. If you desire an acknowledgment of receipt of your Proof\n2. Remember to attach copies of supporting documentation. of Claim, please send it Certified Mail, Return Receipt\n Requested.\n3. Do not send originals of certificates or other documentation\n as they will not be returned. 6. If you move, please send your new address to the\n address below.\n4. Keep a copy of your Proof of Claim and all supporting\n documentation for your records. 7. Do not use red pen or highlighter on the Proof of\n Claim or supporting documentation.\n\n\n\n THIS PROOF OF CLAIM MUST BE SUBMITTED ONLINE OR MAILED\n NO LATER THAN MARCH 9, 2026, ADDRESSED AS FOLLOWS:\n DocGo Securities Settlement\n Claims Administrator\n c/o Verita Global\n P.O. Box 301171\n Los Angeles, CA 90030-1171\n Online Submissions: www.DocGoSecuritiesSettlement.com\n\n\n\n\n *DCGONINE* 9\n\f Case 1:23-cv-09476-KPF Document 114-2 Filed 02/17/26 Page 27 of 27\n\n\n\n\n THIS PAGE INTENTIONALLY LEFT BLANK\n\n\n\n\n*DCGOTEN* 10\n\f","ocr_status":1,"date_upload":"2026-06-22T23:06:22.679692-07:00","document_number":"114","attachment_number":2,"pacer_doc_id":"127039079637","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit B (Claim Package)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663620/","id":483663620,"tags":[],"absolute_url":"/docket/67923163/114/3/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:05:29.262906-07:00","date_modified":"2026-06-23T06:03:33.497713-07:00","sha1":"35ade6260ffdecede33a969114f4d972b6e75136","page_count":2,"file_size":97253,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 114-3 Filed 02/17/26 Page 1 of 2\n\n\n\n\n EXHIBIT C\n\f Case 1:23-cv-09476-KPF Document 114-3 Filed 02/17/26 Page 2 of 2\n\n\n\n 1 McInnis Parkway\n Suite 250\n San Rafael, CA 94903\n P: (415) 458-3015\n December 9, 2025\n\n \u00abFirstName\u00bb \u00abLastName\u00bb\n \u00abCompany\u00bb\n \u00abAddr1\u00bb\n \u00abAddr2\u00bb\n South Bend, IN 46601\n \u00abFCountry\u00bb\n\n Re: DocGo Securities Settlement\n\nDear \u00abGENDER\u00bb \u00abLastName\u00bb:\n\nPlease find enclosed the Postcard Notice for the above-referenced class action settlement. Please note both the Class\nPeriod and the designated eligible securities described on page one of the full Notice of Pendency and Proposed\nSettlement of Class Action (\u201cNotice\u201d), available on the settlement website, specifically the inclusion of all Persons\nwho purchased DocGo Inc. (\u201cDocGo\u201d) publicly traded common stock between November 5, 2021, and September\n15, 2023, inclusive (the \u201cClass Period\u201d). In addition, the Notice provides that the Exclusion Deadline is March 3,\n2026 and the Claim Filing Deadline is March 9, 2026.\n\nPlease pay particular attention to the \"Special Notice to Securities Brokers and Other Nominees\" on page thirteen of\nthe Notice which states in part: Nominees who purchased DocGo publicly traded common stock during the Class\nPeriod for beneficial owners who are Class Members are directed to: (i) request within seven (7) calendar days of\nreceipt of the Postcard Notice sufficient copies of the Postcard Notice from the Claims Administrator to forward via\nFirst Class Mail to all such beneficial owners; or (ii) send a list of the names and addresses (including email addresses\nif available) of such beneficial owners to the Claims Administrator within seven (7) calendar days after receipt of the\nPostcard Notice. If a nominee elects to send the Postcard Notice to beneficial owners, such nominee is directed to\nemail or mail (where an email is unavailable) the Postcard Notice within seven (7) calendar days of receipt of those\ndocuments from the Claims Administrator, and upon such emailing or mailing, the nominee shall send a statement to\nthe Claims Administrator confirming that the emailing or mailing was made as directed, and the nominee shall retain\nthe list of names and addresses for use in connection with any possible future notice to the Class.\n\nPlease do not make your own copies of the Proof of Claim Form, as copies may not be accepted for processing.\nAdditional copies of the appropriate documents may be requested by contacting us at the above address and/or phone\nnumber.\n\nIf we conduct the necessary mailing on your behalf, please submit names and addresses either via email to\nnotifications@veritaglobal.com, via CD Rom to the above address or contact us to obtain secure FTP transmission\ninstructions. Mailing labels will be accepted, but you may be requested to provide an additional copy of the address\ninformation you send. Do not include any confidential information that should not appear on a mailing label.\n\nThe data provided must be in one of the following formats: ASCII Fixed Length file, ASCII Tab Delimited file, or\nMicrosoft Excel spreadsheet. Your request must also specify the case name and Control Total(s) (for example, the\ntotal number of name and address records provided) for each file submission.\n\nIf you have any questions, please email notifications@veritaglobal.com.\n\nSincerely,\n\nVerita Global\n\f","ocr_status":1,"date_upload":"2026-06-22T23:06:14.047537-07:00","document_number":"114","attachment_number":3,"pacer_doc_id":"127039079638","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit C (Nominee Letter)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483663621/","id":483663621,"tags":[],"absolute_url":"/docket/67923163/114/4/naclerio-v-docgo-inc/","date_created":"2026-06-22T23:05:29.273734-07:00","date_modified":"2026-06-23T06:03:37.961027-07:00","sha1":"18429fa4dad60484db02decaaaa49a0d76a04856","page_count":5,"file_size":2802058,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.114.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 114-4 Filed 02/17/26 Page 1 of 5\n\n\n\n\n EXHIBIT D\n\fP2JW350000-0-B00400-1--------XA\n Case 1:23-cv-09476-KPF Document 114-4 Filed 02/17/26 Page 2 of 5\n\n B4 | Tuesday, December 16, 2025 THE WALL STREET JOURNAL.\n\n TECHNOLOGY & MEDIA WSJ.com/Tech\n\n\n\n OpenAI Rolls Out More Robust Version of ChatGPT\n BY BELLE LIN pany has been on high alert corporate customers has also texts, using tools and then link- Ray Wang, founder and metric for measuring knowl-\n from the rising threat of been under pressure from An- ing complex multi-step principal analyst for Constella- edge work across 44 occupa-\n OpenAI on Thursday an- Google\u2019s latest Gemini AI thropic, which has recently projects.\u201d tion Research, said GPT-5.2 is a tions. Those occupations in-\n nounced the release of GPT-5.2, model, which outperformed ramped up its efforts to sell to The application of AI to such good response to Google\u2019s clude jobs in sectors like\n calling the artificial-intelligence ChatGPT on certain bench- enterprises. tasks will be critical as busi- Gemini, but not enough to re- manufacturing, professional\n model its most advanced for marks including expert-level \u201cWe designed 5.2 to unlock nesses seek to get value from verse its rival\u2019s momentum. For services, healthcare and fi-\n professional knowledge work. knowledge, logic puzzles, math even more economic value for AI and drive a return on those businesses, \u201cwhat OpenAI did nance, where people often\n The release comes about a problems and image recogni- people,\u201d Fidji Simo, OpenAI\u2019s investments. was make it easier to create of- work with spreadsheets and\n week after Chief Executive Sam tion. CEO of applications said on a Simo, the former CEO of fice productivity tools,\u201d Wang slide decks.\n Altman declared a \u201ccode red\u201d The new OpenAI model was Thursday call with reporters. Instacart, joined OpenAI this said. \u201cGemini is still more inte- Access to GPT-5.2 began\n effort to improve the quality of described by the company as \u201cIt\u2019s better at creating spread- year and is charged with help- grated.\u201d rolling out to paying ChatGPT\n ChatGPT and to delay develop- better at math, science and sheets, building presentations, ing the ChatGPT maker become OpenAI had no updates users on Thursday.\n ment of some other initiatives, coding benchmarks. writing code, perceiving im- a profitable global business. Thursday on image generation The first version of GPT-5,\n including advertising. The com- OpenAI\u2019s business targeting ages, understanding long con- It isn\u2019t yet clear if OpenAI\u2019s in GPT-5.2. That capability has released in August, was rocky\n latest productivity- and work- been a key differentiator for and showed OpenAI\u2019s struggle\n ADVERTISEMENT focused model will win over Google\u2019s Gemini since the Au- to remain the undisputed AI\n customers, or help it compete gust release of its image gener- leader.\n\n The Marketplace\n To advertise: 800-366-3975 or WSJ.com/classifieds\n against rivals. Many businesses\n are still early on in their use of\n AI, and have yet to see wide-\n ator, Nano Banana, and Altman\n listed improving the technology\n as a key priority in his code-red\n At the time, users flooded\n social media with embarrassing\n examples of how the chatbot\n spread returns from the tech- memo to employees. failed to answer simple math\n nology. Yet compared with the prior questions or accurately draw a\n CLASS ACTION GPT-5.2 shows improve- version of its model, GPT-5.1, map of North America.\n ments in reasoning, coding and released in mid-November, OpenAI\u2019s Simo said on\n UNITED STATES DISTRICT COURT working with a range of inputs GPT-5.2 \u201crepresents a huge Thursday\u2019s call that the release\n SOUTHERN DISTRICT OF NEW YORK from text to audio, video, and jump\u201d in a variety of profes- of GPT-5.2 had been planned\n x more\u2014all areas where OpenAI sional-worker tasks, said Aaron for many months, and\n GENESEE COUNTY EMPLOYEES\u2019 RETIREMENT : Civil Action No. 1:23-cv-09476-KPF\n SYSTEM, Individually and on Behalf of All Others : has faced challenges from Levie, CEO and co-founder of shouldn\u2019t be considered part of\n Similarly Situated, : CLASS ACTION Google and Anthropic, said Box. Tasks that knowledge its code-red effort.\n : Arun Chandrasekaran, an ana- workers commonly take on in- News Corp, owner of The\n Plainti\ufb00, :\n : SUMMARY NOTICE OF PENDENCY AND lyst at market research and IT clude creating spreadsheets Wall Street Journal, has a con-\n : PROPOSED SETTLEMENT OF CLASS ACTION consulting firm Gartner. The and presentations. tent-licensing partnership with\n vs. : company also made progress in In the realm of real-world OpenAI.\n :\n : knowledge-work capabilities work, OpenAI said GPT-5.2 beat\n DOCGO INC. and ANTHONY CAPONE, : essential to making ChatGPT or tied top industry profession- Belle Lin writes for WSJ\n : the AI assistant of choice for als on 70.9% of knowledge Leadership Institute\u2019s CIO\n :\n Defendants. : professional workers, he added. work tasks on GDPval, its own Journal.\n x\n TO: ALL PERSONS AND ENTITIES WHO PURCHASED DOCGO INC. (\u201cDocGo\u201d) PUBLICLY TRADED\n COMMON STOCK BETWEEN NOVEMBER 5, 2021, AND SEPTEMBER 15, 2023, INCLUSIVE (THE \u201cCLASS\n PERIOD\u201d)\n THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION. PLEASE READ THIS\n NOTICE CAREFULLY AND IN ITS ENTIRETY.\n YOU ARE HEREBY NOTIFIED, pursuant to Rule 23 of the Federal Rules of Civil Procedure and an Order of the United\n States District Court for the Southern District of New York (\u201cCourt\u201d), that the above-captioned action (\u201cLitigation\u201d) has been\n certi\ufb01ed as a class action, except for certain Persons and entities who are excluded from the Class by de\ufb01nition as set forth in the\n Stipulation of Settlement, dated November 12, 2025 (\u201cStipulation\u201d) and the detailed Notice of Pendency and Proposed Settlement\n of Class Action (\u201cNotice\u201d). The Stipulation and Notice can be viewed at www.DocGoSecuritiesSettlement.com.\n YOU ARE ALSO HEREBY NOTIFIED that Genesee County Employees\u2019 Retirement System (\u201cLead Plainti\ufb00\u201d) and\n defendants DocGo and Anthony Capone (\u201cDefendants\u201d) have reached a proposed settlement of the Litigation on behalf of the\n Class for $12.5 million in cash (\u201cSettlement\u201d). If approved by the Court, the Settlement will resolve all claims in the Litigation.\n YOU ARE ALSO HEREBY NOTIFIED that a hearing will be held on March 24, 2026, at 10:00 a.m., before the Honorable\n Katherine Polk Failla at the United States District Court, Southern District of New York, Thurgood Marshall United States\n Courthouse, 40 Foley Square, Courtroom 618, New York, NY 10007, to determine whether: (1) the Settlement of the above-\n captioned Litigation as set forth in the Stipulation for $12.5 million in cash should be approved by the Court as fair, reasonable,\n and adequate; (2) the Judgment as provided under the Stipulation should be entered dismissing the Litigation with prejudice;\n (3) to award Lead Plainti\ufb00\u2019s Counsel attorneys\u2019 fees and expenses out of the Settlement Fund (as de\ufb01ned in the Notice) and, if so,\n in what amounts; and (4) the Plan of Allocation should be approved by the Court as fair, reasonable, and adequate.\n The Court may decide to change the date and/or time of the Settlement Hearing, conduct the hearing by video or telephonic\n conference, or otherwise allow Class Members to appear at the hearing by telephone or videoconference, without further written\n notice to the Class. It is important that you check the Settlement website, www.DocGoSecuritiesSettlement.com, before making\n any plans to attend the Settlement Hearing. Any updates regarding the Settlement Hearing, including any changes to the date\n\n\n\n\n ANGEL GARCIA/BLOOMBERG NEWS\n or time of the hearing or updates regarding in-person or telephonic appearances at the hearing, will be posted to the Settlement\n website. Also, if the Court requires or allows Class Members to participate in the hearing by telephone or videoconference, the\n access information will be posted to the website.\n IF YOU PURCHASED DocGo PUBLICLY TRADED COMMON STOCK BETWEEN NOVEMBER 5, 2021, AND\n SEPTEMBER 15, 2023, INCLUSIVE, YOUR RIGHTS ARE AFFECTED BY THE SETTLEMENT OF THIS LITIGATION.\n To share in the distribution of the Net Settlement Fund, you must establish your rights by submitting a Proof of Claim and\n Release form (\u201cProof of Claim\u201d) by mail (postmarked no later than March 9, 2026) or electronically via the Settlement website\n (no later than March 9, 2026). Failure to submit your Proof of Claim by March 9, 2026, will subject your claim to rejection and\n preclude you from receiving any of the recovery in connection with the Settlement of this Litigation. If you are a Class Member\n and do not timely and validly request exclusion from the Class (as described below), you will be bound by the Settlement and any\n judgment and release entered in the Litigation, including, but not limited to, the Judgment, whether or not you submit a Proof of The bank will use the Ethereum blockchain to record investors\u2019 MONY transactions.\n Claim.\n The Notice, which more completely describes the Settlement and your rights thereunder (including your right to object to\n the Settlement), the Proof of Claim, the Stipulation (which, among other things, contains de\ufb01nitions for the capitalized terms used\n in this Summary Notice), and other important documents, may be accessed online at www.DocGoSecuritiesSettlement.com, or by\n writing to or calling:\n JPMorgan holds baskets of relatively safe\n short-term debt securities\n that usually yield more than\n Some tokenized money-\n market funds are accepted as\n collateral on several crypto\n DocGo Securities Settlement\n Claims Administrator\n c/o Verita Global\n P.O. Box 301171\n Expands bank deposits. It pays interest\n and accrues dividends daily.\n Investors can subscribe and\n exchanges. And proponents\n say such offerings can help\n traditional asset managers at-\n\n In Crypto\n Los Angeles, CA 90030-1171 redeem shares using cash or tract new clients in the digi-\n 1-888-808-8947\n USDC, the stablecoin issued by tal-assets space.\n Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.\n Circle Internet Group. JPMorgan\u2019s expansion into\n Inquiries, other than requests for the Notice or for a Proof of Claim, may be made to Lead Counsel: Money-market funds, an in- tokenization is the latest move\n Robbins Geller Rudman & Dowd LLP Continued from page B1 vesting stalwart since the in a growing trend initiated by\n Ellen Gusiko\ufb00 Stewart\n 655 West Broadway, Suite 1900 investors\u2019 MONY transactions. 1970s, have grown more popu- several major asset managers,\n San Diego, CA 92101 Wall Street has waded lar this past year. Assets in including BlackRock, which\n 1-800-449-4900 deeper into tokenization since money funds total about $7.7 operates the largest tokenized\n settlementinfo@rgrdlaw.com\n the passage of the Genius Act trillion, up from $6.9 trillion money-market fund, with\n IF YOU DESIRE TO BE EXCLUDED FROM THE CLASS, YOU MUST SUBMIT A REQUEST FOR EXCLUSION\n SUCH THAT IT IS POSTMARKED BY MARCH 3, 2026, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE. this year. The measure, which at the start of 2025, according more than $1.8 billion in as-\n IF YOU PROPERLY EXCLUDE YOURSELF FROM THE CLASS, YOU WILL NOT BE BOUND BY ANY RELEASES, establishes a regulatory to the Invest- sets under\n JUDGMENTS, OR ORDERS ENTERED BY THE COURT IN THE LITIGATION AND YOU WILL NOT RECEIVE ANY framework for tokenized dol- ment Company management.\n BENEFITS FROM THE SETTLEMENT. EXCLUDING YOURSELF FROM THE CLASS IS THE ONLY OPTION THAT MAY\n ALLOW YOU TO BE PART OF ANY OTHER CURRENT OR FUTURE LAWSUIT AGAINST DEFENDANTS CONCERNING lars known as stablecoins, has Institute. In July,\n THE CLAIMS BEING RESOLVED BY THE SETTLEMENT. unleashed a wave of efforts to Meanwhile, the \u2018There is a Goldman Sachs\n IF YOU ARE A CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF\n ALLOCATION, AND/OR THE REQUEST BY LEAD COUNSEL FOR AN AWARD OF ATTORNEYS\u2019 FEES NOT TO EXCEED\n tokenize everything from total market massive amount and Bank of\n 33% OF THE $12.5 MILLION SETTLEMENT AMOUNT AND EXPENSES NOT TO EXCEED $250,000, PLUS INTEREST\n stocks and bonds to funds and capitalization New York Mel-\n ON BOTH AMOUNTS. ANY OBJECTIONS MUST BE FILED WITH THE COURT AND SENT TO LEAD COUNSEL AND real assets. of all stable- of interest from lon said they\n DEFENDANTS\u2019 COUNSEL BY MARCH 3, 2026, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE. \u201cThere is a massive amount coins has would partner\n BY ORDER OF THE COURT: of interest from clients around grown to more\n clients around to launch digi-\n DATED: November 18, 2025 UNITED STATES DISTRICT COURT\n SOUTHERN DISTRICT OF NEW YORK\n tokenization,\u201d said John than $300 bil- tokenization.\u2019 tal tokens that\n Donohue, head of global li- lion, according confer owner-\n quidity at J.P. Morgan Asset to CoinGecko. ship of money-\n PUBLIC NOTICES Management. \u201cAnd we expect Tokenized market funds\n to be a leader in this space money-market funds have be- managed by many of the big-\n and work with clients to make come an attractive offering for gest investment firms, includ-\n MARKETPLACE\n\n\n\n\n To all persons or entities interested in the liquidation of\n EXECUTIVE LIFE INSURANCE COMPANY OF NEW YORK sure that we have a product crypto investors because they ing BlackRock and Fidelity In-\n and the affairs of lineup that allows them to allow holders to earn a yield vestments, as well as their\n GUARANTY ASSOCIATION BENEFITS COMPANY\n By order of the Supreme Court of the State of New York, County of Nassau (the \u201cCourt\u201d), entered on April 19, have the choices that we have while their assets remain en- own asset-management arms.\n 2012 (the \u201cLiquidation Order\u201d), Executive Life Insurance Company of New York (\u201cELNY\u201d) was placed into liquidation,\n which liquidation became effective on August 8, 2013. Pursuant to the Agreement of Restructuring in Connection in traditional money-market tirely on the blockchain. This JPMorgan recently token-\n with the Liquidation of ELNY, dated April 23, 2012 (\u201cRestructuring Agreement\u201d), which was approved by the Court funds on blockchain.\u201d solves a previous dilemma ized a private-equity fund on\n in the Liquidation Order, Guaranty Association Bene\ufb01ts Company (\u201cGABC\u201d) assumed the ELNY restructured annuity\n bene\ufb01ts and enhanced those annuity bene\ufb01ts pursuant to the Restructuring Agreement. Since ELNY\u2019s liquidation, and Investors can subscribe to where investors typically held its blockchain platform for\n in accordance with the Restructuring Agreement, GABC has made payments of those annuity bene\ufb01ts as they have\n ADVERTISE TODAY\n\n\n\n\n become due. GABC hereby gives notice that it has petitioned the Court (the \u201cVeri\ufb01ed Petition\u201d), by order to show the MONY fund through the large amounts of idled cash in wealthy clients served by its\n cause (the \u201cOrder to Show Cause\u201d), for an order in furtherance of Liquidation Order, inter alia: bank\u2019s Morgan Money portal, stablecoins, which tradition- private bank.\n (1) Approving the Assumption Reinsurance Agreement (\u201cARA\u201d)1 among GABC (as the cedent) and Paci\ufb01c\n Life Insurance Company and its wholly-owned subsidiary Paci\ufb01c Life & Annuity Company (collectively, \u201cPaci\ufb01c a money-market investing ally don\u2019t pass on interest in- And companies, including\n Life\u201d) (as the reinsurers), pursuant to which Paci\ufb01c Life will assume all of the remaining GABC Liabilities, and\n (800) 366-3975\n\n\n\n\n the transactions it contemplates as satisfaction of the obligations of GABC, the National Organization of Life platform. In exchange, they come to holders. Robinhood, Kraken and Gem-\n and Health Insurance Guaranty Associations (\u201cNOLHGA\u201d), and the Participating Guaranty Associations (\u201cPGAs\u201d), will receive digital tokens in For fund managers, tokeni- ini, earlier this year launched\n under the Liquidation Order and Sections 6.2.1 and 6.2.5 of the Restructuring Agreement;\n (2) Releasing all Persons, including but not limited to GABC, NOLHGA, the PGAs, the Life Insurance their crypto wallets. zation can help cut costs and tokenized stocks and ex-\n Companies (as de\ufb01ned in the Restructuring Agreement) and the Supplemental Bene\ufb01ts Participating Companies,\n from any and all future obligations under or related to the Restructuring Agreement upon Closing except only the Like most money-market reduce the time it takes to change-traded funds for non-\n obligations of GABC and the Receiver (as de\ufb01ned in the Restructuring Agreement) under Sections 6.2.2 and 6.2.3\n THE\n\n\n\n\n of the Restructuring Agreement; funds, JPMorgan\u2019s MONY settle transactions. U.S. investors.\n (3) Ordering that, upon a transfer of all of the remaining GABC Liabilities to Paci\ufb01c Life, the net proceeds,\n after deducting certain amounts as speci\ufb01ed in Section 6.2.2 of the Restructuring Agreement, be remitted to ELNY\n as the Net Proceeds Transfer at a time and in the manner agreed upon by the Receiver and GABC;\n\n\n Holiday\n (4) Overruling any comment, suggestion, and/or objection presented to this Court to the extent any such\n comment, suggestion, and/or objection is inconsistent with the ARA, any related document, the Restructuring\n Agreement and/or the Liquidation Order, and denying any relief requested therein;\n (5) Con\ufb01rming that the order is issued pursuant to and under the Court\u2019s subject matter jurisdiction over\n (i) the Restructuring Agreement as retained by the Court under the Liquidation Order and (ii) the liquidation of\n ELNY under New York Insurance Law Article 74; and\n (6) Granting such other and further relief as this Court deems just and proper.\n A hearing on the Veri\ufb01ed Petition is scheduled for March 10, 2026, at 9:30 a.m., before the Honorable Thomas\n Rademaker, J.S.C., at IAS part 11, at the Courthouse located at 100 Supreme Court Drive, Mineola, New York\n 11501.\n For more information visit:\n wsj.com/classifieds\n Ads Start\n Early\n If you wish to support or object to the Veri\ufb01ed Petition, you must serve a written statement setting forth your\n position and all supporting documentation (the \u201cAnswering Papers\u201d) by \ufb01ling the Answering Papers on the New York\n State Courts Electronic Filing system (\u201cNYSCEF\u201d) or mailing the Answering Papers to GABC and the Receiver by First-\n Class mail or overnight carrier at the following addresses so as to be received by February 13, 2026:\n Guaranty Association Bene\ufb01ts Company\n c/o Faegre Drinker Biddle & Reath LLP\n Attn: Kevin P. Grif\ufb01th\n 300 North Meridian Street, Suite 2500 Continued from page B1\n Indianapolis, IN 46204\n AND childhood bedroom now con-\n Liquidator of Executive Life Insurance Company of New York tains a treadmill, with her fa-\n c/o Sidley Austin, LLP\n Attn: Martin B. Jackson ther running on it awkwardly,\n 787 Seventh Ave\n New York, NY 10019 wearing short shorts. The\n GABC will submit all Answering Papers not \ufb01led through NYCEF but received by GABC to the Court by \ufb01ling on young woman checks the Am-\n NYCEF by February 18, 2026.\n Any reply to the Answering Papers shall be \ufb01led by the Receiver and GABC on NYSCEF by March 5, 2026.\n azon app for more appropriate\n If no Answering Papers are \ufb01led as provided herein, the Court may enter relief without a hearing and no party shall workout gear.\n be entitled to be heard thereon. Despite the deluge, Ameri-\n If you fail to serve Answering Papers as provided herein, you shall be deemed to have waived any objections to\n the relief sought in the Veri\ufb01ed Petition and shall be barred from raising objections in this or any other proceeding cans generally like holiday\n concerning matters set forth in the Order to Show Cause. Further, if you serve Answering Papers as provided herein,\n you shall be deemed to have waived any objections that are not set forth in your Answering Papers. ads, according to an online Brent Bailey reprises his role as Kris K. in Target\u2019s campaign.\n Except as expressly modi\ufb01ed by the Order to Show Cause, the Liquidation Order is continued in full force and effect, poll conducted this month by\n including the injunctions provided for in the Liquidation Order.\n A copy of the Veri\ufb01ed Petition (including supporting documentation) and the Order to Show Cause may be viewed at\n Morning Consult for The Wall litical election cycles. somewhat. Just 9% expressed\n www.nylb.org/ELNY.html and www.gabene\ufb01tsco.com. To the extent there are any discrepancies between this notice\n \u00a9 2025 Dow Jones & Company, Inc.\n Street Journal. This stands in Two-thirds of respondents dislike. But many\u2014including\n and the Order to Show Cause, the Order to Show Cause controls.\n All Rights Reserved. contrast to the often-criticized said they enjoy seeing holiday- 70% of baby boomers\u2014felt the\n 1\n Capitalized terms not otherwise de\ufb01ned herein have the meaning ascribed to them in the ARA.\n ad blitzes associated with po- themed ads either a lot or spots start too early.\n\f Case 1:23-cv-09476-KPF Document 114-4 Filed 02/17/26 Page 3 of 5\n\n\n\n\n Declaration of Publication\n\n\nI, Jonathan D. Carameros, as Senior Vice President, Settlement Administration at Verita\nGlobal LLC f/k/a Gilardi Settlement Administration Company in San Rafael, California,\nhereby certify that I caused the attached notice to be printed in said publication on\nDecember 16, 2025:\n\nName of Publication: The Wall Street Journal\nAddress: 1211 Avenue of the Americas\nCity, State, Zip: New York, NY 10036\nPhone #: 1-800-568-7625\nState of: New York\n\nI declare under penalty of perjury that the foregoing is true and correct. Executed on this\n16th day of December 2025, at Danville, California.\n\n\n\n\n Jonathan D. Carameros\n\fCase 1:23-cv-09476-KPF Document 114-4 Filed 02/17/26 Page 4 of 5\n\f Case 1:23-cv-09476-KPF Document 114-4 Filed 02/17/26 Page 5 of 5\n\n\n\n\n Declaration of Publication\n\n\nI, Jonathan D. Carameros, as Senior Vice President, Settlement Administration at Verita\nGlobal LLC f/k/a Gilardi Settlement Administration Company in San Rafael, California,\nhereby certify that I caused the attached notice to be published as a press release by the\nfollowing wire service:\n\nName of Publication: BusinessWire\nAddress: 101 California Street 20th Floor\nCity, ST Zip: San Francisco, CA 94111\nPhone #: 415-986-4422\nState of: California\n\nThe press release was distributed on December 16, 2025 to the following media circuits\noffered by the above-referenced wire service:\n\n 1. National Newsline\n\nI declare under penalty of perjury that the foregoing is true and correct. Executed on this\n16th day of December 2025, at Danville, California.\n\n\n\n\n Jonathan D. Carameros\n\f","ocr_status":1,"date_upload":"2026-06-22T23:06:21.601785-07:00","document_number":"114","attachment_number":4,"pacer_doc_id":"127039079639","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit D (Confirmations of Publication)","acms_document_guid":""}],"date_created":"2026-02-17T13:09:07.812748-08:00","date_modified":"2026-02-20T12:05:41.077732-08:00","date_filed":"2026-02-17","time_filed":"14:08:47","entry_number":114,"recap_sequence_number":"2026-02-17.007","pacer_sequence_number":381,"description":"DECLARATION of Ross D. Murray on Behalf of Verita Global in Support re: 110 MOTION for Attorney Fees and Expenses., 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation.. Document filed by Genesee County Employees' Retirement System. (Attachments: # 1 Exhibit A (Postcard Notice), # 2 Exhibit B (Claim Package), # 3 Exhibit C (Nominee Letter), # 4 Exhibit D (Confirmations of Publication)).(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454111486/","id":454111486,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469020132/","id":469020132,"tags":[],"absolute_url":"/docket/67923163/115/naclerio-v-docgo-inc/","date_created":"2026-02-17T13:09:02.981923-08:00","date_modified":"2026-06-23T05:34:52.439290-07:00","sha1":"938fee500931ece014d2be2e38bb2265edc42b39","page_count":6,"file_size":166291,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 1 of 6\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : DECLARATION OF CHRISTOPHER M.\n : WOOD FILED ON BEHALF OF ROBBINS\n vs. : GELLER RUDMAN & DOWD LLP IN\n : SUPPORT OF APPLICATION FOR\nDOCGO INC. and ANTHONY CAPONE, : AWARD OF ATTORNEYS\u2019 FEES AND\n : EXPENSES\n Defendants.\n :\n x\n\n\n\n\n4902-1354-7658.v4\n\f Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 2 of 6\n\n\n\n\n I, CHRISTOPHER M. WOOD, declare as follows:\n\n 1. I am a member of the firm of Robbins Geller Rudman & Dowd LLP (\u201cRobbins\n\nGeller\u201d or the \u201cFirm\u201d). I am submitting this declaration in support of the application for an award\n\nof attorneys\u2019 fees, expenses and charges (\u201cexpenses\u201d) in connection with services rendered in the\n\nabove-entitled action (the \u201cLitigation\u201d).\n\n 2. This Firm is Lead Counsel of record for Lead Plaintiff Genesee County Employees\u2019\n\nRetirement System and the Class herein.\n\n 3. The information in this declaration regarding the Firm\u2019s time and expenses is taken\n\nfrom time and expense reports and supporting documentation prepared and/or maintained by the\n\nFirm in the ordinary course of business. I am the partner who oversaw and/or conducted the day-\n\nto-day activities in the Litigation and I reviewed these reports (and backup documentation where\n\nnecessary or appropriate) in connection with the preparation of this declaration. The purpose of\n\nthis review was to confirm both the accuracy of the entries as well as the necessity for, and\n\nreasonableness of, the time and expenses committed to the Litigation. As a result of this review,\n\nreductions were made to both time and expenses in the exercise of billing judgment. Based on this\n\nreview and the adjustments made, I believe that the time reflected in the Firm\u2019s lodestar calculation\n\nand the expenses for which payment is sought herein are reasonable and were necessary for the\n\neffective and efficient prosecution and resolution of the Litigation.\n\n 4. After the reductions referred to above, the number of hours spent on the Litigation\n\nby the Firm is 1,932.90. A breakdown of the lodestar is provided in the attached Exhibit A. The\n\nlodestar amount for attorney/paraprofessional time based on the Firm\u2019s current rates is\n\n$1,440,804.50. The hourly rates shown in Exhibit A are the Firm\u2019s current rates in contingent\n\ncases set by the Firm for each individual. These hourly rates are consistent with hourly rates\n\n -1-\n4902-1354-7658.v4\n\f Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 3 of 6\n\n\n\n\nsubmitted by the Firm to state and federal courts in other securities class action litigation. The\n\nFirm\u2019s rates are set based on periodic analysis of rates charged by firms performing comparable\n\nwork both on the plaintiff and defense side. Different timekeepers within the same employment\n\ncategory (e.g., partners, associates, paralegals, etc.) may have different rates based on a variety of\n\nfactors, including years of practice, years at the Firm, years in the current position (e.g., years as a\n\npartner), relevant experience, relative expertise, and the rates of similarly experienced peers at this\n\nFirm or other firms. For personnel who are no longer employed by the Firm, the \u201ccurrent rate\u201d\n\nused for the lodestar calculation is based upon the rate for that person in his or her final year of\n\nemployment with the Firm.\n\n 5. The Firm seeks an award of $183,676.18 in expenses and charges in connection\n\nwith the prosecution of the Litigation. Those expenses and charges are summarized by category\n\nin the attached Exhibit B.\n\n 6. The following is additional information regarding certain of these expenses:\n\n (a) Filing and Attorney Service Fees: $4,100.00. These expenses have been\n\npaid to the Court for filing fees and to an attorney service firm who served process of subpoenas.\n\nThe vendors who were paid for these services are set forth in the attached Exhibit C.\n\n (b) Business Wire: $155.00. This expense was necessary under the Private\n\nSecurities Litigation Reform Act of 1995\u2019s (\u201cPSLRA\u201d) \u201cearly notice\u201d requirements, which\n\nprovides, among other things, that\n\n Not later than 20 days after the date on which the complaint is filed, the\n plaintiff or plaintiffs shall cause to be published, in a widely circulated national\n business-oriented publication or wire service, a notice advising members of the\n purported plaintiff class \u2013 (I) of the pendency of the action, the claims asserted\n therein, and the purported class period; and (II) that, not later than 60 days after the\n date on which the notice is published, any member of the purported class may move\n the court to serve as lead plaintiff of the purported class.\n\n -2-\n4902-1354-7658.v4\n\f Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 4 of 6\n\n\n\n\nSee 15 U.S.C. \u00a778u-4(a)(3)(A)(i).\n\n (c) Consultants/Experts: $125,543.75.\n\n (i) Fideres USA Inc.: $95,500.00. Lead Plaintiff retained the services\n\nof Matthew D. Cain, Ph.D., and consulting group Fideres USA Inc., concerning causation and\n\ndamages. Mr. Cain, with the assistance of Fideres, provided critical economic analysis and drafted\n\nan expert report in connection with class certification, which was submitted to the Court on July\n\n21, 2025.\n\n (ii) BVA Group LLC: $30,043.75. Lead Plaintiff retained the services\n\nof consulting group BVA and one of its partners, W. Scott Dalrymple, CFA, concerning causation\n\nand damages. Mr. Dalrymple, with the assistance of other members of BVA, served as a consulting\n\nexpert in connection with the drafting of the complaint, as well as Lead Plaintiff\u2019s settlement\n\nefforts.\n\n (d) Outside Counsel for Third Party Subpoena (Zimmerman Reed, PLLP):\n\n$21,012.81. Outside counsel fees for services provided from June through September 2025 in the\n\nrepresentation of Summit Creek Advisors, LLC - one of Lead Plaintiff\u2019s investment managers -\n\nwho was subpoenaed by Defendants in the course of the Litigation.\n\n (e) Online Legal and Financial Research: $3,064.86. This category includes\n\nvendors such as LexisNexis Products, Refinitiv, and Westlaw. These resources were used to obtain\n\naccess to SEC filings, factual databases, legal research, and for proofreading and \u201cblue-booking\u201d\n\ncourt filings (including checking all legal authorities cited and quoted in briefs). This category\n\nrepresents the expenses incurred by Robbins Geller for use of these services in connection with\n\nthis Litigation. The charges for these vendors vary depending upon the type of services requested.\n\nFor example, Robbins Geller has flat-rate contracts with some of these providers for use of their\n\n\n -3-\n4902-1354-7658.v4\n\f Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 5 of 6\n\n\n\n\nservices. When Robbins Geller utilizes online services provided by a vendor with a flat-rate\n\ncontract, access to the service is by a billing code entered for the specific case being litigated. At\n\nthe end of each billing period in which such service is used, Robbins Geller\u2019s costs for such\n\nservices are allocated to specific cases based on the percentage of use in connection with that\n\nspecific case in the billing period. As a result of the contracts negotiated by Robbins Geller with\n\ncertain providers, the Class enjoys substantial savings in comparison with the \u201cmarket-rate\u201d for a\n\nla carte use of such services which some law firms pass on to their clients. For example, the\n\n\u201cmarket-rate\u201d charged to others by LexisNexis for the types of services used by Robbins Geller is\n\nmore expensive than the rates negotiated by Robbins Geller.\n\n (f) eDiscovery Database Hosting: $797.30. Robbins Geller has installed top\n\ntier database software, infrastructure, and security. The platform implemented, Relativity, is\n\noffered by over 100 vendors and is currently being used by 198 of the AmLaw200 firms. Over 50\n\nservers are dedicated to Robbins Geller\u2019s Relativity hosting environment with all data stored in a\n\nsecure SSAE 18 Tier III data center with automatic replication to a datacenter located in a different\n\ngeographic location. By hosting in-house, Robbins Geller is able to charge a reduced all-in rate\n\nthat includes many services which are often charged as extra fees when hosted by a third-party\n\nvendor. Robbins Geller\u2019s hosting fee includes user logins, ingestion, processing, OCRing,\n\nTIFFing, bates stamping, productions, and archiving \u2013 all at no additional per unit cost. Also\n\nincluded is unlimited structured and conceptual analytics (i.e., email threading, inclusive detection,\n\nnear-dupe detection, concept searching, active learning, clustering, and more). Robbins Geller is\n\nable to provide all these services for a cost that is typically much lower than outsourcing to a third-\n\nparty vendor. Utilizing this secure, advanced platform in-house has allowed Robbins Geller to\n\nprosecute actions more efficiently, utilize AI technology, and has reduced the expense of\n\n -4-\n4902-1354-7658.v4\n\f Case 1:23-cv-09476-KPF Document 115 Filed 02/17/26 Page 6 of 6\n\n\n\n\nmaintaining and searching electronic discovery databases. Similar to third-party vendors, Robbins\n\nGeller uses a tiered rate system to calculate hosting charges. The amount requested reflects charges\n\nfor the hosting of over 25,000 pages of documents received by parties and non-parties in this\n\naction.\n\n (g) Mediation Fees (Phillips ADR Enterprises, P.C.): $28,262.50. These are\n\nthe fees of the mediator, Miles N. Ruthberg, who conducted a mediation session, as well as many\n\nfollow-up discussions with the parties, leading to the eventual settlement of the Litigation.\n\n 7. The expenses pertaining to this case are reflected in the books and records of this\n\nFirm. These books and records are prepared from receipts, expense vouchers, check records, and\n\nother documents and are an accurate record of the expenses.\n\n 8. The identification and background of my Firm and its partners is attached hereto as\n\nExhibit D.\n\n I declare under penalty of perjury that the foregoing is true and correct. Executed this 17th\n\nday of February, 2026, at Nashville, Tennessee.\n\n s/Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n\n -5-\n4902-1354-7658.v4\n\f","ocr_status":2,"date_upload":"2026-06-22T23:04:56.868285-07:00","document_number":"115","attachment_number":null,"pacer_doc_id":"127039079701","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Declaration in Support of Motion","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469472076/","id":469472076,"tags":[],"absolute_url":"/docket/67923163/115/1/naclerio-v-docgo-inc/","date_created":"2026-02-20T12:09:32.940434-08:00","date_modified":"2026-06-23T03:26:48.391717-07:00","sha1":"6be58070a1cee24b1406bc551fa20e33b435222d","page_count":2,"file_size":55692,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 115-1 Filed 02/17/26 Page 1 of 2\n\n\n\n\n EXHIBIT A\n\fCase 1:23-cv-09476-KPF Document 115-1 Filed 02/17/26 Page 2 of 2\n\n\n\n\n EXHIBIT A\n\n Genesee Cnty. Emps.' Ret. Sys. v. DocGo Inc. & Anthony Capone,\n Civil Action No. 1:23-cv-09476-KPF\n Robbins Geller Rudman & Dowd LLP\n Inception through December 17, 2025\n\n NAME HOURS RATE LODESTAR\n Bays, Lea M. (P) 17.30 1055 $ 18,251.50\n Gusikoff Stewart, Ellen A. (P) 43.30 1370 59,321.00\n Myers, Danielle S. (P) 6.60 1145 7,557.00\n Niehaus, Eric I. (P) 435.30 1070 465,771.00\n Rosenfeld, David A. (P) 24.70 1140 28,158.00\n Rudman, Samuel H. (P) 10.50 1600 16,800.00\n Wood, Christopher M. (P) 363.50 1070 388,945.00\n Bator, Henry S. (A) 266.80 425 113,390.00\n Dolitsky, Kenneth P. (A) 9.10 470 4,277.00\n Tull, Joseph J. (A) 211.20 540 114,048.00\n Barhoum, Anthony J. (EA) 8.60 485 4,171.00\n Hensley, Austin B. (EA) 8.00 315 2,520.00\n Topp, Jennifer M. (EA) 12.00 425 5,100.00\n Roelen, Scott R. (RA) 9.20 370 3,404.00\n McLaughlin, Mara A. (I) 196.40 405 79,542.00\n Peitler, Steven J. (I) 40.50 430 17,415.00\n Keita, Omar C. (LS) 19.50 350 6,825.00\n Peters, Camielle (LS) 7.70 240 1,848.00\n Paralegals 209.40 475 99,465.00\n Shareholder Relations 33.30 120 3,996.00\n TOTAL 1,932.90 $ 1,440,804.50\n (P) Partner\n (A) Associate\n (EA) Economic Analyst\n (RA) Research Analyst\n (I) Investigator\n (LS) Litigation Support\n\f","ocr_status":1,"date_upload":"2026-06-22T23:05:17.901989-07:00","document_number":"115","attachment_number":1,"pacer_doc_id":"127039079702","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit A (Lodestar Report)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469472077/","id":469472077,"tags":[],"absolute_url":"/docket/67923163/115/2/naclerio-v-docgo-inc/","date_created":"2026-02-20T12:09:33.030832-08:00","date_modified":"2026-06-23T05:41:29.621574-07:00","sha1":"69025da5c53dee77f33e88f7e956e518e0f1d1a8","page_count":2,"file_size":35711,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 115-2 Filed 02/17/26 Page 1 of 2\n\n\n\n\n EXHIBIT B\n\fCase 1:23-cv-09476-KPF Document 115-2 Filed 02/17/26 Page 2 of 2\n\n\n\n\n EXHIBIT B\n\n Genesee Cnty. Emps.' Ret. Sys. v. DocGo Inc. & Anthony Capone,\n Civil Action No. 1:23-CV-09476-KPF\n Robbins Geller Rudman & Dowd LLP\n Expense Summary\n Inception through November 30, 2025\n\n CATEGORY AMOUNT\n Filing and Attorney Service Fees $ 4,100.00\n Business Wire 155.00\n In-House Messenger 540.36\n Consultants/Experts 125,543.75\n Fideres USA Inc. $ 95,500.00\n BVA Group LLC 30,043.75\n Outside Counsel for Third Party Subpoena\n (Zimmerman Reed, PLLP) 21,012.81\n Online Legal and Financial Research 3,064.86\n eDiscovery Database Hosting 797.30\n Mediation Fees (Phillips ADR Enterprises, P.C.) 28,262.50\n Miscellaneous (Publications/Subscriptions) 199.60\n TOTAL $ 183,676.18\n\f","ocr_status":1,"date_upload":"2026-06-22T23:05:23.640604-07:00","document_number":"115","attachment_number":2,"pacer_doc_id":"127039079703","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit B (Expense Summary)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469472078/","id":469472078,"tags":[],"absolute_url":"/docket/67923163/115/3/naclerio-v-docgo-inc/","date_created":"2026-02-20T12:09:33.048595-08:00","date_modified":"2026-06-23T03:27:01.020550-07:00","sha1":"356a7d03911637cac4bfebe3924eaea065928a9c","page_count":4,"file_size":49665,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 115-3 Filed 02/17/26 Page 1 of 4\n\n\n\n\n EXHIBIT C\n\f Case 1:23-cv-09476-KPF Document 115-3 Filed 02/17/26 Page 2 of 4\n\n\n\n\n EXHIBIT C\n\n Genesee Cnty. Emps.' Ret. Sys. v. DocGo Inc. & Anthony Capone,\n Civil Action No. 1:23-CV-09476-KPF\n Robbins Geller Rudman & Dowd LLP\n\nFiling and Attorney Service Fees: $4,100.00\n\n DATE VENDOR PURPOSE\n 01/24/24 CLERK OF THE COURT CERTIFICATE OF GOOD STANDING FOR\n C. WOOD\n 02/03/24 CLERK OF THE COURT PRO HAC VICE FILING FEE FOR C. WOOD\n 02/09/24 CLERK OF THE COURT CERTIFICATE OF GOOD STANDING FOR\n H. BATOR\n 02/22/24 RGR&D LLP ELECTRONIC PRO HAC VICE APPLICATION FOR H.\n FILINGS ACCOUNT BATOR\n 04/10/25 RGR&D LLP ELECTRONIC CERTIFICATE OF GOOD STANDING FOR\n FILINGS ACCOUNT J. TULL\n 04/10/25 RGR&D LLP ELECTRONIC CERTIFICATE OF GOOD STANDING FOR\n FILINGS ACCOUNT E. NIEHAUS\n 04/14/25 RGR&D LLP ELECTRONIC PRO HAC VICE FILING FEE FOR E.\n FILINGS ACCOUNT NIEHAUS\n 04/14/25 RGR&D LLP ELECTRONIC PRO HAC VICE FILING FEE FOR J. TULL\n FILINGS ACCOUNT\n 04/15/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: THE STATE\n LITIGATION SUPPORT UNIVERSITY OF NEW YORK AT\n SERVICES, INC. POTSDAM - SUBPOENA TO PRODUCE\n DOCUMENTS, INFORMATION, OR\n OBJECTS OR TO PERMIT INSPECTION\n OF PREMISES IN A CIVIL ACTION;\n SCHEDULE A\n 04/15/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: CLARKSON\n LITIGATION SUPPORT UNIVERSITY - SUBPOENA TO PRODUCE\n SERVICES, INC. DOCUMENTS, INFORMATION, OR\n OBJECTS OR TO PERMIT INSPECTION\n OF PREMISES IN A CIVIL ACTION;\n SCHEDULE A\n 04/15/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: UNITEDHEALTH\n LITIGATION SUPPORT GROUP INCORPORATED - SUBPOENA\n SERVICES, INC. TO PRODUCE DOCUMENTS,\n INFORMATION, OR OBJECTS OR TO\n PERMIT INSPECTION OF PREMISES IN A\n CIVIL ACTION; SCHEDULE A\n 06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: CANACCORD\n LITIGATION SUPPORT GENUITY, LLC - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n\f Case 1:23-cv-09476-KPF Document 115-3 Filed 02/17/26 Page 3 of 4\n\n\n\n\nDATE VENDOR PURPOSE\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: NORTHLAND\n LITIGATION SUPPORT SECURITIES, INC. - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: STIFEL, NICOLAUS\n LITIGATION SUPPORT & COMPANY - SUBPOENA TO PRODUCE\n SERVICES, INC. DOCUMENTS, INFORMATION, OR\n OBJECTS OR TO PERMIT INSPECTION\n OF PREMISES IN A CIVIL ACTION;\n SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: BTIG, LLC -\n LITIGATION SUPPORT SUBPOENA TO PRODUCE DOCUMENTS,\n SERVICES, INC. INFORMATION, OR OBJECTS OR TO\n PERMIT INSPECTION OF PREMISES IN A\n CIVIL ACTION; SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: NEEDHAM &\n LITIGATION SUPPORT COMPANY, LLC - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: LIFESCI\n LITIGATION SUPPORT ADVISORS, LLC - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n06/25/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: CANTOR\n LITIGATION SUPPORT FITZGERALD, L.P. - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n\f Case 1:23-cv-09476-KPF Document 115-3 Filed 02/17/26 Page 4 of 4\n\n\n\n\n DATE VENDOR PURPOSE\n06/30/25 CLASS ACTION RESEARCH & RETURNED NOT SERVED: 5W PUBLIC\n LITIGATION SUPPORT RELATIONS, LLC - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n07/15/25 CLASS ACTION RESEARCH & PERSONAL SERVICE: 5W PUBLIC\n LITIGATION SUPPORT RELATIONS, LLC - SUBPOENA TO\n SERVICES, INC. PRODUCE DOCUMENTS, INFORMATION,\n OR OBJECTS OR TO PERMIT\n INSPECTION OF PREMISES IN A CIVIL\n ACTION; SCHEDULE A\n11/13/25 CLERK OF THE COURT PRO HAC VICE APPLICATION FOR E.\n GUSIKOFF STEWART\n\f","ocr_status":1,"date_upload":"2026-06-22T23:05:34.723126-07:00","document_number":"115","attachment_number":3,"pacer_doc_id":"127039079704","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit C (Filing Expenses)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469472079/","id":469472079,"tags":[],"absolute_url":"/docket/67923163/115/4/naclerio-v-docgo-inc/","date_created":"2026-02-20T12:09:33.631271-08:00","date_modified":"2026-06-23T05:41:22.512831-07:00","sha1":"b36f381b75c86db40b26266940b3932c4b98e8d7","page_count":159,"file_size":1479255,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.115.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 1 of 159\n\n\n\n\n EXHIBIT D\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 2 of 159\n\n\n\n\n FIRM RESUME\n\n\n\n\nRobbins Geller\nRudman&Dowd lip (800) 449-4900 | rgrdlaw.com\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 3 of 159\n\n\n\n\nTABLE OF CONTENTS\nIntroduction 1\n\n\nPractice Areas and Services 2\n Securities Fraud.................................................................................................... 2\n Shareholder Derivative and Corporate Governance Litigation.......................... 9\n Options Backdating Litigation............................................................................. 12\n Corporate Takeover Litigation............................................................................ 12\n Antitrust................................................................................................................ 15\n Consumer Fraud and Privacy.............................................................................. 16\n Human Rights, Labor Practices, and Public Policy............................................. 20\n Environment and Public Health.......................................................................... 21\n Pro Bono............................................................................................................... 22\n\nProminent Cases, Precedent-Setting Decisions, and Judicial Commendations 24\n Prominent Cases................................................................................................... 24\n Precedent-Setting Decisions................................................................................. 33\n Additional Judicial Commendations.................................................................... 40\n\nAttorney Biographies 48\n Partners................................................................................................................. 48\n Of Counsel............................................................................................................ 130\n Special Counsel..................................................................................................... 154\n Forensic Accountants............................................................................................ 155\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 4 of 159\n\n\n\n\nINTRODUCTION\n\nRobbins Geller Rudman & Dowd LLP (\u201cRobbins Geller\u201d or the \u201cFirm\u201d) is a 200-lawyer firm with offices in\nBoca Raton, Chicago, Manhattan, Melville, Nashville, San Diego, San Francisco, Philadelphia,\nWashington, D.C., and Wilmington (www.rgrdlaw.com). The Firm is actively engaged in complex\nlitigation, emphasizing securities, consumer, antitrust, insurance, healthcare, human rights, and\nemployment discrimination class actions. The Firm\u2019s unparalleled experience and capabilities in these\nfields are based upon the talents of its attorneys, who have successfully prosecuted thousands of class\naction lawsuits and numerous individual cases, recovering billions of dollars.\n\nThis successful track record stems from our experienced attorneys, including many who came to the Firm\nfrom federal or state law enforcement agencies. The Firm also includes several dozen former federal and\nstate judicial clerks.\n\nThe Firm is committed to practicing law with the highest level of integrity in an ethical and professional\nmanner. We are a diverse firm with lawyers and staff from all walks of life. Our lawyers and other\nemployees are hired and promoted based on the quality of their work and their ability to treat others with\nrespect and dignity.\n\nWe strive to be good corporate citizens and work with a sense of global responsibility. Contributing to our\ncommunities and environment is important to us. We often take cases on a pro bono basis and are\ncommitted to the rights of workers, and to the extent possible, we contract with union vendors. We care\nabout civil rights, workers\u2019 rights and treatment, workplace safety, and environmental protection.\nIndeed, while we have built a reputation as the finest securities and consumer class action law firm in the\nnation, our lawyers have also worked tirelessly in less high-profile, but no less important, cases involving\nhuman rights and other social issues.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 1\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 5 of 159\n\n\n\nPRACTICE AREAS AND SERVICES\nSecurities Fraud\nAs recent corporate scandals demonstrate clearly, it has become all too common for companies and their\nexecutives \u2013 often with the help of their advisors, such as bankers, lawyers, and accountants \u2013 to\nmanipulate the market price of their securities by misleading the public about the company\u2019s financial\ncondition or prospects for the future. This misleading information has the effect of artificially inflating\nthe price of the company\u2019s securities above their true value. When the underlying truth is eventually\nrevealed, the prices of these securities plummet, harming those innocent investors who relied upon the\ncompany\u2019s misrepresentations.\n\nRobbins Geller is the leader in the fight to protect investors from corporate securities fraud. We utilize a\nwide range of federal and state laws to provide investors with remedies, either by bringing a class action\non behalf of all affected investors or, where appropriate, by bringing individual cases.\n\nThe Firm\u2019s reputation for excellence has been repeatedly noted by courts and has resulted in the\nappointment of Firm attorneys to lead roles in hundreds of complex class-action securities and other\ncases. In the securities area alone, the Firm\u2019s attorneys have been responsible for a number of\noutstanding recoveries on behalf of investors. Currently, Robbins Geller attorneys are lead or named\ncounsel in hundreds of securities class action or large institutional-investor cases. Some notable current\nand past cases include:\n\n In re Enron Corp. Sec. Litig., No. H-01-3624 (S.D. Tex.). Robbins Geller attorneys and lead\n plaintiff The Regents of the University of California aggressively pursued numerous defendants,\n including many of Wall Street\u2019s biggest banks, and successfully obtained settlements in excess of\n $7.2 billion for the benefit of investors. This is the largest securities class action recovery in history.\n\n Jaffe v. Household Int\u2019l, Inc., No. 02-C-05893 (N.D. Ill.). As sole lead counsel, Robbins Geller\n obtained a record-breaking settlement of $1.575 billion after 14 years of litigation, including a six-\n week jury trial in 2009 that resulted in a securities fraud verdict in favor of the class. In 2015, the\n Seventh Circuit Court of Appeals upheld the jury\u2019s verdict that defendants made false or\n misleading statements of material fact about the company\u2019s business practices and financial results,\n but remanded the case for a new trial on the issue of whether the individual defendants \u201cmade\u201d\n certain false statements, whether those false statements caused plaintiffs\u2019 losses, and the amount of\n damages. The parties reached an agreement to settle the case just hours before the retrial was\n scheduled to begin on June 6, 2016. The $1.575 billion settlement, approved in October 2016, is the\n largest ever following a securities fraud class action trial, the largest securities fraud settlement in\n the Seventh Circuit and the eighth-largest settlement ever in a post-PSLRA securities fraud case.\n According to published reports, the case was just the seventh securities fraud case tried to a verdict\n since the passage of the PSLRA.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 2\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 6 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., No. 3:15-cv-07658 (D.N.J.). As sole lead counsel,\nRobbins Geller attorneys obtained a $1.2 billion settlement in the securities case that Vanity Fair\nreported as \u201cthe corporate scandal of its era\u201d that had raised \u201cfundamental questions about the\nfunctioning of our health-care system, the nature of modern markets, and the slippery slope of\nethical rationalizations.\u201d The settlement resolves claims that defendants made false and misleading\nstatements regarding Valeant\u2019s business and financial performance during the class period,\nattributing Valeant\u2019s dramatic growth in revenues and profitability to \u201cinnovative new marketing\napproaches\u201d as part of a business model that was low risk and \u201cdurable and sustainable.\u201d Valeant is\nthe largest securities class action settlement against a pharmaceutical manufacturer and the ninth\nlargest ever.\n\nIn re Am. Realty Cap. Props., Inc. Litig., No. 1:15-mc-00040 (S.D.N.Y.). As sole lead counsel,\nRobbins Geller attorneys zealously litigated the case arising out of ARCP\u2019s manipulative accounting\npractices and obtained a $1.025 billion settlement. For five years, the litigation team prosecuted\nnine different claims for violations of the Securities Exchange Act of 1934 and the Securities Act of\n1933, involving seven different stock or debt offerings and two mergers. The recovery represents\nthe highest percentage of damages of any major PSLRA case prior to trial and includes the largest\npersonal contributions by individual defendants in history.\n\nIn re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.). Robbins Geller\nrepresented the California Public Employees\u2019 Retirement System (\u201cCalPERS\u201d) and demonstrated\nits willingness to vigorously advocate for its institutional clients, even under the most difficult\ncircumstances. The Firm obtained an $895 million recovery on behalf of UnitedHealth\nshareholders, and former CEO William A. McGuire paid $30 million and returned stock options\nrepresenting more than three million shares to the shareholders, bringing the total recovery for\nthe class to over $925 million, the largest stock option backdating recovery ever, and a recovery\nthat is more than four times larger than the next largest options backdating recovery. Moreover,\nRobbins Geller obtained unprecedented corporate governance reforms, including election of a\nshareholder-nominated member to the company\u2019s board of directors, a mandatory holding period\nfor shares acquired by executives via option exercise, and executive compensation reforms that tie\npay to performance.\n\nAlaska Elec. Pension Fund v. CitiGroup, Inc. (In re WorldCom Sec. Litig.), No. 03 Civ. 8269\n(S.D.N.Y.). Robbins Geller attorneys represented more than 50 private and public institutions that\nopted out of the class action case and sued WorldCom\u2019s bankers, officers and directors, and\nauditors in courts around the country for losses related to WorldCom bond offerings from 1998 to\n2001. The Firm\u2019s attorneys recovered more than $650 million for their clients, substantially more\nthan they would have recovered as part of the class.\n\nLuther v. Countrywide Fin. Corp., No. 12-cv-05125 (C.D. Cal.). Robbins Geller attorneys secured a\n$500 million settlement for institutional and individual investors in what is the largest RMBS\npurchaser class action settlement in history, and one of the largest class action securities\nsettlements of all time. The unprecedented settlement resolves claims against Countrywide and\nWall Street banks that issued the securities. The action was the first securities class action case filed\nagainst originators and Wall Street banks as a result of the credit crisis. As co-lead counsel Robbins\nGeller forged through six years of hard-fought litigation, oftentimes litigating issues of first\nimpression, in order to secure the landmark settlement for its clients and the class.\n\nIn re Wachovia Preferred Sec. & Bond/Notes Litig., No. 09-cv-06351 (S.D.N.Y.). On behalf of\ninvestors in bonds and preferred securities issued between 2006 and 2008, Robbins Geller and co-\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 3\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 7 of 159\n PRACTICE AREAS AND SERVICES\n\ncounsel obtained a significant settlement with Wachovia successor Wells Fargo & Company and\nWachovia auditor KPMG LLP. The total settlement \u2013 $627 million \u2013 is one of the largest credit-crisis\nsettlements involving Securities Act claims and one of the 25 largest securities class action recoveries\nin history. The settlement is also one of the biggest securities class action recoveries arising from\nthe credit crisis. The lawsuit focused on Wachovia\u2019s exposure to \u201cpick-a-pay\u201d loans, which the\nbank\u2019s offering materials said were of \u201cpristine credit quality,\u201d but which were actually allegedly\nmade to subprime borrowers, and which ultimately massively impaired the bank\u2019s mortgage\nportfolio. Robbins Geller served as co-lead counsel representing the City of Livonia Employees\u2019\nRetirement System, Hawaii Sheet Metal Workers Pension Fund, and the investor class.\n\nIn re Cardinal Health, Inc. Sec. Litig., No. C2-04-575 (S.D. Ohio). As sole lead counsel\nrepresenting Cardinal Health shareholders, Robbins Geller obtained a recovery of $600 million\nfor investors on behalf of the lead plaintiffs, Amalgamated Bank, the New Mexico State Investment\nCouncil, and the California Ironworkers Field Trust Fund. At the time, the $600 million\nsettlement was the tenth-largest settlement in the history of securities fraud litigation and is the\nlargest-ever recovery in a securities fraud action in the Sixth Circuit.\n\nAOL Time Warner Cases I & II, JCCP Nos. 4322 & 4325 (Cal. Super. Ct., Los Angeles Cnty.).\nRobbins Geller represented The Regents of the University of California, six Ohio state pension\nfunds, Rabo Bank (NL), the Scottish Widows Investment Partnership, several Australian public\nand private funds, insurance companies, and numerous additional institutional investors, both\ndomestic and international, in state and federal court opt-out litigation stemming from Time\nWarner\u2019s disastrous 2001 merger with Internet high flier America Online. After almost four years\nof litigation involving extensive discovery, the Firm secured combined settlements for its opt-out\nclients totaling over $629 million just weeks before The Regents\u2019 case pending in California state\ncourt was scheduled to go to trial. The Regents\u2019 gross recovery of $246 million is the largest\nindividual opt-out securities recovery in history.\n\nIn re HealthSouth Corp. Sec. Litig., No. CV-03-BE-1500-S (N.D. Ala.). As court-appointed co-lead\ncounsel, Robbins Geller attorneys obtained a combined recovery of $671 million from\nHealthSouth, its auditor Ernst & Young, and its investment banker, UBS, for the benefit of\nstockholder plaintiffs. The settlement against HealthSouth represents one of the larger\nsettlements in securities class action history and is considered among the top 15 settlements\nachieved after passage of the PSLRA. Likewise, the settlement against Ernst & Young is one of the\nlargest securities class action settlements entered into by an accounting firm since the passage of\nthe PSLRA.\n\nJones v. Pfizer Inc., No. 1:10-cv-03864 (S.D.N.Y.). Lead plaintiff Stichting Philips Pensioenfonds\nobtained a $400 million settlement on behalf of class members who purchased Pfizer common\nstock during the January 19, 2006 to January 23, 2009 class period. The settlement against Pfizer\nresolves accusations that it misled investors about an alleged off-label drug marketing scheme. As\nsole lead counsel, Robbins Geller attorneys helped achieve this exceptional result after five years of\nhard-fought litigation against the toughest and the brightest members of the securities defense bar\nby litigating this case all the way to trial.\n\nIn re Dynegy Inc. Sec. Litig., No. H-02-1571 (S.D. Tex.). As sole lead counsel representing The\nRegents of the University of California and the class of Dynegy investors, Robbins Geller attorneys\nobtained a combined settlement of $474 million from Dynegy, Citigroup, Inc., and Arthur\nAndersen LLP for their involvement in a clandestine financing scheme known as Project Alpha.\nMost notably, the settlement agreement provides that Dynegy will appoint two board members to\nbe nominated by The Regents, which Robbins Geller and The Regents believe will benefit all of\nDynegy\u2019s stockholders.\n\n Robbins Geller Rudman & Dowd LLP | 4\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 8 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Qwest Commc\u2019ns Int\u2019l, Inc. Sec. Litig., No. 01-cv-1451 (D. Colo.). In July 2001, the Firm filed\nthe initial complaint in this action on behalf of its clients, long before any investigation into Qwest\u2019s\nfinancial statements was initiated by the SEC or Department of Justice. After five years of\nlitigation, lead plaintiffs entered into a settlement with Qwest and certain individual defendants\nthat provided a $400 million recovery for the class and created a mechanism that allowed the vast\nmajority of class members to share in an additional $250 million recovered by the SEC. In 2008,\nRobbins Geller attorneys recovered an additional $45 million for the class in a settlement with\ndefendants Joseph P. Nacchio and Robert S. Woodruff, the CEO and CFO, respectively, of Qwest\nduring large portions of the class period.\n\nFort Worth Emps.\u2019 Ret. Fund v. J.P. Morgan Chase & Co., No. 1:09-cv-03701 (S.D.N.Y.). Robbins\nGeller attorneys served as lead counsel for a class of investors and obtained court approval of a\n$388 million recovery in nine 2007 residential mortgage-backed securities offerings issued by J.P.\nMorgan. The settlement represents, on a percentage basis, the largest recovery ever achieved in\nan MBS purchaser class action. The result was achieved after more than five years of hard-fought\nlitigation and an extensive investigation.\n\nSmilovits v. First Solar, Inc., No. 2:12-cv-00555 (D. Ariz.). As sole lead counsel, Robbins Geller\nobtained a $350 million settlement in Smilovits v. First Solar, Inc. The settlement, which was\nreached after a long legal battle and on the day before jury selection, resolves claims that First\nSolar violated \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. The\nsettlement is the fifth-largest PSLRA settlement ever recovered in the Ninth Circuit.\n\nNECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co., No. 1:08-cv-10783 (S.D.N.Y.). As\nsole lead counsel, Robbins Geller obtained a $272 million settlement on behalf of Goldman Sachs\u2019\nshareholders. The settlement concludes one of the last remaining mortgage-backed securities\npurchaser class actions arising out of the global financial crisis. The remarkable result was\nachieved following seven years of extensive litigation. After the claims were dismissed in 2010,\nRobbins Geller secured a landmark victory from the Second Circuit Court of Appeals that clarified\nthe scope of permissible class actions asserting claims under the Securities Act of 1933 on behalf of\nMBS investors. Specifically, the Second Circuit\u2019s decision rejected the concept of \u201ctranche\u201d\nstanding and concluded that a lead plaintiff in an MBS class action has class standing to pursue\nclaims on behalf of purchasers of other securities that were issued from the same registration\nstatement and backed by pools of mortgages originated by the same lenders who had originated\nmortgages backing the lead plaintiff\u2019s securities.\n\nSchuh v. HCA Holdings, Inc., No. 3:11-cv-01033 (M.D. Tenn.). As sole lead counsel, Robbins\nGeller obtained a groundbreaking $215 million settlement for former HCA Holdings, Inc.\nshareholders \u2013 the largest securities class action recovery ever in Tennessee. Reached shortly\nbefore trial was scheduled to commence, the settlement resolves claims that the Registration\nStatement and Prospectus HCA filed in connection with the company\u2019s massive $4.3 billion 2011\nIPO contained material misstatements and omissions. The recovery achieved represents more\nthan 30% of the aggregate classwide damages, far exceeding the typical recovery in a securities\nclass action.\n\nIn re AT&T Corp. Sec. Litig., MDL No. 1399 (D.N.J.). Robbins Geller attorneys served as lead\ncounsel for a class of investors that purchased AT&T common stock. The case charged defendants\nAT&T and its former Chairman and CEO, C. Michael Armstrong, with violations of the federal\nsecurities laws in connection with AT&T\u2019s April 2000 initial public offering of its wireless tracking\nstock, one of the largest IPOs in American history. After two weeks of trial, and on the eve of\nscheduled testimony by Armstrong and infamous telecom analyst Jack Grubman, defendants\nagreed to settle the case for $100 million.\n\n Robbins Geller Rudman & Dowd LLP | 5\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 9 of 159\n PRACTICE AREAS AND SERVICES\n\nSilverman v. Motorola, Inc., No. 1:07-cv-04507 (N.D. Ill.). The Firm served as lead counsel on\nbehalf of a class of investors in Motorola, Inc., ultimately recovering $200 million for investors just\ntwo months before the case was set for trial. This outstanding result was obtained despite the lack\nof an SEC investigation or any financial restatement.\n\nCity of Pontiac Gen. Emps.\u2019 Ret. Sys. v. Wal-Mart Stores, Inc., No. 5:12-cv-05162 (W.D. Ark.).\nRobbins Geller attorneys and lead plaintiff City of Pontiac General Employees\u2019 Retirement System\nachieved a $160 million settlement in a securities class action case arising from allegations\npublished by The New York Times in an article released on April 21, 2012 describing an alleged\nbribery scheme that occurred in Mexico. The case charged that Wal-Mart portrayed itself to\ninvestors as a model corporate citizen that had proactively uncovered potential corruption and\npromptly reported it to law enforcement, when in truth, a former in-house lawyer had blown the\nwhistle on Wal-Mart\u2019s corruption years earlier, and Wal-Mart concealed the allegations from law\nenforcement by refusing its own in-house and outside counsel\u2019s calls for an independent\ninvestigation. Robbins Geller \u201cachieved an exceptional [s]ettlement with skill, perseverance, and\ndiligent advocacy,\u201d said Judge Hickey when granting final approval.\n\nBennett v. Sprint Nextel Corp., No. 2:09-cv-02122 (D. Kan.). As co-lead counsel, Robbins Geller\nobtained a $131 million recovery for a class of Sprint investors. The settlement, secured after five\nyears of hard-fought litigation, resolved claims that former Sprint executives misled investors\nconcerning the success of Sprint\u2019s ill-advised merger with Nextel and the deteriorating credit\nquality of Sprint\u2019s customer base, artificially inflating the value of Sprint\u2019s securities.\n\nIn re LendingClub Sec. Litig., No. 3:16-cv-02627 (N.D. Cal.). Robbins Geller attorneys obtained a\n$125 million settlement for the court-appointed lead plaintiff Water and Power Employees\u2019\nRetirement, Disability and Death Plan of the City of Los Angeles and the class. The settlement\nresolved allegations that LendingClub promised investors an opportunity to get in on the ground\nfloor of a revolutionary lending market fueled by the highest standards of honesty and integrity.\nThe settlement ranked among the top ten largest securities recoveries ever in the Northern\nDistrict of California.\n\nKnurr v. Orbital ATK, Inc., No. 1:16-cv-01031 (E.D. Va.). In the Orbital securities class action,\nRobbins Geller obtained court approval of a $108 million recovery for the class. The Firm\nsucceeded in overcoming two successive motions to dismiss the case, and during discovery were\nrequired to file ten motions to compel, all of which were either negotiated to a resolution or\ngranted in large part, which resulted in the production of critical evidence in support of plaintiffs\u2019\nclaims. Believed to be the fourth-largest securities class action settlement in the history of the\nEastern District of Virginia, the settlement provides a recovery for investors that is more than ten\ntimes larger than the reported median recovery of estimated damages for all securities class action\nsettlements in 2018.\n\nHsu v. Puma Biotechnology, No. SACV15-0865 (C.D. Cal.). After a two-week jury trial, Robbins\nGeller attorneys won a complete plaintiffs\u2019 verdict against both defendants on both claims, with the\njury finding that Puma Biotechnology, Inc. and its CEO, Alan H. Auerbach, committed securities\nfraud. The Puma case is only the fifteenth securities class action case tried to a verdict since the\nPrivate Securities Litigation Reform Act was enacted in 1995.\n\nMarcus v. J.C. Penney Co., Inc., No. 13-cv-00736 (E.D. Tex.). Robbins Geller attorneys obtained a\n$97.5 million recovery on behalf of J.C. Penney shareholders. The result resolves claims that J.C.\nPenney and certain officers and directors made misstatements and/or omissions regarding the\ncompany\u2019s financial position that resulted in artificially inflated stock prices. Specifically,\ndefendants failed to disclose and/or misrepresented adverse facts, including that J.C. Penney\n\n Robbins Geller Rudman & Dowd LLP | 6\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 10 of 159\n PRACTICE AREAS AND SERVICES\n\nwould have insufficient liquidity to get through year-end and would require additional funds to\nmake it through the holiday season, and that the company was concealing its need for liquidity so\nas not to add to its vendors\u2019 concerns.\n\nMonroe County Employees\u2019 Retirement System v. The Southern Company, No. 1:17-cv-00241 (N.D.\nGa.). As lead counsel, Robbins Geller obtained an $87.5 million settlement in a securities class\naction on behalf of plaintiffs Monroe County Employees\u2019 Retirement System and Roofers Local\nNo. 149 Pension Fund. The settlement resolves claims for violations of the Securities Exchange Act\nof 1934 stemming from defendants\u2019 issuance of materially misleading statements and omissions\nregarding the status of construction of a first-of-its-kind \u201cclean coal\u201d power plant in Kemper\nCounty, Mississippi. Plaintiffs alleged that these misstatements caused The Southern Company\u2019s\nstock price to be artificially inflated during the class period. Prior to resolving the case, Robbins\nGeller uncovered critical documentary evidence and deposition testimony supporting plaintiffs\u2019\nclaims. In granting final approval of the settlement, the court praised Robbins Geller for its \u201chard-\nfought litigation in the Eleventh Circuit\u201d and its \u201cexperience, reputation, and abilities of [its]\nattorneys,\u201d and highlighted that the firm is \u201cwell-regarded in the legal community, especially in\nlitigating class-action securities cases\n\nChicago Laborers Pension Fund v. Alibaba Grp. Holding Ltd., No. CIV535692 (Cal. Super. Ct., San\nMateo Cnty.). Robbins Geller attorneys and co-counsel obtained a $75 million settlement in the\nAlibaba Group Holding Limited securities class action, resolving investors\u2019 claims that Alibaba\nviolated the Securities Act of 1933 in connection with its September 2014 initial public offering.\nChicago Laborers Pension Fund served as a plaintiff in the action.\n\nLuna v. Marvell Tech. Grp., Ltd., No. 3:15-cv-05447 (N.D. Cal.). In the Marvell litigation, Robbins\nGeller attorneys represented the Plumbers and Pipefitters National Pension Fund and obtained a\n$72.5 million settlement. The case involved claims that Marvell reported revenue and earnings\nduring the class period that were misleading as a result of undisclosed pull-in and concession\nsales. The settlement represents approximately 24% to 50% of the best estimate of classwide\ndamages suffered by investors who purchased shares during the February 19, 2015 through\nDecember 7, 2015 class period.\n\nGarden City Emps.\u2019 Ret. Sys. v. Psychiatric Sols., Inc., No. 3:09-cv-00882 (M.D. Tenn.). In the\nPsychiatric Solutions case, Robbins Geller represented lead plaintiff and class representative Central\nStates, Southeast and Southwest Areas Pension Fund in litigation spanning more than four years.\nPsychiatric Solutions and its top executives were accused of insufficiently staffing their in-patient\nhospitals, downplaying the significance of regulatory investigations and manipulating their\nmalpractice reserves. Just days before trial was set to commence, attorneys from Robbins Geller\nachieved a $65 million settlement that was the fourth-largest securities recovery ever in the district\nand one of the largest in a decade.\n\nPlumbers & Pipefitters Nat\u2019l Pension Fund v. Burns, No. 3:05-cv-07393 (N.D. Ohio). After 11 years\nof hard-fought litigation, Robbins Geller attorneys secured a $64 million recovery for shareholders\nin a case that accused the former heads of Dana Corp. of securities fraud for trumpeting the auto\nparts maker\u2019s condition while it actually spiraled toward bankruptcy. The Firm\u2019s Appellate\nPractice Group successfully appealed to the Sixth Circuit Court of Appeals twice, reversing the\ndistrict court\u2019s dismissal of the action.\n\nVillella v. Chemical and Mining Company of Chile Inc., No. 1:15-cv-02106 (S.D.N.Y.) Robbins\nGeller attorneys, serving as lead consel, obtained a $62.5 million settlement against Sociedad\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 7\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 11 of 159\n PRACTICE AREAS AND SERVICES\n\n Qu\u00edmica y Minera de Chile S.A. (\u201cSQM\u201d), a Chilean mining company. The case alleged that SQM\n violated the Securities Exchange Act of 1934 by issuing materially false and misleading statements\n regarding the company\u2019s failure to disclose that money from SQM was channeled illegally to\n electoral campaigns for Chilean politicians and political parties as far back as 2009. SQM had also\n filed millions of dollars\u2019 worth of fictitious tax receipts with Chilean authorities in order to conceal\n bribery payments from at least 2009 through fiscal 2014. Due to the company being based out of\n Chile and subject to Chilean law and rules, the Robbins Geller litigation team put together a\n multilingual litigation team with Chilean expertise. Depositions are considered unlawful in the\n country of Chile, so Robbins Geller successfully moved the court to compel SQM to bring witnesses\n to the United States.\n\n In re BHP Billiton Ltd. Sec. Litig., No. 1:16-cv-01445 (S.D.N.Y.). As lead counsel, Robbins Geller\n obtained a $50 million class action settlement against BHP, a Australian-based mining company\n that was accused of failing to disclose significant safety problems at the Fund\u00e3o iron-ore dam, in\n Brazil. The Firm achieved this result for lead plaintiffs City of Birmingham Retirement and Relief\n System and City of Birmingham Firemen\u2019s and Policemen\u2019s Supplemental Pension System, on\n behalf of purchasers of the American Depositary Shares (\u201cADRs\u201d) of defendants BHP Billiton\n Limited and BHP Billiton Plc (together, \u201cBHP\u201d) from September 25, 2014 to November 30, 2015.\n\n In re St. Jude Med., Inc. Sec. Litig., No. 0:10-cv-00851 (D. Minn.). After four and a half years of\n litigation and mere weeks before the jury selection, Robbins Geller obtained a $50 million\n settlement on behalf of investors in medical device company St. Jude Medical. The settlement\n resolves accusations that St. Jude Medical misled investors by utilizing heavily discounted end-of-\n quarter bulk sales to meet quarterly expectations, which created a false picture of demand by\n increasing customer inventory due of St. Jude Medical devices. The complaint alleged that the\n risk of St. Jude Medical\u2019s reliance on such bulk sales manifested when it failed to meet its forecast\n guidance for the third quarter of 2009, which the company had reaffirmed only weeks earlier.\n\n Deka Investment GmbH v. Santander Consumer USA Holdings Inc., No. 3:15-cv-02129 (N.D. Tex.).\n Robbins Geller and co-counsel secured a $47 million settlement in a securities class action\n against Santander Consumer USA Holdings Inc. (\u201cSCUSA\u201d). The case alleges that SCUSA, 2 of its\n officers, 10 of its directors, as well as 17 underwriters of its January 23, 2014 multi-billion dollar\n IPO violated \u00a7\u00a711, 12(a)(2), and 15 of the Securities Act of 1933 as a result of their negligence in\n connection with misrepresentations in the prospectus and registration statement for the IPO\n (\u201cOffering Documents\u201d). The complaint also alleged that SCUSA and two of its officers violated\n \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 as a result of their fraud\n in issuing misleading statements in the IPO Offering Documents as well as in subsequent\n statements to investors.\n\n Snap Inc. Securities Cases, JCCP No. 4960 (Cal. Super. Ct., Los Angeles Cnty). Robbins Geller,\n along with co-counsel, reached a settlement in the Snap, Inc. securities class action, providing for\n the payment of $32,812,500 to eligible settlement class members. The securities class action\n sought remedies under \u00a7\u00a711, 12(a)(2) and 15 of the Securities Act of 1933. The case alleged that\n Snap, certain Snap officers and directors, and the underwriters for Snap\u2019s Initial Public Offering\n (\u201cIPO\u201d) were liable for materially false and misleading statements and omissions in the Registration\n Statement for the IPO, related to trends and uncertainties in Snap\u2019s growth metrics, a potential\n patent-infringement action, and stated risk factors.\n\nRobbins Geller\u2019s securities practice is also strengthened by the existence of a strong appellate department,\nwhose collective work has established numerous legal precedents. The securities practice also utilizes an\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 8\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 12 of 159\n PRACTICE AREAS AND SERVICES\n\nextensive group of in-house economic and damage analysts, investigators, and forensic accountants to aid\nin the prosecution of complex securities issues.\n\n\n\nShareholder Derivative and Corporate Governance Litigation\nThe Firm\u2019s shareholder derivative and corporate governance practice is focused on preserving corporate\nassets and enhancing long-term shareowner value. Shareowner derivative actions are often brought by\ninstitutional investors to vindicate the rights of the corporation injured by its executives\u2019 misconduct,\nwhich can effect violations of the nation\u2019s securities, anti-corruption, false claims, cyber-security, labor,\nenvironmental, and/or health & safety laws.\n\nRobbins Geller attorneys have aided Firm clients in significantly enhancing shareowner value by obtaining\nhundreds of millions of dollars in financial clawbacks and successfully negotiating corporate governance\nenhancements. Robbins Geller has worked with its institutional clients to address corporate misconduct\nsuch as options backdating, bribery of foreign officials, pollution, off-label marketing, and insider trading\nand related self-dealing. Additionally, the Firm works closely with noted corporate governance\nconsultants Robert Monks and Richard Bennett and their firm, ValueEdge Advisors LLC, to shape\ncorporate governance practices that will benefit shareowners.\n\nRobbins Geller\u2019s efforts have conferred substantial benefits upon shareowners, and the market effect of\nthese benefits measures in the billions of dollars. The Firm\u2019s significant achievements include:\n\n City of Westland Police & Fire Ret. Sys. v. Stumpf (Wells Fargo Derivative Litigation), No.\n 3:11-cv-02369 (N.D. Cal.). Prosecuted shareholder derivative action on behalf of Wells Fargo &\n Co. alleging that Wells Fargo\u2019s executives allowed participation in the mass-processing of home\n foreclosure documents by engaging in widespread robo-signing, i.e., the execution and submission\n of false legal documents in courts across the country without verification of their truth or accuracy,\n and failed to disclose Wells Fargo\u2019s lack of cooperation in a federal investigation into the bank\u2019s\n mortgage and foreclosure practices. In settlement of the action, Wells Fargo agreed to provide\n $67 million in homeowner down-payment assistance, credit counseling, and improvements to its\n mortgage servicing system. The initiatives will be concentrated in cities severely impacted by the\n bank\u2019s foreclosure practices and the ensuing mortgage foreclosure crisis. Additionally, Wells\n Fargo agreed to change its procedures for reviewing shareholder proposals and a strict ban on\n stock pledges by Wells Fargo board members.\n\n In re Ormat Techs., Inc. Derivative Litig., No. CV10-00759 (Nev. Dist. Ct., Washoe Cnty.). Robbins\n Geller brought derivative claims for breach of fiduciary duty and unjust enrichment against the\n directors and certain officers of Ormat Technologies, Inc., a leading geothermal and recovered\n energy power business. During the relevant time period, these Ormat insiders caused the\n company to engage in accounting manipulations that ultimately required restatement of the\n company\u2019s financial statements. The settlement in this action includes numerous corporate\n governance reforms designed to, among other things: (i) increase director independence; (ii)\n provide continuing education to directors; (iii) enhance the company\u2019s internal controls; (iv) make\n the company\u2019s board more independent; and (iv) strengthen the company\u2019s internal audit\n function.\n\n In re Alphatec Holdings, Inc. Derivative S\u2019holder Litig., No. 37-2010-00058586 (Cal. Super. Ct., San\n Diego Cnty.). Obtained sweeping changes to Alphatec\u2019s governance, including separation of the\n Chairman and CEO positions, enhanced conflict of interest procedures to address related-party\n transactions, rigorous director independence standards requiring that at least a majority of\n directors be outside independent directors, and ongoing director education and training.\n\n\n Robbins Geller Rudman & Dowd LLP | 9\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 13 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Finisar Corp. Derivative Litig., No. C-06-07660 (N.D. Cal.). Prosecuted shareholder\nderivative action on behalf of Finisar against certain of its current and former directors and\nofficers for engaging in an alleged nearly decade-long stock option backdating scheme that was\nalleged to have inflicted substantial damage upon Finisar. After obtaining a reversal of the district\ncourt\u2019s order dismissing the complaint for failing to adequately allege that a pre-suit demand was\nfutile, Robbins Geller lawyers successfully prosecuted the derivative claims to resolution obtaining\nover $15 million in financial clawbacks for Finisar. Robbins Geller attorneys also obtained\nsignificant changes to Finisar\u2019s stock option granting procedures and corporate governance. As a\npart of the settlement, Finisar agreed to ban the repricing of stock options without first obtaining\nspecific shareholder approval, prohibit the retrospective selection of grant dates for stock options\nand similar awards, limit the number of other boards on which Finisar directors may serve,\nrequire directors to own a minimum amount of Finisar shares, annually elect a Lead Independent\nDirector whenever the position of Chairman and CEO are held by the same person, and require\nthe board to appoint a Trading Compliance officer responsible for ensuring compliance with\nFinisar\u2019s insider trading policies.\n\nLoizides v. Schramm (Maxwell Technology Derivative Litigation), No. 37-2010-00097953 (Cal.\nSuper. Ct., San Diego Cnty.). Prosecuted shareholder derivative claims arising from the\ncompany\u2019s alleged violations of the Foreign Corrupt Practices Act of 1977 (\u201cFCPA\u201d). As a result of\nRobbins Geller\u2019s efforts, Maxwell insiders agreed to adopt significant changes in Maxwell\u2019s internal\ncontrols and systems designed to protect Maxwell against future potential violations of the FCPA.\nThese corporate governance changes included establishing the following, among other things: a\ncompliance plan to improve board oversight of Maxwell\u2019s compliance processes and internal\ncontrols; a clear corporate policy prohibiting bribery and subcontracting kickbacks, whereby\nindividuals are accountable; mandatory employee training requirements, including the\ncomprehensive explanation of whistleblower provisions, to provide for confidential reporting of\nFCPA violations or other corruption; enhanced resources and internal control and compliance\nprocedures for the audit committee to act quickly if an FCPA violation or other corruption is\ndetected; an FCPA and Anti-Corruption Compliance department that has the authority and\nresources required to assess global operations and detect violations of the FCPA and other\ninstances of corruption; a rigorous ethics and compliance program applicable to all directors,\nofficers, and employees, designed to prevent and detect violations of the FCPA and other\napplicable anti-corruption laws; an executive-level position of Chief Compliance Officer with direct\nboard-level reporting responsibilities, who shall be responsible for overseeing and managing\ncompliance issues within the company; a rigorous insider trading policy buttressed by enhanced\nreview and supervision mechanisms and a requirement that all trades are timely disclosed; and\nenhanced provisions requiring that business entities are only acquired after thorough FCPA and\nanti-corruption due diligence by legal, accounting, and compliance personnel at Maxwell.\n\nIn re SciClone Pharms., Inc. S\u2019holder Derivative Litig., No. CIV 499030 (Cal. Super. Ct., San Mateo\nCnty.). Robbins Geller attorneys successfully prosecuted the derivative claims on behalf of\nnominal party SciClone Pharmaceuticals, Inc., resulting in the adoption of state-of-the-art\ncorporate governance reforms. The corporate governance reforms included the establishment of\nan FCPA compliance coordinator; the adoption of an FCPA compliance program and code; and\nthe adoption of additional internal controls and compliance functions.\n\nPolicemen & Firemen Ret. Sys. of the City of Detroit v. Cornelison (Halliburton Derivative\nLitigation), No. 2009-29987 (Tex. Dist. Ct., Harris Cnty.). Prosecuted shareholder derivative\nclaims on behalf of Halliburton Company against certain Halliburton insiders for breaches of\nfiduciary duty arising from Halliburton\u2019s alleged violations of the FCPA. In the settlement,\nHalliburton agreed, among other things, to adopt strict intensive controls and systems designed to\ndetect and deter the payment of bribes and other improper payments to foreign officials, to\n\n\n Robbins Geller Rudman & Dowd LLP | 10\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 14 of 159\n PRACTICE AREAS AND SERVICES\n\nenhanced executive compensation clawback, director stock ownership requirements, a limitation\non the number of other boards that Halliburton directors may serve, a lead director charter,\nenhanced director independence standards, and the creation of a management compliance\ncommittee.\n\nIn re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.). In the UnitedHealth case,\nour client, CalPERS, obtained sweeping corporate governance improvements, including the\nelection of a shareholder-nominated member to the company\u2019s board of directors, a mandatory\nholding period for shares acquired by executives via option exercises, as well as executive\ncompensation reforms that tie pay to performance. In addition, the class obtained $925 million,\nthe largest stock option backdating recovery ever and four times the next largest options\nbackdating recovery.\n\nIn re Fossil, Inc. Derivative Litig., No. 3:06-cv-01672 (N.D. Tex.). The settlement agreement\nincluded the following corporate governance changes: declassification of elected board members;\nretirement of three directors and addition of five new independent directors; two-thirds board\nindependence requirements; corporate governance guidelines providing for \u201cMajority Voting\u201d\nelection of directors; lead independent director requirements; revised accounting measurement\ndates of options; addition of standing finance committee; compensation clawbacks; director\ncompensation standards; revised stock option plans and grant procedures; limited stock option\ngranting authority, timing, and pricing; enhanced education and training; and audit engagement\npartner rotation and outside audit firm review.\n\nPirelli Armstrong Tire Corp. Retiree Med. Benefits Tr. v. Sinegal (Costco Derivative Litigation), No.\n2:08-cv-01450 (W.D. Wash.). The parties agreed to settlement terms providing for the following\ncorporate governance changes: the amendment of Costco\u2019s bylaws to provide \u201cMajority Voting\u201d\nelection of directors; the elimination of overlapping compensation and audit committee\nmembership on common subject matters; enhanced Dodd-Frank requirements; enhanced internal\naudit standards and controls, and revised information-sharing procedures; revised compensation\npolicies and procedures; revised stock option plans and grant procedures; limited stock option\ngranting authority, timing, and pricing; and enhanced ethics compliance standards and training.\n\nIn re F5 Networks, Inc. Derivative Litig., No. C-06-0794 (W.D. Wash.). The parties agreed to the\nfollowing corporate governance changes as part of the settlement: revised stock option plans and\ngrant procedures; limited stock option granting authority, timing, and pricing; \u201cMajority Voting\u201d\nelection of directors; lead independent director requirements; director independence standards;\nelimination of director perquisites; and revised compensation practices.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 11\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 15 of 159\n PRACTICE AREAS AND SERVICES\n\n In re Community Health Sys., Inc. S\u2019holder Derivative Litig., No. 3:11-cv-00489 (M.D. Tenn.).\n Robbins Geller obtained unprecedented corporate governance reforms on behalf of Community\n Health Systems, Inc. in a case against the company\u2019s directors and officers for breaching their\n fiduciary duties by causing Community Health to develop and implement admissions criteria that\n systematically steered patients into unnecessary inpatient admissions, in contravention of Medicare\n and Medicaid regulations. The governance reforms obtained as part of the settlement include two\n shareholder-nominated directors, the creation of a Healthcare Law Compliance Coordinator with\n specified qualifications and duties, a requirement that the board\u2019s compensation committee be\n comprised solely of independent directors, the implementation of a compensation clawback that\n will automatically recover compensation improperly paid to the company\u2019s CEO or CFO in the\n event of a restatement, the establishment of an insider trading controls committee, and the\n adoption of a political expenditure disclosure policy. In addition to these reforms, $60 million in\n financial relief was obtained, which is the largest shareholder derivative recovery ever in\n Tennessee and the Sixth Circuit.\n\n\n\nOptions Backdating Litigation\nAs has been widely reported in the media, the stock options backdating scandal suddenly engulfed\nhundreds of publicly traded companies throughout the country in 2006. Robbins Geller was at the\nforefront of investigating and prosecuting options backdating derivative and securities cases. The Firm\nhas recovered over $1 billion in damages on behalf of injured companies and shareholders.\n\n In re KLA-Tencor Corp. S\u2019holder Derivative Litig., No. C-06-03445 (N.D. Cal.). After successfully\n opposing the special litigation committee of the board of directors\u2019 motion to terminate the\n derivative claims, Robbins Geller recovered $43.6 million in direct financial benefits for KLA-\n Tencor, including $33.2 million in cash payments by certain former executives and their directors\u2019\n and officers\u2019 insurance carriers.\n\n In re Marvell Tech. Grp. Ltd. Derivative Litig., No. C-06-03894 (N.D. Cal.). Robbins Geller\n recovered $54.9 million in financial benefits, including $14.6 million in cash, for Marvell, in\n addition to extensive corporate governance reforms related to Marvell\u2019s stock option granting\n practices, board of directors\u2019 procedures, and executive compensation.\n\n In re KB Home S\u2019holder Derivative Litig., No. 06-CV-05148 (C.D. Cal.). Robbins Geller served as\n co-lead counsel for the plaintiffs and recovered more than $31 million in financial benefits,\n including $21.5 million in cash, for KB Home, plus substantial corporate governance\n enhancements relating to KB Home\u2019s stock option granting practices, director elections, and\n executive compensation practices.\n\n\n\nCorporate Takeover Litigation\nRobbins Geller has earned a reputation as the leading law firm in representing shareholders in corporate\ntakeover litigation. Through its aggressive efforts in prosecuting corporate takeovers, the Firm has\nsecured for shareholders billions of dollars of additional consideration as well as beneficial changes for\nshareholders in the context of mergers and acquisitions.\n\nThe Firm regularly prosecutes merger and acquisition cases post-merger, often through trial, to maximize\nthe benefit for its shareholder class. Some of these cases include:\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 12\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 16 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Tesla Motors, Inc. S\u2019holder Litig., No. 12711-VCS (Del. Ch.). Robbins Geller, along with co-\ncounsel, secured a $60 million partial settlement after nearly four years of litigation against Tesla.\nThis partial settlement is one of the largest derivative recoveries in a stockholder action\nchallenging a merger. This partial settlement resolves the claims brought against defendants\nKimbal Musk, Antonio J. Gracias, Stephen T. Jurvetson, Brad W. Buss, Ira Ehrenpreis, and Robyn\nM. Denholm, but not the claims against defendant Elon Musk.\n\nIn re Kinder Morgan, Inc. S\u2019holders Litig., No. 06-C-801 (Kan. Dist. Ct., Shawnee Cnty.). In the\nlargest recovery ever for corporate takeover class action litigation, the Firm negotiated a\nsettlement fund of $200 million in 2010.\n\nIn re Dole Food Co., Inc. S\u2019holder Litig., No. 8703-VCL (Del. Ch.). Robbins Geller and co-counsel\nwent to trial in the Delaware Court of Chancery on claims of breach of fiduciary duty on behalf of\nDole Food Co., Inc. shareholders. The litigation challenged the 2013 buyout of Dole by its\nbillionaire Chief Executive Officer and Chairman, David H. Murdock. On August 27, 2015, the\ncourt issued a post-trial ruling that Murdock and fellow director C. Michael Carter \u2013 who also\nserved as Dole\u2019s General Counsel, Chief Operating Officer, and Murdock\u2019s top lieutenant \u2013 had\nengaged in fraud and other misconduct in connection with the buyout and are liable to Dole\u2019s\nformer stockholders for over $148 million, the largest trial verdict ever in a class action\nchallenging a merger transaction.\n\nNieman v. Duke Energy Corp., No. 3:12-cv-00456 (W.D.N.C.). Robbins Geller, along with co-\ncounsel, obtained a $146.25 million settlement on behalf of Duke Energy Corporation investors.\nThe settlement resolves accusations that defendants misled investors regarding Duke\u2019s future\nleadership following its merger with Progress Energy, Inc., and specifically, their premeditated\ncoup to oust William D. Johnson (CEO of Progress) and replace him with Duke\u2019s then-CEO, John\nRogers. This historic settlement represents the largest recovery ever in a North Carolina securities\nfraud action, and one of the five largest recoveries in the Fourth Circuit.\n\nIn re Rural Metro Corp. S\u2019holders Litig., No. 6350-VCL (Del. Ch.). Robbins Geller and co-counsel\nwere appointed lead counsel in this case after successfully objecting to an inadequate settlement\nthat did not take into account evidence of defendants\u2019 conflicts of interest. In a post-trial opinion,\nDelaware Vice Chancellor J. Travis Laster found defendant RBC Capital Markets, LLC liable for\naiding and abetting Rural/Metro\u2019s board of directors\u2019 fiduciary duty breaches in the $438 million\nbuyout of Rural/Metro, citing \u201cthe magnitude of the conflict between RBC\u2019s claims and the\nevidence.\u201d RBC was ordered to pay nearly $110 million as a result of its wrongdoing, the largest\ndamage award ever obtained against a bank over its role as a merger adviser. The Delaware\nSupreme Court issued a landmark opinion affirming the judgment on November 30, 2015, RBC\nCap. Mkts., LLC v. Jervis, 129 A.3d 816 (Del. 2015).\n\nIn re Del Monte Foods Co. S\u2019holders Litig., No. 6027-VCL (Del. Ch.). Robbins Geller exposed the\nunseemly practice by investment bankers of participating on both sides of large merger and\nacquisition transactions and ultimately secured an $89 million settlement for shareholders of Del\nMonte. For efforts in achieving these results, the Robbins Geller lawyers prosecuting the case were\nnamed Attorneys of the Year by California Lawyer magazine in 2012.\n\nIn re TD Banknorth S\u2019holders Litig., No. 2557-VCL (Del. Ch.). After objecting to a modest\nrecovery of just a few cents per share, the Firm took over the litigation and obtained a common\nfund settlement of $50 million.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 13\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 17 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Chaparral Res., Inc. S\u2019holders Litig., No. 2633-VCL (Del. Ch.). After a full trial and a\nsubsequent mediation before the Delaware Chancellor, the Firm obtained a common fund\nsettlement of $41 million (or 45% increase above merger price) for both class and appraisal claims.\n\nLaborers\u2019 Local #231 Pension Fund v. Websense, Inc., No. 37-2013-00050879-CU-BT-CTL (Cal.\nSuper. Ct., San Diego Cnty.). Robbins Geller successfully obtained a record-breaking $40 million\nin Websense, which is believed to be the largest post-merger common fund settlement in California\nstate court history. The class action challenged the May 2013 buyout of Websense by Vista Equity\nPartners (and affiliates) for $24.75 per share and alleged breach of fiduciary duty against the\nformer Websense board of directors, and aiding and abetting against Websense\u2019s financial advisor,\nMerrill Lynch, Pierce, Fenner & Smith, Inc. Claims were pursued by the plaintiff in both\nCalifornia state court and the Delaware Court of Chancery.\n\nIn re Onyx Pharms., Inc. S\u2019holder Litig., No. CIV523789 (Cal. Super. Ct., San Mateo Cnty.).\nRobbins Geller obtained $30 million in a case against the former Onyx board of directors for\nbreaching its fiduciary duties in connection with the acquisition of Onyx by Amgen Inc. for $125\nper share at the expense of shareholders. At the time of the settlement, it was believed to set the\nrecord for the largest post-merger common fund settlement in California state court history. Over\nthe case\u2019s three years, Robbins Geller defeated defendants\u2019 motions to dismiss, obtained class\ncertification, took over 20 depositions, and reviewed over one million pages of documents.\nFurther, the settlement was reached just days before a hearing on defendants\u2019 motion for\nsummary judgment was set to take place, and the result is now believed to be the second largest\npost-merger common fund settlement in California state court history.\n\nHarrah\u2019s Entertainment, No. A529183 (Nev. Dist. Ct., Clark Cnty.). The Firm\u2019s active prosecution\nof the case on several fronts, both in federal and state court, assisted Harrah\u2019s shareholders in\nsecuring an additional $1.65 billion in merger consideration.\n\nIn re Chiron S\u2019holder Deal Litig., No. RG 05-230567 (Cal. Super. Ct., Alameda Cnty.). The Firm\u2019s\nefforts helped to obtain an additional $800 million in increased merger consideration for Chiron\nshareholders.\n\nIn re Dollar Gen. Corp. S\u2019holder Litig., No. 07MD-1 (Tenn. Cir. Ct., Davidson Cnty.). As lead\ncounsel, the Firm secured a recovery of up to $57 million in cash for former Dollar General\nshareholders on the eve of trial.\n\nIn re Prime Hosp., Inc. S\u2019holders Litig., No. 652-N (Del. Ch.). The Firm objected to a settlement\nthat was unfair to the class and proceeded to litigate breach of fiduciary duty issues involving a sale\nof hotels to a private equity firm. The litigation yielded a common fund of $25 million for\nshareholders.\n\nIn re UnitedGlobalCom, Inc. S\u2019holder Litig., No. 1012-VCS (Del. Ch.). The Firm secured a common\nfund settlement of $25 million just weeks before trial.\n\nIn re eMachines, Inc. Merger Litig., No. 01-CC-00156 (Cal. Super. Ct., Orange Cnty.). After four\nyears of litigation, the Firm secured a common fund settlement of $24 million on the brink of trial.\n\nIn re PeopleSoft, Inc. S\u2019holder Litig., No. RG-03100291 (Cal. Super. Ct., Alameda Cnty.). The Firm\nsuccessfully objected to a proposed compromise of class claims arising from takeover defenses by\nPeopleSoft, Inc. to thwart an acquisition by Oracle Corp., resulting in shareholders receiving an\nincrease of over $900 million in merger consideration.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 14\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 18 of 159\n PRACTICE AREAS AND SERVICES\n\n ACS S\u2019holder Litig., No. CC-09-07377-C (Tex. Cty. Ct., Dallas Cnty.). The Firm forced ACS\u2019s\n acquirer, Xerox, to make significant concessions by which shareholders would not be locked out of\n receiving more money from another buyer.\n\n\n\nAntitrust\nRobbins Geller\u2019s antitrust practice focuses on representing businesses and individuals who have been the\nvictims of price-fixing, unlawful monopolization, market allocation, tying, and other anti-competitive\nconduct. The Firm has taken a leading role in many of the largest federal and state price-fixing,\nmonopolization, market allocation, and tying cases throughout the United States.\n\n In re Payment Card Interchange Fee and Merchant Discount Antitrust Litigation, MDL No. 1720\n (E.D.N.Y.). Robbins Geller attorneys, serving as co-lead counsel on behalf of merchants, obtained\n a settlement amount of $5.54 billion. In approving the settlement, the court noted that Robbins\n Geller and co-counsel \u201cdemonstrated the utmost professionalism despite the demands of the\n extreme perseverance that this case has required, litigating on behalf of a class of over 12 million\n for over fourteen years, across a changing legal landscape, significant motion practice, and appeal\n and remand. Class counsel\u2019s pedigree and efforts alone speak to the quality of their\n representation.\u201d\n\n Dahl v. Bain Cap. Partners, LLC, No. 07-cv-12388 (D. Mass). Robbins Geller attorneys served as co-\n lead counsel on behalf of shareholders in this antitrust action against the nation\u2019s largest private\n equity firms that colluded to restrain competition and suppress prices paid to shareholders of\n public companies in connection with leveraged buyouts. Robbins Geller attorneys recovered more\n than $590 million for the class from the private equity firm defendants, including Goldman Sachs\n Group Inc. and Carlyle Group LP.\n\n Alaska Elec. Pension Fund v. Bank of Am. Corp., No. 14-cv-07126 (S.D.N.Y.). Robbins Geller\n attorneys prosecuted antitrust claims against 14 major banks and broker ICAP plc who were\n alleged to have conspired to manipulate the ISDAfix rate, the key interest rate for a broad range\n of interest rate derivatives and other financial instruments in contravention of the competition\n laws. The class action was brought on behalf of investors and market participants who entered\n into interest rate derivative transactions between 2006 and 2013. Final approval has been granted\n to settlements collectively yielding $504.5 million from all defendants.\n\n In re Currency Conversion Fee Antitrust Litig., 01 MDL No. 1409 (S.D.N.Y.). Robbins\n Geller attorneys served as lead counsel and recovered $336 million for a class of credit and debit\n cardholders. The court praised the Firm as \u201cindefatigable,\u201d noting that the Firm\u2019s lawyers\n \u201cvigorously litigated every issue against some of the ablest lawyers in the antitrust defense bar.\u201d\n\n In re SSA Bonds Antitrust Litig., No. 1:16-cv-03711 (S.D.N.Y.). Robbins Geller attorneys are\n serving as co-lead counsel in a case against several of the world\u2019s largest banks and the traders of\n certain specialized government bonds. They are alleged to have entered into a wide-ranging price-\n fixing and bid-rigging scheme costing pension funds and other investors hundreds of millions. To\n date, three of the more than a dozen corporate defendants have settled for $95.5 million.\n\n In re Aftermarket Auto. Lighting Prods. Antitrust Litig., 09 MDL No. 2007 (C.D. Cal.). Robbins\n Geller attorneys served as co-lead counsel in this multi-district litigation in which plaintiffs allege\n that defendants conspired to fix prices and allocate markets for automotive lighting products. The\n last defendants settled just before the scheduled trial, resulting in total settlements of more than\n $50 million. Commenting on the quality of representation, the court commended the Firm for\n\n\n Robbins Geller Rudman & Dowd LLP | 15\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 19 of 159\n PRACTICE AREAS AND SERVICES\n\n \u201cexpend[ing] substantial and skilled time and efforts in an efficient manner to bring this action to\n conclusion.\u201d\n\n In re Dynamic Random Access Memory (DRAM) Antitrust Litig., 02 MDL No. 1486 (N.D. Cal.).\n Robbins Geller attorneys served on the executive committee in this multi-district class action in\n which a class of purchasers of dynamic random access memory (or DRAM) chips alleged that the\n leading manufacturers of semiconductor products fixed the price of DRAM chips from the fall of\n 2001 through at least the end of June 2002. The case settled for more than $300 million.\n\n Microsoft I-V Cases, JCCP No. 4106 (Cal. Super. Ct., San Francisco Cnty.). Robbins Geller\n attorneys served on the executive committee in these consolidated cases in which California\n indirect purchasers challenged Microsoft\u2019s illegal exercise of monopoly power in the operating\n system, word processing, and spreadsheet markets. In a settlement approved by the court, class\n counsel obtained an unprecedented $1.1 billion worth of relief for the business and consumer class\n members who purchased the Microsoft products.\n\n\n\nConsumer Fraud and Privacy\nIn our consumer-based economy, working families who purchase products and services must receive\ntruthful information so they can make meaningful choices about how to spend their hard-earned money.\nWhen financial institutions and other corporations deceive consumers or take advantage of unequal\nbargaining power, class action suits provide, in many instances, the only realistic means for an individual\nto right a corporate wrong.\n\nRobbins Geller attorneys represent consumers around the country in a variety of important, complex class\nactions. Our attorneys have taken a leading role in many of the largest federal and state consumer fraud,\nprivacy, environmental, human rights, and public health cases throughout the United States. The Firm is\nalso actively involved in many cases relating to banks and the financial services industry, pursuing claims\non behalf of individuals victimized by abusive telemarketing practices, abusive mortgage lending practices,\nmarket timing violations in the sale of variable annuities, and deceptive consumer credit lending practices\nin violation of the Truth-In-Lending Act. Below are a few representative samples of our robust,\nnationwide consumer and privacy practice.\n\n In re Nat\u2019l Prescription Opiate Litig. Robbins Geller serves on the Plaintiffs\u2019 Executive Committee\n to spearhead more than 2,900 federal lawsuits brought on behalf of governmental entities and\n other plaintiffs in the sprawling litigation concerning the nationwide prescription opioid\n epidemic. In reporting on the selection of the lawyers to lead the case, The National Law Journal\n reported that \u201c[t]he team reads like a \u2018Who\u2019s Who\u2019 in mass torts.\u201d\n\n Apple Inc. Device Performance Litigation. Robbins Geller serves on the Plaintiffs\u2019 Executive\n Committee to advance judicial interests of efficiency and protect the interests of the proposed class\n in the Apple litigation. The case alleges Apple misrepresented its iPhone devices and the nature of\n updates to its mobile operating system (iOS), which allegedly included code that significantly\n reduced the performance of older-model iPhones and forced users to incur expenses replacing\n these devices or their batteries.\n\n In re EpiPen (Epinephrine Injection, USP) Mktg., Sales Pracs. & Antitrust Litig. Robbins Geller\n served as co-lead class counsel in a case against Mylan Pharmaceuticals and Pfizer alleging anti-\n competitive behavior that allowed the price of ubiquitous, life-saving EpiPen auto-injector devices\n to rise over 600%, resulting in inflated prices for American families. Two settlements totaling $609\n million were reached after five years of litigation and weeks prior to trial.\n\n\n Robbins Geller Rudman & Dowd LLP | 16\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 20 of 159\n PRACTICE AREAS AND SERVICES\n\nCordova v. Greyhound Lines, Inc. Robbins Geller represented California bus passengers pro bono in\na landmark consumer and civil rights case against Greyhound for subjecting them to\ndiscriminatory immigration raids. Robbins Geller achieved a watershed court ruling that a private\ncompany may be held liable under California law for allowing border patrol to harass and racially\nprofile its customers. The case heralds that Greyhound passengers do not check their rights and\ndignity at the bus door and has had an immediate impact, not only in California but nationwide.\nWithin weeks of Robbins Geller filing the case, Greyhound added \u201cknow your rights\u201d information\nto passengers to its website and on posters in bus stations around the country, along with adopting\nother business reforms.\n\nIn re Volkswagen \u201cClean Diesel\u201d Mktg., Sales Pracs., & Prods. Liab. Litig. As part of the Plaintiffs\u2019\nSteering Committee, Robbins Geller reached a series of settlements on behalf of purchasers,\nlessees, and dealers that total well over $17 billion, the largest settlement in history, concerning\nillegal \u201cdefeat devices\u201d that Volkswagen installed on many of its diesel-engine vehicles. The device\ntricked regulators into believing the cars were complying with emissions standards, while the cars\nwere actually emitting between 10 and 40 times the allowable limit for harmful pollutants.\n\nIn re Facebook Biometric Info. Privacy Litig., No. 3:15-cv-03747 (N.D. Cal.). Robbins Geller\nserved as co-lead class counsel in a cutting-edge certified class action, securing a record-breaking\n$650 million all-cash settlement, the largest privacy settlement in history. The case concerned\nFacebook\u2019s alleged privacy violations through its collection of its users\u2019 biometric identifiers\nwithout informed consent through its \u201cTag Suggestions\u201d feature, which uses proprietary facial\nrecognition software to extract from user-uploaded photographs the unique biometric identifiers\n(i.e., graphical representations of facial features, also known as facial geometry) associated with\npeople\u2019s faces and identify who they are. The Honorable James Donato called the settlement \u201ca\ngroundbreaking settlement in a novel area\u201d and praised the unprecedented 22% claims rate as\n\u201cpretty phenomenal\u201d and \u201ca pretty good day in class settlement history.\u201d\n\nYahoo Data Breach Class Action. Robbins Geller helped secure final approval of a $117.5 million\nsettlement in a class action lawsuit against Yahoo, Inc. arising out of Yahoo\u2019s reckless disregard for\nthe safety and security of its customers\u2019 personal, private information. In September 2016, Yahoo\nrevealed that personal information associated with at least 500 million user accounts, including\nnames, email addresses, telephone numbers, dates of birth, hashed passwords, and security\nquestions and answers, was stolen from Yahoo\u2019s user database in late 2014. The company made\nanother announcement in December 2016 that personal information associated with more than\none billion user accounts was extracted in August 2013. Ten months later, Yahoo announced that\nthe breach in 2013 actually affected all three billion existing accounts. This was the largest data\nbreach in history, and caused severe financial and emotional damage to Yahoo account holders.\nIn 2017, Robbins Geller was appointed to the Plaintiffs\u2019 Executive Committee charged with\noverseeing the litigation.\n\nTrump University. After six and a half years of tireless litigation and on the eve of trial, Robbins\nGeller, serving as co-lead counsel, secured a historic recovery on behalf of Trump University\nstudents around the country. The settlement provides $25 million to approximately 7,000\nconsumers, including senior citizens who accessed retirement accounts and maxed out credit cards\nto enroll in Trump University. The extraordinary result means individual class members are\neligible for upwards of $35,000 in restitution. The settlement resolves claims that\nPresident Donald J. Trump and Trump University violated federal and state laws by misleadingly\nmarketing \u201cLive Events\u201d seminars and mentorships as teaching Trump\u2019s \u201creal-estate techniques\u201d\nthrough his \u201chand-picked\u201d \u201cprofessors\u201d at his so-called \u201cuniversity.\u201d Robbins Geller represented the\nclass on a pro bono basis.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 17\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 21 of 159\n PRACTICE AREAS AND SERVICES\n\nIn re Morning Song Bird Food Litig. Robbins Geller obtained final approval of a settlement in a\ncivil Racketeer Influenced and Corrupt Organizations Act consumer class action against The Scotts\nMiracle-Gro Company and its CEO James Hagedorn. The settlement of up to $85 million\nprovides full refunds to consumers around the country and resolves claims that Scotts Miracle-Gro\nknowingly sold wild bird food treated with pesticides that are hazardous to birds. In approving\nthe settlement, Judge Houston commended Robbins Gelller\u2019s \u201cskill and quality of work [as]\nextraordinary\u201d and the case as \u201caggressively litigated.\u201d The Robbins Geller team battled a series of\ndismissal motions before achieving class certification for the plaintiffs in March 2017, with the\ncourt finding that \u201cPlaintiffs would not have purchased the bird food if they knew it was poison.\u201d\nDefendants then appealed the class certification to the Ninth Circuit, which was denied, and then\ntried to have the claims from non-California class members thrown out, which was also denied.\n\nBank Overdraft Fees Litigation. The banking industry charges consumers exorbitant amounts for\n\u201coverdraft\u201d of their checking accounts, even if the customer did not authorize a charge beyond the\navailable balance and even if the account would not have been overdrawn had the transactions\nbeen ordered chronologically as they occurred \u2013 that is, banks reorder transactions to maximize\nsuch fees. The Firm brought lawsuits against major banks to stop this practice and recover these\nfalse fees. These cases have recovered over $500 million thus far from a dozen banks and we\ncontinue to investigate other banks engaging in this practice.\n\nVisa and MasterCard Fees. After years of litigation and a six-month trial, Robbins Geller attorneys\nwon one of the largest consumer-protection verdicts ever awarded in the United States. The\nFirm\u2019s attorneys represented California consumers in an action against Visa and MasterCard for\nintentionally imposing and concealing a fee from cardholders. The court ordered Visa and\nMasterCard to return $800 million in cardholder losses, which represented 100% of the amount\nillegally taken, plus 2% interest. In addition, the court ordered full disclosure of the hidden fee.\n\nSony Gaming Networks & Customer Data Security Breach Litigation. The Firm served as a member\nof the Plaintiffs\u2019 Steering Committee, helping to obtain a precedential opinion denying in part\nSony\u2019s motion to dismiss plaintiffs\u2019 claims involving the breach of Sony\u2019s gaming network, leading\nto a $15 million settlement.\n\nTobacco Litigation. Robbins Geller attorneys have led the fight against Big Tobacco since 1991.\nAs an example, Robbins Geller attorneys filed the case that helped get rid of Joe Camel,\nrepresenting various public and private plaintiffs, including the State of Arkansas, the general\npublic in California, the cities of San Francisco, Los Angeles, and Birmingham, 14 counties in\nCalifornia, and the working men and women of this country in the Union Pension and Welfare\nFund cases that have been filed in 40 states. In 1992, Robbins Geller attorneys filed the first case\nin the country that alleged a conspiracy by the Big Tobacco companies.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 18\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 22 of 159\n PRACTICE AREAS AND SERVICES\n\nGarment Workers Sweatshop Litigation. Robbins Geller attorneys represented a class of 30,000\ngarment workers who alleged that they had worked under sweatshop conditions in garment\nfactories in Saipan that produced clothing for top U.S. retailers such as The Gap, Target, and J.C.\nPenney. In the first action of its kind, Robbins Geller attorneys pursued claims against the\nfactories and the retailers alleging violations of RICO, the Alien Tort Claims Act, and the Law of\nNations based on the alleged systemic labor and human rights abuses occurring in Saipan. This\ncase was a companion to two other actions, one which alleged overtime violations by the garment\nfactories under the Fair Labor Standards Act and local labor law, and another which alleged\nviolations of California\u2019s Unfair Practices Law by the U.S. retailers. These actions resulted in a\nsettlement of approximately $20 million that included a comprehensive monitoring program to\naddress past violations by the factories and prevent future ones. The members of the litigation\nteam were honored as Trial Lawyers of the Year by the Trial Lawyers for Public Justice in\nrecognition of the team\u2019s efforts at bringing about the precedent-setting settlement of the actions.\n\nIn re Intel Corp. CPU Mktg., Sales Pracs. & Prods. Liab. Litig. Robbins Geller serves on the\nPlaintiffs\u2019 Steering Committee in Intel, a massive multidistrict litigation pending in the United\nStates District Court for the District of Oregon. Intel concerns serious security vulnerabilities \u2013\nknown as \u201cSpectre\u201d and \u201cMeltdown\u201d \u2013 that infect nearly all of Intel\u2019s x86 processors manufactured\nand sold since 1995, the patching of which results in processing speed degradation of the impacted\ncomputer, server or mobile device.\n\nWest Telemarketing Case. Robbins Geller attorneys secured a $39 million settlement for class\nmembers caught up in a telemarketing scheme where consumers were charged for an unwanted\nmembership program after purchasing Tae-Bo exercise videos. Under the settlement, consumers\nwere entitled to claim between one and one-half to three times the amount of all fees they\nunknowingly paid.\n\nDannon Activia\u00ae. Robbins Geller attorneys secured the largest ever settlement for a false\nadvertising case involving a food product. The case alleged that Dannon\u2019s advertising for its\nActivia\u00ae and DanActive\u00ae branded products and their benefits from \u201cprobiotic\u201d bacteria were\noverstated. As part of the nationwide settlement, Dannon agreed to modify its advertising and\nestablish a fund of up to $45 million to compensate consumers for their purchases of Activia\u00ae and\nDanActive\u00ae.\n\nMattel Lead Paint Toys. In 2006-2007, toy manufacturing giant Mattel and its subsidiary Fisher-\nPrice announced the recall of over 14 million toys made in China due to hazardous lead and\ndangerous magnets. Robbins Geller attorneys filed lawsuits on behalf of millions of parents and\nother consumers who purchased or received toys for children that were marketed as safe but were\nlater recalled because they were dangerous. The Firm\u2019s attorneys reached a landmark settlement\nfor millions of dollars in refunds and lead testing reimbursements, as well as important testing\nrequirements to ensure that Mattel\u2019s toys are safe for consumers in the future.\n\nTenet Healthcare Cases. Robbins Geller attorneys were co-lead counsel in a class action alleging a\nfraudulent scheme of corporate misconduct, resulting in the overcharging of uninsured patients\nby the Tenet chain of hospitals. The Firm\u2019s attorneys represented uninsured patients of Tenet\nhospitals nationwide who were overcharged by Tenet\u2019s admittedly \u201caggressive pricing strategy,\u201d\nwhich resulted in price gouging of the uninsured. The case was settled with Tenet changing its\npractices and making refunds to patients.\n\nPet Food Products Liability Litigation. Robbins Geller served as co-lead counsel in this massive,\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 19\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 23 of 159\n PRACTICE AREAS AND SERVICES\n\n 100+ case products liability MDL in the District of New Jersey concerning the death of and injury\n to thousands of the nation\u2019s cats and dogs due to tainted pet food. The case settled for $24\n million.\n\n\n\nHuman Rights, Labor Practices, and Public Policy\nRobbins Geller attorneys have a long tradition of representing the victims of unfair labor practices and\nviolations of human rights. These include:\n\n Does I v. The Gap, Inc., No. 01 0031 (D. N. Mar. I.). In this groundbreaking case, Robbins Geller\n attorneys represented a class of 30,000 garment workers who alleged that they had worked under\n sweatshop conditions in garment factories in Saipan that produced clothing for top U.S. retailers\n such as The Gap, Target, and J.C. Penney. In the first action of its kind, Robbins Geller attorneys\n pursued claims against the factories and the retailers alleging violations of RICO, the Alien Tort\n Claims Act, and the Law of Nations based on the alleged systemic labor and human rights abuses\n occurring in Saipan. This case was a companion to two other actions: Does I v. Advance Textile\n Corp., No. 99 0002 (D. N. Mar. I.), which alleged overtime violations by the garment factories\n under the Fair Labor Standards Act and local labor law, and UNITE v. The Gap, Inc., No. 300474\n (Cal. Super. Ct., San Francisco Cty.), which alleged violations of California\u2019s Unfair Practices Law\n by the U.S. retailers. These actions resulted in a settlement of approximately $20 million that\n included a comprehensive monitoring program to address past violations by the factories and\n prevent future ones. The members of the litigation team were honored as Trial Lawyers of the\n Year by the Trial Lawyers for Public Justice in recognition of the team\u2019s efforts at bringing about\n the precedent-setting settlement of the actions.\n\n Liberty Mutual Overtime Cases, No. JCCP 4234 (Cal. Super. Ct., Los Angeles Cnty.). Robbins\n Geller attorneys served as co-lead counsel on behalf of 1,600 current and former insurance claims\n adjusters at Liberty Mutual Insurance Company and several of its subsidiaries. Plaintiffs brought\n the case to recover unpaid overtime compensation and associated penalties, alleging that Liberty\n Mutual had misclassified its claims adjusters as exempt from overtime under California law. After\n 13 years of complex and exhaustive litigation, Robbins Geller secured a settlement in which\n Liberty Mutual agreed to pay $65 million into a fund to compensate the class of claims adjusters\n for unpaid overtime. The Liberty Mutual action is one of a few claims adjuster overtime actions\n brought in California or elsewhere to result in a successful outcome for plaintiffs since 2004.\n\n Veliz v. Cintas Corp., No. 5:03-cv-01180 (N.D. Cal.). Brought against one of the nation\u2019s largest\n commercial laundries for violations of the Fair Labor Standards Act for misclassifying truck drivers\n as salesmen to avoid payment of overtime.\n\n Kasky v. Nike, Inc., 27 Cal. 4th 939 (2002). The California Supreme Court upheld claims that an\n apparel manufacturer misled the public regarding its exploitative labor practices, thereby violating\n California statutes prohibiting unfair competition and false advertising. The court rejected\n defense contentions that any misconduct was protected by the First Amendment, finding the\n heightened constitutional protection afforded to noncommercial speech inappropriate in such a\n circumstance.\n\nShareholder derivative litigation brought by Robbins Geller attorneys at times also involves stopping anti-\nunion activities, including:\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 20\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 24 of 159\n PRACTICE AREAS AND SERVICES\n\n Southern Pacific/Overnite. A shareholder action stemming from several hundred million dollars in\n loss of value in the company due to systematic violations by Overnite of U.S. labor laws.\n\n Massey Energy. A shareholder action against an anti-union employer for flagrant violations of\n environmental laws resulting in multi-million-dollar penalties.\n\n Crown Petroleum. A shareholder action against a Texas-based oil company for self-dealing and\n breach of fiduciary duty while also involved in a union lockout.\n\n\n\nEnvironment and Public Health\nRobbins Geller attorneys have also represented plaintiffs in class actions related to environmental law.\nThe Firm\u2019s attorneys represented, on a pro bono basis, the Sierra Club and the National Economic\nDevelopment and Law Center as amici curiae in a federal suit designed to uphold the federal and state use\nof project labor agreements (\u201cPLAs\u201d). The suit represented a legal challenge to President Bush\u2019s Executive\nOrder 13202, which prohibits the use of project labor agreements on construction projects receiving\nfederal funds. Our amici brief in the matter outlined and stressed the significant environmental and socio-\neconomic benefits associated with the use of PLAs on large-scale construction projects.\n\nAttorneys with Robbins Geller have been involved in several other significant environmental cases,\nincluding:\n\n Public Citizen v. U.S. D.O.T. Robbins Geller attorneys represented a coalition of labor,\n environmental, industry, and public health organizations including Public Citizen, The\n International Brotherhood of Teamsters, California AFL-CIO, and California Trucking Industry\n in a challenge to a decision by the Bush administration to lift a Congressionally-imposed\n \u201cmoratorium\u201d on cross-border trucking from Mexico on the basis that such trucks do not conform\n to emission controls under the Clean Air Act, and further, that the administration did not first\n complete a comprehensive environmental impact analysis as required by the National\n Environmental Policy Act. The suit was dismissed by the United States Supreme Court, the court\n holding that because the D.O.T. lacked discretion to prevent crossborder trucking, an\n environmental assessment was not required.\n\n Sierra Club v. AK Steel. Brought on behalf of the Sierra Club for massive emissions of air and\n water pollution by a steel mill, including homes of workers living in the adjacent communities, in\n violation of the Federal Clean Air Act, the Resource Conservation Recovery Act, and the Clean\n Water Act.\n\n MTBE Litigation. Brought on behalf of various water districts for befouling public drinking water\n with MTBE, a gasoline additive linked to cancer.\n\n Exxon Valdez. Brought on behalf of fisherman and Alaska residents for billions of dollars in\n damages resulting from the greatest oil spill in U.S. history.\n\n Avila Beach. A citizens\u2019 suit against UNOCAL for leakage from the oil company pipeline so severe\n it literally destroyed the town of Avila Beach, California.\n\nFederal laws such as the Clean Water Act, the Clean Air Act, and the Resource Conservation and Recovery\nAct and state laws such as California\u2019s Proposition 65 exist to protect the environment and the public from\nabuses by corporate and government organizations. Companies can be found liable for negligence,\ntrespass, or intentional environmental damage, be forced to pay for reparations, and to come into\n\n\n Robbins Geller Rudman & Dowd LLP | 21\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 25 of 159\n PRACTICE AREAS AND SERVICES\n\ncompliance with existing laws. Prominent cases litigated by Robbins Geller attorneys include representing\nmore than 4,000 individuals suing for personal injury and property damage related to the Stringfellow\nDump Site in Southern California, participation in the Exxon Valdez oil spill litigation, and litigation\ninvolving the toxic spill arising from a Southern Pacific train derailment near Dunsmuir, California.\n\nRobbins Geller attorneys have led the fight against Big Tobacco since 1991. As an example, Robbins\nGeller attorneys filed the case that helped get rid of Joe Camel, representing various public and private\nplaintiffs, including the State of Arkansas, the general public in California, the cities of San Francisco, Los\nAngeles, and Birmingham, 14 counties in California, and the working men and women of this country in\nthe Union Pension and Welfare Fund cases that have been filed in 40 states. In 1992, Robbins Geller\nattorneys filed the first case in the country that alleged a conspiracy by the Big Tobacco companies.\n\n\n\nPro Bono\nRobbins Geller provides counsel to those unable to afford legal representation as part of a continuous and\nlongstanding commitment to the communities in which it serves. Over the years the Firm has dedicated a\nconsiderable amount of time, energy, and a full range of its resources for many pro bono and charitable\nactions.\n\nRobbins Geller has been honored for its pro bono efforts by the California State Bar (including a\nnomination for the President\u2019s Pro Bono Law Firm of the Year award) and the San Diego Volunteer\nLawyer\u2019s Program, among others.\n\nSome of the Firm\u2019s and its attorneys\u2019 pro bono and charitable actions include:\n\n Representing public school children and parents in Tennessee challenging the state\u2019s private\n school voucher law, known as the Education Savings Account (ESA) Pilot Program. Robbins Geller\n helped achieve favorable rulings enjoining implementation of the ESA for violating the Home\n Rule provision of the Tennessee Constitution, which prohibits the General Assembly from passing\n laws that target specific counties without local approval.\n\n Representing California bus passengers pro bono in a landmark consumer and civil rights case\n against Greyhound for subjecting them to discriminatory immigration raids. Robbins Geller\n achieved a watershed court ruling that a private company may be held liable under California law\n for allowing border patrol to harass and racially profile its customers. The case heralds that\n Greyhound passengers do not check their rights and dignity at the bus door and has had an\n immediate impact, not only in California but nationwide. Within weeks of Robbins Geller filing\n the case, Greyhound added \u201cknow your rights\u201d information to passengers to its website and on\n posters in bus stations around the country, along with adopting other business reforms.\n\n Working with the Homeless Action Center (HAC) to provide no-cost, barrier-free, culturally\n competent legal representation that makes it possible for people who are homeless (or at risk of\n becoming homeless) to access social safety net programs that help restore dignity and provide\n sustainable income, healthcare, mental health treatment, and housing. Based in Oakland and\n Berkeley, the non-profit is the only program in the Bay Area that specializes in legal services to\n those who are chronically homeless. In 2016, HAC provided assistance to 1,403 men and 936\n women, and 1,691 cases were completed. An additional 1,357 cases were still pending when the\n year ended. The results include 512 completed SSI cases with a success rate of 87%.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 22\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 26 of 159\n PRACTICE AREAS AND SERVICES\n\nRepresenting Trump University students in two class actions against President Donald J. Trump.\nThe historic settlement provides $25 million to approximately 7,000 consumers. This means\nindividual class members are eligible for upwards of $35,000 in restitution \u2013 an extraordinary\nresult.\n\nRepresenting children diagnosed with Autism Spectrum Disorder, as well as children with\nsignificant disabilities, in New York to remedy flawed educational policies and practices that cause\nsubstantial harm to these and other similar children year after year.\n\nRepresenting 19 San Diego County children diagnosed with Autism Spectrum Disorder in their\nappeal of the San Diego Regional Center\u2019s termination of funding for a crucial therapy. The\nvictory resulted in a complete reinstatement of funding and set a precedent that allows other\nchildren to obtain the treatments they need.\n\nServing as Northern California and Hawaii District Coordinator for the United States Court of\nAppeals for the Ninth Circuit\u2019s Pro Bono program since 1993.\n\nRepresenting the Sierra Club and the National Economic Development and Law Center as amici\ncuriae before the U.S. Supreme Court.\n\nObtaining political asylum, after an initial application had been denied, for an impoverished\nSomali family whose ethnic minority faced systematic persecution and genocidal violence in\nSomalia, as well as forced female mutilation.\n\nWorking with the ACLU in a class action filed on behalf of welfare applicants subject to San Diego\nCounty\u2019s \u201cProject 100%\u201d program. Relief was had when the County admitted that food-stamp\neligibility could not hinge upon the Project 100% \u201chome visits,\u201d and again when the district court\nruled that unconsented \u201ccollateral contacts\u201d violated state regulations. The decision was noted by\nthe Harvard Law Review, The New York Times, and The Colbert Report.\n\nFiling numerous amicus curiae briefs on behalf of religious organizations and clergy that support\ncivil rights, oppose government-backed religious-viewpoint discrimination, and uphold the\nAmerican traditions of religious freedom and church-state separation.\n\nServing as amicus counsel in a Ninth Circuit appeal from a Board of Immigration Appeals\ndeportation decision. In addition to obtaining a reversal of the BIA\u2019s deportation order, the Firm\nconsulted with the Federal Defenders\u2019 Office on cases presenting similar fact patterns, which\nresulted in a precedent-setting en banc decision from the Ninth Circuit resolving a question of state\nand federal law that had been contested and conflicted for decades.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 23\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 27 of 159\n\n\n\nPROMINENT CASES, PRECEDENT-SETTING\nDECISIONS, AND JUDICIAL COMMENDATIONS\nProminent Cases\nOver the years, Robbins Geller attorneys have obtained outstanding results in some of the most notorious\nand well-known cases, frequently earning judicial commendations for the quality of their representation.\n\n In re Enron Corp. Sec. Litig., No. H-01-3624 (S.D. Tex.). Investors lost billions of dollars as a result\n of the massive fraud at Enron. In appointing Robbins Geller lawyers as sole lead counsel to\n represent the interests of Enron investors, the court found that the Firm\u2019s zealous prosecution and\n level of \u201cinsight\u201d set it apart from its peers. Robbins Geller attorneys and lead plaintiff The\n Regents of the University of California aggressively pursued numerous defendants, including\n many of Wall Street\u2019s biggest banks, and successfully obtained settlements in excess of $7.2 billion\n for the benefit of investors. This is the largest securities class action recovery in history.\n\n The court overseeing this action had utmost praise for Robbins Geller\u2019s efforts and stated that\n \u201c[t]he experience, ability, and reputation of the attorneys of [Robbins Geller] is not disputed; it is\n one of the most successful law firms in securities class actions, if not the preeminent one, in the\n country.\u201d In re Enron Corp. Sec., Derivative & \u201cERISA\u201d Litig., 586 F. Supp. 2d 732, 797 (S.D. Tex.\n 2008).\n\n The court further commented: \u201c[I]n the face of extraordinary obstacles, the skills, expertise,\n commitment, and tenacity of [Robbins Geller] in this litigation cannot be overstated. Not to be\n overlooked are the unparalleled results, . . . which demonstrate counsel\u2019s clearly superlative\n litigating and negotiating skills.\u201d Id. at 789.\n\n The court stated that the Firm\u2019s attorneys \u201care to be commended for their zealousness, their\n diligence, their perseverance, their creativity, the enormous breadth and depth of their\n investigations and analysis, and their expertise in all areas of securities law on behalf of the\n proposed class.\u201d Id.\n\n In addition, the court noted, \u201cThis Court considers [Robbins Geller] \u2018a lion\u2019 at the securities bar\n on the national level,\u201d noting that the Lead Plaintiff selected Robbins Geller because of the Firm\u2019s\n \u201coutstanding reputation, experience, and success in securities litigation nationwide.\u201d Id. at 790.\n\n The court further stated that \u201cLead Counsel\u2019s fearsome reputation and successful track record\n undoubtedly were substantial factors in . . . obtaining these recoveries.\u201d Id.\n\n Finally, Judge Harmon stated: \u201cAs this Court has explained [this is] an extraordinary group of\n attorneys who achieved the largest settlement fund ever despite the great odds against them.\u201d Id.\n at 828.\n\n Jaffe v. Household Int\u2019l, Inc., No. 02-C-05893 (N.D. Ill). As sole lead counsel, Robbins Geller\n obtained a record-breaking settlement of $1.575 billion after 14 years of litigation, including a six-\n week jury trial in 2009 that resulted in a securities fraud verdict in favor of the class. In 2015, the\n Seventh Circuit Court of Appeals upheld the jury\u2019s verdict that defendants made false or\n misleading statements of material fact about the company\u2019s business practices and financial results,\n but remanded the case for a new trial on the issue of whether the individual defendants \u201cmade\u201d\n certain false statements, whether those false statements caused plaintiffs\u2019 losses, and the amount of\n\n\n Robbins Geller Rudman & Dowd LLP | 24\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 28 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\ndamages. The parties reached an agreement to settle the case just hours before the retrial was\nscheduled to begin on June 6, 2016. The $1.575 billion settlement, approved in October 2016, is the\nlargest ever following a securities fraud class action trial, the largest securities fraud settlement in\nthe Seventh Circuit and the eighth-largest settlement ever in a post-PSLRA securities fraud case.\nAccording to published reports, the case was just the seventh securities fraud case tried to a verdict\nsince the passage of the PSLRA.\n\nIn approving the settlement, the Honorable Jorge L. Alonso noted the team\u2019s \u201cskill and\ndetermination\u201d while recognizing that \u201cLead Counsel prosecuted the case vigorously and skillfully\nover 14 years against nine of the country\u2019s most prominent law firms\u201d and \u201cachieved an\nexceptionally significant recovery for the class.\u201d The court added that the team faced \u201csignificant\nhurdles\u201d and \u201cuphill battles\u201d throughout the case and recognized that \u201c[c]lass counsel performed a\nvery high-quality legal work in the context of a thorny case in which the state of the law has been\nand is in flux.\u201d The court succinctly concluded that the settlement was \u201ca spectacular result for the\nclass.\u201d Jaffe v. Household Int\u2019l, Inc., No. 02-C-5892, 2016 U.S. Dist. LEXIS 156921, at *8 (N.D. Ill.\nNov. 10, 2016); Jaffe v. Household Int\u2019l, Inc., No. 02-C-05893, Transcript at 56, 65 (N.D. Ill. Oct. 20,\n2016).\n\nIn re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., No. 3:15-cv-07658 (D.N.J.). As sole lead counsel,\nRobbins Geller attorneys obtained a $1.2 billion settlement in the securities case that Vanity Fair\nreported as \u201cthe corporate scandal of its era\u201d that had raised \u201cfundamental questions about the\nfunctioning of our health-care system, the nature of modern markets, and the slippery slope of\nethical rationalizations.\u201d The settlement resolves claims that defendants made false and misleading\nstatements regarding Valeant\u2019s business and financial performance during the class period,\nattributing Valeant\u2019s dramatic growth in revenues and profitability to \u201cinnovative new marketing\napproaches\u201d as part of a business model that was low risk and \u201cdurable and sustainable.\u201d Valeant is\nthe largest securities class action settlement against a pharmaceutical manufacturer and the ninth\nlargest ever.\n\nIn re Am. Realty Cap. Props., Inc. Litig., No. 1:15-mc-00040 (S.D.N.Y.). As sole lead counsel,\nRobbins Geller attorneys zealously litigated the case arising out of ARCP\u2019s manipulative accounting\npractices and obtained a $1.025 billion settlement. For five years, the litigation team prosecuted\nnine different claims for violations of the Securities Exchange Act of 1934 and Securities Act of\n1933, involving seven different stock or debt offerings and two mergers. The recovery represents\nthe highest percentage of damages of any major PSLRA case prior to trial and includes the largest\npersonal contributions by individual defendants in history.\n\nIn approving the settlement, the Honorable Alvin K. Hellerstein lauded the Robbins Geller\nlitigation team, noting: \u201cMy own observation is that plaintiffs\u2019 representation is adequate and that\nthe role of lead counsel was fulfilled in an extremely fine fashion by [Robbins Geller]. At every\njuncture, the representations made to me were reliable, the arguments were cogent, and the\nrepresentation of their client was zealous.\u201d\n\nIn re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.). In the UnitedHealth case,\nRobbins Geller represented the California Public Employees\u2019 Retirement System (\u201cCalPERS\u201d) and\ndemonstrated its willingness to vigorously advocate for its institutional clients, even under the most\ndifficult circumstances. For example, in 2006, the issue of high-level executives backdating stock\noptions made national headlines. During that time, many law firms, including Robbins Geller,\nbrought shareholder derivative lawsuits against the companies\u2019 boards of directors for breaches of\ntheir fiduciary duties or for improperly granting backdated options. Rather than pursuing a\nshareholder derivative case, the Firm filed a securities fraud class action against the company on\nbehalf of CalPERS. In doing so, Robbins Geller faced significant and unprecedented legal\n\n\n Robbins Geller Rudman & Dowd LLP | 25\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 29 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nobstacles with respect to loss causation, i.e., that defendants\u2019 actions were responsible for causing\nthe stock losses. Despite these legal hurdles, Robbins Geller obtained an $895 million recovery on\nbehalf of the UnitedHealth shareholders. Shortly after reaching the $895 million settlement with\nUnitedHealth, the remaining corporate defendants, including former CEO William A. McGuire,\nalso settled. McGuire paid $30 million and returned stock options representing more than three\nmillion shares to the shareholders. The total recovery for the class was over $925 million, the\nlargest stock option backdating recovery ever, and a recovery that is more than four times larger\nthan the next largest options backdating recovery. Moreover, Robbins Geller obtained\nunprecedented corporate governance reforms, including election of a shareholder-nominated\nmember to the company\u2019s board of directors, a mandatory holding period for shares acquired by\nexecutives via option exercise, and executive compensation reforms that tie pay to performance.\n\nAlaska Elec. Pension Fund v. CitiGroup, Inc. (In re WorldCom Sec. Litig.), No. 03 Civ. 8269\n(S.D.N.Y.). Robbins Geller attorneys represented more than 50 private and public institutions that\nopted out of the class action case and sued WorldCom\u2019s bankers, officers and directors, and\nauditors in courts around the country for losses related to WorldCom bond offerings from 1998 to\n2001. The Firm\u2019s clients included major public institutions from across the country such as\nCalPERS, CalSTRS, the state pension funds of Maine, Illinois, New Mexico, and West Virginia,\nunion pension funds, and private entities such as AIG and Northwestern Mutual. Robbins Geller\nattorneys recovered more than $650 million for their clients, substantially more than they would\nhave recovered as part of the class.\n\nLuther v. Countrywide Fin. Corp., No. 12-cv-05125 (C.D. Cal.). Robbins Geller attorneys secured a\n$500 million settlement for institutional and individual investors in what is the largest RMBS\npurchaser class action settlement in history, and one of the largest class action securities\nsettlements of all time. The unprecedented settlement resolves claims against Countrywide and\nWall Street banks that issued the securities. The action was the first securities class action case filed\nagainst originators and Wall Street banks as a result of the credit crisis. As co-lead counsel Robbins\nGeller forged through six years of hard-fought litigation, oftentimes litigating issues of first\nimpression, in order to secure the landmark settlement for its clients and the class.\n\nIn approving the settlement, Judge Mariana R. Pfaelzer repeatedly complimented plaintiffs\u2019\nattorneys, noting that it was \u201cbeyond serious dispute that Class Counsel has vigorously prosecuted\nthe Settlement Actions on both the state and federal level over the last six years.\u201d Judge Pfaelzer\nalso commented that \u201c[w]ithout a settlement, these cases would continue indefinitely, resulting in\nsignificant risks to recovery and continued litigation costs. It is difficult to understate the risks to\nrecovery if litigation had continued.\u201d Me. State Ret. Sys. v. Countrywide Fin. Corp., No.\n2:10-CV-00302, 2013 U.S. Dist. LEXIS 179190, at *44, *56 (C.D. Cal. Dec. 5, 2013).\n\nJudge Pfaelzer further noted that the proposed $500 million settlement represents one of the\n\u201clargest MBS class action settlements to date. Indeed, this settlement easily surpasses the next\nlargest . . . MBS settlement.\u201d Id. at *59.\n\nIn re Wachovia Preferred Sec. & Bond/Notes Litig., No. 09-cv-06351 (S.D.N.Y.). In litigation over\nbonds and preferred securities, issued by Wachovia between 2006 and 2008, Robbins Geller and\nco-counsel obtained a significant settlement with Wachovia successor Wells Fargo & Company\n($590 million) and Wachovia auditor KPMG LLP ($37 million). The total settlement \u2013 $627 million \u2013\nis one of the largest credit-crisis settlements involving Securities Act claims and one of the 25 largest\nsecurities class action recoveries in history. The settlement is also one of the biggest securities class\naction recoveries arising from the credit crisis.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 26\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 30 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nAs alleged in the complaint, the offering materials for the bonds and preferred securities misstated\nand failed to disclose the true nature and quality of Wachovia\u2019s mortgage loan portfolio, which\nexposed the bank and misled investors to tens of billions of dollars in losses on mortgage-related\nassets. In reality, Wachovia employed high-risk underwriting standards and made loans to\nsubprime borrowers, contrary to the offering materials and their statements of \u201cpristine credit\nquality.\u201d Robbins Geller served as co-lead counsel representing the City of Livonia Employees\u2019\nRetirement System, Hawaii Sheet Metal Workers Pension Fund, and the investor class.\n\nIn re Cardinal Health, Inc. Sec. Litig., No. C2-04-575 (S.D. Ohio). As sole lead counsel\nrepresenting Cardinal Health shareholders, Robbins Geller obtained a recovery of $600 million\nfor investors. On behalf of the lead plaintiffs, Amalgamated Bank, the New Mexico State\nInvestment Council, and the California Ironworkers Field Trust Fund, the Firm aggressively\npursued class claims and won numerous courtroom victories, including a favorable decision on\ndefendants\u2019 motion to dismiss. In re Cardinal Health, Inc. Sec. Litigs., 426 F. Supp. 2d 688 (S.D.\nOhio 2006). At the time, the $600 million settlement was the tenth-largest settlement in the\nhistory of securities fraud litigation and is the largest-ever recovery in a securities fraud action in\nthe Sixth Circuit. Judge Marbley commented: \u201c[T]his is an extraordinary settlement relative to all\nthe other settlements in cases of this nature and certainly cases of this magnitude. . . . This was an\noutstanding settlement. . . . [I]n most instances, if you\u2019ve gotten four cents on the dollar, you\u2019ve\ndone well. You\u2019ve gotten twenty cents on the dollar, so that\u2019s been extraordinary. In re Cardinal\nHealth, Inc. Sec. Litig., No. 2:04-CV-575, Transcript at 16, 32 (S.D. Ohio Oct. 19, 2007). Judge\nMarbley further stated:\n\n The quality of representation in this case was superb. Lead Counsel,\n [Robbins Geller], are nationally recognized leaders in complex securities litigation\n class actions. The quality of the representation is demonstrated by the substantial\n benefit achieved for the Class and the efficient, effective prosecution and resolution\n of this action. Lead Counsel defeated a volley of motions to dismiss, thwarting well-\n formed challenges from prominent and capable attorneys from six different law\n firms.\n\nIn re Cardinal Health Inc. Sec. Litigs., 528 F. Supp. 2d 752, 768 (S.D. Ohio 2007).\n\nAOL Time Warner Cases I & II, JCCP Nos. 4322 & 4325 (Cal. Super. Ct., Los Angeles Cnty.).\nRobbins Geller represented The Regents of the University of California, six Ohio state pension\nfunds, Rabo Bank (NL), the Scottish Widows Investment Partnership, several Australian public\nand private funds, insurance companies, and numerous additional institutional investors, both\ndomestic and international, in state and federal court opt-out litigation stemming from Time\nWarner\u2019s disastrous 2001 merger with Internet high flier America Online. Robbins Geller\nattorneys exposed a massive and sophisticated accounting fraud involving America Online\u2019s e-\ncommerce and advertising revenue. After almost four years of litigation involving extensive\ndiscovery, the Firm secured combined settlements for its opt-out clients totaling over $629 million\njust weeks before The Regents\u2019 case pending in California state court was scheduled to go to trial.\nThe Regents\u2019 gross recovery of $246 million is the largest individual opt-out securities recovery in\nhistory.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 27\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 31 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nAbu Dhabi Commercial Bank v. Morgan Stanley & Co., No. 1:08-cv-07508-SAS-DCF (S.D.N.Y.), and\nKing County, Washington v. IKB Deutsche Industriebank AG, No. 1:09-cv-08387-SAS (S.D.N.Y.).\nThe Firm represented multiple institutional investors in successfully pursuing recoveries from two\nfailed structured investment vehicles, each of which had been rated \u201cAAA\u201d by Standard & Poors\nand Moody\u2019s, but which failed fantastically in 2007. The matter settled just prior to trial in 2013.\nThis result was only made possible after Robbins Geller lawyers beat back the rating agencies\u2019\nlongtime argument that ratings were opinions protected by the First Amendment.\n\nIn re HealthSouth Corp. Sec. Litig., No. CV-03-BE-1500-S (N.D. Ala.). As court-appointed co-lead\ncounsel, Robbins Geller attorneys obtained a combined recovery of $671 million from\nHealthSouth, its auditor Ernst & Young, and its investment banker, UBS, for the benefit of\nstockholder plaintiffs. The settlement against HealthSouth represents one of the larger\nsettlements in securities class action history and is considered among the top 15 settlements\nachieved after passage of the PSLRA. Likewise, the settlement against Ernst & Young is one of the\nlargest securities class action settlements entered into by an accounting firm since the passage of\nthe PSLRA. HealthSouth and its financial advisors perpetrated one of the largest and most\npervasive frauds in the history of U.S. healthcare, prompting Congressional and law enforcement\ninquiry and resulting in guilty pleas of 16 former HealthSouth executives in related federal\ncriminal prosecutions. In March 2009, Judge Karon Bowdre commented in the HealthSouth class\ncertification opinion: \u201cThe court has had many opportunities since November 2001 to examine the\nwork of class counsel and the supervision by the Class Representatives. The court finds both to be\nfar more than adequate.\u201d In re HealthSouth Corp. Sec. Litig., 257 F.R.D. 260, 275 (N.D. Ala. 2009).\n\nIn re Facebook Biometric Info. Privacy Litig., No. 3:15-cv-03747 (N.D. Cal.). Robbins Geller\nserved as co-lead class counsel in a cutting-edge certified class action, securing a record-breaking\n$650 million all-cash settlement, the largest privacy settlement in history. The case concerned\nFacebook\u2019s alleged privacy violations through its collection of its users\u2019 biometric identifiers\nwithout informed consent through its \u201cTag Suggestions\u201d feature, which uses proprietary facial\nrecognition software to extract from user-uploaded photographs the unique biometric identifiers\n(i.e., graphical representations of facial features, also known as facial geometry) associated with\npeople\u2019s faces and identify who they are. The Honorable James Donato called the settlement \u201ca\ngroundbreaking settlement in a novel area\u201d and praised the unprecedented 22% claims rate as\n\u201cpretty phenomenal\u201d and \u201ca pretty good day in class settlement history.\u201d\n\nIn re Dynegy Inc. Sec. Litig., No. H-02-1571 (S.D. Tex.). As sole lead counsel representing The\nRegents of the University of California and the class of Dynegy investors, Robbins Geller attorneys\nobtained a combined settlement of $474 million from Dynegy, Citigroup, Inc., and Arthur\nAndersen LLP for their involvement in a clandestine financing scheme known as Project Alpha.\nGiven Dynegy\u2019s limited ability to pay, Robbins Geller attorneys structured a settlement (reached\nshortly before the commencement of trial) that maximized plaintiffs\u2019 recovery without\nbankrupting the company. Most notably, the settlement agreement provides that Dynegy will\nappoint two board members to be nominated by The Regents, which Robbins Geller and The\nRegents believe will benefit all of Dynegy\u2019s stockholders.\n\nJones v. Pfizer Inc., No. 1:10-cv-03864 (S.D.N.Y.). Lead plaintiff Stichting Philips Pensioenfonds\nobtained a $400 million settlement on behalf of class members who purchased Pfizer common\nstock during the January 19, 2006 to January 23, 2009 class period. The settlement against Pfizer\nresolves accusations that it misled investors about an alleged off-label drug marketing scheme. As\nsole lead counsel, Robbins Geller attorneys helped achieve this exceptional result after five years of\nhard-fought litigation against the toughest and the brightest members of the securities defense bar\nby litigating this case all the way to trial.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 28\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 32 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn approving the settlement, United States District Judge Alvin K. Hellerstein commended the\nFirm, noting that \u201c[w]ithout the quality and the toughness that you have exhibited, our society\nwould not be as good as it is with all its problems. So from me to you is a vote of thanks for\ndevoting yourself to this work and doing it well. . . . You did a really good job. Congratulations.\u201d\n\nIn re Qwest Commc\u2019ns Int\u2019l, Inc. Sec. Litig., No. 01-cv-1451 (D. Colo.). Robbins Geller attorneys\nserved as lead counsel for a class of investors that purchased Qwest securities. In July 2001, the\nFirm filed the initial complaint in this action on behalf of its clients, long before any investigation\ninto Qwest\u2019s financial statements was initiated by the SEC or Department of Justice. After five\nyears of litigation, lead plaintiffs entered into a settlement with Qwest and certain individual\ndefendants that provided a $400 million recovery for the class and created a mechanism that\nallowed the vast majority of class members to share in an additional $250 million recovered by the\nSEC. In 2008, Robbins Geller attorneys recovered an additional $45 million for the class in a\nsettlement with defendants Joseph P. Nacchio and Robert S. Woodruff, the CEO and CFO,\nrespectively, of Qwest during large portions of the class period.\n\nFort Worth Emps.\u2019 Ret. Fund v. J.P. Morgan Chase & Co., No. 1:09-cv-03701 (S.D.N.Y.). Robbins\nGeller attorneys served as lead counsel for a class of investors and obtained court approval of a\n$388 million recovery in nine 2007 residential mortgage-backed securities offerings issued by J.P.\nMorgan. The settlement represents, on a percentage basis, the largest recovery ever achieved in\nan MBS purchaser class action. The result was achieved after more than five years of hard-fought\nlitigation and an extensive investigation. In granting approval of the settlement, the court stated\nthe following about Robbins Geller attorneys litigating the case: \u201c[T]here is no question in my mind\nthat this is a very good result for the class and that the plaintiffs\u2019 counsel fought the case very hard\nwith extensive discovery, a lot of depositions, several rounds of briefing of various legal issues\ngoing all the way through class certification.\u201d\n\nSmilovits v. First Solar, Inc., No. 2:12-cv-00555 (D. Ariz.). As sole lead counsel, Robbins Geller\nobtained a $350 million settlement in Smilovits v. First Solar, Inc. The settlement, which was\nreached after a long legal battle and on the day before jury selection, resolves claims that First\nSolar violated \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. The\nsettlement is the fifth-largest PSLRA settlement ever recovered in the Ninth Circuit.\n\nNECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co., No. 1:08-cv-10783 (S.D.N.Y.). As\nsole lead counsel, Robbins Geller obtained a $272 million settlement on behalf of Goldman Sachs\u2019\nshareholders. The settlement concludes one of the last remaining mortgage-backed securities\npurchaser class actions arising out of the global financial crisis. The remarkable result was\nachieved following seven years of extensive litigation. After the claims were dismissed in 2010,\nRobbins Geller secured a landmark victory from the Second Circuit Court of Appeals that clarified\nthe scope of permissible class actions asserting claims under the Securities Act of 1933 on behalf of\nMBS investors. Specifically, the Second Circuit\u2019s decision rejected the concept of \u201ctranche\u201d\nstanding and concluded that a lead plaintiff in an MBS class action has class standing to pursue\nclaims on behalf of purchasers of other securities that were issued from the same registration\nstatement and backed by pools of mortgages originated by the same lenders who had originated\nmortgages backing the lead plaintiff\u2019s securities.\n\nIn approving the settlement, the Honorable Loretta A. Preska of the Southern District of New\nYork complimented Robbins Geller attorneys, noting:\n\n Counsel, thank you for your papers. They were, by the way, extraordinary\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 29\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 33 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\n papers in support of the settlement, and I will particularly note Professor Miller\u2019s\n declaration in which he details the procedural aspects of the case and then speaks\n of plaintiffs\u2019 counsel\u2019s success in the Second Circuit essentially changing the law.\n\n I will also note what counsel have said, and that is that this case illustrates\n the proper functioning of the statute.\n\n * * *\n\n Counsel, you can all be proud of what you\u2019ve done for your clients. You\u2019ve\n done an extraordinarily good job.\n\nNECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co., No. 1:08-cv-10783, Transcript at\n10-11 (S.D.N.Y. May 2, 2016).\n\nSchuh v. HCA Holdings, Inc., No. 3:11-cv-01033 (M.D. Tenn.). As sole lead counsel, Robbins\nGeller obtained a groundbreaking $215 million settlement for former HCA Holdings, Inc.\nshareholders \u2013 the largest securities class action recovery ever in Tennessee. Reached shortly\nbefore trial was scheduled to commence, the settlement resolves claims that the Registration\nStatement and Prospectus HCA filed in connection with the company\u2019s massive $4.3 billion 2011\nIPO contained material misstatements and omissions. The recovery achieved represents more\nthan 30% of the aggregate classwide damages, far exceeding the typical recovery in a securities\nclass action. At the hearing on final approval of the settlement, the Honorable Kevin H. Sharp\ndescribed Robbins Geller attorneys as \u201cgladiators\u201d and commented: \u201cLooking at the benefit\nobtained, the effort that you had to put into it, [and] the complexity in this case . . . I appreciate\nthe work that you all have done on this.\u201d Schuh v. HCA Holdings, Inc., No. 3:11-CV-01033,\nTranscript at 12-13 (M.D. Tenn. Apr. 11, 2016).\n\nSilverman v. Motorola, Inc., No. 1:07-cv-04507 (N.D. Ill.). The Firm served as lead counsel on\nbehalf of a class of investors in Motorola, ultimately recovering $200 million for investors just two\nmonths before the case was set for trial. This outstanding result was obtained despite the lack of\nan SEC investigation or any financial restatement. In May 2012, the Honorable Amy J. St. Eve of\nthe Northern District of Illinois commented: \u201cThe representation that [Robbins Geller] provided to\nthe class was significant, both in terms of quality and quantity.\u201d Silverman v. Motorola, Inc., No. 07\nC 4507, 2012 U.S. Dist. LEXIS 63477, at *11 (N.D. Ill. May 7, 2012), aff\u2019d, 739 F.3d 956 (7th Cir.\n2013).\n\nIn affirming the district court\u2019s award of attorneys\u2019 fees, the Seventh Circuit noted that \u201cno other\nlaw firm was willing to serve as lead counsel. Lack of competition not only implies a higher fee\nbut also suggests that most members of the securities bar saw this litigation as too risky for their\npractices.\u201d Silverman v. Motorola Sols., Inc., 739 F.3d 956, 958 (7th Cir. 2013).\n\nIn re AT&T Corp. Sec. Litig., MDL No. 1399 (D.N.J.). Robbins Geller attorneys served as lead\ncounsel for a class of investors that purchased AT&T common stock. The case charged defendants\nAT&T and its former Chairman and CEO, C. Michael Armstrong, with violations of the federal\nsecurities laws in connection with AT&T\u2019s April 2000 initial public offering of its wireless tracking\nstock, one of the largest IPOs in American history. After two weeks of trial, and on the eve of\nscheduled testimony by Armstrong and infamous telecom analyst Jack Grubman, defendants\nagreed to settle the case for $100 million. In granting approval of the settlement, the court stated\nthe following about the Robbins Geller attorneys handling the case:\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 30\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 34 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\n Lead Counsel are highly skilled attorneys with great experience in prosecuting\n complex securities action[s], and their professionalism and diligence displayed\n during [this] litigation substantiates this characterization. The Court notes that\n Lead Counsel displayed excellent lawyering skills through their consistent\n preparedness during court proceedings, arguments and the trial, and their well-\n written and thoroughly researched submissions to the Court. Undoubtedly, the\n attentive and persistent effort of Lead Counsel was integral in achieving the\n excellent result for the Class.\n\nIn re AT&T Corp. Sec. Litig., MDL No. 1399, 2005 U.S. Dist. LEXIS 46144, at *28-*29 (D.N.J. Apr.\n25, 2005), aff\u2019d, 455 F.3d 160 (3d Cir. 2006).\n\nIn re Dollar Gen. Corp. Sec. Litig., No. 01-CV-00388 (M.D. Tenn.). Robbins Geller attorneys\nserved as lead counsel in this case in which the Firm recovered $172.5 million for investors. The\nDollar General settlement was the largest shareholder class action recovery ever in Tennessee.\n\nCarpenters Health & Welfare Fund v. Coca-Cola Co., No. 00-CV-2838 (N.D. Ga.). As co-lead\ncounsel representing Coca-Cola shareholders, Robbins Geller attorneys obtained a recovery of\n$137.5 million after nearly eight years of litigation. Robbins Geller attorneys traveled to three\ncontinents to uncover the evidence that ultimately resulted in the settlement of this hard-fought\nlitigation. The case concerned Coca-Cola\u2019s shipping of excess concentrate at the end of financial\nreporting periods for the sole purpose of meeting analyst earnings expectations, as well as the\ncompany\u2019s failure to properly account for certain impaired foreign bottling assets.\n\nSchwartz v. TXU Corp., No. 02-CV-2243 (N.D. Tex.). As co-lead counsel, Robbins Geller attorneys\nobtained a recovery of over $149 million for a class of purchasers of TXU securities. The recovery\ncompensated class members for damages they incurred as a result of their purchases of TXU\nsecurities at inflated prices. Defendants had inflated the price of these securities by concealing the\nfact that TXU\u2019s operating earnings were declining due to a deteriorating gas pipeline and the\nfailure of the company\u2019s European operations.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 31\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 35 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn re Doral Fin. Corp. Sec. Litig., 05 MDL No. 1706 (S.D.N.Y.). In July 2007, the Honorable\nRichard Owen of the Southern District of New York approved the $129 million settlement, finding\nin his order:\n\n The services provided by Lead Counsel [Robbins Geller] were efficient and highly\n successful, resulting in an outstanding recovery for the Class without the\n substantial expense, risk and delay of continued litigation. Such efficiency and\n effectiveness supports the requested fee percentage.\n\n Cases brought under the federal securities laws are notably difficult and\n notoriously uncertain. . . . Despite the novelty and difficulty of the issues raised,\n Lead Plaintiffs\u2019 counsel secured an excellent result for the Class.\n\n . . . Based upon Lead Plaintiff\u2019s counsel\u2019s diligent efforts on behalf of the\n Class, as well as their skill and reputations, Lead Plaintiff\u2019s counsel were able to\n negotiate a very favorable result for the Class. . . . The ability of [Robbins Geller]\n to obtain such a favorable partial settlement for the Class in the face of such\n formidable opposition confirms the superior quality of their representation . . . .\n\nIn re Doral Fin. Corp. Sec. Litig., No. 1:05-md-01706, Order at 4-5 (S.D.N.Y. July 17, 2007).\n\nIn re Exxon Valdez, No. A89 095 Civ. (D. Alaska), and In re Exxon Valdez Oil Spill Litig., No. 3 AN\n89 2533 (Alaska Super. Ct., 3d Jud. Dist.). Robbins Geller attorneys served on the Plaintiffs\u2019\nCoordinating Committee and Plaintiffs\u2019 Law Committee in this massive litigation resulting from\nthe Exxon Valdez oil spill in Alaska in March 1989. The jury awarded hundreds of millions in\ncompensatory damages, as well as $5 billion in punitive damages (the latter were later reduced by\nthe U.S. Supreme Court to $507 million).\n\nMangini v. R.J. Reynolds Tobacco Co., No. 939359 (Cal. Super. Ct., San Francisco Cnty.). In this\ncase, R.J. Reynolds admitted that \u201cthe Mangini action, and the way that it was vigorously litigated,\nwas an early, significant and unique driver of the overall legal and social controversy regarding\nunderage smoking that led to the decision to phase out the Joe Camel Campaign.\u201d\n\nDoes I v. The Gap, Inc., No. 01 0031 (D. N. Mar. I.). In this groundbreaking case, Robbins Geller\nattorneys represented a class of 30,000 garment workers who alleged that they had worked under\nsweatshop conditions in garment factories in Saipan that produced clothing for top U.S. retailers\nsuch as The Gap, Target, and J.C. Penney. In the first action of its kind, Robbins Geller attorneys\npursued claims against the factories and the retailers alleging violations of RICO, the Alien Tort\nClaims Act, and the Law of Nations based on the alleged systemic labor and human rights abuses\noccurring in Saipan. This case was a companion to two other actions: Does I v. Advance Textile\nCorp., No. 99 0002 (D. N. Mar. I.), which alleged overtime violations by the garment factories\nunder the Fair Labor Standards Act and local labor law, and UNITE v. The Gap, Inc., No. 300474\n(Cal. Super. Ct., San Francisco Cty.), which alleged violations of California\u2019s Unfair Practices Law\nby the U.S. retailers. These actions resulted in a settlement of approximately $20 million that\nincluded a comprehensive monitoring program to address past violations by the factories and\nprevent future ones. The members of the litigation team were honored as Trial Lawyers of the\nYear by the Trial Lawyers for Public Justice in recognition of the team\u2019s efforts in bringing about\nthe precedent-setting settlement of the actions.\n\nHall v. NCAA (Restricted Earnings Coach Antitrust Litigation), No. 94-2392 (D. Kan.). Robbins\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 32\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 36 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\n Geller attorneys were lead counsel and lead trial counsel for one of three classes of coaches in\n these consolidated price-fixing actions against the National Collegiate Athletic Association. On\n May 4, 1998, the jury returned verdicts in favor of the three classes for more than $70 million.\n\n In re Prison Realty Sec. Litig., No. 3:99-0452 (M.D. Tenn.). Robbins Geller attorneys served as\n lead counsel for the class, obtaining a $105 million recovery.\n\n In re Honeywell Int\u2019l, Inc. Sec. Litig., No. 00-cv-03605 (D.N.J.). Robbins Geller attorneys served as\n lead counsel for a class of investors that purchased Honeywell common stock. The case charged\n Honeywell and its top officers with violations of the federal securities laws, alleging the defendants\n made false public statements concerning Honeywell\u2019s merger with Allied Signal, Inc. and that\n defendants falsified Honeywell\u2019s financial statements. After extensive discovery, Robbins Geller\n attorneys obtained a $100 million settlement for the class.\n\n Schwartz v. Visa Int\u2019l, No. 822404-4 (Cal. Super. Ct., Alameda Cnty.). After years of litigation and\n a six-month trial, Robbins Geller attorneys won one of the largest consumer protection verdicts\n ever awarded in the United States. Robbins Geller attorneys represented California consumers in\n an action against Visa and MasterCard for intentionally imposing and concealing a fee from their\n cardholders. The court ordered Visa and MasterCard to return $800 million in cardholder losses,\n which represented 100% of the amount illegally taken, plus 2% interest. In addition, the court\n ordered full disclosure of the hidden fee.\n\n Thompson v. Metro. Life Ins. Co., No. 00-cv-5071 (S.D.N.Y.). Robbins Geller attorneys served as\n lead counsel and obtained $145 million for the class in a settlement involving racial discrimination\n claims in the sale of life insurance.\n\n In re Prudential Ins. Co. of Am. Sales Pracs. Litig., MDL No. 1061 (D.N.J.). In one of the first cases\n of its kind, Robbins Geller attorneys obtained a settlement of $4 billion for deceptive sales practices\n in connection with the sale of life insurance involving the \u201cvanishing premium\u201d sales scheme.\n\n\n\nPrecedent-Setting Decisions\nRobbins Geller attorneys operate at the vanguard of complex class action of litigation. Our work often\nchanges the legal landscape, resulting in an environment that is more-favorable for obtaining recoveries\nfor our clients.\n\n Stoyas v. Toshiba Corp., 896 F.3d 933 (9th Cir. 2018), cert. denied, 588 U.S. __ (2019). In July 2018,\n the Ninth Circuit ruled in plaintiffs\u2019 favor in the Toshiba securities class action. Following appellate\n briefing and oral argument by Robbins Geller attorneys, a three-judge Ninth Circuit panel\n reversed the district court\u2019s prior dismissal in a unanimous, 36-page opinion, holding that Toshiba\n ADRs are a \u201csecurity\u201d and the Securities Exchange Act of 1934 could apply to those ADRs that were\n purchased in a domestic transaction. Id. at 939, 949. The court adopted the Second and Third\n Circuits\u2019 \u201cirrevocable liability\u201d test for determining whether the transactions were domestic and\n held that plaintiffs must be allowed to amend their complaint to allege that the purchase of\n Toshiba ADRs on the over-the-counter market was a domestic purchase and that the alleged fraud\n was in connection with the purchase.\n\n Cyan, Inc. v. Beaver Cnty. Emps. Ret. Fund, No. 15-1439 (U.S.). In March 2018, the U.S. Supreme\n Court ruled in favor of investors represented by Robbins Geller, holding that state courts continue\n to have jurisdiction over class actions asserting violations of the Securities Act of 1933. The court\u2019s\n ruling secures investors\u2019 ability to bring Securities Act actions when companies fail to make full and\n\n\n Robbins Geller Rudman & Dowd LLP | 33\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 37 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nfair disclosure of relevant information in offering documents. The court confirmed that the\nSecurities Litigation Uniform Standards Act of 1998 was designed to preclude securities class\nactions asserting violations of state law \u2013 not to preclude securities actions asserting federal law\nviolations brought in state courts.\n\nMineworkers\u2019 Pension Scheme v. First Solar Inc., 881 F.3d 750 (9th Cir. 2018), cert. denied, 588 U.S.\n__ (2019). In January 2018, the Ninth Circuit upheld the district court\u2019s denial of defendants\u2019\nmotion for summary judgment, agreeing with plaintiffs that the test for loss causation in the Ninth\nCircuit is a general \u201cproximate cause test,\u201d and rejecting the more stringent revelation of the\nfraudulent practices standard advocated by the defendants. The opinion is a significant victory for\ninvestors, as it forecloses defendants\u2019 ability to immunize themselves from liability simply by\nrefusing to publicly acknowledge their fraudulent conduct.\n\nIn re Quality Sys., Inc. Sec. Litig., No. 15-55173 (9th Cir.). In July 2017, Robbins Geller\u2019s Appellate\nPractice Group scored a significant win in the Ninth Circuit in the Quality Systems securities class\naction. On appeal, a three-judge Ninth Circuit panel unanimously reversed the district court\u2019s\nprior dismissal of the action against Quality Systems and remanded the case to the district court\nfor further proceedings. The decision addressed an issue of first impression concerning \u201cmixed\u201d\nfuture and present-tense misstatements. The appellate panel explained that \u201cnon-forward-looking\nportions of mixed statements are not eligible for the safe harbor provisions of the PSLRA . . . .\nDefendants made a number of mixed statements that included projections of growth in revenue\nand earnings based on the state of QSI\u2019s sales pipeline.\u201d The panel then held both the non-forward-\nlooking and forward-looking statements false and misleading and made with scienter, deeming\nthem actionable. Later, although defendants sought rehearing by the Ninth Circuit sitting en banc,\nthe circuit court denied their petition.\n\nLocal 703, I.B. of T. Grocery & Food Emps. Welfare Fund v. Regions Fin. Corp., No. CV-10-J-2847-S\n(N.D. Ala.). In the Regions Financial securities class action, Robbins Geller represented Local 703,\nI.B. of T. Grocery and Food Employees Welfare Fund and obtained a $90 million settlement in\nSeptember 2015 on behalf of purchasers of Regions Financial common stock during the class\nperiod. In August 2014, the Eleventh Circuit Court of Appeals affirmed the district court\u2019s\ndecision to certify a class action based upon alleged misrepresentations about Regions Financial\u2019s\nfinancial health before and during the recent economic recession, and in November 2014, the U.S.\nDistrict Court for the Northern District of Alabama denied defendants\u2019 third attempt to avoid\nplaintiffs\u2019 motion for class certification.\n\nOmnicare, Inc. v. Laborers Dist. Council Constr. Indus. Pension Fund, No. 13-435 (U.S.). In March\n2015, the U.S. Supreme Court ruled in favor of investors represented by Robbins Geller that\ninvestors asserting a claim under \u00a711 of the Securities Act of 1933 with respect to a misleading\nstatement of opinion do not, as defendant Omnicare had contended, have to prove that the\nstatement was subjectively disbelieved when made. Rather, the court held that a statement of\nopinion may be actionable either because it was not believed, or because it lacked a reasonable\nbasis in fact. This decision is significant in that it resolved a conflict among the federal circuit\ncourts and expressly overruled the Second Circuit\u2019s widely followed, more stringent pleading\nstandard for \u00a711 claims involving statements of opinion. The Supreme Court remanded the case\nback to the district court for determination under the newly articulated standard. In August of\n2016, upon remand, the district court applied the Supreme Court\u2019s new test and denied\ndefendants\u2019 motion to dismiss in full.\n\nNECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co., 693 F.3d 145 (2d Cir. 2012). In a\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 34\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 38 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nsecurities fraud action involving mortgage-backed securities, the Second Circuit rejected the\nconcept of \u201ctranche\u201d standing and found that a lead plaintiff has class standing to pursue claims on\nbehalf of purchasers of securities that were backed by pools of mortgages originated by the same\nlenders who had originated mortgages backing the lead plaintiff\u2019s securities. The court noted that,\ngiven those common lenders, the lead plaintiff\u2019s claims as to its purchases implicated \u201cthe same set\nof concerns\u201d that purchasers in several of the other offerings possessed. The court also rejected\nthe notion that the lead plaintiff lacked standing to represent investors in different tranches.\n\nIn re VeriFone Holdings, Inc. Sec. Litig., 704 F.3d 694 (9th Cir. 2012). The panel reversed in part\nand affirmed in part the dismissal of investors\u2019 securities fraud class action alleging violations of\n\u00a7\u00a710(b), 20(a), and 20A of the Securities Exchange Act of 1934 and SEC Rule 10b-5 in connection\nwith a restatement of financial results of the company in which the investors had purchased stock.\n\nThe panel held that the third amended complaint adequately pleaded the \u00a710(b), \u00a720A, and Rule\n10b-5 claims. Considering the allegations of scienter holistically, as the U.S. Supreme Court\ndirected in Matrixx Initiatives, Inc. v. Siracusano, 563 U.S 27, 48-49 (2011), the panel concluded that\nthe inference that the defendant company and its chief executive officer and former chief financial\nofficer were deliberately reckless as to the truth of their financial reports and related public\nstatements following a merger was at least as compelling as any opposing inference.\n\nFox v. JAMDAT Mobile, Inc., 185 Cal. App. 4th 1068 (2010). Concluding that Delaware\u2019s\nshareholder ratification doctrine did not bar the claims, the California Court of Appeal reversed\ndismissal of a shareholder class action alleging breach of fiduciary duty in a corporate merger.\n\nIn re Constar Int\u2019l Inc. Sec. Litig., 585 F.3d 774 (3d Cir. 2009). The Third Circuit flatly rejected\ndefense contentions that where relief is sought under \u00a711 of the Securities Act of 1933, which\nimposes liability when securities are issued pursuant to an incomplete or misleading registration\nstatement, class certification should depend upon findings concerning market efficiency and loss\ncausation.\n\nMatrixx Initiatives, Inc. v. Siracusano, 563 U.S 27 (2011), aff\u2019g 585 F.3d 1167 (9th Cir. 2009). In a\nsecurities fraud action involving the defendants\u2019 failure to disclose a possible link between the\ncompany\u2019s popular cold remedy and a life-altering side effect observed in some users, the U.S.\nSupreme Court unanimously affirmed the Ninth Circuit\u2019s (a) rejection of a bright-line \u201cstatistical\nsignificance\u201d materiality standard, and (b) holding that plaintiffs had successfully pleaded a strong\ninference of the defendants\u2019 scienter.\n\nAlaska Elec. Pension Fund v. Flowserve Corp., 572 F.3d 221 (5th Cir. 2009). Aided by former U.S.\nSupreme Court Justice O\u2019Connor\u2019s presence on the panel, the Fifth Circuit reversed a district\ncourt order denying class certification and also reversed an order granting summary judgment to\ndefendants. The court held that the district court applied an incorrect fact-for-fact standard of loss\ncausation, and that genuine issues of fact on loss causation precluded summary judgment.\n\nIn re F5 Networks, Inc., Derivative Litig., 207 P.3d 433 (Wash. 2009). In a derivative action\nalleging unlawful stock option backdating, the Supreme Court of Washington ruled that\nshareholders need not make a pre-suit demand on the board of directors where this step would be\nfutile, agreeing with plaintiffs that favorable Delaware case law should be followed as persuasive\nauthority.\n\nLormand v. US Unwired, Inc., 565 F.3d 228 (5th Cir. 2009). In a rare win for investors in the Fifth\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 35\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 39 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nCircuit, the court reversed an order of dismissal, holding that safe harbor warnings were not\nmeaningful when the facts alleged established a strong inference that defendants knew their\nforecasts were false. The court also held that plaintiffs sufficiently alleged loss causation.\n\nInstitutional Inv\u2019rs Grp. v. Avaya, Inc., 564 F.3d 242 (3d Cir. 2009). In a victory for investors in\nthe Third Circuit, the court reversed an order of dismissal, holding that shareholders pled with\nparticularity why the company\u2019s repeated denials of price discounts on products were false and\nmisleading when the totality of facts alleged established a strong inference that defendants knew\ntheir denials were false.\n\nAlaska Elec. Pension Fund v. Pharmacia Corp., 554 F.3d 342 (3d Cir. 2009). The Third Circuit\nheld that claims filed for violation of \u00a710(b) of the Securities Exchange Act of 1934 were timely,\nadopting investors\u2019 argument that because scienter is a critical element of the claims, the time for\nfiling them cannot begin to run until the defendants\u2019 fraudulent state of mind should be apparent.\n\nRael v. Page, 222 P.3d 678 (N.M. Ct. App. 2009). In this shareholder class and derivative action,\nRobbins Geller attorneys obtained an appellate decision reversing the trial court\u2019s dismissal of the\ncomplaint alleging serious director misconduct in connection with the merger of SunCal\nCompanies and Westland Development Co., Inc., a New Mexico company with large and historic\nlandholdings and other assets in the Albuquerque area. The appellate court held that plaintiff\u2019s\nclaims for breach of fiduciary duty were direct, not derivative, because they constituted an attack\non the validity or fairness of the merger and the conduct of the directors. Although New Mexico\nlaw had not addressed this question directly, at the urging of the Firm\u2019s attorneys, the court relied\non Delaware law for guidance, rejecting the \u201cspecial injury\u201d test for determining the direct versus\nderivative inquiry and instead applying more recent Delaware case law.\n\nLane v. Page, No. 06-cv-1071 (D.N.M. 2012). In May 2012, while granting final approval of the\nsettlement in the federal component of the Westland cases, Judge Browning in the District of New\nMexico commented:\n\n Class Counsel are highly skilled and specialized attorneys who use their substantial\n experience and expertise to prosecute complex securities class actions. In possibly\n one of the best known and most prominent recent securities cases, Robbins Geller\n served as sole lead counsel \u2013 In re Enron Corp. Sec. Litig., No. H-01-3624 (S.D.\n Tex.). See Report at 3. The Court has previously noted that the class would\n \u201creceive high caliber legal representation\u201d from class counsel, and throughout the\n course of the litigation the Court has been impressed with the quality of\n representation on each side. Lane v. Page, 250 F.R.D. at 647.\n\nLane v. Page, 862 F. Supp. 2d 1182, 1253-54 (D.N.M. 2012).\n\nIn addition, Judge Browning stated: \u201c\u2018Few plaintiffs\u2019 law firms could have devoted the kind of\ntime, skill, and financial resources over a five-year period necessary to achieve the pre- and post-\nMerger benefits obtained for the class here.\u2019 . . . [Robbins Geller is] both skilled and experienced,\nand used those skills and experience for the benefit of the class [Robbins Geller is] both skilled and\nexperienced, and used those skills and experience for the benefit of the class.\u201d Id. at 1254.\n\nLuther v. Countrywide Home Loans Servicing LP, 533 F.3d 1031 (9th Cir. 2008). In a case of first\nimpression, the Ninth Circuit held that the Securities Act of 1933\u2019s specific non-removal features\nhad not been trumped by the general removal provisions of the Class Action Fairness Act of 2005.\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 36\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 40 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn re Gilead Scis. Sec. Litig., 536 F.3d 1049 (9th Cir. 2008). The Ninth Circuit upheld defrauded\ninvestors\u2019 loss causation theory as plausible, ruling that a limited temporal gap between the time\ndefendants\u2019 misrepresentation was publicly revealed and the subsequent decline in stock value was\nreasonable where the public had not immediately understood the impact of defendants\u2019 fraud.\n\nIn re WorldCom Sec. Litig., 496 F.3d 245 (2d Cir. 2007). The Second Circuit held that the filing of\na class action complaint tolls the limitations period for all members of the class, including those\nwho choose to opt out of the class action and file their own individual actions without waiting to\nsee whether the district court certifies a class \u2013 reversing the decision below and effectively\noverruling multiple district court rulings that American Pipe tolling did not apply under these\ncircumstances.\n\nIn re Merck & Co. Sec., Derivative & ERISA Litig., 493 F.3d 393 (3d Cir. 2007). In a shareholder\nderivative suit appeal, the Third Circuit held that the general rule that discovery may not be used\nto supplement demand-futility allegations does not apply where the defendants enter a voluntary\nstipulation to produce materials relevant to demand futility without providing for any limitation as\nto their use. In April 2007, the Honorable D. Brooks Smith praised Robbins Geller partner Joe\nDaley\u2019s efforts in this litigation:\n\n Thank you very much Mr. Daley and a thank you to all counsel. As Judge Cowen\n mentioned, this was an exquisitely well-briefed case; it was also an extremely well-\n argued case, and we thank counsel for their respective jobs here in the matter,\n which we will take under advisement. Thank you.\n\nIn re Merck & Co., Inc. Sec., Derivative & ERISA Litig., No. 06-2911, Transcript at 35:37-36:00 (3d\nCir. Apr. 12, 2007).\n\nAlaska Elec. Pension Fund v. Brown, 941 A.2d 1011 (Del. 2007). The Supreme Court of Delaware\nheld that the Alaska Electrical Pension Fund, for purposes of the \u201ccorporate benefit\u201d attorney-fee\ndoctrine, was presumed to have caused a substantial increase in the tender offer price paid in a\n\u201cgoing private\u201d buyout transaction. The Court of Chancery originally ruled that Alaska\u2019s counsel,\nRobbins Geller, was not entitled to an award of attorney fees, but Delaware\u2019s high court, in its\npublished opinion, reversed and remanded for further proceedings.\n\nCrandon Cap. Partners v. Shelk, 157 P.3d 176 (Or. 2007). Oregon\u2019s Supreme Court ruled that a\nshareholder plaintiff in a derivative action may still seek attorney fees even if the defendants took\nactions to moot the underlying claims. The Firm\u2019s attorneys convinced Oregon\u2019s highest court to\ntake the case, and reverse, despite the contrary position articulated by both the trial court and the\nOregon Court of Appeals.\n\nIn re Qwest Commc\u2019ns Int\u2019l, 450 F.3d 1179 (10th Cir. 2006). In a case of first impression, the Tenth\nCircuit held that a corporation\u2019s deliberate release of purportedly privileged materials to\ngovernmental agencies was not a \u201cselective waiver\u201d of the privileges such that the corporation could\nrefuse to produce the same materials to non-governmental plaintiffs in private securities fraud\nlitigation.\n\nIn re Guidant S\u2019holders Derivative Litig., 841 N.E.2d 571 (Ind. 2006). Answering a certified\nquestion from a federal court, the Supreme Court of Indiana unanimously held that a pre-suit\ndemand in a derivative action is excused if the demand would be a futile gesture. The court\nadopted a \u201cdemand futility\u201d standard and rejected defendants\u2019 call for a \u201cuniversal demand\u201d\nstandard that might have immediately ended the case.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 37\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 41 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nDenver Area Meat Cutters v. Clayton, 209 S.W.3d 584 (Tenn. Ct. App. 2006). The Tennessee\nCourt of Appeals rejected an objector\u2019s challenge to a class action settlement arising out of Warren\nBuffet\u2019s 2003 acquisition of Tennessee-based Clayton Homes. In their effort to secure relief for\nClayton Homes stockholders, the Firm\u2019s attorneys obtained a temporary injunction of the Buffet\nacquisition for six weeks in 2003 while the matter was litigated in the courts. The temporary halt\nto Buffet\u2019s acquisition received national press attention.\n\nDeJulius v. New Eng. Health Care Emps. Pension Fund, 429 F.3d 935 (10th Cir. 2005). The Tenth\nCircuit held that the multi-faceted notice of a $50 million settlement in a securities fraud class\naction had been the best notice practicable under the circumstances, and thus satisfied both\nconstitutional due process and Rule 23 of the Federal Rules of Civil Procedure.\n\nIn re Daou Sys., 411 F.3d 1006 (9th Cir. 2005). The Ninth Circuit sustained investors\u2019 allegations\nof accounting fraud and ruled that loss causation was adequately alleged by pleading that the value\nof the stock they purchased declined when the issuer\u2019s true financial condition was revealed.\n\nBarrie v. Intervoice-Brite, Inc., 397 F.3d 249 (5th Cir.), reh\u2019g denied and opinion modified, 409 F.3d\n653 (5th Cir. 2005). The Fifth Circuit upheld investors\u2019 accounting-fraud claims, holding that\nfraud is pled as to both defendants when one knowingly utters a false statement and the other\nknowingly fails to correct it, even if the complaint does not specify who spoke and who listened.\n\nCity of Monroe Emps. Ret. Sys. v. Bridgestone Corp., 399 F.3d 651 (6th Cir. 2005). The Sixth\nCircuit held that a statement regarding objective data supposedly supporting a corporation\u2019s belief\nthat its tires were safe was actionable where jurors could have found a reasonable basis to believe\nthe corporation was aware of undisclosed facts seriously undermining the statement\u2019s accuracy.\n\nIll. Mun. Ret. Fund v. Citigroup, Inc., 391 F.3d 844 (7th Cir. 2004). The Seventh Circuit upheld a\ndistrict court\u2019s decision that the Illinois Municipal Retirement Fund was entitled to litigate its\nclaims under the Securities Act of 1933 against WorldCom\u2019s underwriters before a state court\nrather than before the federal forum sought by the defendants.\n\nNursing Home Pension Fund, Local 144 v. Oracle Corp., 380 F.3d 1226 (9th Cir. 2004). The Ninth\nCircuit ruled that defendants\u2019 fraudulent intent could be inferred from allegations concerning\ntheir false representations, insider stock sales and improper accounting methods.\n\nSouthland Sec. Corp. v. INSpire Ins. Sols. Inc., 365 F.3d 353 (5th Cir. 2004). The Fifth Circuit\nsustained allegations that an issuer\u2019s CEO made fraudulent statements in connection with a\ncontract announcement.\n\nSmith v. Am. Family Mut. Ins. Co., 289 S.W.3d 675 (Mo. Ct. App. 2009). Capping nearly a decade\nof hotly contested litigation, the Missouri Court of Appeals reversed the trial court\u2019s judgment\nnotwithstanding the verdict for auto insurer American Family and reinstated a unanimous jury\nverdict for the plaintiff class.\n\nTroyk v. Farmers Grp., Inc., 171 Cal. App. 4th 1305 (2009). The California Court of Appeal held\nthat Farmers Insurance\u2019s practice of levying a \u201cservice charge\u201d on one-month auto insurance\npolicies, without specifying the charge in the policy, violated California\u2019s Insurance Code.\n\nLebrilla v. Farmers Grp., Inc., 119 Cal. App. 4th 1070 (2004). Reversing the trial court, the\nCalifornia Court of Appeal ordered class certification of a suit against Farmers, one of the largest\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 38\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 42 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nautomobile insurers in California, and ruled that Farmers\u2019 standard automobile policy requires it\nto provide parts that are as good as those made by vehicle\u2019s manufacturer. The case involved\nFarmers\u2019 practice of using inferior imitation parts when repairing insureds\u2019 vehicles.\n\nIn re Monumental Life Ins. Co., 365 F.3d 408, 416 (5th Cir. 2004). The Fifth Circuit Court of\nAppeals reversed a district court\u2019s denial of class certification in a case filed by African-Americans\nseeking to remedy racially discriminatory insurance practices. The Fifth Circuit held that a\nmonetary relief claim is viable in a Rule 23(b)(2) class if it flows directly from liability to the class as\na whole and is capable of classwide \u201c\u2018computation by means of objective standards and not\ndependent in any significant way on the intangible, subjective differences of each class member\u2019s\ncircumstances.\u2019\u201d\n\nDent v. National Football League, No. 15-15143 (9th Cir.). In September 2018, the United States\nCourt of Appeals for the Ninth Circuit issued an important decision reversing the district court\u2019s\nprevious dismissal of the Dent v. National Football League litigation, concluding that the complaint\nbrought by NFL Hall of Famer Richard Dent and others should not be dismissed on labor-law\npreemption grounds. The case was remanded to the district court for further proceedings.\n\nKwikset Corp. v. Superior Court, 51 Cal. 4th 310 (2011). In a leading decision interpreting the\nscope of Proposition 64\u2019s new standing requirements under California\u2019s Unfair Competition Law\n(UCL), the California Supreme Court held that consumers alleging that a manufacturer has\nmisrepresented its product have \u201clost money or property\u201d within the meaning of the initiative, and\nthus have standing to sue under the UCL, if they \u201ccan truthfully allege that they were deceived by\na product\u2019s label into spending money to purchase the product, and would not have purchased it\notherwise.\u201d Id. at 317. Kwikset involved allegations, proven at trial, that defendants violated\nCalifornia\u2019s \u201cMade in the U.S.A.\u201d statute by representing on their labels that their products were\n\u201cMade in U.S.A.\u201d or \u201cAll-American Made\u201d when, in fact, the products were substantially made with\nforeign parts and labor.\n\nSafeco Ins. Co. of Am. v. Superior Court, 173 Cal. App. 4th 814 (2009). In a class action against\nauto insurer Safeco, the California Court of Appeal agreed that the plaintiff should have access to\ndiscovery to identify a new class representative after her standing to sue was challenged.\n\nConsumer Privacy Cases, 175 Cal. App. 4th 545 (2009). The California Court of Appeal rejected\nobjections to a nationwide class action settlement benefiting Bank of America customers.\n\nKoponen v. Pac. Gas & Elec. Co., 165 Cal. App. 4th 345 (2008). The Firm\u2019s attorneys obtained a\npublished decision reversing the trial court\u2019s dismissal of the action, and holding that the plaintiff\u2019s\nclaims for damages arising from the utility\u2019s unauthorized use of rights-of-way or easements\nobtained from the plaintiff and other landowners were not barred by a statute limiting the\nauthority of California courts to review or correct decisions of the California Public Utilities\nCommission.\n\nSanford v. MemberWorks, Inc., 483 F.3d 956 (9th Cir. 2007). In a telemarketing-fraud case, where\nthe plaintiff consumer insisted she had never entered the contractual arrangement that defendants\nsaid bound her to arbitrate individual claims to the exclusion of pursuing class claims, the Ninth\nCircuit reversed an order compelling arbitration \u2013 allowing the plaintiff to litigate on behalf of a\nclass.\n\nRitt v. Billy Blanks Enters., 870 N.E.2d 212 (Ohio Ct. App. 2007). In the Ohio analog to the West\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 39\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 43 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\n case, the Ohio Court of Appeals approved certification of a class of Ohio residents seeking relief\n under Ohio\u2019s consumer protection laws for the same telemarketing fraud.\n\n Haw. Med. Ass\u2019n v. Haw. Med. Serv. Ass\u2019n, 148 P.3d 1179 (Haw. 2006). The Supreme Court of\n Hawaii ruled that claims of unfair competition were not subject to arbitration and that claims of\n tortious interference with prospective economic advantage were adequately alleged.\n\n Branick v. Downey Sav. & Loan Ass\u2019n, 39 Cal. 4th 235 (2006). Robbins Geller attorneys were part\n of a team of lawyers that briefed this case before the Supreme Court of California. The court\n issued a unanimous decision holding that new plaintiffs may be substituted, if necessary, to\n preserve actions pending when Proposition 64 was passed by California voters in 2004.\n Proposition 64 amended California\u2019s Unfair Competition Law and was aggressively cited by\n defense lawyers in an effort to dismiss cases after the initiative was adopted.\n\n McKell v. Wash. Mut., Inc., 142 Cal. App. 4th 1457 (2006). The California Court of Appeal\n reversed the trial court, holding that plaintiff\u2019s theories attacking a variety of allegedly inflated\n mortgage-related fees were actionable.\n\n West Corp. v. Superior Court, 116 Cal. App. 4th 1167 (2004). The California Court of Appeal\n upheld the trial court\u2019s finding that jurisdiction in California was appropriate over the out-of-state\n corporate defendant whose telemarketing was aimed at California residents. Exercise of\n jurisdiction was found to be in keeping with considerations of fair play and substantial justice.\n\n Kruse v. Wells Fargo Home Mortg., Inc., 383 F.3d 49 (2d Cir. 2004), and Santiago v. GMAC Mortg.\n Grp., Inc., 417 F.3d 384 (3d Cir. 2005). In two groundbreaking federal appellate decisions, the\n Second and Third Circuits each ruled that the Real Estate Settlement Practices Act prohibits\n marking up home loan-related fees and charges.\n\n\n\nAdditional Judicial Commendations\nRobbins Geller attorneys have been praised by countless judges all over the country for the quality of their\nrepresentation in class-action lawsuits. In addition to the judicial commendations set forth in the\nProminent Cases and Precedent-Setting Decisions sections, judges have acknowledged the successful\nresults of the Firm and its attorneys with the following plaudits:\n\n On October 5, 2022, at the final approval hearing of the settlement, the Honorable Paul A.\n Fioravanti, Jr. stated: \u201cThe settlement achieved here is, in short, impressive. . . . This litigation was\n hard fought. The issues were complex. . . . Plaintiffs\u2019 lead counsel here are among the most\n highly respected practitioners in this Court with a reputation for exacting substantial awards for\n the classes that they represent. . . . Again, the benefit was outstanding. . . . Counsel, this was an\n interesting case. I know you worked really hard on it. Fantastic result. The fee was well\n deserved.\u201d City of Warren Gen. Emps.\u2019 Ret. Sys. v. Roche, No. 2019-0740-PAF, Transcript at 26-29\n (Del. Ch. Oct. 5, 2022).\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 40\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 44 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nOn February 4, 2021, in granting final approval of the settlement, the Honorable Mark H. Cohen\nof the United States District Court for the Northern District of Georgia stated: \u201cLead Counsel\nsuccessfully achieved a greater-than-average settlement \u2018in the face of significant risks.\u2019\u201d Robbins\nGeller\u2019s \u201chard-fought litigation in the Eleventh Circuit\u201d and \u201c[i]n considering the experience,\nreputation, and abilities of the attorneys, the Court recognize[d] that Lead Counsel is well-\nregarded in the legal community, especially in litigating class-action securities cases.\u201d Monroe\nCounty Employees\u2019 Retirement System v. The Southern Company, No. 1:17-cv-00241, Order at 8-9 (N.D.\nGa. Feb. 4, 2021).\n\nOn December 18, 2020, at the final approval hearing of the settlement, the Honorable Yvonne\nGonzalez Rogers of the United States District Court for the Northern District of California\ncommended Robbins Geller, stating: \u201cCounsel performed excellent work in not only investigating\nand analyzing the core of the issues, but in negotiating and demanding the necessary reforms to\nprevent malfeasance for the benefit of the shareholders and the consumers. The Court\ncomplements counsel for its excellence.\u201d In re RH S\u2019holder Derivative Litig., No. 4:18-cv-02452-YGR,\nOrder and Final Judgment at 3 (N.D. Cal. Dec. 18, 2020).\n\nOn October 23, 2020, at the final approval hearing of the settlement, the Honorable P. Kevin\nCastel of the United States District Court for the Southern District of New York praised the firm,\n\u201c[Robbins Geller] has been sophisticated and experienced.\u201d He also noted that: \u201c[ T]he quality of\nthe representation . . . was excellent. The experience of counsel is also a factor. Robbins Geller\ncertainly has the extensive experience and they were litigating against national powerhouses . . . .\u201d\nCity of Birmingham Ret. & Relief Sys. v. BRF S.A., No. 18 Civ. 2213 (PKC), Transcript at 12-13, 18\n(S.D.N.Y. Oct. 23, 2020).\n\nIn May 2020, in granting final approval of the settlement, the Honorable Mark L. Wolf praised\nRobbins Geller: \u201c[T]he class has been represented by excellent honorable counsel . . . . [T]he fund\nwas represented by experienced, energetic, able counsel, the fund was engaged and informed, and\nthe fund followed advice of experienced counsel. Counsel for the class have been excellent, and I\nwould say honorable.\u201d Additionally, Judge Wolf noted, \u201cI find that the work that's been done\nprimarily by Robbins Geller has been excellent and honorable and efficient. . . . [T]his has been a\nchallenging case, and they\u2019ve done an excellent job.\u201d McGee v. Constant Contact, Inc., No.\n1:15-cv-13114-MLW, Transcript at 21, 31, 61 (D. Mass. May 27, 2020).\n\nIn December 2019, the Honorable Margo K. Brodie noted in granting final approval of the\nsettlement that \u201c[Robbins Geller and co-counsel] have also demonstrated the utmost\nprofessionalism despite the demands of the extreme perseverance that this case has required,\nlitigating on behalf of a class of over 12 million for over fourteen years, across a changing legal\nlandscape, significant motion practice, and appeal and remand. Class counsel\u2019s pedigree and\nefforts alone speak to the quality of their representation.\u201d In re Payment Card Interchange Fee\n& Merch. Disc. Antitrust Litig., No. 1:05-md-01720-MKB-JO, Memorandum & Order (E.D.N.Y.\nDec. 16, 2019).\n\nIn October 2019, the Honorable Claire C. Cecchi noted that Robbins Geller is \u201ccapable of\nadequately representing the class, both based on their prior experience in class action lawsuits and\nbased on their capable advocacy on behalf of the class in this action.\u201d The court further\ncommended the Firm and co-counsel for \u201cconduct[ing] the [l]itigation . . . with skill, perseverance,\nand diligent advocacy.\u201d Lincoln Adventures, LLC v. Those Certain Underwriters at Lloyd\u2019s, London\nMembers, No. 2:08-cv-00235-CCC-JAD, Order at 4 (D.N.J. Oct. 3, 2019); Lincoln Adventures, LLC v.\nThose Certain Underwriters at Lloyd\u2019s, London Members of Syndicates, No. 2:08-cv-00235-CCC-JAD,\nOrder Awarding Attorneys\u2019 Fees and Expenses/Charges and Service Awards at 3 (D.N.J. Oct. 3,\n2019).\n\n\n Robbins Geller Rudman & Dowd LLP | 41\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 45 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn June 2019, the Honorable T.S. Ellis, III noted that Robbins Geller \u201cachieved the [$108 million]\n[s]ettlement with skill, perseverance, and diligent advocacy.\u201d At the final approval hearing, the\ncourt further commended Robbins Geller by stating, \u201cI think the case was fully and appropriately\nlitigated [and] you all did a very good job. . . . [T]hank you for your service in the court. . . .\n[You\u2019re] first-class lawyers . . . .\u201d Knurr v. Orbital ATK, Inc., No. 1:16-cv-01031, Order Awarding\nAttorneys\u2019 Fees and Expenses at 3 (E.D. Va. June 7, 2019); Knurr v. Orbital ATK, Inc., No.\n1:16-cv-01031, Transcript at 28-29 (E.D. Va. June 7, 2019).\n\nIn June 2019, in granting final approval of the settlement, the Honorable John A. Houston stated:\nRobbins Geller\u2019s \u201cskill and quality of work was extraordinary . . . . I\u2019ll note from the top that this\nhas been an aggressively litigated action.\u201d In re Morning Song Bird Food Litig., No.\n3:12-cv-01592-JAH-AGS, Transcript at 4, 9 (S.D. Cal. June 3, 2019).\n\nIn May 2019, in granting final approval of the settlement, the Honorable Richard H. DuBois\nstated: Robbins Geller is \u201chighly experienced and skilled\u201d for obtaining a \u201cfair, reasonable, and\nadequate\u201d settlement in the \u201cinterest of the [c]lass [m]embers\u201d after \u201cextensive investigation.\u201d\nChicago Laborers Pension Fund v. Alibaba Grp. Holding Ltd., No. CIV535692, Judgment and Order\nGranting Final Approval of Class Action Settlement at 3 (Cal. Super. Ct., San Mateo Cnty. May 17,\n2019).\n\nIn April 2019, the Honorable Kathaleen St. J. McCormick noted: \u201c[S]ince the inception of this\nlitigation, plaintiffs and their counsel have vigorously prosecuted the claims brought on behalf of\nthe class. . . . When Vice Chancellor Laster appointed lead counsel, he effectively said: Go get a\ngood result. And counsel took that to heart and did it. . . . The proposed settlement was the\nproduct of intense litigation and complex mediation. . . . [Robbins Geller has] only built a\nconsiderable track record, never burned it, which gave them the credibility necessary to extract the\nbenefits achieved.\u201d In re Calamos Asset Mgmt., Inc. S\u2019holder Litig., No. 2017-0058-JTL, Transcript at\n87, 93, 95, 98 (Del. Ch. Apr. 25, 2019).\n\nIn April 2019, the Honorable Susan O. Hickey noted that Robbins Geller \u201cachieved an exceptional\n[s]ettlement with skill, perseverance, and diligent advocacy.\u201d City of Pontiac Gen. Emps.\u2019 Ret. Sys. v.\nWal-Mart Stores, Inc., No. 5:12-cv-5162, Order Awarding Attorneys\u2019 Fees and Expenses at 3 (W.D.\nArk. Apr. 8, 2019).\n\nIn January 2019, the Honorable Margo K. Brodie noted that Robbins Geller \u201chas arduously\nrepresented a variety of plaintiffs\u2019 groups in this action[,] . . . [has] extensive antitrust class action\nlitigation experience . . . [and] negotiated what [may be] the largest antitrust settlement in\nhistory.\u201d In re Payment Card Interchange Fee & Merch. Disc. Antitrust Litig., 330 F.R.D. 11, 34\n(E.D.N.Y. 2019).\n\nOn December 20, 2018, at the final approval hearing for the settlement, the court lauded Robbins\nGeller\u2019s attorneys and their work: \u201c[T]his is a pretty extraordinary settlement, recovery on behalf\nof the members of the class. . . . I\u2019ve been very impressed with the level of lawyering in the case . . .\nand with the level of briefing . . . and I wanted to express my appreciation for that and for the\nwork that everyone has done here.\u201d The court concluded, \u201cyour clients were all blessed to have\nyou, [and] not just because of the outcome.\u201d Duncan v. Joy Global, Inc., No. 16-CV-1229,\nTranscript at 12, 20-21 (E.D. Wis. Dec. 20, 2018).\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 42\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 46 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn October 2017, the Honorable William Alsup noted that Robbins Geller and lead plaintiff\n\u201cvigorously prosecuted this action.\u201d In re LendingClub Sec. Litig., No. 3:16-cv-02627-WHA, Order\nat 13 (N.D. Cal. Oct. 20, 2017).\n\nOn November 9, 2018, in granting final approval of the settlement, the Honorable Jesse M.\nFurman commented: \u201c[Robbins Geller] did an extraordinary job here. . . . [I]t is fair to say [this\nwas] probably the most complicated case I have had since I have been on the bench. . . . I cannot\nreally imagine how complicated it would have been if I didn't have counsel who had done as\nadmirable [a] job in briefing it and arguing as you have done. You have in my view done an\nextraordinary service to the class. . . . I think you have done an extraordinary job and deserve\nthanks and commendation for that.\u201d Alaska Elec. Pension Fund v. Bank of Am. Corp., No.\n1:14-cv-07126-JMF-OTW, Transcript at 27-28 (S.D.N.Y. Nov. 9, 2018).\n\nOn September 12, 2018, at the final approval hearing of the settlement, the Honorable William H.\nOrrick of the Northern District of California praised Robbins Geller\u2019s \u201chigh-quality lawyering\u201d in a\ncase that \u201cinvolved complicated discovery and complicated and novel legal issues,\u201d resulting in an\n\u201cexcellent\u201d settlement for the class. The \u201clawyering . . . was excellent\u201d and the case was \u201cvery well\nlitigated.\u201d In re Lidoderm Antitrust Litig., No. 14-MDL-02521-WHO, Transcript at 11, 14, 22 (N.D.\nCal. Sep. 12, 2018).\n\nOn March 31, 2017, in granting final approval of the settlement, the Honorable Gonzalo P. Curiel\nhailed the settlement as \u201cextraordinary\u201d and \u201call the more exceptional when viewed in light of the\nrisk\u201d of continued litigation. The court further commended Robbins Geller for prosecuting the\ncase on a pro bono basis: \u201cClass Counsel\u2019s exceptional decision to provide nearly seven years of legal\nservices to Class Members on a pro bono basis evidences not only a lack of collusion, but also that\nClass Counsel are in fact representing the best interests of Plaintiffs and the Class Members in this\nSettlement. Instead of seeking compensation for fees and costs that they would otherwise be\nentitled to, Class Counsel have acted to allow maximum recovery to Plaintiffs and Class Members.\nIndeed, that Eligible Class Members may receive recovery of 90% or greater is a testament to Class\nCounsel\u2019s representation and dedication to act in their clients\u2019 best interest.\u201d In addition, at the\nfinal approval hearing, the court commented that \"this is a case that has been litigated \u2013 if not\nfiercely, zealously throughout.\u201d Low v. Trump Univ., LLC, 246 F. Supp. 3d 1295, 1302, 1312 (S.D.\nCal. 2017), aff\u2019d, 881 F.3d 1111 (9th Cir. 2018); Low v. Trump University LLC and Donald J. Trump,\nNo. 10-cv-0940 GPC-WVG, and Cohen v. Donald J. Trump, No. 13-cv-2519-GPC-WVG, Transcript\nat 7 (S.D. Cal. Mar. 30, 2017).\n\nIn January 2017, at the final approval hearing, the Honorable Kevin H. Sharp of the Middle\nDistrict of Tennessee commended Robbins Geller attorneys, stating: \u201cIt was complicated, it was\ndrawn out, and a lot of work clearly went into this [case] . . . . I think there is some benefit to the\nshareholders that are above and beyond money, a benefit to the company above and beyond\nmoney that changed hands.\u201d In re Community Health Sys., Inc. S\u2019holder Derivative Litig., No.\n3:11-cv-00489, Transcript at 10 (M.D. Tenn. Jan. 17, 2017).\n\nIn November 2016, at the final approval hearing, the Honorable James G. Carr stated: \u201cI kept\nthrowing the case out, and you kept coming back. . . . And it\u2019s both remarkable and noteworthy\nand a credit to you and your firm that you did so. . . . [Y]ou persuaded the Sixth Circuit. As we\nknow, that\u2019s no mean feat at all.\u201d Judge Carr further complimented the Firm, noting that it \u201cgoes\nwithout question or even saying\u201d that Robbins Geller is very well-known nationally and that the\nsettlement is an excellent result for the class. He succinctly concluded that \u201cgiven the tenacity and\nthe time and the effort that [Robbins Geller] lawyers put into [the case]\u201d makes the class \u201ca lot\nbetter off.\u201d Plumbers & Pipefitters Nat\u2019l Pension Fund v. Burns, No. 3:05-cv-07393-JGC, Transcript at\n4, 10, 14, 17 (N.D. Ohio Nov. 18, 2016).\n\n\n Robbins Geller Rudman & Dowd LLP | 43\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 47 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn September 2016, in granting final approval of the settlement, Judge Arleo commended the\n\u201cvigorous and skilled efforts\u201d of Robbins Geller attorneys for obtaining \u201can excellent recovery.\u201d\nJudge Arleo added that the settlement was reached after \u201ccontentious, hard-fought litigation\u201d that\nended with \u201ca very, very good result for the class\u201d in a \u201crisky case.\u201d City of Sterling Heights Gen.\nEmps.\u2019 Ret. Sys. v. Prudential Fin., Inc., No. 2:12-cv-05275-MCA-LDW, Transcript of Hearing at\n18-20 (D.N.J. Sep. 28, 2016).\n\nIn August 2015, at the final approval hearing for the settlement, the Honorable Karen M.\nHumphreys praised Robbins Geller\u2019s \u201cextraordinary efforts\u201d and \u201cexcellent lawyering,\u201d noting that\nthe settlement \u201creally does signal that the best is yet to come for your clients and for your\nprodigious labor as professionals. . . . I wish more citizens in our country could have an\nappreciation of what this [settlement] truly represents.\u201d Bennett v. Sprint Nextel Corp., No.\n2:09-cv-02122-EFM-KMH, Transcript at 8, 25 (D. Kan. Aug. 12, 2015).\n\nIn August 2015, the Honorable Judge Max O. Cogburn, Jr. noted that \u201cplaintiffs\u2019 attorneys were\nable [to] achieve the big success early\u201d in the case and obtained an \u201cexcellent result.\u201d The\n\u201cextraordinary\u201d settlement was because of \u201cgood lawyers . . . doing their good work.\u201d Nieman v.\nDuke Energy Corp., No. 3:12-cv-456, Transcript at 21, 23, 30 (W.D.N.C. Aug. 12, 2015).\n\nIn July 2015, in approving the settlement, the Honorable Douglas L. Rayes of the District of\nArizona stated: \u201cSettlement of the case during pendency of appeal for more than an insignificant\namount is rare. The settlement here is substantial and provides favorable recovery for the\nsettlement class under these circumstances.\u201d He continued, noting, \u201c[a]s against the objective\nmeasures of . . . settlements [in] other similar cases, [the recovery] is on the high end.\u201d Teamsters\nLocal 617 Pension & Welfare Funds v. Apollo Grp., Inc., No. 2:06-cv-02674-DLR, Transcript at 8, 11\n(D. Ariz. July 28, 2015).\n\nIn June 2015, at the conclusion of the hearing for final approval of the settlement, the Honorable\nSusan Richard Nelson of the District of Minnesota noted that it was \u201ca pleasure to be able to\npreside over a case like this,\u201d praising Robbins Geller in achieving \u201can outstanding [result] for [its]\nclients,\u201d as she was \u201cvery impressed with the work done on th[e] case.\u201d In re St. Jude Med., Inc. Sec.\nLitig., No. 0:10-cv-00851-SRN-TNL, Transcript at 7 (D. Minn. June 12, 2015).\n\nIn May 2015, at the fairness hearing on the settlement, the Honorable William G. Young noted\nthat the case was \u201cvery well litigated\u201d by Robbins Geller attorneys, adding that \u201cI don\u2019t just say that\nas a matter of form. . . . I thank you for the vigorous litigation that I\u2019ve been permitted to be a part\nof.\u201d Courtney v. Avid Tech., Inc., No. 1:13-cv-10686-WGY, Transcript at 8-9 (D. Mass. May 12,\n2015).\n\nIn January 2015, the Honorable William J. Haynes, Jr. of the Middle District of Tennessee\ndescribed the settlement as a \u201chighly favorable result achieved for the Class\u201d through Robbins\nGeller\u2019s \u201cdiligent prosecution . . . [and] quality of legal services.\u201d The settlement represents the\nfourth-largest securities recovery ever in the Middle District of Tennessee and one of the largest in\nmore than a decade. Garden City Emps.\u2019 Ret. Sys. v. Psychiatric Sols., Inc., No. 3:09-cv-00882, 2015\nU.S. Dist. LEXIS 181943, at *6-*7 (M.D. Tenn. Jan. 16, 2015).\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 44\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 48 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn September 2014, in approving the settlement for shareholders, Vice Chancellor John W. Noble\nnoted \u201c[t]he litigation caused a substantial benefit for the class. It is unusual to see a $29 million\nrecovery.\u201d Vice Chancellor Noble characterized the litigation as \u201cnovel\u201d and \u201cnot easy,\u201d but \u201c[t]he\nlawyers took a case and made something of it.\u201d The court commended Robbins Geller\u2019s efforts in\nobtaining this result: \u201cThe standing and ability of counsel cannot be questioned\u201d and \u201cthe benefits\nachieved by plaintiffs\u2019 counsel in this case cannot be ignored.\u201d In re Gardner Denver, Inc. S\u2019holder\nLitig., No. 8505-VCN, Transcript at 26-28 (Del. Ch. Sep. 3, 2014).\n\nIn May 2014, at the conclusion of the hearing for final approval of the settlement, the Honorable\nElihu M. Berle stated: \u201cI would finally like to congratulate counsel on their efforts to resolve this\ncase, on excellent work \u2013 it was the best interest of the class \u2013 and to the exhibition of\nprofessionalism. So I do thank you for all your efforts.\u201d Liberty Mutual Overtime Cases, No. JCCP\n4234, Transcript at 20:1-5 (Cal. Super. Ct., Los Angeles Cnty. May 29, 2014).\n\nIn March 2014, Ninth Circuit Judge J. Clifford Wallace (presiding) expressed the gratitude of the\ncourt: \u201cThank you. I want to especially thank counsel for this argument. This is a very\ncomplicated case and I think we were assisted no matter how we come out by competent counsel\ncoming well prepared. . . . It was a model of the type of an exercise that we appreciate. Thank\nyou very much for your work . . . you were of service to the court.\u201d Eclectic Properties East, LLC v.\nThe Marcus & Millichap Co., No. 12-16526, Transcript (9th Cir. Mar. 14, 2014).\n\nIn February 2014, in approving a settlement, Judge Edward M. Chen noted the \u201cvery substantial\nrisks\u201d in the case and recognized Robbins Geller had performed \u201cextensive work on the case.\u201d In\nre VeriFone Holdings, Inc. Sec. Litig., No. C-07-6140, 2014 U.S. Dist. LEXIS 20044, at *5, *11-*12\n(N.D. Cal. Feb. 18, 2014).\n\nIn August 2013, in granting final approval of the settlement, the Honorable Richard J. Sullivan\nstated: \u201cLead Counsel is to be commended for this result: it expended considerable effort and\nresources over the course of the action researching, investigating, and prosecuting the claims, at\nsignificant risk to itself, and in a skillful and efficient manner, to achieve an outstanding recovery\nfor class members. Indeed, the result \u2013 and the class\u2019s embrace of it \u2013 is a testament to the\nexperience and tenacity Lead Counsel brought to bear.\u201d City of Livonia Emps. Ret. Sys. v. Wyeth, No.\n07 Civ. 10329, 2013 U.S. Dist. LEXIS 113658, at *13 (S.D.N.Y. Aug. 7, 2013).\n\nIn July 2013, in granting final approval of the settlement, the Honorable William H. Alsup stated\nthat Robbins Geller did \u201cexcellent work in this case,\u201d and continued, \u201cI look forward to seeing you\non the next case.\u201d Fraser v. Asus Comput. Int\u2019l, No. C 12-0652, Transcript at 12:2-3 (N.D. Cal. July\n11, 2013).\n\nIn June 2013, in certifying the class, U.S. District Judge James G. Carr recognized Robbins\nGeller\u2019s steadfast commitment to the class, noting that \u201cplaintiffs, with the help of Robbins Geller,\nhave twice successfully appealed this court\u2019s orders granting defendants\u2019 motion to dismiss.\u201d\nPlumbers & Pipefitters Nat\u2019l Pension Fund v. Burns, 292 F.R.D. 515, 524 (N.D. Ohio 2013).\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 45\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 49 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nIn November 2012, in granting appointment of lead plaintiff, Chief Judge James F. Holderman\ncommended Robbins Geller for its \u201csubstantial experience in securities class action litigation\u201d and\ncommented that the Firm \u201cis recognized as \u2018one of the most successful law firms in securities class\nactions, if not the preeminent one, in the country.\u2019 In re Enron Corp. Sec., 586 F. Supp. 2d 732, 797\n(S.D. Tex. 2008) (Harmon, J.).\u201d He continued further that, \u201c\u2018Robbins Geller attorneys are\nresponsible for obtaining the largest securities fraud class action recovery ever [$7.2 billion in\nEnron], as well as the largest recoveries in the Fifth, Sixth, Eighth, Tenth and Eleventh\nCircuits.\u2019\u201d Bristol Cnty. Ret. Sys. v. Allscripts Healthcare Sols., Inc., No. 12 C 3297, 2012 U.S. Dist.\nLEXIS 161441, at *21 (N.D. Ill. Nov. 9, 2012).\n\nIn June 2012, in granting plaintiffs\u2019 motion for class certification, the Honorable Inge Prytz\nJohnson noted that other courts have referred to Robbins Geller as \u201c\u2018one of the most successful law\nfirms in securities class actions . . . in the country.\u2019\u201d Local 703, I.B. v. Regions Fin. Corp., 282 F.R.D.\n607, 616 (N.D. Ala. 2012) (quoting In re Enron Corp. Sec. Litig., 586 F. Supp. 2d 732, 797 (S.D. Tex.\n2008)), aff\u2019d in part and vacated in part on other grounds, 762 F.3d 1248 (11th Cir. 2014).\n\nIn June 2012, in granting final approval of the settlement, the Honorable Barbara S. Jones\ncommented that \u201cclass counsel\u2019s representation, from the work that I saw, appeared to me to be of\nthe highest quality.\u201d In re CIT Grp. Inc. Sec. Litig., No. 08 Civ. 6613, Transcript at 9:16-18 (S.D.N.Y.\nJune 13, 2012).\n\nIn March 2012, in granting certification for the class, Judge Robert W. Sweet referenced the Enron\ncase, agreeing that Robbins Geller\u2019s \u201c\u2018clearly superlative litigating and negotiating skills\u2019\u201d give the\nFirm an \u201c\u2018outstanding reputation, experience, and success in securities litigation nationwide,\u2019\u201d thus,\n\u201c\u2018[t]he experience, ability, and reputation of the attorneys of [Robbins Geller] is not disputed; it is\none of the most successful law firms in securities class actions, if not the preeminent one, in the\ncountry.\u2019\u201d Billhofer v. Flamel Techs., S.A., 281 F.R.D. 150, 158 (S.D.N.Y. 2012).\n\nIn March 2011, in denying defendants\u2019 motion to dismiss, Judge Richard Sullivan commented:\n\u201cLet me thank you all. . . . [The motion] was well argued . . . and . . . well briefed . . . . I certainly\nappreciate having good lawyers who put the time in to be prepared . . . .\u201d Anegada Master Fund\nLtd. v. PxRE Grp. Ltd., No. 08-cv-10584, Transcript at 83 (S.D.N.Y. Mar. 16, 2011).\n\nIn January 2011, the court praised Robbins Geller attorneys: \u201cThey have gotten very good results\nfor stockholders. . . . [Robbins Geller has] such a good track record.\u201d In re Compellent Techs., Inc.\nS\u2019holder Litig., No. 6084-VCL, Transcript at 20-21 (Del. Ch. Jan. 13, 2011).\n\nIn August 2010, in reviewing the settlement papers submitted by the Firm, Judge Carlos Murguia\nstated that Robbins Geller performed \u201ca commendable job of addressing the relevant issues with\ngreat detail and in a comprehensive manner . . . . The court respects the [Firm\u2019s] experience in\nthe field of derivative [litigation].\u201d Alaska Elec. Pension Fund v. Olofson, No. 08-cv-02344-CM-JPO\n(D. Kan.) (Aug. 20, 2010 e-mail from court re: settlement papers).\n\nIn June 2009, Judge Ira Warshawsky praised the Firm\u2019s efforts in In re Aeroflex, Inc. S\u2019holder Litig.:\n\u201cThere is no doubt that the law firms involved in this matter represented in my opinion the cream\nof the crop of class action business law and mergers and acquisition litigators, and from a judicial\npoint of view it was a pleasure working with them.\u201d In re Aeroflex, Inc. S\u2019holder Litig., No.\n003943/07, Transcript at 25:14-18 (N.Y. Sup. Ct., Nassau Cnty. June 30, 2009).\n\nIn March 2009, in granting class certification, the Honorable Robert Sweet of the Southern District\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 46\n\fCase 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 50 of 159\n PROMINENT CASES, PRECEDENT-SETTING DECISIONS,\n AND JUDICIAL COMMENDATIONS\nof New York commented in In re NYSE Specialists Sec. Litig., 260 F.R.D. 55, 74 (S.D.N.Y. 2009): \u201cAs\nto the second prong, the Specialist Firms have not challenged, in this motion, the qualifications,\nexperience, or ability of counsel for Lead Plaintiff, [Robbins Geller], to conduct this litigation.\nGiven [Robbins Geller\u2019s] substantial experience in securities class action litigation and the extensive\ndiscovery already conducted in this case, this element of adequacy has also been satisfied.\u201d\n\nIn June 2008, the court commented, \u201cPlaintiffs\u2019 lead counsel in this litigation, [Robbins Geller], has\ndemonstrated its considerable expertise in shareholder litigation, diligently advocating the rights\nof Home Depot shareholders in this Litigation. [Robbins Geller] has acted with substantial skill\nand professionalism in representing the plaintiffs and the interests of Home Depot and its\nshareholders in prosecuting this case.\u201d City of Pontiac Gen. Emps.\u2019 Ret. Sys. v. Langone, No.\n2006-122302, Findings of Fact in Support of Order and Final Judgment at 2 (Ga. Super. Ct.,\nFulton Cnty. June 10, 2008).\n\nIn a December 2006 hearing on the $50 million consumer privacy class action settlement in Kehoe\nv. Fidelity Fed. Bank & Tr., No. 03-80593-CIV (S.D. Fla.), United States District Court Judge Daniel\nT.K. Hurley said the following:\n\n First, I thank counsel. As I said repeatedly on both sides, we have been very, very\n fortunate. We have had fine lawyers on both sides. The issues in the case are\n significant issues. We are talking about issues dealing with consumer protection\n and privacy. Something that is increasingly important today in our society. . . . I\n want you to know I thought long and hard about this. I am absolutely satisfied\n that the settlement is a fair and reasonable settlement. . . . I thank the lawyers on\n both sides for the extraordinary effort that has been brought to bear here . . . .\n\nKehoe v. Fidelity Fed. Bank & Tr., No. 03-80593-CIV, Transcript at 26, 28-29 (S.D. Fla. Dec. 7,\n2006).\n\nIn Stanley v. Safeskin Corp., No. 99 CV 454 (S.D. Cal.), where Robbins Geller attorneys obtained\n$55 million for the class of investors, Judge Moskowitz stated:\n\n I said this once before, and I\u2019ll say it again. I thought the way that your firm\n handled this case was outstanding. This was not an easy case. It was a complicated\n case, and every step of the way, I thought they did a very professional job.\n\nStanley v. Safeskin Corp., No. 99 CV 454, Transcript at 13 (S.D. Cal. May 25, 2004).\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 47\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 51 of 159\n\n\n\nATTORNEY BIOGRAPHIES\nMario Alba Jr. | Partner\nMario Alba is a partner in the Firm\u2019s Melville office. He is a member of the Firm\u2019s Institutional Outreach\nTeam, which provides advice to the Firm\u2019s institutional clients, including numerous public pension\nsystems and Taft-Hartley funds throughout the United States, and consults with them on issues relating to\ncorporate fraud in the U.S. securities markets, as well as corporate governance issues and shareholder\nlitigation. Some of Alba\u2019s institutional clients are currently involved in securities cases involving Avalara,\nInc., Clarivate plc, Dentsply Sirona Inc., Generac Holdings Inc., Globe Life Inc., Amgen, Inc., Virtu\nFinancial, Inc., The Walt Disney Company, The Boeing Company, Merck & Co., Inc., Daimler, Novo\nNordisk, and National Instruments Corporation.\n\nAlba\u2019s institutional clients are/were also involved in other types of class actions, namely, In re National\nPrescription Opiate Litigation (over $50 billion paid to communities across the country), In re Epipen\n(Epinephrine Injection, USP) Marketing, Sales Practices and Antitrust Litigation ($609 million total recovery),\nForth v. Walgreen Co. ($100 million recovery), and In re Humira (Adalimumab) Antitrust Litigation.\n\nAlba has served as lead counsel in numerous cases and is responsible for initiating, investigating,\nresearching, and filing securities and consumer fraud class actions. He has recovered hundreds of millions\nof dollars in numerous actions, including cases against Acadia Healthcare Company, Inc. ($179 million\nrecovery); BHP Billiton Limited ($50 million recovery), Equinix, Inc. ($41.5 million recovery), Green Dot\nCorporation ($40 million recovery), BRF S.A. ($40 million recovery), L3 Technologies, Inc. ($34.5 million\nrecovery), Impax Laboratories Inc. ($33 million recovery), Waste Management, Inc. ($30 million\nrecovery), Reckitt Benckiser Group plc ($19.6 million recovery), Super Micro Computer, Inc. ($18.25\nmillion recovery), and NBTY, Inc. ($16 million recovery).\n\n\nEducation\nB.S., St. John\u2019s University, 1999; J.D., Hofstra University School of Law, 2002\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2022-2025; Leading Plaintiff Financial Lawyer, Lawdragon,\n2024-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024; Rising Star, Super Lawyers\nMagazine, 2012-2013, 2016-2017; B.S., Dean\u2019s List, St. John\u2019s University, 1999; Selected as participant in\nHofstra Moot Court Seminar, Hofstra University School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 48\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 52 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMichael Albert | Partner\nMichael Albert is a partner in the Firm\u2019s San Diego office, where his practice focuses on complex securities\nlitigation. Albert is a member of the Firm\u2019s Lead Plaintiff Advisory Team, which advises institutional\ninvestors in connection with lead plaintiff motions, and assists them in securing appointment as lead\nplaintiff.\n\nAlbert has been a member of litigation teams that have successfully recovered hundreds of millions of\ndollars for investors in securities class actions, including: In re Alphabet, Inc. Securities Litigation ($350\nmillion recovery), NECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co. ($272 million recovery), City\nof Pontiac General Employees\u2019 Retirement Systems v. Wal-Mart Stores, Inc. ($160 million recovery), and In re\nLendingClub Securities Litigation ($125 million recovery). Albert was also a member of the litigation team\nthat obtained a $85 million cash settlement in a consumer class action against Scotts Miracle-Gro.\n\n\nEducation\nB.A., University of Wisconsin-Madison, 2010; J.D., University of Virginia School of Law, 2014\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; Best Lawyer in America, Best Lawyers\u00ae, 2025-2026;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2024-2025; Impact Case Award: In re Alphabet, Inc.\nSecurities Litigation, Benchmark Litigation, 2025; 500 X \u2013 The Next Generation, Lawdragon, 2023-2024;\nRising Star, Super Lawyers Magazine, 2020-2024; Managing Board Member, Virginia Tax Review, University\nof Virginia School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 49\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 53 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMatthew I. Alpert | Partner\nMatthew Alpert is a partner in the Firm\u2019s San Diego office and focuses on the prosecution of securities\nfraud litigation. Most recently, Alpert and a team of Robbins Geller attorneys obtained a $434 million\nsettlement in In re Under Armour Sec. Litig. (D. Md.) after nearly seven years of hard-fought litigation and\nless than a month before a jury trial in Baltimore was scheduled to commence. Alpert was also a member\nof the litigation team that successfully obtained class certification in a securities fraud class action against\nRegions Financial, a class certification decision that was substantively affirmed by the United States Court\nof Appeals for the Eleventh Circuit in Loc. 703, I.B. of T. Grocery & Food Emps. Welfare Fund v. Regions Fin.\nCorp., 762 F.3d 1248 (11th Cir. 2014). Upon remand, the United States District Court for the Northern\nDistrict of Alabama granted class certification again, rejecting defendants\u2019 post-Halliburton II arguments\nconcerning stock price impact. Alpert and the Robbins Geller team litigated the case until it eventually\nsettled for $90 million.\n\nSome of Alpert\u2019s previous cases include: the individual opt-out actions of the AOL Time Warner class\naction \u2013 Regents of the Univ. of Cal. v. Parsons (Cal. Super. Ct., Los Angeles Cnty.) and Ohio Pub. Emps. Ret.\nSys. v. Parsons (Ohio. Ct. of Common Pleas, Franklin Cnty.) (total settlement over $600 million); In re\nUnder Armour Sec. Litig. (D. Md.); ($434 million settlement); Loc. 703, I.B. of T. Grocery & Food Emps.\nWelfare Fund v. Regions Fin. Corp. (N.D. Ala.) ($90 million settlement); In re MGM Mirage Sec. Litig. (D.\nNev.) ($75 million); In re CIT Grp. Inc. Sec. Litig. (S.D.N.Y.) ($75 million settlement); Luna v. Marvell Tech.\nGrp., Ltd. (N.D. Cal.) ($72.5 million settlement); Deka Inv. GmbH v. Santander Consumer USA Holdings Inc.\n(N.D. Tex.) ($47 million settlement); In re Bridgestone Sec. Litig. (M.D. Tenn.) ($30 million settlement); In re\nWalter Energy, Inc. Sec. Litig. (N.D. Ala.) ($25 million); City of Hialeah Emps.\u2019 Ret. Sys. & Laborers Pension\nTr. Fund for N. Cal. v. Toll Bros., Inc. (E.D. Pa.) ($25 million settlement); In re Molycorp, Inc. Sec. Litig. (D.\nColo.) ($20.5 million settlement); In re Banc of Cal. Sec. Litig. (C.D. Cal.) ($19.75 million); Zimmerman v.\nDiplomat Pharmacy, Inc. (E.D. Mich.) ($14.1 million); Batwin v. Occam Networks, Inc. (C.D. Cal.) ($13.9\nmillion settlement); Int\u2019l Bhd. of Elec. Workers Loc. 697 Pension Fund v. Int\u2019l Game Tech. (D. Nev.) ($12.5\nmillion settlement); Kmiec v. Powerwave Techs. Inc. (C.D. Cal.) ($8.2 million); In re Sunterra Corp. Sec.\nLitig. (D. Nev.) ($8 million settlement); and Luman v. Anderson (W.D. Mo.) ($4.25 million settlement).\n\n\nEducation\nB.A., University of Wisconsin at Madison, 2001; J.D., Washington University, St. Louis, 2005\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015-2019\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 50\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 54 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDarryl J. Alvarado | Partner\nDarryl Alvarado is a partner in the Firm\u2019s San Diego office. He focuses his practice on securities fraud\nand other complex civil litigation. Alvarado was a member of the trial team in Smilovits v. First Solar, Inc.,\nwhich recovered $350 million for aggrieved investors. The First Solar settlement, reached on the eve of\ntrial after more than seven years of litigation and an interlocutory appeal to the U.S. Supreme Court, is\nthe fifth-largest PSLRA recovery ever obtained in the Ninth Circuit. Alvarado recently litigated Monroe\nCounty Employees\u2019 Retirement System v. The Southern Company, which recovered $87.5 million for investors\nafter more than three years of litigation. The settlement resolved securities fraud claims stemming from\ndefendants\u2019 issuance of misleading statements and omissions regarding the construction of a first-of-its-\nkind \u201cclean coal\u201d power plant in Kemper County, Mississippi. Alvarado helped secure $388 million for\ninvestors in J.P. Morgan residential mortgage-backed securities in Fort Worth Employees\u2019 Retirement Fund v.\nJ.P. Morgan Chase & Co. That settlement is, on a percentage basis, the largest recovery ever achieved in an\nRMBS class action. He was also a member of a team of attorneys that secured $95 million for investors in\nMorgan Stanley-issued RMBS in In re Morgan Stanley Mortgage Pass-Through Certificates Litigation.\n\nAlvarado was a member of a team of lawyers that obtained landmark settlements, on the eve of trial, from\nthe major credit rating agencies and Morgan Stanley arising out of the fraudulent ratings of bonds issued\nby the Cheyne and Rhinebridge structured investment vehicles in Abu Dhabi Commercial Bank v. Morgan\nStanley & Co. Incorporated and King County, Washington v. IKB Deutsche Industriebank AG. He was integral in\nobtaining several precedent-setting decisions in those cases, including defeating the rating agencies\u2019\nhistoric First Amendment defense and defeating the ratings agencies\u2019 motions for summary judgment\nconcerning the actionability of credit ratings. Alvarado was also a member of a team of attorneys\nresponsible for obtaining for aggrieved investors $27 million in In re Cooper Companies Securities Litigation,\n$19.5 million in City of Pontiac General Employees\u2019 Retirement System v. Lockheed Martin Corporation, and\ncomprehensive corporate governance reforms to address widespread off-label marketing and product\nsafety violations in In re Johnson & Johnson Derivative Litigation.\n\n\nEducation\nB.A., University of California, Santa Barbara, 2004; J.D., University of San Diego School of Law, 2007\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2023-2025; Future Star, Benchmark Litigation, 2024;\nRising Star, Super Lawyers Magazine, 2015-2022; 40 & Under Hot List, Benchmark Litigation, 2018-2021;\nTop 40 Under 40, Daily Journal, 2021; \u201cOutstanding Young Attorneys,\u201d San Diego Daily Transcript, 2011\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 51\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 55 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMathew Andrews | Partner\nMathew Andrews is a partner in the Firm\u2019s Manhattan office and focuses his practice on complex\nsecurities litigation. He has unique experience representing both plaintiffs and defendants in securities\nfraud cases. Before joining the Firm in January 2026, Andrews served as an Assistant United States\nAttorney in the U.S. Attorney\u2019s Office for the Southern District of New York for over seven years.\n\nAs an Assistant U.S. Attorney, Andrews represented the United States in criminal cases of securities fraud,\npublic corruption, money laundering, tax evasion, violations of the Bank Secrecy Act, racketeering, and\nmurder. Andrews headed the prosecution team in United States v. Gulkarov et al., which charged over 70\ndefendants with participating in one of the largest healthcare fraud, money laundering, and bribery\nschemes in New York history. He also led prosecutions and investigations of fintech companies, privately\nheld banks, and AI and crypto companies.\n\nAndrews successfully tried seven cases to verdict, including two convictions of high-ranking DEA Special\nAgents for bribery, three convictions for murder, and multiple convictions for fraud and money\nlaundering. He also successfully litigated over a dozen cases before the U.S. Court of Appeals for the\nSecond Circuit, including the habeus appeal of Dimitry Aronshtein, who co-led one of the largest bribery\nschemes in New York City history.\n\nEarlier in his career, Andrews defended individuals in securities fraud cases and investigations as an\nassociate at Morvillo Abramowitz Grand Iason & Anello P.C. He completed clerkships with the\nHonorable Jed Rakoff of the U.S. District Court for the Southern District of New York and the Honorable\nRobert Katzmann, then-Chief Judge of the U.S. Court of Appeals for the Second Circuit.\n\n\nEducation\nB.A., Yale University, 2011; J.D., Yale Law School, 2014\n\nHonors / Awards\nFederal Law Enforcement Foundation Prosecutor of the Year, 2024; B.A., Summa Cum Laude, Yale\nUniversity, 2011\n\n\n\nDory P. Antullis | Partner\nDory Antullis is a partner in the Firm\u2019s Boca Raton office. Her litigation practice focuses on complex class\nactions, covering consumer fraud, public nuisance, environmental litigation, privacy litigation,\npharmaceuticals, RICO, and antitrust litigation. Antullis also works with the Firm\u2019s settlement\ndepartment, negotiating and documenting intricate, high-stakes settlements.\n\nAntullis is a core member of the Firm\u2019s opioids team, leading the effort on behalf of cities, counties, and\nthird-party payors around the country in In re Nat\u2019l Prescription Opiate Litig., No. 1:17-md-02804 (N.D.\nOhio). In addition to serving on several committees in the MDL, she was a member of the winning trial\nteam on behalf of the People of the State of California in San Francisco\u2019s bellwether case against Allergan,\nTeva, Walgreens, and others in the prescription opioid supply chain. Together with a trial win against\nWalgreens, the case has resulted in settlements valued at over $350 million. Antullis was also part of a\nsmall group of lawyers who negotiated and drafted settlement documents for the national opioid\nsettlements with major distributors, manufacturers, and pharmacies \u2013 now totaling more than $50 billion.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 52\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 56 of 159\n ATTORNEY BIOGRAPHIES\n\nAntullis has also been an integral part of Robbins Geller\u2019s history of successful privacy and data breach\nclass action cases. She is currently serving as Co-Lead Class Counsel in In re Luxottica of America, Inc. Data\nBreach Litig., No. 1:20-cv-00908-MRB (S.D. Ohio), and served as Liaison Counsel in DeSue v. 20/20 Eye\nCare Network, Inc., No. 21-cv-61275-RAR (S.D. Fla.) ($3 million class settlement). Antullis\u2019s heavy lifting at\nevery stage of the litigation in In re Yahoo! Inc. Customer Data Sec. Breach Litig., No. 5:16-md-02752-LHK\n(N.D. Cal.), helped to secure a $117.5 million recovery in the largest data breach in history. Antullis\nsuccessfully defeated two rounds of dispositive briefing, worked with leadership and computer privacy\nand damages experts to plan a winning strategy for the case, and drafted an innovative motion for class\ncertification that immediately preceded a successful mediation with defendants in that litigation. Antullis\nalso provided meaningful \u201cnuts-and-bolts\u201d support in other data breach class actions, including In re Am.\nMed. Collection Agency, Inc., Customer Data Sec. Breach Litig., No. 2:19-md-02904-MCA-MAH (D.N.J.)\n(representing class of LabCorp customers), and In re Solara Med. Supplies Customer Data Breach Litig., No.\n3:19-cv-02284-H-KSC (S.D. Cal.) ($5.06 million settlement). And she currently represents consumers in\nstate and federal court against North Broward Hospital District for a 2021 data breach.\n\nAntullis\u2019s other current and recent cases include: In re McKinsey & Co., Inc. Nat\u2019l Prescription Opiate\nConsultant Litig., No. 3:21-md-02996-CRB (N.D. Cal.) (representing governmental subdivisions); In re\nAllergan Biocell Textured Breast Implant Prod. Liab. Litig., No. 2:19-md-02921-BRM-ESK (D.N.J.) (court-\nappointed member of the Plaintiffs\u2019 Steering Committee); Zimmerman v. The 3M Co., No.\n1:17-cv-01062-HYJ-SJB (W.D. Mich.) (court-appointed member of the Plaintiffs\u2019 Steering Committee; $54\nmillion settlement on behalf of class of Michigan homeowners whose property was allegedly contaminated\nwith PFAS); In re Aqueous Film-Forming Foams Prods. Liab. Litig., No. 2:18-mn-02873-RMG (D.S.C.)\n(representing water and wastewater utility providers against AFFF manufacturers); In re Zantac\n(Ranitidine) Prods. Liab. Litig., No. 9:20-md-02924-RLR (S.D. Fla.) (representing consumers and third-\nparty payors); In re Apple Inc. Device Performance Litig., No. 5:18-md-02827-EJD (N.D. Cal.) ($500 million\nsettlement on behalf of consumers who purchased certain model iPhones); In re Liquid Aluminum Sulfate\nAntitrust Litig., No. 2:16-md-02687-MCA-MAH (D.N.J.) (direct purchaser class settled in excess of $100\nmillion); Gardner v. StarKist Co., 418 F. Supp. 3d 443 (N.D. Cal. 2019); In re FieldTurf Artificial Turf Mktg.\n& Sales Pracs. Litig., No. 3:17-md-02779-MAS-JTB (D.N.J.); In re NHL Players\u2019 Concussion Injury Litig., 2015\nU.S. Dist. LEXIS 38755 (D. Minn. Mar. 25, 2015); Friedman v. AARP Inc., No. 2:14-cv-00034-DDP-PLA\n(C.D. Cal.); In re Ford Fusion & C-Max Fuel Econ. Litig., No. 7:13-md-02450-KMK (S.D.N.Y.); Looper v. FCA\nUS LLC, No. 5:14-cv-00700-VAP-DTB (C.D. Cal.); and In re Aluminum Warehousing Antitrust Litig., 95 F.\nSupp. 3d 419 (S.D.N.Y. 2015), aff\u2019d, 833 F.3d 151 (2d Cir. 2016).\n\n\nEducation\nB.A., Rice University, 1999; J.D., Columbia Law School, 2003\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2026; Leading Litigator in America, Lawdragon, 2024-2026;\nRecommended Lawyer, The Legal 500, 2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2024-2025; Leading Plaintiff Consumer Lawyer, Lawdragon, 2022-2025; National\nMerit Scholar, Rice University; Golden Key National Honor Society, Rice University; Nominated for The\nRice Undergraduate academic journal, Rice University; Michael I. Sovern Scholar, Columbia Law\nSchool; Hague Appeal for Peace, Committee for a Just and Effective Response to 9/11, Columbia Law\nSchool; Columbia Mediation and Political Asylum Clinics, Columbia Law School; Harlem Tutorial\nProgram, Columbia Law School; Journal of Eastern European Law, Columbia Law School; Columbia Law\nWomen\u2019s Association, Columbia Law School\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 53\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 57 of 159\n ATTORNEY BIOGRAPHIES\n\n\nStephen R. Astley | Partner\nStephen Astley is a partner in the Firm\u2019s Boca Raton office. Astley devotes his practice to representing\ninstitutional and individual shareholders in their pursuit to recover investment losses caused by fraud.\nHe has been lead counsel in numerous securities fraud class actions across the country, helping secure\nsignificant recoveries for his clients and investors.\n\nMost recently, Astley obtained a $434 million settlement in In re Under Armour Sec. Litig. The case settled\njust prior to the commencement of trial in Baltimore, Maryland, and represents the second largest\nsecurities fraud settlement ever in the Fourth Circuit and is among the top 50 largest such recoveries in\nU.S. history. Other notable settlements include: In re Nutanix Inc. Sec. Litig. (N.D. Cal.) ($71 million\nsettlement); City of Sterling Heights Gen. Emps.\u2019 Ret. Sys. v. Hospira, Inc. (N.D. Ill.) ($60 million\nsettlement); In re ADT Inc. S\u2019holder Litig. (Fla. Cir. Ct., 15th Jud. Cir.) ($30 million settlement); In re Red\nHat, Inc. Sec. Litig. (E.D.N.C.) ($20 million settlement); Eshe Fund v. Fifth Third Bancorp (S.D. Ohio) ($16\nmillion); City of St. Clair Shores Gen. Emps.\u2019 Ret. Sys. v. Lender Processing Servs., Inc. (M.D. Fla.) ($14 million);\nand In re Synovus Fin. Corp. (N.D. Ga.) ($11.75 million).\n\nPrior to joining the Firm, Astley was with the Miami office of Hunton & Williams, where he concentrated\nhis practice on class action defense, including securities class actions and white collar criminal defense.\nAdditionally, he represented numerous corporate clients accused of engaging in unfair and deceptive\npractices. Astley was also an active duty member of the United States Navy\u2019s Judge Advocate General\u2019s\nCorps where he was the Senior Defense Counsel for the Naval Legal Service Office Pearl Harbor\nDetachment. In that capacity, Astley oversaw trial operations for the Detachment and gained substantial\nfirst-chair trial experience as the lead defense counsel in over 75 courts-martial and administrative\nproceedings. Additionally, from 2002-2003, Astley clerked for the Honorable Peter T. Fay, U.S. Court of\nAppeals for the Eleventh Circuit.\n\n\nEducation\nB.S., Florida State University, 1992; M. Acc., University of Hawaii at Manoa, 2001; J.D., University of\nMiami School of Law, 1997\n\nHonors / Awards\nJ.D., Cum Laude, University of Miami School of Law, 1997; United States Navy Judge Advocate General\u2019s\nCorps., Lieutenant\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 54\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 58 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAelish M. Baig | Partner\nAelish Marie Baig is a partner in the Firm\u2019s San Francisco office and specializes in consumer and securities\nfraud actions. Baig has litigated a number of cases through jury trial, resulting in multi-million and\nbillion dollar awards and settlements for her clients.\n\nBaig was one of the originators of the national opioid litigation, filing among the earliest complaints\nagainst the opioid industry defendants and working on all aspects of that litigation. In 2022, Baig served\nas co-trial counsel in a federal bench trial in San Francisco in a case selected as a bellwether in the national\nmulti-district opioid litigation. The team achieved combined settlements of over $350 million for San\nFrancisco and contributed to securing more than $50 billion for local governments nationwide to be used\nfor abatement of the national opioid epidemic. For her work in co-leading the trial team and securing a\nhistoric trial result against Walgreens for the City and County of San Francisco, she was honored\nby The National Law Journal as one of the \u201cElite Women of the Plaintiffs Bar\u201d and she received \u201cCalifornia\nLawyer Attorney of the Year\u201d by the Daily Journal.\n\nBaig was also appointed to leadership in the Juul ($1.7 billion settlement) and McKinsey ($230 million\nsettlement) MDL litigations. She was recently appointed to the Plaintiffs\u2019 Steering Committee of the\nnational social media litigation MDL against the country\u2019s largest social media platforms (Meta, YouTube,\nSnapchat, and Tiktok) for fueling addiction and other mental health issues among youth. She represents\nnumerous local and state governments and school districts across the country that have filed federal cases\nagainst opioids, McKinsey, Juul, and/or social media defendants. Baig has also prosecuted securities\nfraud and derivative actions obtaining millions of dollars in recoveries against corporations such as Wells\nFargo, Celera, Pall, and Prudential.\n\n\nEducation\nB.A., Brown University, 1992; J.D., Washington College of Law at American University, 1998\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2020-2026; Best Lawyer in America, Best Lawyers\u00ae, 2024-2026;\nRecommended Lawyer, The Legal 500, 2023-2025; Ranked by Chambers USA, 2024-2025; Leading Plaintiff\nFinancial Lawyer, Lawdragon, 2019-2025; Leading Plaintiff Consumer Lawyer, Lawdragon, 2022-2025;\nLeading Commercial Litigator, Daily Journal, 2024; Class Action/Mass Tort Litigation Trailblazer, The\nNational Law Journal, 2023; Elite Women of the Plaintiffs Bar, Elite Trial Lawyers, The National Law\nJournal, 2023; Plaintiffs\u2019 Lawyers Trailblazer, The National Law Journal, 2021, 2023; California Lawyer\nAttorney of the Year (CLAY), Daily Journal, 2023; Best Lawyer in America: One to Watch, Best Lawyers\u00ae,\n2021-2023; Best Lawyer in Northern California: One to Watch, Best Lawyers\u00ae, 2021; Featured in \u201cLawyer\nLimelight\u201d series, Lawdragon, 2020; Litigation Trailblazer, The National Law Journal, 2019; California\nTrailblazer, The Recorder, 2019; Super Lawyer, Super Lawyers Magazine, 2012-2013; J.D., Cum Laude,\nWashington College of Law at American University, 1998; Senior Editor, Administrative Law Review,\nWashington College of Law at American University\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 55\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 59 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRandall J. Baron | Partner\nRandy Baron is a partner in the Firm\u2019s San Diego office. He specializes in securities litigation, corporate\ntakeover litigation, and breach of fiduciary duty actions. For almost two decades, Baron has headed up a\nteam of lawyers whose accomplishments include obtaining instrumental rulings both at injunction and\ntrial phases, and establishing liability of financial advisors and investment banks. With an in-depth\nunderstanding of merger and acquisition and breach of fiduciary duty law, an ability to work under\nextreme time pressures, and the experience and willingness to take a case through trial, he has been\nresponsible for recovering more than a billion dollars for shareholders.\n\nNotable achievements over the years include: In re Kinder Morgan, Inc. S\u2019holders Litig. (Kan. Dist. Ct.,\nShawnee Cnty.), where Baron obtained an unprecedented $200 million common fund for former Kinder\nMorgan shareholders, the largest merger & acquisition class action recovery in history; In re Dole Food Co.,\nInc. S\u2019holder Litig. (Del. Ch.), where he went to trial in the Delaware Court of Chancery on claims of breach\nof fiduciary duty on behalf of Dole Food Co., Inc. shareholders and obtained $148 million, the largest\ntrial verdict ever in a class action challenging a merger transaction; and In re Rural/Metro Corp. S\u2019holders\nLitig. (Del. Ch.), where Baron and co-counsel obtained nearly $110 million total recovery for shareholders\nagainst Royal Bank of Canada Capital Markets LLC. In In re Del Monte Foods Co. S\u2019holders Litig. (Del. Ch.),\nhe exposed the unseemly practice by investment bankers of participating on both sides of large merger\nand acquisition transactions and ultimately secured an $89 million settlement for shareholders of Del\nMonte. Baron was one of the lead attorneys representing about 75 public and private institutional\ninvestors that filed and settled individual actions in In re WorldCom Sec. Litig. (S.D.N.Y.), where more than\n$657 million was recovered, the largest opt-out (non-class) securities action in history. Most recently,\nBaron successfully obtained a partial settlement of $60 million in In re Tesla Motors, Inc. S\u2019holder Litig., a\ncase that alleged that the members of the Tesla Board of Directors breached their fiduciary duties,\nunjustly enriched themselves, and wasted corporate assets in connection with their approval of Tesla\u2019s\nacquisition of SolarCity Corp. in 2016.\n\n\nEducation\nB.A., University of Colorado at Boulder, 1987; J.D., University of San Diego School of Law, 1990\n\nHonors / Awards\nFellow, Advisory Board, Litigation Counsel of America (LCA); Rated Distinguished by Martindale-\nHubbell; Litigation Star, Benchmark Litigation, 2016-2019, 2023-2026; National Practice Area\nStar, Benchmark Litigation, 2019-2020, 2024, 2026; Lawyer of the Year: Litigation \u2013 Mergers and\nAcquisitions, San Diego, Best Lawyers\u00ae, 2026; Best Lawyer in America, Best Lawyers\u00ae, 2019-2026; Hall of\nFame, The Legal 500, 2020-2025; Ranked by Chambers USA, 2016-2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; California - Litigation Star, Benchmark Litigation, 2024; Lawyer of the\nYear: Derivatives and Futures Law, Best Lawyers\u00ae, 2023; Plaintiffs\u2019 Lawyer Trailblazer, The National Law\nJournal, 2022; Leading Lawyer in America, Lawdragon, 2011, 2017-2019, 2021-2022; Southern California\nBest Lawyer, Best Lawyers\u00ae, 2019-2021; Super Lawyer, Super Lawyers Magazine, 2014-2016, 2018-2020;\nLocal Litigation Star, Benchmark Litigation, 2018, 2020; Leading Lawyer, The Legal 500, 2014-2019;\nCalifornia Star, Benchmark Litigation, 2019; State Litigation Star, Benchmark Litigation, 2019; Winning\nLitigator, The National Law Journal, 2018; Titan of the Industry, The American Lawyer, 2018;\nRecommended Lawyer, The Legal 500, 2017; Mergers & Acquisitions Trailblazer, The National Law Journal,\n2015-2016; Litigator of the Week, The American Lawyer, October 16, 2014; Attorney of the Year, California\nLawyer, 2012; Litigator of the Week, The American Lawyer, October 7, 2011; J.D., Cum Laude, University of\nSan Diego School of Law, 1990\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 56\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 60 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJames E. Barz | Partner\nJim Barz is a partner with the Firm and manages the Firm\u2019s Chicago office. Barz is an experienced trial\nlawyer who has been lead counsel in dozens of evidentiary and contested hearings, tried 18 cases to\nverdict, and argued 9 cases in the Seventh Circuit. Barz is a registered CPA, former federal prosecutor,\nand an adjunct professor at Northwestern University School of Law from 2008 to 2025, teaching courses\non trial advocacy and class action litigation.\n\nBarz has represented investors in securities fraud class actions that have resulted in recoveries of over $2\nbillion. Barz was the lead counsel in In re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., and secured a $1.21 billion\nrecovery for investors, a case that Vanity Fair reported as \u201cthe corporate scandal of its era.\u201d This is the\nlargest securities class action settlement against a pharmaceutical manufacturer and the ninth largest\nsecurities class action settlement ever. Barz was recognized as a Litigator of the Week by The American\nLawyer for his work in the case.\n\nBarz has also secured substantial recoveries for investors in HCA ($215 million, M.D.\nTenn.); Motorola ($200 million, N.D. Ill.); Exelon ($173 million, N.D. Ill.); Sprint ($131 million, D.\nKan.); Orbital ATK ($108 million, E.D. Va.); Walgreens ($105 million, N.D. Ill.); Nutanix ($71 million, N.D.\nCal.); Psychiatric Solutions ($65 million, M.D. Tenn.); Dana ($64 million, Ohio); Oak Street ($60 million, N.D.\nIll.); Hospira ($60 million, N.D. Ill.); and other matters. Jim was honored by the Judges of the United\nStates District Court for the Northern District of Illinois with an Award for Excellence in Pro Bono Service\nin 2021.\n\n\nEducation\nB.B.A., Loyola University Chicago, School of Business Administration, 1995; J.D., Northwestern\nUniversity School of Law, 1998\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2018-2026; Leading Lawyer in America, Lawdragon, 2025-2026;\nLitigation Star, Benchmark Litigation, 2025-2026; Leading Plaintiff Financial Lawyer, Lawdragon,\n2019-2025; Recommended Lawyer, The Legal 500, 2024; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2023; Midwest Trailblazer, The American Lawyer, 2022; Award for Excellence in Pro Bono\nService, United States District Court for the Northern District of Illinois, 2021; Litigator of the Week, The\nAmerican Lawyer, 2021; Leading Lawyer, Law Bulletin Media, 2018; B.B.A., Summa Cum Laude, Loyola\nUniversity Chicago, School of Business Administration, 1995; J.D., Cum Laude, Northwestern University\nSchool of Law, 1998\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 57\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 61 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLea Malani Bays | Partner\nLea Malani Bays is a partner in the Firm\u2019s San Diego office. She focuses on e-discovery issues, from\npreservation through production, and provides counsel to the Firm\u2019s multi-disciplinary e-discovery team\nconsisting of attorneys, forensic analysts, and database professionals. Through her role as counsel to the e-\ndiscovery team, Bays is very familiar with the various stages of e-discovery, including identification of\nrelevant electronically stored information, data culling, predictive coding protocols, privilege, and\nresponsiveness reviews, as well as having experience in post-production discovery through trial\npreparation. Through speaking at various events, she is also a leader in shaping the broader dialogue on\ne-discovery issues.\n\nBays was recently part of the litigation team that earned the approval of a $131 million settlement in favor\nof plaintiffs in Bennett v. Sprint Nextel Corp. The settlement, which resolved claims arising from Sprint\nCorporation\u2019s ill-fated merger with Nextel Communications in 2005, represents a significant recovery for\nthe plaintiff class, achieved after five years of tireless effort by the Firm. Prior to joining Robbins Geller,\nBays was a Litigation Associate at Kaye Scholer LLP\u2019s New York office. She has experience in a wide\nrange of litigation, including complex securities litigation, commercial contract disputes, business torts,\nantitrust, civil fraud, and trust and estate litigation.\n\n\nEducation\nB.A., University of California, Santa Cruz, 1997; J.D., New York Law School, 2007\n\nHonors / Awards\nLaw360 Distinguished Legal Writing Award, The Burton Awards Program, 2025; Ranked by Chambers USA,\n2019-2022; J.D., Magna Cum Laude, New York Law School, 2007; Executive Editor, New York Law School\nLaw Review; Legal Aid Society\u2019s Pro Bono Publico Award; NYSBA Empire State Counsel; Professor\nStephen J. Ellmann Clinical Legal Education Prize; John Marshall Harlan Scholars Program, Justice\nAction Center\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 58\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 62 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAlexandra S. Bernay | Partner\nAlexandra Bernay is a partner in the Firm\u2019s San Diego office, where she specializes in antitrust and unfair\ncompetition class-action litigation. She has also worked on some of the Firm\u2019s largest securities fraud class\nactions, including the Enron litigation, which recovered an unprecedented $7.2 billion for investors.\n\nBernay currently serves as co-lead counsel in In re Payment Card Interchange Fee and Merchant Discount\nAntitrust Litig., in which a settlement of $5.5 billion was upheld by the Second Circuit Court of Appeals.\nThis case was brought on behalf of millions of U.S. merchants against Visa and MasterCard and various\ncard-issuing banks, challenging the way these companies set and collect tens of billions of dollars annually\nin merchant fees. The settlement is believed to be the largest antitrust class action settlement of all time.\n\nAdditionally, Bernay is litigating In re American Airlines/JetBlue Antitrust Litig., a large antitrust case pending\nin the Eastern District of New York. That case is brought on behalf of airline passengers who overpaid for\ntickets because of alleged anticompetitive conduct between American Airlines and JetBlue. She is also\npart of the litigation team in a nationwide class action against LiveNation on behalf of concert ticket\nbuyers. Other representative cases include In re Remicade Antitrust Litig., a large case that settled for $25\nmillion involving anticompetitive conduct in the biosimilars market, where the Firm was sole lead counsel\nfor the end-payor plaintiffs, and In re Dealer Mgmt. Sys. Antitrust Litig., which involves anticompetitive\nconduct related to dealer management systems on behalf of auto dealerships across the country. Another\nrepresentative case is against Lloyd\u2019s of London. That action is a massive civil RICO case against the\ninsurance company and its syndicates.\n\nBernay has also had experience in large consumer class actions, including In re Checking Account Overdraft\nLitig., which case was brought on behalf of bank customers who were overcharged for debit card\ntransactions and resulted in more than $500 million in settlements with major banks that manipulated\ncustomers\u2019 debit transactions to maximize overdraft fees. She also helped try to verdict a case against one\nof the world\u2019s largest companies who was sued on behalf of consumers. Her more recent trial experience\nincludes a jury trial related to foreign exchange trading against one of the largest banks in the world,\nwhere the jury found that plaintiffs had proved a conspiracy as to a large network of banks. She was\nresponsible for many of the successful trial motions in the case.\n\n\nEducation\nB.A., Humboldt State University, 1997; J.D., University of San Diego School of Law, 2000\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2023-2025; Leading Plaintiff Financial Lawyer, Lawdragon,\n2019-2024; Outstanding Antitrust Litigation Achievement in Private Law Practice, American Antitrust\nInstitute, 2023; Distinguished Alumni, Forever Humboldt Alumni Association, 2023; Litigator of the\nWeek, Global Competition Review, October 1, 2014\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 59\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 63 of 159\n ATTORNEY BIOGRAPHIES\n\n\nKenneth J. Black | Partner\nKenneth Black is a partner in the Firm\u2019s San Francisco office, where his practice focuses on complex\nsecurities litigation and shareholder derivative litigation. Before joining the Firm, Black was a Sanctions\nInvestigator at the Office of Foreign Assets Control, U.S. Treasury Department, where he investigated\nand assembled the evidentiary cases against targets of U.S. financial sanctions, and tracked the finances\nand assets of those targets.\n\n\nEducation\nB.A., University of Michigan, 2004; M.A., American University, 2007; J.D., University of Michigan Law\nSchool, 2013\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; 500 X \u2013 The Next Generation, Lawdragon,\n2023-2025; Comments Editor, Michigan Journal of Private Equity & Venture Capital Law, University of\nMichigan Law School\n\n\n\nErin W. Boardman | Partner\nErin Boardman is a partner in the Firm\u2019s Melville office, where her practice focuses on representing\nindividual and institutional investors in class actions brought pursuant to the federal securities laws. She\nhas been involved in the prosecution of numerous securities class actions that have resulted in millions of\ndollars in recoveries for defrauded investors, including: Medoff v. CVS Caremark Corp. (D.R.I.) ($48 million\nrecovery); Construction Laborers Pension Tr. of Greater St. Louis v. Autoliv Inc. (S.D.N.Y.) ($22.5 million\nrecovery); In re Gildan Activewear Inc. Sec. Litig. (S.D.N.Y.) (resolved as part of a $22.5 million global\nsettlement); In re L.G. Phillips LCD Co., Ltd., Sec. Litig. (S.D.N.Y.) ($18 million recovery); In re Giant\nInteractive Grp., Inc. Sec. Litig. (S.D.N.Y.) ($13 million recovery); In re Coventry HealthCare, Inc. Sec. Litig. (D.\nMd.) ($10 million recovery); Lenartz v. American Superconductor Corp. (D. Mass.) ($10 million recovery);\nDudley v. Haub (D.N.J.) ($9 million recovery); Hildenbrand v. W Holding Co. (D.P.R.) ($8.75 million\nrecovery); In re Doral Fin. Corp. Sec. Litig. (D.P.R.) ($7 million recovery); and Van Dongen v. CNinsure Inc.\n(S.D.N.Y.) ($6.625 million recovery). During law school, Boardman served as Associate Managing Editor\nof the Journal of Corporate, Financial and Commercial Law, interned in the chambers of the Honorable Kiyo\nA. Matsumoto in the United States District Court for the Eastern District of New York, and represented\nindividuals on a pro bono basis through the Workers\u2019 Rights Clinic.\n\n\nEducation\nB.A., State University of New York at Binghamton, 2003; J.D., Brooklyn Law School, 2007\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2022-2025; Leading Plaintiff Financial Lawyer, Lawdragon,\n2022-2025; Rising Star, Super Lawyers Magazine, 2015-2018; B.A., Magna Cum Laude, State University of\nNew York at Binghamton, 2003\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 60\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 64 of 159\n ATTORNEY BIOGRAPHIES\n\n\nNicolle B. Brito | Partner\nNicolle Brito is a partner in the Firm\u2019s Florida office. Her practice focuses on complex class actions and\nMDLs, covering consumer fraud, public nuisance, racketeering, conspiracy, environmental, and privacy\nlitigation.\n\nBrito currently represents numerous school boards and counties in the social media youth addiction MDL\n(In re Social Media Adolescent Addiction/Personal Injury Prods. Liab. Litig., No. 4:22-md-03047-YGR (N.D.\nCal.)), and is counsel to the State of Arkansas in its own enforcement suits against tech titans Meta and\nYouTube (Arkansas, ex rel. Griffin v. Meta Platforms, Inc., No. 57CV-23-47 (Ark. Cir. Ct., Polk Cnty.), and\nArkansas, ex rel. Griffin v. Alphabet Inc., No. 54CV-24-258 (Ark. Cir. Ct., Phillips Cnty.)). She is also\ncurrently working on the AFFF (aqueous firefighting foam) MDL (In re Aqueous Film-Forming Foams Prods.\nLiab. Litig., No. 2:18-mn-02873-RMG (D.S.C.)), representing governmental entities for PFAS\ncontamination. All told, the AFFF cases have resulted in recoveries of over $12 billion from chemical\ngiants such as 3M, DuPont, Tyco, and BASF.\n\nIn prior years, Brito was a part of the Firm\u2019s team leading the effort on behalf of cities and counties\naround the country in the opioid epidemic MDL (In re Nat\u2019l Prescription Opiate Litig., No.\n1:17-md-02804-DAP (N.D. Ohio)), where, among other things, she was a member of the winning trial\nteam in San Francisco\u2019s bellwether trial before Judge Breyer against Allergan, Teva, Walgreens, and\nothers in the prescription opioid supply chain (City & Cnty. of San Francisco v. Purdue Pharma L.P., No.\n3:18-cv-07591-CRB (N.D. Cal.)), which ultimately yielded a $350 million post-liability verdict settlement.\nShe also worked on notable data breach cases such as In re Luxottica of Am., Inc. Data Sec. Breach Litig., No.\n1:20-cv-00908-MRB (S.D. Ohio), and In re Lakeview Loan Servicing Data Breach Litig., No.\n1:22-cv-20955-DPG (S.D. Fla.), where she significantly contributed through all phases of litigation and\nhelped yield weighty recoveries for the respective classes.\n\nBefore joining the Firm, Brito worked in complex arbitration, insurance, and personal injury law, where\nshe gained significant litigation experience.\n\n\nEducation\nB.A., Florida International University, 2003; J.D., Nova Southeastern University Shepard Broad College\nof Law, 2007\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; Leading Plaintiff Consumer\nLawyer, Lawdragon, 2025; 500 X - The Next Generation, Lawdragon, 2023; J.D., Cum Laude, Nova\nSoutheastern University Shepard Broad College of Law, 2007\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 61\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 65 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLuke O. Brooks | Partner\nLuke Brooks is a partner in the Firm\u2019s securities litigation practice group in the San Diego office. He\nfocuses primarily on securities fraud litigation on behalf of individual and institutional investors, including\nstate and municipal pension funds, Taft-Hartley funds, and private retirement and investment funds.\nBrooks served as trial counsel in Jaffe v. Household International in the Northern District of Illinois, a\nsecurities class action that obtained a record-breaking $1.575 billion settlement after 14 years of litigation,\nincluding a six-week jury trial in 2009 that resulted in a verdict for plaintiffs. Other prominent cases\nrecently prosecuted by Brooks include Fort Worth Emps.\u2019 Ret. Fund v. J.P. Morgan Chase & Co., in which\nplaintiffs recovered $388 million for investors in J.P. Morgan residential mortgage-backed securities, and\na pair of cases \u2013 Abu Dhabi Commercial Bank v. Morgan Stanley & Co. Inc. (\u201cCheyne\u201d) and King\nCounty, Washington, et al. v. IKB Deutsche Industriebank AG (\u201cRhinebridge\u201d) \u2013 in which plaintiffs obtained a\nsettlement, on the eve of trial in Cheyne, from the major credit rating agencies and Morgan Stanley\narising out of the fraudulent ratings of bonds issued by the Cheyne and Rhinebridge structured\ninvestment vehicles. Reuters described the settlement as a \u201clandmark\u201d deal and emphasized that it was the\n\u201cfirst time S&P and Moody\u2019s have settled accusations that investors were misled by their ratings.\u201d An\narticle published in Rolling Stone magazine entitled \u201cThe Last Mystery of the Financial Crisis\u201d similarly\ncredited Robbins Geller with uncovering \u201ca mountain of evidence\u201d detailing the credit rating agencies\u2019\nfraud. Most recently, Brooks served as lead counsel in Smilovits v. First Solar, Inc., and obtained a $350\nmillion settlement on the eve of trial. The settlement is fifth-largest PSLRA settlement ever recovered in\nthe Ninth Circuit.\n\n\nEducation\nB.A., University of Massachusetts at Amherst, 1997; J.D., University of San Francisco, 2000\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2026; Litigation Star, Benchmark Litigation, 2023-2026; Leading\nPlaintiff Financial Lawyer, Lawdragon, 2019-2025; California - Litigation Star, Benchmark Litigation,\n2024; Local Litigation Star, Benchmark Litigation, 2017-2018, 2020; California Star, Benchmark Litigation,\n2019; State Litigation Star, Benchmark Litigation, 2019; Recommended Lawyer, The Legal 500, 2017-2018;\nMember, University of San Francisco Law Review, University of San Francisco\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 62\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 66 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSpencer A. Burkholz | Partner\nSpence Burkholz is a partner in the Firm\u2019s San Diego office and a member of the Firm\u2019s Management\nCommittee. He has over 25 years of experience in prosecuting securities class actions and private actions\non behalf of large institutional investors. Burkholz was one of the lead trial attorneys in Jaffe v. Household\nInternational in the Northern District of Illinois, a securities class action that obtained a record-breaking\n$1.575 billion settlement after 14 years of litigation, including a six-week jury trial in 2009 that resulted in\na verdict for plaintiffs. Burkholz has also recovered billions of dollars for injured shareholders in cases\nsuch as Enron ($7.2 billion), WorldCom ($657 million), Countrywide ($500 million), Qwest ($445\nmillion), Wells Fargo ($300 million), Envision ($177.5 million), McKesson ($141 million), Cardinal\nHealth ($109 million), and Cisco Systems ($99.25 million).\n\n\nEducation\nB.A., Clark University, 1985; J.D., University of Virginia School of Law, 1989\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; San Diego Elite Lawyer, The Legal 500, 2026; Leading\nLawyer in America, Lawdragon, 2018-2026; Litigation Star, Benchmark Litigation, 2023-2026; National\nPractice Area Star, Benchmark Litigation, 2020, 2024-2026; Best Lawyer in America, Best Lawyers\u00ae,\n2018-2026; Leading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; California Lawyer Attorney of the\nYear (CLAY), Daily Journal, 2024; Top 20 Trial Lawyer in California, Benchmark Litigation, 2019,\n2023-2024; Titan of the Plaintiffs Bar, Law360, 2024; Top Plaintiff Lawyer, Daily Journal, 2017, 2023;\nPlaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2020, 2022; Top Lawyer in San Diego, San Diego\nMagazine, 2013-2022; Southern California Best Lawyer, Best Lawyers\u00ae, 2018-2021; Super Lawyer, Super\nLawyers Magazine, 2015-2016, 2020; Top 100 Trial Lawyer, Benchmark Litigation, 2018-2020; Local\nLitigation Star, Benchmark Litigation, 2015-2018, 2020; Lawyer of the Year, Best Lawyers\u00ae, 2020;\nRecommended Lawyer, The Legal 500, 2017-2019; California Star, Benchmark Litigation, 2019; State\nLitigation Star, Benchmark Litigation, 2019; Plaintiff Attorney of the Year, Benchmark Litigation, 2018; B.A.,\nCum Laude, Clark University, 1985; Phi Beta Kappa, Clark University, 1985\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 63\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 67 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMichael G. Capeci | Partner\nMichael Capeci is a partner in the Firm\u2019s Melville office. His practice focuses on prosecuting complex\nsecurities class action lawsuits in federal and state courts. Throughout his tenure with the Firm, Capeci\nhas led the litigation teams prosecuting numerous class action cases in federal and/or state court alleging\nviolations of the Securities Exchange Act of 1934 and/or the Securities Act of 1933, such as: Strougo v.\nMallinckrodt plc ($46 million recovery); Gordon v. Vanda Pharmaceuticals, Inc. ($11.5 million recovery);\nNayani v. LifeStance Health Group, Inc. ($50 million recovery); and Chester County Emps.\u2019 Ret. Fund v. Alnylam\nPharmaceuticals, Inc. ($7 million recovery). In addition, Capeci has played an integral role in the teams\nprosecuting securities class action cases such as: In re BHP Billiton Ltd. Sec. Litig. ($50 million recovery);\nGalestan v. OneMain Holdings, Inc. ($9 million recovery); and City of Pontiac Gen. Emps.\u2019 Ret. Sys. v. Lockheed\nMartin Corp. ($19.5 million recovery).\n\n\nEducation\nB.S., Villanova University, 2007; J.D., Hofstra University School of Law, 2010\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2022-2025; 500 X \u2013 The Next Generation, Lawdragon, 2023-2025;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2025; Rising Star, Super Lawyers Magazine, 2014-2021; J.D.,\nCum Laude, Hofstra University School of Law, 2010\n\n\n\nJennifer N. Caringal | Partner\nJennifer Caringal is a partner in the Firm\u2019s San Diego office, where her practice focuses on\ncomplex securities litigation. Jennifer is a member of the Firm\u2019s Lead Plaintiff Advisory Team, which\nadvises institutional investors in connection with lead plaintiff motions, and assists them in securing\nappointment as lead plaintiff.\n\nCaringal served as lead counsel in In re Am. Realty Cap. Props., Inc. Litig., a case arising out of ARCP\u2019s\nmanipulative accounting practices, and obtained a $1.025 billion recovery. For five years, she and the\nlitigation team prosecuted nine different claims for violations of the Securities Exchange Act of 1934 and\nthe Securities Act of 1933, involving seven different stock or debt offerings and two mergers. The\nrecovery represents the highest percentage of damages of any major PSLRA case prior to trial and\nincludes the largest personal contributions by individual defendants in history.\n\n\nEducation\nB.A., University of Illinois, 2006; J.D., Washington University in St. Louis, School of Law, 2012\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2025-2026; Leading Plaintiff Financial Lawyer, Lawdragon,\n2022-2025; 500 X \u2013 The Next Generation, Lawdragon, 2023-2024; Best Lawyer in America: One to Watch,\nBest Lawyers\u00ae, 2021-2024; They\u2019ve Got Next: The 40 Under 40, Bloomberg Law, 2022; Rising Star, Super\nLawyers Magazine, 2021-2022; Best Lawyer in Southern California: One to Watch, Best Lawyers\u00ae, 2021\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 64\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 68 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRachel A. Cocalis | Partner\nRachel Cocalis is a partner in the Firm\u2019s San Diego office. She represents pension funds and class\nmembers in securities fraud class actions. Cocalis was on the team of Robbins Geller attorneys who\nobtained a $97.5 million recovery in Marcus v. J.C. Penney Company, Inc.\n\nMost recently, Cocalis was a key member of the Robbins Geller litigation team in Monroe County Employees\u2019\nRetirement System v. The Southern Company in which a $87.5 million settlement was reached after three years\nof litigation. The settlement resolved claims for violations of the Securities Exchange Act of 1934\nstemming from defendants\u2019 issuance of materially misleading statements and omissions regarding the\nstatus of construction of a first-of-its-kind \u201cclean coal\u201d power plant that was designed to transform coal into\nsynthetic gas that could then be used to fuel the power plant. Cocalis was also on the litigation team that\nobtained a settlement of up to $85 million in In re Morning Song Bird Food Litigation, resolving claims\nthat Scotts Miracle-Gro knowingly sold wild bird food treated with pesticides that are hazardous to birds.\n\n\nEducation\nB.A., Princeton University, 2010; J.D., University of California, Hastings College of the Law, 2016\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; Leading Plaintiff Financial Lawyer,\nLawdragon, 2025; Rising Star, Super Lawyers Magazine, 2025; 500 X - The Next Generation, Lawdragon,\n2024; J.D., magna cum laude, University of California, Hastings College of the Law, 2016; B.A., High\nHonors, Princeton University, 2010\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 65\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 69 of 159\n ATTORNEY BIOGRAPHIES\n\n\nBrian E. Cochran | Partner\nBrian Cochran is a partner in the Firm\u2019s San Diego and Chicago offices. He focuses his practice on\ncomplex securities, shareholder, consumer protection, and ERISA litigation. Cochran specializes in case\ninvestigation and initiation and lead plaintiff issues arising under the Private Securities Litigation Reform\nAct of 1995. He has developed dozens of cases under the federal securities laws and recovered billions of\ndollars for injured investors and consumers. Several of Cochran\u2019s cases have pioneered new ground, such\nas cases on behalf of cryptocurrency investors and in blank check companies (a.k.a \u201cSPACs\u201d), and sparked\nfollow-on governmental investigations into corporate malfeasance.\n\nCochran was a member of the litigation team that achieved a $1.21 billion settlement in the Valeant\nPharmaceuticals securities litigation. Cochran also developed the Dynamic Ledger securities litigation, one of\nthe first cases to challenge a cryptocurrency issuer\u2019s failure to register under the federal securities laws,\nwhich settled for $25 million. In addition, Cochran was part of the team that secured a historic $25\nmillion settlement on behalf of Trump University students, which Cochran prosecuted on a pro bono basis.\nOther notable recoveries include: Rite Aid Merger ($192.5 million); Exelon ($173 million); Alta Mesa ($126.3\nmillion); Micro Focus ($107.5 million); Walgreens ($105 million); VMWare ($102.5 million); Scotts Miracle-\nGro (up to $85 million); Psychiatric Solutions ($65 million); SQM Chemical & Mining Co. of Chile ($62.5\nmillion); GE ERISA ($61 million); HPE-DXC Merger ($47.5 million, subject to court approval);\nGrubhub ($42 million); Sea, Ltd. ($40 million); Big Lots ($38 million); Credit Suisse ($32.5 million); Waste\nManagement ($30 million, subject to court approval); GoHealth ($29.5 million); Reckitt Benckiser ($19.6\nmillion); DouYu ($15 million); REV Group ($14.25 million); Fifth Street Finance ($14 million); Third Avenue\nManagement ($14 million); Funko ($14 million); LJM ($12.85 million); Sealed Air ($12.5 million); and\nCamping World ($12.5 million).\n\n\nEducation\nA.B., Princeton University, 2006; J.D., University of California at Berkeley School of Law, Boalt Hall,\n2012\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2026; Leading Litigator in America, Lawdragon, 2025-2026; Best Lawyer\nin America, Best Lawyers\u00ae, 2025-2026; Leading Lawyer, The Legal 500, 2024-2025; Leading Plaintiff\nFinancial Lawyer, Lawdragon, 2024-2025; 500 X \u2013 The Next Generation, Lawdragon, 2023-2024; 40 &\nUnder List, Benchmark Litigation, 2021, 2023-2024; Next Generation Partner, The Legal 500, 2020-2023;\nRising Star, Super Lawyers Magazine, 2020-2022; Rising Star, The Legal 500, 2019; A.B., with\nHonors, Princeton University, 2006; J.D., Order of the Coif, University of California at Berkeley School of\nLaw, Boalt Hall, 2012\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 66\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 70 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMark Conover | Partner\nMark Conover is a partner with Robbins Geller, based in the Firm\u2019s San Diego office. With over 50 felony\njury trials and a distinguished career as a former federal prosecutor, Conover brings a wealth of trial\nexperience to the Firm. He focuses on complex investigations, securities fraud litigation, and high-stakes\ntrials, drawing on his extensive background in handling large-scale financial fraud, public corruption, and\ncorporate misconduct cases.\n\nConover began his legal career as a litigation associate at Luce, Forward, Hamilton & Scripps LLP, before\njoining the U.S. Attorney\u2019s Office for the Southern District of California. There, he rose through the\nranks to serve as second-in-command, overseeing the day-to-day administration of one of the largest U.S.\nAttorney\u2019s offices in the nation. At the U.S. Attorney\u2019s Office, Conover also served as Chief of the Major\nFrauds and Public Corruption Section, where he oversaw the prosecution of complex cases that resulted\nin groundbreaking convictions and exceptional outcomes. He played a key role in prosecuting high-\nprofile cases, including the conviction of a sitting U.S. Congressman.\n\nThroughout his tenure at the U.S. Attorney\u2019s Office, Conover prosecuted and convicted high-level\nexecutives at publicly traded companies and led investigations into violations of the Foreign Corrupt\nPractices Act (FCPA). His strategic collaborations with agencies such as the FBI, IRS, SEC, and DOJ have\nbeen instrumental in tackling multi-jurisdictional investigations and holding corporate and government\nwrongdoers accountable. These experiences gave him invaluable insights into the investigation of\nsecurities fraud by the DOJ and the SEC.\n\nIn addition to his legal practice, Conover has served as an adjunct professor at California Western School\nof Law for over a decade, mentoring the next generation of lawyers. He also served for many years as a\nDOJ mediator, successfully resolving disputes across the country.\n\n\nEducation\nB.S., Utah Valley University, 2001; J.D., University of Southern California School of Law, 2004\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2026\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 67\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 71 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSheri M. Coverman | Partner\nSheri Coverman is a partner in the Firm\u2019s Boca Raton office. Her practice focuses on complex class\nactions, including securities, corporate governance, and consumer fraud litigation.\n\nCoverman is a member of the Firm\u2019s Institutional Outreach Team, which provides advice to the Firm\u2019s\ninstitutional clients, including numerous public pension systems and Taft-Hartley funds throughout the\nUnited States, on issues related to corporate fraud, shareholder litigation, and corporate governance\nissues. Coverman frequently addresses trustees regarding their options for seeking redress for losses due\nto violations of securities laws and assists in ongoing litigation involving many Firm clients. Coverman\u2019s\ninstitutional clients are also involved in other types of class actions, namely: In re National Prescription\nOpiate Litigation.\n\n\nEducation\nB.A., University of Florida, 2008; J.D., University of Florida Levin College of Law, 2011\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026\n\n\n\nJoseph D. Daley | Partner\nJoseph Daley is a partner in the Firm\u2019s San Diego office, serves on the Firm\u2019s Securities Hiring\nCommittee, and is a member of the Firm\u2019s Appellate Practice Group. Precedents include: City of\nBirmingham Ret. & Relief Sys. v. Davis, 806 F. App\u2019x 17 (2d Cir. 2020); City of Providence v. Bats Glob. Mkts.,\nInc., 878 F.3d 36 (2d Cir. 2017); DeJulius v. New Eng. Health Care Emps. Pension Fund, 429 F.3d 935 (10th\nCir. 2005); Fikes Wholesale, Inc. v. Visa U.S.A., Inc., 62 F.4th 704 (2d Cir. 2023); Frank v. Dana Corp. (\u201cDana\nI\u201d), 547 F.3d 564 (6th Cir. 2008); Frank v. Dana Corp. (\u201cDana II\u201d), 646 F.3d 954 (6th Cir. 2011); Freidus v.\nBarclays Bank PLC, 734 F.3d 132 (2d Cir. 2013); In re HealthSouth Corp. Sec. Litig., 334 F. App\u2019x 248 (11th\nCir. 2009); In re Merck & Co. Sec., Derivative & ERISA Litig., 493 F.3d 393 (3d Cir. 2007); In re Quality Sys.,\nInc. Sec. Litig., 865 F.3d 1130 (9th Cir. 2017); In re Qwest Commc\u2019ns Int\u2019l, 450 F.3d 1179 (10th Cir.\n2006); Luther v. Countrywide Home Loans Servicing LP, 533 F.3d 1031 (9th Cir. 2008); NECA-IBEW Health &\nWelfare Fund v. Goldman Sachs & Co., 693 F.3d 145 (2d Cir. 2012); Rosenbloom v. Pyott (\u201cAllergan\u201d), 765 F.3d\n1137 (9th Cir. 2014); San Diego Cnty. Emps. Ret. Ass\u2019n v. Johnson & Johnson, 2025 U.S. App. LEXIS 18986\n(3d Cir. July 30, 2025); Silverman v. Motorola Sols., Inc., 739 F.3d 956 (7th Cir. 2013); Siracusano v. Matrixx\nInitiatives, Inc., 585 F.3d 1167 (9th Cir. 2009), aff\u2019d, 563 U.S. 27 (2011); and Southland Sec. Corp. v. INSpire\nIns. Sols. Inc., 365 F.3d 353 (5th Cir. 2004). Daley is admitted to practice before the U.S. Supreme Court,\nas well as before 12 U.S. Courts of Appeals around the nation.\n\n\nEducation\nB.S., Jacksonville University, 1981; J.D., University of San Diego School of Law, 1996\n\nHonors / Awards\nBest Lawyer in America, Best Lawyers\u00ae, 2024-2026; Seven-time Super Lawyer, Super Lawyers Magazine;\nAppellate Moot Court Board, Order of the Barristers, University of San Diego School of Law; Best\nAdvocate Award (Traynore Constitutional Law Moot Court Competition), First Place and Best Briefs\n(Alumni Torts Moot Court Competition and USD Jessup International Law Moot Court Competition)\n\n\n\n Robbins Geller Rudman & Dowd LLP | 68\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 72 of 159\n ATTORNEY BIOGRAPHIES\n\n\nStuart A. Davidson | Partner\nStuart Davidson is a partner in the Firm\u2019s Boca Raton office. His practice focuses on complex consumer\nclass actions, including cases involving deceptive and unfair trade practices, privacy and data breach\nissues, and antitrust violations.\n\nHe has served as class counsel in some of the nation\u2019s most significant privacy and consumer cases,\nincluding: In re Facebook Biometric Information Privacy Litigation, No. 3:15-cv-03747-JD (N.D. Cal.) ($650\nmillion recovery in a cutting-edge class action concerning Facebook\u2019s alleged privacy violations through\nits collection of user\u2019s biometric identifiers without informed consent); In re Yahoo! Inc. Customer Data\nSecurity Breach Litigation, No. 5:16-md-02752-LHK (N.D. Cal.) ($117.5 million recovery in the largest data\nbreach in history); Kehoe v. Fidelity Federal Bank & Trust, No. 9:03-cv-80593-DTKH (S.D. Fla.) ($50 million\nrecovery in Driver\u2019s Privacy Protection Act case on behalf of half-a-million Florida drivers against a\nnational bank); In re Independent Living Systems Data Breach Litigation, No. 1:23-cv-21060-KMW (S.D. Fla.)\n($14 million recovery); In re Fortra File Transfer Software Data Security Breach Litigation, No.\n1:24-md-03090-RAR (S.D. Fla.) ($20 million recovery, representing Aetna patients); In re American\nFinancial Resources, Inc. Data Breach Litigation, No. 2:22-cv-01757-MCA-JSA (D.N.J.) ($2.5 million\nrecovery); In re Sony Gaming Networks & Customer Data Security Breach Litigation, No. 3:11-md-02258-AJB-\nMDD (S.D. Cal.) (settlement valued at $15 million concerning the massive data breach of Sony\u2019s\nPlayStation Network); and In re Solara Medical Supplies Data Breach Litigation, No. 3:19-cv-02284-H-KSC\n(S.D. Cal.) ($5 million all-cash settlement for 114,000 victims of healthcare data breach).\n\nDavidson currently serves as Plaintiffs\u2019 Co-Lead Counsel in In re Perry Johnson & Associates Medical\nTranscription Data Security Breach Litigation, No. 1:24-md-03096-RPK-LGD (E.D.N.Y.), In re American\nMedical Collection Agency, Inc. Customer Data Security Breach Litigation, No. 2:19-md-02904-MCA-MAH\n(D.N.J.) (representing class of LabCorp customers), and Garner v. Amazon.com, Inc., No.\n2:21-cv-00750-RSL (W.D. Wash.) (certified class of 100 million Amazon Alexa registrants alleging\nAmazon\u2019s deceptive advertising for Alexa-enabled devices); on Plaintiffs\u2019 Executive Committee in In re\nLakeview Loan Servicing Data Breach Litigation, No. 1:22-cv-20955-DPG (S.D. Fla.); and on Plaintiffs\u2019\nSteering Committee in In re FTX Cryptocurrency Exchange Collapse Litigation, No. 1:23-md-03076-KMM\n(S.D. Fla.). Davidson also currently represents the State of Arkansas in a major antitrust enforcement\naction, State of Arkansas ex rel. Griffin v. Syngenta Crop Protection AG, No. 4:22-cv-01287-BSM (E.D. Ark.)\nand a privacy enforcement action, State of Arkansas ex rel. Griffin v. General Motors LLC, No. 54CV-25-77\n(Ark. Cir. Ct., Phillips Cnty.).\n\nDavidson also spearheaded several aspects of In re EpiPen (Epinephrine Injection, USP) Marketing, Sales\nPractices & Antitrust Litigation, No. 2:17-md-02785-DDC-TJJ (D. Kan.) ($609 million total recovery\nachieved weeks prior to trial in certified class action alleging antitrust claims involving the illegal reverse\npayment settlement to delay the generic EpiPen, which allowed the prices of the life-saving EpiPen to rise\nover 600% in 9 years), served as Co-Lead Class Counsel in three cases brought against Genworth Life\nInsurance Company on behalf of long-term care insureds, Skochin v. Genworth Life. Ins. Co., No.\n3:19-cv-00049-REP (E.D. Va.); Halcom v. Genworth Life Ins. Co., No. 3:21-cv-00019-REP (E.D. Va.); and\nHaney v. Genworth Life Ins. Co., No. 3:22-cv-00055-REP (E.D. Va.), recovering hundreds of millions of\ndollars in cash damages for policyholders, and served as Plaintiffs\u2019 Co-Lead Counsel in In re NHL Players\u2019\nConcussion Injury Litigation, No. 0:14-md-02551-SRN-BRT (D. Minn.) (representing retired National\nHockey League players in multidistrict litigation suit against the NHL regarding injuries suffered due to\nrepetitive head trauma and concussions), and in In re Pet Food Products Liability Litigation, No.\n1:07-cv-02867-NLH-AMD (D.N.J.) ($24 million recovery in multidistrict consumer class action on behalf\nof thousands of aggrieved pet owners nationwide against some of the nation\u2019s largest pet food\nmanufacturers, distributors, and retailers). He also served as Plaintiffs\u2019 Co-Lead Counsel in In re\n\n\n\n Robbins Geller Rudman & Dowd LLP | 69\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 73 of 159\n ATTORNEY BIOGRAPHIES\n\nUnitedGlobalCom, Inc. Shareholder Litigation, C.A. No. 1012-VCS (Del. Ch.) ($25 million recovery weeks\nbefore trial); In re Winn-Dixie Stores, Inc. Shareholder Litigation, No. 16-2011-CA-010616 (Fla. Cir. Ct.) ($11.5\nmillion recovery for former Winn-Dixie shareholders following the corporate buyout by BI-LO); and In re\nAuthenTec, Inc. Shareholder Litigation, No. 5-2012-CA-57589 (Fla. Cir. Ct.) ($10 million recovery for former\nAuthenTec shareholders following a merger with Apple). The latter two cases are the two largest merger\nand acquisition recoveries in Florida history.\n\nDavidson is a former lead assistant public defender in the Felony Division of the Broward County, Florida\nPublic Defender\u2019s Office. During his tenure at the Public Defender\u2019s Office, he tried over 30 jury trials\nand defended individuals charged with major crimes ranging from third-degree felonies to life and capital\nfelonies.\n\n\nEducation\nB.A., State University of New York at Geneseo, 1993; J.D., Nova Southeastern University Shepard\nBroad College of Law, 1996\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2023-2026; Litigation Star, Benchmark Litigation, 2023-2026;\nLeading Litigator in America, Lawdragon, 2024-2026; Best Lawyer in America, Best Lawyers\u00ae,\n2026; Recommended Lawyer, The Legal 500, 2023-2025; Leading Plaintiff Financial Lawyer, Lawdragon,\n2020-2025; Law360 Distinguished Legal Writing Award, The Burton Awards Program, 2025; Leading\nPlaintiff Consumer Lawyer, Lawdragon, 2022-2025; Outstanding Antitrust Litigation Achievement in\nPrivate Law Practice, American Antitrust Institute, 2022; Super Lawyer, Super Lawyers Magazine,\n2021-2022; One of \u201cFlorida\u2019s Most Effective Lawyers\u201d in the Privacy category, American Law Media, 2020;\nJ.D., Summa Cum Laude, Nova Southeastern University Shepard Broad College of Law, 1996; Associate\nEditor, Nova Law Review, Book Awards in Trial Advocacy, International Law, and Criminal Pretrial\nPractice\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 70\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 74 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJason C. Davis | Partner\nJason Davis is a partner in the Firm\u2019s San Francisco office where he practices securities class actions and\ncomplex litigation involving equities, fixed-income, synthetic, and structured securities issued in public\nand private transactions. Davis was on the trial team in Jaffe v. Household Int\u2019l, Inc., a securities class action\nthat obtained a record-breaking $1.575 billion settlement after 14 years of litigation, including a six-week\njury trial in 2009 that resulted in a verdict for plaintiffs. Most recently, he was part of the litigation team\nin Luna v. Marvell Tech. Grp., Ltd., resulting in a $72.5 million settlement that represents approximately\n24% to 50% of the best estimate of classwide damages suffered by investors.\n\nBefore joining the Firm, Davis focused on cross-border transactions, mergers and acquisitions at Cravath,\nSwaine and Moore LLP in New York.\n\n\nEducation\nB.A., Syracuse University, 1998; J.D., University of California at Berkeley, Boalt Hall School of Law, 2002\n\nHonors / Awards\nB.A., Summa Cum Laude, Syracuse University, 1998; International Relations Scholar of the year, Syracuse\nUniversity; Teaching fellow, examination awards, Moot court award, University of California at Berkeley,\nBoalt Hall School of Law\n\n\n\nMark J. Dearman | Partner\nMark Dearman is a partner in the Firm\u2019s Boca Raton office, where his practice focuses on consumer\nfraud, securities fraud, mass torts, antitrust, and whistleblower litigation.\n\nDearman, along with other Robbins Geller attorneys, is currently leading the effort on behalf of cities and\ncounties around the country in In re National Prescription Opiate Litigation, No. 1:17-md-02804-DAP (N.D.\nOhio). He was appointed to the Plaintiffs\u2019 Steering Committee in In re Insulin Pricing Litigation, No.\n2:23-md-03080 (D.N.J.). Robbins Geller is working with a coalition of other nationally prominent law\nfirms to investigate and bring cases on behalf of states, counties, cities, and other entities who maintain self-\nfunded healthcare plans and who have been harmed as a result of their purchases of, or reimbursements\nfor, overpriced insulin medication. Dearman is currently on the Plaintiffs\u2019 Executive Committee in In re\nZF-TRW Airbag Control Units Products Liability Litigation, No. 2:19-ml-02905 (C.D. Cal.), involving an\nalleged defect in airbag control units found in more than 15 million vehicles nationwide. Plaintiffs allege\nthe defendants misled consumers and caused them to overpay for vehicles with dangerously defective\nairbag and seat belt systems. The litigation team has secured over $290 million in settlement benefits\nfrom several of the automotive defendants and continue to litigate claims against the remaining\ndefendants. Dearman was also appointed to the Plaintiffs\u2019 Steering Committee in In re Zantac (Ranitidine)\nProducts Liability Litigation, No. 9:20-md-02924-RLR (S.D. Fla.), and as Chair of the Plaintiffs\u2019 Executive\nCommittee in In re Apple Inc. Device Performance Litigation, No. 5:18-md-02827-EJD (N.D. Cal.), where\nDearman, along with co-counsel, obtained a $310 million settlement. His other recent representative\ncases include serving as class counsel in In re Juul Labs, Inc., Marketing, Sales Practices, and Products Liability\nLitigation, No. 3:19-md-02913-WHO (N.D. Cal.); In re McKinsey & Co., Inc. National Prescription Opiate\nConsultant Litigation, No. 3:21-md-02996-CRB (N.D. Cal.); In re Facebook Biometric Information Privacy\nLitigation, No. 3:15-cv-03747-JD (N.D. Cal.) ($650 million recovery in a class action concerning Facebook\u2019s\nalleged privacy violations through its collection of user\u2019s biometric identifiers without informed\nconsent); In re EpiPen (Epinephrine Injection, USP) Marketing, Sales Practices & Antitrust Litigation, No.\n\n\n Robbins Geller Rudman & Dowd LLP | 71\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 75 of 159\n ATTORNEY BIOGRAPHIES\n\n2:17-md-02785-DDC-TJJ (D. Kan.) ($609 million total recovery achieved weeks prior to trial in certified\nclass action alleging antitrust claims involving the illegal reverse payment settlement to delay the generic\nEpiPen); Zimmerman v. The 3M Co. f/k/a Minnesota Mining & Manufacturing Co., No. 1:17-cv-1062 (W.D.\nMich.) ($54 million settlement on behalf of class of Michigan homeowners whose property was allegedly\ncontaminated with PFAS); In re FieldTurf Artificial Turf Sales & Marketing Practices Litigation, No.\n3:17-md-02779-MAS-TJB (D.N.J.); In re Sony Gaming Networks & Customer Data Security Breach Litigation,\n903 F. Supp. 2d 942 (S.D. Cal. 2012); In re Volkswagen \u201cClean Diesel\u201d Marketing, Sales Practices, & Products\nLiability Litigation, 2016 U.S. Dist. LEXIS 1357 (N.D. Cal. Jan. 5, 2016); In re Aluminum Warehousing\nAntitrust Litigation, 95 F. Supp. 3d 419 (S.D.N.Y. 2015); In re Liquid Aluminum Sulfate Antitrust Litigation,\nNo. 2:16-md-2687-MCA-MAH (D.N.J.); In re Winn-Dixie Stores, Inc. Shareholder Litigation, No.\n16-2011-CA-010616 (Fla. 4th Jud. Cir. Ct., Duval Cnty.); Gemelas v. Dannon Co. Inc., No.\n1:08-cv-00236-DAP (N.D. Ohio); and In re AuthenTec, Inc. Shareholder Litigation, No. 05-2012-CA-57589\n(Fla. 18th Jud. Cir. Ct., Brevard Cnty.).\n\n\nEducation\nB.A., University of Florida, 1990; J.D., Nova Southeastern University, 1993\n\nHonors / Awards\nAV rated by Martindale-Hubbell; Leading Lawyer in America, Lawdragon, 2023-2026; Leading Litigator\nin America, Lawdragon, 2024-2026; Best Lawyer in America, Best Lawyers\u00ae, 2024-2026; Super Lawyer,\nSuper Lawyers Magazine, 2014-2020, 2025; Recommended Lawyer, The Legal 500, 2023, 2025; Leading\nPlaintiff Financial Lawyer, Lawdragon, 2020-2025; Leading Plaintiff Consumer Lawyer, Lawdragon,\n2022-2025; In top 1.5% of Florida Civil Trial Lawyers in Florida Trend\u2019s Florida Legal Elite, 2004, 2006\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 72\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 76 of 159\n ATTORNEY BIOGRAPHIES\n\n\nKathleen B. Douglas | Partner\nKathleen Douglas is a partner in the Firm\u2019s Boca Raton office. She focuses her practice on securities\nfraud class actions and consumer fraud. Most recently, Douglas and a team of Robbins Geller attorneys\nobtained a $1.21 billion settlement in In re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., a case that Vanity Fair\nreported as \u201cthe corporate scandal of its era\u201d that had raised \u201cfundamental questions about the functioning\nof our health-care system, the nature of modern markets, and the slippery slope of ethical\nrationalizations.\u201d This is the largest securities class action settlement against a pharmaceutical\nmanufacturer and the ninth largest ever.\n\nDouglas was also a key member of the litigation team in In re UnitedHealth Grp. Inc. PSLRA Litig., in which\nshe and team of Robbins Geller attorneys achieved a substantial $925 million recovery. In addition to the\nmonetary recovery, UnitedHealth also made critical changes to a number of its corporate governance\npolicies, including electing a shareholder-nominated member to the company\u2019s Board of Directors.\nLikewise, in Nieman v. Duke Energy Corp., she and a team of attorneys obtained a $146.25 million recovery,\nwhich is the largest recovery in North Carolina for a case involving securities fraud and is one of the five\nlargest recoveries in the Fourth Circuit. In addition, Douglas was a member of the team of attorneys\nthat represented investors in Knurr v. Orbital ATK, Inc., which recovered $108 million for shareholders\nand is believed to be the fourth-largest securities class action settlement in the history of the Eastern\nDistrict of Virginia. Douglas has served as class counsel in several class actions brought on behalf of\nFlorida emergency room physicians. These cases were against some of the nation\u2019s largest Health\nMaintenance Organizations and settled for substantial increases in reimbursement rates and millions of\ndollars in past damages for the class.\n\n\nEducation\nB.S., Georgetown University, 2004; J.D., University of Miami School of Law, 2007\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2025-2026; Leading Plaintiff Consumer Lawyer, Lawdragon, 2023-2025;\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024-2025; 40 & Under List, Benchmark Litigation,\n2023; 40 & Under Hot List, Benchmark Litigation, 2021; Rising Star, Super Lawyers\nMagazine, 2012-2017; B.S., Cum Laude, Georgetown University, 2004\n\n\n\nDaniel S. Drosman | Partner\nDan Drosman is a partner in the Firm\u2019s San Diego office and a member of the Firm\u2019s Management\nCommittee. He focuses his practice on securities fraud and other complex civil litigation and has obtained\nsignificant recoveries for investors in cases such as Morgan Stanley, Cisco Systems, The Coca-Cola\nCompany, Petco, PMI, and America West. Drosman served as lead trial counsel in Jaffe v. Household\nInternational in the Northern District of Illinois, a securities class action that obtained a record-breaking\n$1.575 billion settlement after 14 years of litigation, including a six-week jury trial in 2009 that resulted in\na verdict for plaintiffs. Drosman also helped secure a $388 million recovery for investors in J.P. Morgan\nresidential mortgage-backed securities in Fort Worth Employees\u2019 Retirement Fund v. J.P. Morgan Chase &\nCo. On a percentage basis, that settlement is the largest recovery ever achieved in an RMBS class action.\nDrosman also served as lead counsel in Smilovits v. First Solar, Inc., and obtained a $350 million settlement\non the eve of trial. The settlement is fifth-largest PSLRA settlement ever recovered in the Ninth Circuit.\n\nMost recently, Drosman led a team of Robbins Geller attorneys to a record-breaking $809.5 million\n\n\n Robbins Geller Rudman & Dowd LLP | 73\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 77 of 159\n ATTORNEY BIOGRAPHIES\n\nsettlement in In re Twitter, Inc. Sec. Litig., which settled the day before trial was set to commence. The\nsettlement is the largest securities fraud class action recovery in the Ninth Circuit in the last decade and\none of the top 20 shareholder class action settlements of all time. Drosman was part of the Robbins Geller\nlitigation team in Monroe County Employees\u2019 Retirement System v. The Southern Company in which an $87.5\nmillion settlement was reached after three years of litigation. The settlement resolved claims for violations\nof the Securities Exchange Act of 1934 stemming from defendants\u2019 issuance of materially misleading\nstatements and omissions regarding the status of construction of a first-of-its-kind \u201cclean coal\u201d power plant\nthat was designed to transform coal into synthetic gas that could then be used to fuel the power plant. In\nanother recent case, Drosman and the Robbins Geller litigation team obtained a $62.5 million settlement\nin Villella v. Chemical and Mining Company of Chile Inc., which alleged that Sociedad Qu\u00edmica y Minera de\nChile S.A. (\u201cSQM\u201d) violated the Securities Exchange Act of 1934 by issuing materially false and misleading\nstatements regarding the Company\u2019s failure to disclose that money from SQM was channeled illegally to\nelectoral campaigns for Chilean politicians and political parties as far back as 2009. SQM had also filed\nmillions of dollars\u2019 worth of fictitious tax receipts with Chilean authorities in order to conceal bribery\npayments from at least 2009 through fiscal year 2014.\n\nIn a pair of cases \u2013 Abu Dhabi Commercial Bank, et al. v. Morgan Stanley & Co. Inc. (\u201cCheyne\u201d litigation)\nand King County, Washington, et al. v. IKB Deutsche Industriebank AG (\u201cRhinebridge\u201d litigation) \u2013 Drosman led a\ngroup of attorneys prosecuting fraud claims against the credit rating agencies, where he is distinguished\nas one of the few plaintiffs\u2019 counsel to defeat the rating agencies\u2019 traditional First Amendment defense and\ntheir motions for summary judgment based on the mischaracterization of credit ratings as mere opinions\nnot actionable in fraud.\n\nBefore joining the Firm, Drosman served as an Assistant District Attorney for the Manhattan District\nAttorney\u2019s Office, and an Assistant United States Attorney in the Southern District of California, where he\ninvestigated and prosecuted violations of the federal narcotics, immigration, and official corruption law.\n\n\nEducation\nB.A., Reed College, 1990; J.D., Harvard Law School, 1993\n\nHonors / Awards\nSan Diego Elite Lawyer, The Legal 500, 2026; Leading Lawyer in America, Lawdragon,\n2018-2026; Litigation Star, Benchmark Litigation, 2023-2026; National Practice Area Star, Benchmark\nLitigation, 2026; Leading Litigator in America, Lawdragon, 2026; Best Lawyer in America, Best Lawyers\u00ae,\n2019-2026; Leading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Legend, Lawdragon, 2025;\nRecommended Lawyer, The Legal 500, 2017-2018, 2023-2024; Lawyer of the Year, Best Lawyers\u00ae, 2022,\n2024; West Trailblazer, The American Lawyer, 2022; Top Plaintiff Lawyer, Daily Journal, 2022; Plaintiff\nLitigator of the Year, Benchmark Litigation, 2022; Titan of the Plaintiffs Bar, Law360, 2022; Southern\nCalifornia Best Lawyers, The Wall Street Journal, 2021; Southern California Best Lawyer, Best Lawyers\u00ae,\n2019-2021; Super Lawyer, Super Lawyers Magazine, 2017-2020; Top 100 Lawyer, Daily Journal, 2017;\nDepartment of Justice Special Achievement Award, Sustained Superior Performance of Duty; B.A.,\nHonors, Reed College, 1990; Phi Beta Kappa, Reed College, 1990\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 74\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 78 of 159\n ATTORNEY BIOGRAPHIES\n\n\nThomas E. Egler | Partner\nThomas Egler is a partner in the Firm\u2019s San Diego office and focuses his practice on representing clients\nin major complex, multidistrict litigations, such as Lehman Brothers, Countrywide Mortgage Backed\nSecurities, WorldCom, AOL Time Warner, and Qwest. He has represented institutional investors both as\nplaintiffs in individual actions and as lead plaintiffs in class actions.\n\nMost recently, along with co-counsel and a team of Robbins Geller attorneys, Egler led the effort on behalf\nof cities and counties around the country in In re National Prescription Opiate Litigation. In 2022,\nEgler served on the team of counsel in a federal bench trial in San Francisco in a case that had been\nselected as a bellwether in the multidistrict litigation. The team achieved combined settlements of nearly\n$70 million for San Francisco and more than $50 billion nationally from multiple pharmaceutical\ncompanies who were defendants in the national litigation. The Honorable Charles R. Breyer of the\nNorthern District of California ruled that Walgreens, the only defendant remaining in the San Francisco\ncase, was liable for its role in the opioid crisis in San Francisco.\n\nEgler also has been a Lawyer Representative to the Ninth Circuit Judicial Conference from the Southern\nDistrict of California, is a member of the Hon. William B. Enright Inn of Court in San Diego, and in the\npast has served on the Executive Board of the San Diego chapter of the Association of Business Trial\nLawyers. Before joining the Firm, Egler was a law clerk to the Honorable Donald E. Ziegler, Chief Judge,\nUnited States District Court, Western District of Pennsylvania.\n\n\nEducation\nB.A., Northwestern University, 1989; J.D., The Catholic University of America, Columbus School of Law,\n1995\n\nHonors / Awards\nBest Lawyer in America, Best Lawyers\u00ae, 2024-2026; Leading Lawyer in America, Lawdragon, 2024; Super\nLawyer, Super Lawyers Magazine, 2017-2018; Associate Editor, Catholic University Law Review\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 75\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 79 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAlan I. Ellman | Partner\nAlan Ellman is a partner in the Firm\u2019s Melville office, where he concentrates his practice on prosecuting\ncomplex securities fraud cases on behalf of institutional investors. Most recently, Ellman was on the team\nof Robbins Geller attorneys who obtained a $34.5 million recovery in Patel v. L-3 Communications Holdings,\nInc., which represents a high percentage of damages that plaintiffs could reasonably expect to be\nrecovered at trial and is more than eight times higher than the average settlement of cases with\ncomparable investor losses. He was also on the team of attorneys who recovered in excess of $34 million\nfor investors in In re OSG Sec. Litig., which represented an outsized recovery of 93% of bond purchasers\u2019\ndamages and 28% of stock purchasers\u2019 damages. The creatively structured settlement included more than\n$15 million paid by a bankrupt entity.\n\nEllman was also on the team of Robbins Geller attorneys who achieved final approval in Curran v. Freshpet,\nInc., which provides for the payment of $10.1 million for the benefit of eligible settlement class members.\nAdditionally, he was on the team of attorneys who obtained final approval of a $7.5 million recovery\nin Plymouth County Retirement Association v. Advisory Board Company. In 2006, Ellman received a Volunteer\nand Leadership Award from Housing Conservation Coordinators (HCC) for his pro bono service\ndefending a client in Housing Court against a non-payment action, arguing an appeal before the\nAppellate Term, and staffing HCC\u2019s legal clinic. He also successfully appealed a pro bono client\u2019s criminal\nsentence before the Appellate Division.\n\n\nEducation\nB.S., B.A., State University of New York at Binghamton, 1999; J.D., Georgetown University Law Center,\n2003\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2017-2025; Pro Bono Publico Award, Casa Cornelia Law Center,\n2021-2022; Rising Star, Super Lawyers Magazine, 2014-2015; B.S., B.A., Cum Laude, State University of New\nYork at Binghamton, 1999\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 76\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 80 of 159\n ATTORNEY BIOGRAPHIES\n\n\nWilliam J. Geddish | Partner\nWilliam Geddish is a partner with the Firm and is based in the Melville office, where his practice focuses\non complex securities litigation. Before joining the Firm, he was an associate in the New York office of a\nlarge international law firm, where his practice focused on complex commercial litigation.\n\nSince joining the Firm, Geddish has played a significant role in the following litigations: In re Barrick Gold\nSec. Litig. ($140 million recovery); Scheufele v. Tableau Software, Inc. ($95 million recovery); Landmen\nPartners, Inc. v. The Blackstone Grp., L.P. ($85 million recovery); In re Jeld-Wen Holding, Inc. Sec. Litig. ($40\nmillion recovery); City of Austin Police Ret. Sys. v. Kinross Gold Corp. ($33 million recovery); City of Roseville\nEmps\u2019 Ret. Sys. v. EnergySolutions, Inc. ($26 million recovery); Beaver Cnty. Emps\u2019 Ret. Fund v. Tile Shop\nHoldings, Inc. ($9.5 million recovery); and Barbara Marciano v. Schell & Kampeter, Inc. ($2 million recovery).\n\n\nEducation\nB.A., Sacred Heart University, 2006, J.D., Hofstra University School of Law, 2009\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024-2025; Rising Star, Super Lawyers Magazine,\n2013-2024; 500 X \u2013 The Next Generation, Lawdragon, 2023; J.D., Magna Cum Laude, Hofstra University\nSchool of Law, 2009; Gina Maria Escarce Memorial Award, Hofstra University School of Law\n\n\n\nPaul J. Geller | Partner\nPaul Geller is a founding partner of Robbins Geller and head of the Firm\u2019s Consumer Practice Group.\nOver the last 30 years, Geller has served as lead counsel in some of the country\u2019s most high-profile\nconsumer, antitrust, and securities class actions and has recovered billions for communities, consumers,\nand investors harmed by corporate abuse.\n\nBefore devoting his practice to the representation of consumers and investors, Geller defended companies\nin high-stakes class action and multi-district litigation, providing him with an invaluable perspective from\n\u201cboth sides of the \u2018v.\u2019\u201d An experienced trial lawyer, he has tried bench and jury trials on behalf of plaintiffs\nand defendants and has argued before numerous state, federal, and appellate courts throughout the\nUnited States.\n\nGeller\u2019s ability to earn respect and trust from all sides in difficult negotiations has been recognized by the\nbar and legal publications. Chambers notes that \u201cPaul is a consummate professional who has the ability to\nwork seamlessly and collaboratively to address daunting challenges that arise in complex mass tort\nlitigation.\u201d\n\nHe serves as a key leader of the nationwide litigation against the companies responsible for the U.S.\nopioid addiction crisis. He played a key role in negotiating and architecting the complex settlements that\nresulted in over $50 billion being paid to communities across the country struggling with the fallout of the\nopioid crisis.\n\nHe has also successfully litigated and negotiated precedent-setting class recoveries in multiple practice\nareas, including data privacy, antitrust, products liability, and securities cases.\n\n Facebook Data Privacy Case \u2013 $650 Million: He secured the then-largest privacy class action\n\n\n Robbins Geller Rudman & Dowd LLP | 77\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 81 of 159\n ATTORNEY BIOGRAPHIES\n\n settlement in history \u2013 a $650 million recovery in a cutting-edge class action against Facebook. The\n case concerned Facebook\u2019s use of biometric identifiers through its \u201ctag\u201d feature, which Geller\u2019s\n team challenged under a new biometric privacy law that had never before been applied in a class\n action. The federal judge that presided over the case called it a \u201clandmark result\u201d and a \u201cmajor win\n for consumers.\u201d In addition to the monetary recovery, Facebook disabled the tag feature\n altogether, deleting 1 billion facial profiles and discontinuing the related facial recognition\n program.\n Volkswagen \u201cClean Diesel\u201d Case \u2013 $17 Billion: Geller was a member of the leadership team\n representing consumers in the massive Volkswagen \u201cClean Diesel\u201d emissions case. The San\n Francisco legal newspaper The Recorder labeled the group that was appointed in that case, which\n settled for more than $17 billion, a \u201cclass action dream team.\u201d\n \u201cEpiPen\u201d Antitrust Case \u2013 $609 Million: As co-lead counsel, Geller secured a recovery of $609\n million for overcharged purchasers of the \u201cEpiPen\u201d device in a nationwide class action alleging that\n the manufacturer and marketer of the EpiPen engaged in anti-competitive and unfair business\n conduct in their sale and marketing of the auto-injector device. The American Antitrust Institute\n honored Geller and the litigation team for Outstanding Antitrust Litigation Achievement in\n Private Law Practice for this result.\n\n\nEducation\nB.S., University of Florida, 1990; J.D., Emory University School of Law, 1993\n\nHonors / Awards\nSenior Fellow, Litigation Counsel of America (LCA) Proven Trial Lawyers; Rated AV by Martindale-\nHubbell; Leading Lawyer in America, Lawdragon, 2006-2007, 2009-2026; Leading Litigator in America,\nLawdragon, 2024-2026; Best Lawyer in America, Best Lawyers\u00ae, 2017-2026; Leading Global\nLitigator, Lawdragon, 2025; Super Lawyer, Super Lawyers Magazine, 2007-2025; Recommended\nLawyer, The Legal 500, 2016, 2019, 2023-2025; Ranked by Chambers USA, 2021-2025; Leading Plaintiff\nFinancial Lawyer, Lawdragon, 2019-2025; Global Plaintiff Lawyer, Lawdragon, 2024-2025; Leading Plaintiff\nConsumer Lawyer, Lawdragon, 2022-2025; Outstanding Antitrust Litigation Achievement in Private Law\nPractice, American Antitrust Institute, 2022; South Trailblazer, The American Lawyer, 2022; Class Action\nMVP, Law360, 2022; Florida Best Lawyer in America, Best Lawyers\u00ae, 2017-2021; One of \u201cFlorida\u2019s Most\nEffective Lawyers\u201d in the Privacy category, American Law Media, 2020; Legend, Lawdragon, 2020;\nPlaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2018; Lawyer of the Year, Best Lawyers\u00ae, 2018;\nAttorney of the Month, Attorney At Law, 2017; Featured in \u201cLawyer Limelight\u201d\nseries, Lawdragon, 2017; Top Rated Lawyer, South Florida\u2019s Legal Leaders, Miami Herald, 2015; Litigation\nStar, Benchmark Litigation, 2013; \u201cLegal Elite,\u201d Florida Trend Magazine; One of \u201cFlorida\u2019s Most Effective\nLawyers,\u201d American Law Media; One of Florida\u2019s top lawyers in South Florida Business Journal; One of the\nNation\u2019s Top \u201c40 Under 40,\u201d The National Law Journal; One of Florida\u2019s Top Lawyers, Law & Politics;\nEditor, Emory Law Journal; Order of the Coif, Emory University School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 78\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 82 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRobert D. Gerson | Partner\nRobert Gerson is a partner in the Firm\u2019s Melville office, where he practices securities fraud litigation and\nother complex matters.\n\nSince joining the Firm, Gerson has played a significant role in prosecuting numerous high-stakes investor\nlitigations. Most recently, Gerson and a team of Robbins Geller attorneys obtained a $27.5 million\nsettlement in Luna v. Carbonite, Inc., following a precedent-setting decision by the U.S. Court of Appeals\nfor the First Circuit. Gerson was also a member of the team in In re Dell Technologies Inc. Class V\nStockholders Litigation, which settled in 2023 for $1 billion in cash \u2013 a record in the Delaware Chancery\nCourt and the largest settlement in U.S. state court history. Other notable cases Gerson has played a\ncritical role in at the Firm include: UA Local 13 & Employers Group Insurance Fund v. Sealed Air Corp. ($12.5\nmillion recovery); In re PPDAI Group Sec. Litig. ($9 million recovery); and Sponn v. Emergent BioSolutions\nInc. ($6.5 million recovery).\n\n\nEducation\nB.A., University of Maryland, 2006; J.D., New York Law School, 2009\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2021-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae,\n2024-2025; 500 X \u2013 The Next Generation, Lawdragon, 2023; Rising Star, Super Lawyers Magazine,\n2015-2020\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 79\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 83 of 159\n ATTORNEY BIOGRAPHIES\n\n\nElise J. Grace | Partner\nElise Grace is a partner in the San Diego office and counsels the Firm\u2019s institutional clients on options to\nsecure premium recoveries in securities litigation both within the United States and internationally.\nGrace is a frequent lecturer and author on securities and accounting fraud, and develops annual MCLE\nand CPE accredited educational programs designed to train public fund representatives on practices to\nprotect and maximize portfolio assets, create long-term portfolio value, and best fulfill fiduciary duties.\nGrace has routinely been named a Recommended Lawyer by The Legal 500 and named a Leading Plaintiff\nFinancial Lawyer by Lawdragon. Grace has prosecuted various significant securities fraud class actions, as\nwell as the AOL Time Warner state and federal securities opt-out litigations, which resulted in a combined\nsettlement of over $629 million for defrauded investors. Before joining the Firm, Grace practiced at\nClifford Chance, where she defended numerous Fortune 500 companies in securities class actions and\ncomplex business litigation.\n\n\nEducation\nB.A., University of California, Los Angeles, 1993; J.D., Pepperdine School of Law, 1999\n\nHonors / Awards\nSecurities Litigation Lawyer of the Year, Lawyer Monthly, 2023, 2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; Recommended Lawyer, The Legal 500, 2016-2017; J.D., Magna Cum\nLaude, Pepperdine School of Law, 1999; American Jurisprudence Bancroft-Whitney Award \u2013 Civil\nProcedure, Evidence, and Dalsimer Moot Court Oral Argument; Dean\u2019s Academic Scholarship Recipient,\nPepperdine School of Law; B.A., Summa Cum Laude, University of California, Los Angeles, 1993; B.A., Phi\nBeta Kappa, University of California, Los Angeles, 1993\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 80\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 84 of 159\n ATTORNEY BIOGRAPHIES\n\n\nTor Gronborg | Partner\nTor Gronborg is a partner in the Firm\u2019s San Diego office and a member of the Firm\u2019s Management\nCommittee. He often lectures on topics such as the Federal Rules of Civil Procedure and electronic\ndiscovery. Gronborg has served as lead or co-lead counsel in numerous securities fraud cases that have\ncollectively recovered more than $4.4 billion for investors. Most recently, Gronborg and a team of\nRobbins Geller attorneys obtained an $809 million settlement in In re Twitter, Inc. Sec. Litig., a case that did\nnot settle until the day before trial was set to commence.\n\nIn addition to Twitter, Gronborg\u2019s work has included significant recoveries against corporations such as\nValeant Pharmaceuticals ($1.21 billion), Cardinal Health ($600 million), Motorola ($200 million), Duke\nEnergy ($146.25 million), Sprint Nextel Corp. ($131 million), and Prison Realty ($104 million), to name a\nfew. Gronborg was also a member of the Firm\u2019s trial team in Hsu v. Puma Biotechnology, Inc., No.\nSACV15-0865 (C.D. Cal.), a securities fraud class action that resulted in a verdict in favor of investors after\na two-week jury trial and ultimately settled for 100% of the claimed damages plus prejudgment interest.\n\nOn three separate occasions, Gronborg\u2019s pleadings have been upheld by the federal Courts of Appeals\n(Broudo v. Dura Pharms., Inc., 339 F.3d 933 (9th Cir. 2003), rev\u2019d on other grounds, 544 U.S. 336 (2005); In re\nDaou Sys., 411 F.3d 1006 (9th Cir. 2005); Staehr v. Hartford Fin. Servs. Grp., 547 F.3d 406 (2d Cir. 2008)).\n\n\nEducation\nB.A., University of California, Santa Barbara, 1991; Rotary International Scholar, University of Lancaster,\nU.K., 1992; J.D., University of California, Berkeley, 1995\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2022-2026; Litigation Star, Benchmark Litigation, 2023-2026;\nNational Practice Area Star, Benchmark Litigation, 2025-2026; Best Lawyer in America, Best Lawyers\u00ae,\n2022-2026; Leading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Recommended Lawyer, The Legal\n500, 2023-2024; West Trailblazer, The American Lawyer, 2022; Super Lawyer, Super Lawyers\nMagazine, 2013-2022; Plaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2019; Moot Court Board\nMember, University of California, Berkeley; AFL-CIO history scholarship, University of California, Santa\nBarbara\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 81\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 85 of 159\n ATTORNEY BIOGRAPHIES\n\n\nEllen Gusikoff Stewart | Partner\nEllen Stewart is a partner in the Firm\u2019s San Diego office, and is a member of the Firm\u2019s Summer Associate\nHiring Committee. She currently practices in the Firm\u2019s settlement department, negotiating and\ndocumenting complex securities, merger, ERISA, and derivative action settlements. Notable recent\nsettlements include: Evanston Police Pension Fund v. McKesson Corp. (N.D. Cal. 2023) ($141 million); In re\nTwitter Inc. Sec. Litig. (N.D. Cal. 2022) ($809.5 million); In re Facebook Biometric Info. Privacy Litig. (N.D. Cal.\n2021) ($650 million); In re Am. Realty Cap. Props., Inc. Litig. (S.D.N.Y. 2020) ($1.025 billion); Klein v. Altria\nGroup, Inc. (E.D. Va. 2022) ($90 million); KBC Asset Management v. 3D Systems Corp. (D.S.C. 2018) ($50\nmillion); and Luna v. Marvell Tech. Grp. (N.D. Cal. 2018) ($72.5 million).\n\nStewart has served on the Federal Bar Association Ad Hoc Committee for the revisions to the Settlement\nGuidelines for the Northern District of California, was a contributor to the Guidelines and Best Practices \u2013\nImplementing 2018 Amendments to Rule 23 Class Action Settlement Provisions manual of the Bolch\nJudicial Institute at the Duke University School of Law, and speaks at conferences around country on\ncurrent settlement and notice issues.\n\n\nEducation\nB.A., Muhlenberg College, 1986; J.D., Case Western Reserve University, 1989\n\nHonors / Awards\nRated Distinguished by Martindale-Hubbell\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 82\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 86 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRobert Henssler | Partner\nBobby Henssler is a partner in the Firm\u2019s San Diego office, where he focuses his practice on securities\nfraud and other complex civil litigation. He has obtained significant recoveries for investors in cases such\nas Under Armour, Blackstone, and J.C. Penney.\n\nMost recently, Henssler led a team of Robbins Geller attorneys in obtaining a $434 million settlement\nin In re Under Armour Sec. Litig. The case was previously dismissed with prejudice in 2019, but then\nresurrected through a highly unusual procedural maneuver, a successful motion for an indicative ruling:\nasking the federal judge who had dismissed the case to issue an indicative opinion informing the Fourth\nCircuit that he would revive the original case if it were remanded to him. Over the next five years, the\nRobbins Geller team defeated defendants\u2019 motions for summary judgment and to exclude plaintiffs\u2019\nexpert witnesses. The case settled just weeks before a jury trial was set to begin in Baltimore, Maryland.\nThe $434 million recovery is the second largest securities-fraud settlement ever in the Fourth Circuit and\nis among the top 50 largest such recoveries in U.S. history.\n\nHenssler was also lead counsel in Schuh v. HCA Holdings, Inc., which resulted in a $215 million recovery\nfor shareholders, the largest securities class action recovery ever in Tennessee. The recovery achieved\nrepresents more than 30% of the aggregate classwide damages, far exceeding the typical recovery in a\nsecurities class action. Henssler has had many other successful results, including in In re Valeant Pharms.\nInt\u2019l, Inc. Sec. Litig. ($1.21 billion), Marcus v. J.C. Penney Company, Inc. ($97.5 million recovery), Landmen\nPartners Inc. v. The Blackstone Group L.P. ($85 million recovery), In re Novatel Wireless Sec. Litig. ($16 million\nrecovery), Carpenters Pension Trust Fund of St. Louis v. Barclays PLC ($14 million settlement), and Kmiec v.\nPowerwave Technologies, Inc. ($8.2 million settlement), to name a few.\n\n\nEducation\nB.A., University of New Hampshire, 1997; J.D., University of San Diego School of Law, 2001\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2025-2026; Leading Litigator in America, Lawdragon, 2024-2026;\nBest Lawyer in America, Best Lawyers\u00ae, 2025-2026; Leading Plaintiff Financial Lawyer, Lawdragon,\n2020-2021, 2023-2025; Top 100 Lawyer, Daily Journal, 2024; California Lawyer of the Year, Daily Journal,\n2022; Plaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2020; Recommended Lawyer, The Legal 500,\n2018-2019\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 83\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 87 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSteven F. Hubachek | Partner\nSteve Hubachek is a partner in the Firm\u2019s San Diego office. He is a member of the Firm\u2019s appellate\ngroup, where his practice concentrates on federal appeals. He has more than 25 years of appellate\nexperience, has argued over 100 federal appeals, including 3 cases before the United States Supreme\nCourt and 7 cases before en banc panels of the Ninth Circuit Court of Appeals. Prior to his work with the\nFirm, Hubachek joined Perkins Coie in Seattle, Washington, as an associate. He was admitted to the\nWashington State Bar in 1987 and was admitted to the California State Bar in 1990, practicing for many\nyears with Federal Defenders of San Diego, Inc. He also had an active trial practice, including over 30\njury trials, and was Chief Appellate Attorney for Federal Defenders.\n\n\nEducation\nB.A., University of California, Berkeley, 1983; J.D., University of California College of the Law, San\nFrancisco, 1987\n\nHonors / Awards\nAV rated by Martindale-Hubbell; Top Lawyer in San Diego, San Diego Magazine, 2014-2022; Super\nLawyer, Super Lawyers Magazine, 2007-2009, 2019-2021; Assistant Federal Public Defender of the Year,\nNational Federal Public Defenders Association, 2011; Appellate Attorney of the Year, San Diego Criminal\nDefense Bar Association, 2011 (co-recipient); President\u2019s Award for Outstanding Volunteer Service, Mid\nCity Little League, San Diego, 2011; E. Stanley Conant Award for exceptional and unselfish devotion to\nprotecting the rights of the indigent accused, 2009 (joint recipient); The Daily Transcript Top Attorneys,\n2007; J.D., Cum Laude, Order of the Coif, Thurston Honor Society, University of California College of the\nLaw, San Francisco, 1987\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 84\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 88 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAndrew W. Hutton | Partner\nDrew Hutton is a partner in the Firm\u2019s San Diego office. Hutton has prosecuted a variety of securities\nactions, achieving high-profile recoveries and results. Representative cases against corporations and their\nauditors include AOL Time Warner ($2.5 billion) and Williams Cos. ($311 million). Representative cases\nagainst corporations and their executives include Broadcom ($150 million), Bank OZK ($45 million),\nand Clarent (class plaintiff\u2019s 10b-5 jury verdict against former CEO). Hutton is also active in shareholder\nderivative litigation, achieving monetary recoveries and governance changes, including Premier ($71\nmillion), Affiliated Computer Servs. ($30 million), KB Home ($30 million), and KeyCorp (modified CEO stock\noptions and governance). Hutton has also litigated securities cases in bankruptcy court (WorldCom \u2013 $15\nmillion for individual claimant), and a complex options case before FINRA (eight-figure settlement for\nstructured products investor).\n\nHutton is also experienced in complex, multi-district consumer litigation. Representative nationwide\ninsurance cases include Prudential ($4 billion), Metro. Life Ins. Co. ($2 billion), and Conseco Life Ins.\nCo. ($200 million). Representative nationwide consumer lending cases include a $30 million class\nsettlement of Truth-in-Lending claims against American Express, and a $24 million class settlement of\nRICO and RESPA claims against Community Bank of Northern Virginia (now PNC Bank).\n\nBefore joining Robbins Geller, Hutton was a public company accountant, Certified Public Accountant,\nand broker of stocks, options, and insurance products. Hutton has also served as an expert litigation\nconsultant in both financial and corporate governance capacities. Hutton is often responsible for working\nwith experts retained by the Firm in litigation and has conducted dozens of depositions of financial\nprofessionals, including audit partners, CFOs, directors, bankers, actuaries, and opposing experts.\n\n\nEducation\nB.A., University of California, Santa Barbara, 1983; J.D., Loyola Law School, 1994\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 85\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 89 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJames I. Jaconette | Partner\nJames Jaconette is one of the founding partners of the Firm and is located in its San Diego office. He\nmanages cases in the Firm\u2019s securities class action and shareholder derivative litigation practices. He has\nserved as one of the lead counsel in securities cases with recoveries to individual and institutional investors\ntotaling over $8 billion. He also advises institutional investors, including hedge funds, pension funds, and\nfinancial institutions. Landmark securities actions in which he contributed in a primary litigating role\ninclude In re Informix Corp. Sec. Litig., and In re Dynegy Inc. Sec. Litig. and In re Enron Corp. Sec. Litig., where\nhe represented lead plaintiff The Regents of the University of California. Most recently, Jaconette was\npart of the trial team in Schuh v. HCA Holdings, Inc., which resulted in a $215 million recovery for\nshareholders, the largest securities class action recovery ever in Tennessee. The recovery achieved\nrepresents more than 30% of the aggregate classwide damages, far exceeding the typical recovery in a\nsecurities class action.\n\n\nEducation\nB.A., San Diego State University, 1989; M.B.A., San Diego State University, 1992; J.D., University of\nCalifornia Hastings College of the Law, 1995\n\nHonors / Awards\nLeading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; J.D., Cum Laude, University of California\nHastings College of the Law, 1995; Associate Articles Editor, Hastings Law Journal, University of California\nHastings College of the Law; B.A., with Honors and Distinction, San Diego State University, 1989\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 86\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 90 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJ. Marco Janoski Gray | Partner\nMarco Janoski is a partner in the Firm\u2019s San Diego office. His practice focuses on complex securities\nlitigation and class actions. An experienced litigator, Janoski has secured record-setting recoveries for\ninvestors, including trial verdicts and large recoveries secured on the eve of trial.\n\nJanoski recently served on the litigation team in In re Alphabet, Inc. Securities Litigation representing\nplaintiffs in a securities fraud case where Robbins Geller achieved a $350 million recovery. The recovery\nis the largest ever privacy or cybersecurity-related securities class action recovery and the Ninth Circuit\u2019s\nlargest ever securities class action recovery following a complete dismissal. Janoski also served on the\nlitigation teams in two securities fraud cases that are among the top ten securities recoveries of 2023: In re\nEnvision Healthcare Corporation Securities Litigation ($177.5 million recovery) and Louisiana Sheriffs\u2019 Pension\n& Relief Fund v. Cardinal Health, Inc. ($109 million recovery). He served on the Firm\u2019s trial team in In re\nTwitter, Inc. Securities Litigation and helped secure an $809.5 million recovery for investors.\nThe Twitter case settled the day before trial was set to commence in 2021 and is the largest securities fraud\nclass action recovery in the Ninth Circuit in the last decade. Likewise, he and a team of Firm lawyers\nsecured a $350 million settlement on the eve of trial in 2020 in Smilovits v. First Solar, Inc., the fifth-largest\nPSLRA settlement ever recovered in the Ninth Circuit at the time. Janoski also served on the Firm\u2019s trial\nteam in Hsu v. Puma Biotechnology, Inc., a securities fraud class action that resulted in a verdict in favor of\ninvestors after a two-week jury trial in federal court.\n\n\nEducation\nUniversidad Complutense de Madrid, 2010-2011; B.A., University of California, Santa Barbara, 2011;\nJ.D., University of California College of the Law, San Francisco (formerly UC Hastings), 2015\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; 40 & Under List, Benchmark Litigation, 2023-2025;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2023-2025; Rising Star, Super Lawyers Magazine,\n2024-2025; California Lawyer Attorney of the Year (CLAY), Daily Journal, 2024; 500 X \u2013 The Next\nGeneration, Lawdragon, 2023; J.D., Magna Cum Laude, University of California College of the Law, San\nFrancisco (formerly UC Hastings), 2015\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 87\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 91 of 159\n ATTORNEY BIOGRAPHIES\n\n\nPatton L. Johnson | Partner\nPatton Johnson is a partner in the Firm\u2019s San Diego office, where he focuses on securities class actions on\nbehalf of investors seeking redress for financial fraud.\n\nIn addition to his experience litigating securities cases, Johnson has substantial experience in financial\nmarkets and transactions. He previously represented institutional clients in connection with cross-\nborder financings, and before practicing law he worked at an global bank in New York and as an expat in\nHong Kong.\n\n\nEducation\nB.S., University of Colorado, Boulder, 2005; J.D., University of California College of the Law, 2017\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; J.D., Magna Cum Laude, University of\nCalifornia, Hastings College of the Law, 2017\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 88\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 92 of 159\n ATTORNEY BIOGRAPHIES\n\n\nEvan J. Kaufman | Partner\nEvan Kaufman is a partner in the Firm\u2019s Melville office. He has recovered hundreds of millions of dollars\nfor class members in securities, ERISA, and complex class actions.\n\nKaufman served as lead counsel in the SandRidge Energy securities litigation and obtained a $35.75 million\nglobal settlement, including $21.8 million for SandRidge common stock purchasers. As lead counsel in\nthe TD Banknorth litigation, Kaufman and the Firm achieved a $50 million recovery after successfully\nobjecting to a $3 million settlement submitted to the court on behalf of the class. The court in the TD\nBanknorth litigation stated: \u201cThis is one of the cases \u2013 there\u2019s probably been a half a dozen since I\u2019ve been a\njudge that I handled which have \u2013 really through the sheer diligence and effort of plaintiffs\u2019 counsel \u2013\nresulted in substantial awards for plaintiffs, after overcoming serious procedural and other barriers . . . it\nappears plainly from the papers that you and your co-counsel have diligently, and at great personal\nexpense and through the devotion of many thousands of hours of your time, prosecuted this case to a\nsuccessful conclusion.\u201d\n\nKaufman served as co-lead class counsel on behalf of 212,000 participants in General Electric\u2019s 401(k)\nplan and obtained $61 million for the class, which was the largest recovery ever in an ERISA case alleging\na retirement plan improperly offered proprietary funds. During the GE ERISA final settlement approval\nhearing, the court described the case as \u201chard-fought\u201d with \u201cinteresting and difficult issues.\u201d Kaufman\nserved as lead counsel or as an integral part of the team in other ERISA actions, including on behalf of\nparticipants in the retirement plans of Invesco, JP Morgan, and Wakemed.\n\nKaufman achieved notable results in numerous other securities class actions, including recovering $26\nmillion in the EnergySolutions litigation, and in cases against Lockheed Martin, State Street, Fidelity,\nWarner Chilcott, Talkspace, Third Avenue Management, and Giant Interactive, among others.\n\nIn the Third Avenue Management litigation, when approving the $14.25 million settlement obtained by\nKaufman and the Firm, the court commended the parties for their \u201cwisdom\u201d and \u201cdiligence\u201d and\nconcluded that \u201clead counsel diligently and with quality represented the interests of the class.\u201d In\nthe Giant Interactive litigation, the court acknowledged the efforts of Kaufman and the Firm in achieving\nthe favorable settlement for the class: \u201cThe Court also recognizes the diligence and hard work of plaintiffs\u2019\ncounsel in achieving such a settlement, particularly in light of the fact that this case (unlike many other\nsecurities class actions) was independently developed by plaintiffs\u2019 counsel, as opposed to following, or\npiggybacking on, a regulatory investigation or settlement.\u201d\n\n\nEducation\nB.A., University of Michigan, 1992; J.D., Fordham University School of Law, 1995\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2013-2015, 2017-2020, 2023-2025; Member, Fordham International\nLaw Journal, Fordham University School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 89\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 93 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAshley M. Kelly | Partner\nAshley Kelly is a partner in the Firm\u2019s San Diego office, where she represents large institutional and\nindividual investors as a member of the Firm\u2019s antitrust and securities fraud practices. Her work is\nprimarily federal and state class actions involving the federal antitrust and securities laws, common law\nfraud, breach of contract, and accounting violations. Kelly\u2019s case work has been in the financial services,\noil & gas, e-commerce, and technology industries. In addition to being an attorney, she is a Certified\nPublic Accountant. Kelly was an important member of the litigation team that obtained a $500 million\nsettlement on behalf of investors in Luther v. Countrywide Fin. Corp., which was the largest residential\nmortgage-backed securities purchaser class action recovery in history.\n\n\nEducation\nB.S., Pennsylvania State University, 2005; J.D., Rutgers University-Camden, 2011\n\nHonors / Awards\n500 X \u2013 The Next Generation, Lawdragon, 2023-2025; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2024-2025; Rising Star, Super Lawyers Magazine, 2016, 2018-2021\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 90\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 94 of 159\n ATTORNEY BIOGRAPHIES\n\n\nChristopher R. Kinnon | Partner\nChristopher Kinnon is a partner in the Firm\u2019s San Diego office, where his practice focuses on securities\nfraud litigation. Kinnon and a team of Robbins Geller attorneys obtained a $1.21 billion settlement in In\nre Valeant Pharms. Int\u2019l, Inc. Sec. Litig. (D.N.J.), a case that Vanity Fair reported as \u201cthe corporate scandal of\nits era\u201d that had raised \u201cfundamental questions about the functioning of our health-care system, the nature\nof modern markets, and the slippery slope of ethical rationalizations.\u201d This is the largest securities class\naction settlement against a pharmaceutical manufacturer and the ninth largest ever. In addition, Kinnon\nand a team of Robbins Geller attorneys obtained an $809 million settlement in In re Twitter, Inc. Sec. Litig.,\na case that did not settle until the day before trial was set to commence.\n\nMost recently, Kinnon was a key member of a team of Robbins Geller attorneys who obtained a $434\nmillion settlement in In re Under Armour Sec. Litig. The case was previously dismissed with prejudice in\n2019, but then resurrected through a highly unusual procedural maneuver, a successful motion for an\nindicative ruling: asking the federal judge who had dismissed the case to issue an indicative opinion\ninforming the Fourth Circuit that he would revive the original case if it were remanded to him. Over the\nnext five years, the Robbins Geller team defeated defendants\u2019 motions for summary judgment and to\nexclude plaintiffs\u2019 expert witnesses. The case settled just weeks before a jury trial was set to begin in\nBaltimore, Maryland. The $434 million recovery is the second largest securities-fraud settlement ever in\nthe Fourth Circuit and is among the top 50 largest such recoveries in U.S. history.\n\nKinnon is currently representing investors in securities fraud actions against Green Dot Corporation\n(C.D. Cal.) and PricewaterhouseCoopers LLP (D.N.J.).\n\nBefore law school, Kinnon was a municipal sanitation worker and an elected executive board member\nwith the Canadian Union of Public Employees, Local 1004 (CUPE 1004). Before that, he was a recording\nartist signed to prominent record labels in Canada and the United States.\n\n\nEducation\nB.A., University of British Columbia, 2008; J.D., University of Michigan Law School, 2017\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; Rising Star, Super Lawyers Magazine,\n2024-2025; California Lawyer of the Year, Daily Journal, 2022\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 91\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 95 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDavid A. Knotts | Partner\nDavid Knotts is a partner in the Firm\u2019s San Diego office. He focuses his practice on shareholder class\naction litigation in the context of mergers and acquisitions, representing both individual shareholders and\ninstitutional investors. Knotts is also part of the Firm\u2019s Delaware Practice Group and has taken multiple\ncases to trial in the Delaware Court of Chancery. Knotts has significant trial experience in high-stakes\ncorporate litigation.\n\nKnotts has been counsel of record for shareholders on a number of significant recoveries in courts\nthroughout the country, including serving as the lead litigator on Chabot v. Walgreens Boots Alliance, Inc.,\nwhich culminated in a $192.5 million recovery for a class of Rite Aid investors. The Walgreens settlement\nwas approved by the Middle District of Pennsylvania in February 2024 and resulted in the second largest\nsecurities recovery in Pennsylvania federal court history. That recovery represents a rarity in securities\nfraud litigation, whereby target-company investors obtained a significant cash recovery from an\nunaffiliated acquirer based on allegations that the acquirer issued misleading statements during the\npendency of a merger.\n\nKnotts also served as the lead litigator in Murray v. EarthLink Holdings Corp., which, after six years of\nlitigation, resulted in an $85 million settlement for former EarthLink stockholders in connection with the\nWindstream/EarthLink merger. The EarthLink settlement was approved by the Eastern District of\nArkansas in February 2025 and, at the time, resulted in the largest securities class action recovery in the\nEighth Circuit over the past five years.\n\nIn addition, Knotts served among lead counsel in In re Rural/Metro Corp. S\u2019holders Litig., which resulted in\na groundbreaking $110 million post-trial recovery affirmed by the Delaware Supreme Court, as well as In\nre Del Monte Foods Co. S\u2019holders Litig. ($89.4 million), Websense ($40 million), In re Onyx S\u2019holders Litig. ($30\nmillion), and Harman ($28 million). Websense and Onyx are both believed to be the largest post-merger\nclass settlements in California state court history. When Knotts presented the settlement as lead counsel\nfor the stockholders in Joy Global, the United States District Court for the Eastern District of Wisconsin\nnoted that \u201cthis is a pretty extraordinary settlement, recovery on behalf of the members of the class. . . .\n[I]t\u2019s always a pleasure to work with people who are experienced and who know what they are doing.\u201d\n\n\nEducation\nB.S., University of Pittsburgh, 2001; J.D., Cornell Law School, 2004\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2026; Litigation Star, Benchmark Litigation, 2026; Leading Plaintiff\nFinancial Lawyer, Lawdragon, 2024-2025; 40 & Under List, Benchmark Litigation, 2023; 40 & Under Hot\nList, Benchmark Litigation, 2018, 2020-2021; Next Generation Partner, The Legal 500, 2019-2021;\nRecommended Lawyer, The Legal 500, 2017-2019; Wiley W. Manuel Award for Pro Bono Legal Services,\nState Bar of California; Casa Cornelia Inns of Court; J.D., Cum Laude, Cornell Law School, 2004\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 92\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 96 of 159\n ATTORNEY BIOGRAPHIES\n\n\nPeter Ko | Partner\nPeter Ko is a partner in the Firm\u2019s San Diego office focused on complex investigation, litigation, trial, and\nappeals.\n\nBefore joining the Firm, Ko served 27 years as a federal prosecutor in Nevada and the Southern District\nof California, handling cases involving fraud, corruption, racketeering, and other crimes. He tried dozens\nof cases and litigated scores of appeals in federal courts and was assigned to handle numerous high-profile\nprosecutions of national or international significance. Since 2010, Ko also served at points as First\nAssistant United States Attorney, Chief of Criminal, Chief of Appeals, Chief of National Security and\nCybercrimes, and Senior Litigation Counsel. While at the U.S. Department of Justice (DOJ), Ko received\nthe Attorney General\u2019s Claudia J. Flynn Award for Professional Responsibility as well as the Director\u2019s\nAward for Superior Performance. He has taught trial advocacy, evidence, discovery, and other litigation\nsubjects for the DOJ and other agencies.\n\n\nEducation\nB.A., University of California, San Diego, 1992; J.D., UCLA School of Law, 1997\n\nHonors / Awards\nAttorney General\u2019s Claudia J. Flynn Award for Professional Responsibility; Director\u2019s Award for Superior\nPerformance, United States Attorney\u2019s Office\n\n\n\nKevin A. Lavelle | Partner\nKevin Lavelle is a partner in the Firm\u2019s San Diego office, where his practice focuses on complex securities\nlitigation.\n\nLavelle has served on numerous litigation teams and helped obtain over $500 million for investors. His\nwork includes several significant recoveries against corporations, including HCA Holdings, Inc. ($215\nmillion); Altria Group and JUUL Labs ($90 million); Endo Pharmaceuticals ($63 million); and Intercept\nPharmaceuticals ($55 million), among others.\n\n\nEducation\nB.A., College of the Holy Cross, 2008; J.D., Brooklyn Law School, 2013\n\nHonors / Awards\n500 X \u2013 The Next Generation, Lawdragon, 2023-2025; J.D., Cum Laude, Brooklyn Law School, 2013; B.A.,\nCum Laude, College of the Holy Cross, 2008\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 93\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 97 of 159\n ATTORNEY BIOGRAPHIES\n\n\nNathan R. Lindell | Partner\nNate Lindell is a partner in the Firm\u2019s San Diego office, where his practice focuses on representing\naggrieved investors in complex civil litigation. He has helped achieve numerous significant recoveries for\ninvestors, including: In re Enron Corp. Sec. Litig. ($7.2 billion recovery); In re HealthSouth Corp. Sec.\nLitig. ($671 million recovery); Luther v. Countrywide Fin. Corp. ($500 million recovery); Fort Worth Emps.\u2019\nRet. Fund v. J.P. Morgan Chase & Co. ($388 million recovery); NECA-IBEW Health & Welfare Fund v.\nGoldman Sachs & Co. ($272 million recovery); In re Morgan Stanley Mortg. Pass-Through Certificates Litig. ($95\nmillion recovery); Massachusetts Bricklayers & Masons Tr. Funds v. Deutsche Alt-A Sec., Inc. ($32.5 million\nrecovery); City of Ann Arbor Emps.\u2019 Ret. Sys. v. Citigroup Mortg. Loan Trust Inc. ($24.9 million\nrecovery); Plumbers\u2019 Union Loc. No. 12 Pension Fund v. Nomura Asset Acceptance Corp. ($21.2 million\nrecovery); and Genesee Cnty. Emps.\u2019 Ret. Sys. v. Thornburg Mortg., Inc. ($11.25 million recovery). In October\n2016, Lindell successfully argued in front of the New York Supreme Court, Appellate Division, First\nJudicial Department, for the reversal of an earlier order granting defendants\u2019 motion to dismiss in Phoenix\nLight SF Limited v. Morgan Stanley.\n\nLindell was also a member of the litigation team responsible for securing a landmark victory from the\nSecond Circuit Court of Appeals in its precedent-setting NECA-IBEW Health & Welfare Fund v. Goldman\nSachs & Co. decision, which dramatically expanded the scope of permissible class actions asserting claims\nunder the Securities Act of 1933 on behalf of mortgage-backed securities investors, and ultimately\nresulted in a $272 million recovery for investors.\n\n\nEducation\nB.S., Princeton University, 2003; J.D., University of San Diego School of Law, 2006\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015-2017; Charles W. Caldwell Alumni Scholarship, University of\nSan Diego School of Law; CALI/AmJur Award in Sports and the Law\n\n\n\nTing H. Liu | Partner\nTing Liu is a partner in the Firm\u2019s San Diego office, where she represents large institutional and\nindividual investors. Her practice focuses on complex securities litigation. Liu was a member of the trial\nteam that obtained a $350 million settlement on the eve of trial in Smilovits v. First Solar, Inc., the fifth-\nlargest PSLRA settlement recovered in the Ninth Circuit at the time. She was also a member of the Firm\u2019s\ntrial team in Hsu v. Puma Biotechnology, Inc., a securities fraud class action that resulted in a verdict in favor\nof investors after a two-week jury trial.\n\n\nEducation\nB.A., University of Washington, 2012; J.D., University of San Diego School of Law, 2015\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; 40 & Under List, Benchmark Litigation,\n2024-2025; Leading Plaintiff Financial Lawyer, Lawdragon, 2024-2025; Rising Star, Super Lawyers\nMagazine, 2023-2025; Rising Star, Law360, 2024\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 94\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 98 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRyan Llorens | Partner\nRyan Llorens is a partner in the Firm\u2019s San Diego office. Llorens\u2019 practice focuses on litigating complex\nsecurities fraud cases. He has worked on a number of securities cases that have resulted in significant\nrecoveries for investors, including: In re HealthSouth Corp. Sec. Litig. ($670 million); AOL Time Warner ($629\nmillion); In re AT&T Corp. Sec. Litig. ($100 million); In re Fleming Cos. Sec. Litig. ($95 million); and In re\nCooper Cos., Inc. Sec Litig. ($27 million).\n\n\nEducation\nB.A., Pitzer College, 1997; J.D., University of San Diego School of Law, 2002\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015\n\n\n\nAndrew S. Love | Partner\nAndrew Love is a partner in the Firm\u2019s San Francisco office and a member of the Firm\u2019s Appellate\nPractice Group. His practice focuses primarily on appeals of securities fraud class actions. Love has\nsuccessfully briefed and argued cases on behalf of defrauded investors and consumers in several U.S.\nCourts of Appeal, as well as in the California appellate courts. Recent published cases include Sherman v.\nAbengoa, S.A., __ F.4th __ , 2025 WL 2825369 (2d Cir. Oct. 6, 2025), New England Carpenters Guaranteed\nAnnuity Pension Funds v. DeCarlo, 122 F.4th 28 (2d Cir. 2023), Stafford v. Rite Aid Corp., 998 F.3d 862 (9th\nCir. 2021), Constr. Indus. & Laborers Joint Pension Tr. v. Carbonite, Inc., 22 F.4th 1 (1st Cir. 2021), and\nFriedman v. AARP, Inc., 855 F.3d 1047 (9th Cir. 2017). He was also co-counsel in Cyan, Inc. v. Beaver Cnty.\nEmps. Ret. Fund, 138 S. Ct. 1061 (2018).\n\nBefore joining the Firm and for more than two decades, Love represented inmates on California\u2019s death\nrow in appellate and habeas corpus proceedings, successfully arguing capital cases in both the California\nSupreme Court and the Ninth Circuit. He co-chaired the Capital Case Defense Seminar (2004-2013),\nrecognized as the largest conference for death penalty practitioners in the country. Additionally, he was\non the faculty of the National Institute for Trial Advocacy\u2019s Post-Conviction Skills Seminar. Love is a\nmember of the California Academy of Appellate Lawyers.\n\n\nEducation\nUniversity of Vermont, 1981; J.D., University of San Francisco School of Law, 1985\n\nHonors / Awards\nJ.D., Cum Laude, University of San Francisco School of Law, 1985; McAuliffe Honor Society, University of\nSan Francisco School of Law, 1982-1985\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 95\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 99 of 159\n ATTORNEY BIOGRAPHIES\n\n\nErik W. Luedeke | Partner\nErik Luedeke is a partner in the Firm\u2019s San Diego office, where he represents individual and institutional\ninvestors in breach of fiduciary duty and securities fraud litigation in state and federal courts nationwide.\nLuedeke is a member of the Firm\u2019s Delaware Practice Group. As corporate fiduciaries, directors and\nofficers are duty-bound to act in the best interest of the corporation and its shareholders. When they fail\nto do so they breach their fiduciary duty and may be held liable for harm caused to the corporation.\nLuedeke\u2019s shareholder derivative practice focuses on litigating breach of fiduciary duty and related claims\non behalf of corporations and shareholders injured by wayward corporate fiduciaries. Notable\nshareholder derivative actions in which he recently participated and the recoveries he helped to achieve\ninclude In re Community Health Sys., Inc. S'holder Derivative Litig. ($60 million in financial relief and\nunprecedented corporate governance reforms), In re Lumber Liquidators Holdings, Inc. S\u2019holder Derivative\nLitig. ($26 million in financial relief plus substantial governance), and In re Google Inc. S\u2019holder Derivative\nLitig. ($250 million in financial relief to fund substantial governance).\n\nLuedeke\u2019s practice also includes the prosecution of complex securities class action cases on behalf of\naggrieved investors. Luedeke was a member of the litigation team in Jaffe v. Household Int\u2019l, Inc., No.\n02-C-5893 (N.D. Ill.), that resulted in a record-breaking $1.575 billion settlement after 14 years of\nlitigation, including a six-week jury trial ending in a plaintiffs\u2019 verdict. He was also a member of the\nlitigation teams in In re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.) ($925 million\nrecovery), and In re Questcor Pharms., Inc. Sec. Litig., No. 8:12-cv-01623 (C.D. Cal.) ($38 million recovery).\n\n\nEducation\nB.S./B.A., University of California Santa Barbara, 2001; J.D., University of San Diego School of Law, 2006\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015-2017; Student Comment Editor, San Diego International Law\nJournal, University of San Diego School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 96\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 100 of 159\n ATTORNEY BIOGRAPHIES\n\n\nChristopher H. Lyons | Partner\nChristopher Lyons is a partner in the Firm\u2019s Nashville and Wilmington offices, and manages the\nWilmington office. He focuses his practice on representing institutional and individual investors in\nmerger-related class action litigation and in complex securities litigation. Lyons has been a significant\npart of litigation teams that have achieved substantial recoveries for investors. Notable Delaware cases\nthat Lyons has co-led include Bioverativ (Goldstein v. Denner) ($124 million recovery), Good Technology ($52\nmillion \u2013 about 1.5 times the consideration paid to common stockholders in the challenged private-\ncompany merger), Blackhawk Network Holdings ($29.5 million), and The Fresh Market (Morrison v. Berry)\n($27.5 million recovered). Lyons has also been part of teams litigating federal securities cases that led to\nsubstantial recoveries, including Envision ($177.5 million), CoreCivic (Grae v. Corrections Corporation of\nAmerica) ($56 million recovered), and Nissan ($36 million). His pro bono work includes representing\nindividuals who are appealing denial of necessary medical benefits by TennCare (Tennessee\u2019s Medicaid\nprogram), through the Tennessee Justice Center.\n\nBoth during and before his time at Robbins Geller, Lyons has litigated extensively in Delaware courts,\nhaving tried cases on behalf of both plaintiffs and defendants in the Delaware Court of Chancery. Before\njoining Robbins Geller, Lyons practiced at a prominent Delaware law firm, where he mostly represented\ncorporate officers and directors defending against breach of fiduciary duty claims in the Delaware Court\nof Chancery and in the Delaware Supreme Court. Before that, he clerked for Vice Chancellor J. Travis\nLaster of the Delaware Court of Chancery. Lyons now applies the expertise he gained from those\nexperiences to help investors uncover wrongful conduct and recover the money and other remedies to\nwhich they are rightfully entitled.\n\n\nEducation\nB.A., Colorado College, 2006; J.D., Vanderbilt University Law School, 2010\n\nHonors / Awards\n40 & Under List, Benchmark Litigation, 2023-2025; Recommended Lawyer, The Legal 500, 2024-2025;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2024-2025; Rising Star, Super Lawyers\nMagazine, 2018-2020, 2022-2024; Best Lawyer in America: One to Watch, Best Lawyers\u00ae, 2022-2024; 500\nX \u2013 The Next Generation, Lawdragon, 2023; 40 & Under Hot List, Benchmark Litigation, 2021;\nB.A., Distinction in International Political Economy, Colorado College, 2006; J.D., Law & Business\nCertificate, Vanderbilt University Law School, 2010\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 97\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 101 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMark T. Millkey | Partner\nMark Millkey is a partner in the Firm\u2019s Melville office. He has significant experience in the areas of\nsecurities and consumer litigation, as well as in federal and state court appeals.\n\nDuring his career, Millkey has worked on a major consumer litigation against MetLife that resulted in a\nbenefit to the class of approximately $1.7 billion, as well as a securities class action against Royal\nDutch/Shell that settled for a minimum cash benefit to the class of $130 million and a contingent value of\nmore than $180 million. Since joining Robbins Geller, he has worked on securities class actions that have\nresulted in more than $1.5 billion in settlements.\n\n\nEducation\nB.A., Yale University, 1981; M.A., University of Virginia, 1983; J.D., University of Virginia, 1987\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2013-2025\n\n\n\nDavid W. Mitchell | Partner\nDavid Mitchell is a partner in the Firm\u2019s San Diego office and focuses his practice on antitrust and\nsecurities fraud litigation. He is a former federal prosecutor who has tried nearly 20 jury trials. As head of\nthe Firm\u2019s Antitrust and Competition Law Practice Group, he has served as lead or co-lead counsel in\nnumerous cases and has helped achieve substantial settlements for shareholders. His most notable\nantitrust cases include Dahl v. Bain Cap. Partners, LLC, obtaining more than $590 million for shareholders,\nand In re Payment Card Interchange Fee and Merchant Discount Antitrust Litig., in which a settlement of\n$5.5 billion was approved in the Eastern District of New York. This case was brought on behalf of\nmillions of U.S. merchants against Visa and MasterCard and various card-issuing banks, challenging the\nway these companies set and collect tens of billions of dollars annually in merchant fees. The settlement is\nbelieved to be the largest antitrust class action settlement of all time.\n\nAdditionally, Mitchell served as co-lead counsel in the ISDAfix Benchmark action against 14 major banks\nand broker ICAP plc, obtaining $504.5 million for plaintiffs. Currently, Mitchell serves as court-\nappointed lead counsel in In re Aluminum Warehousing Antitrust Litig., City of Providence, Rhode Island v.\nBATS Global Markets Inc., In re SSA Bonds Antitrust Litig., In re Remicade Antitrust Litig., and In re 1-800\nContacts Antitrust Litig.\n\n\nEducation\nB.A., University of Richmond, 1995; J.D., University of San Diego School of Law, 1998\n\nHonors / Awards\nMember, Enright Inn of Court; Best Lawyer in America, Best Lawyers\u00ae, 2018-2026; Super Lawyer, Super\nLawyers Magazine, 2016-2025; Leading Plaintiff Financial Lawyer, Lawdragon, 2019-2024; Leading Lawyer\nin America, Lawdragon, 2020-2024; Top 50 Lawyers in San Diego, Super Lawyers Magazine, 2021; Southern\nCalifornia Best Lawyer, Best Lawyers\u00ae, 2018-2021; Honoree, Outstanding Antitrust Litigation\nAchievement in Private Law Practice, American Antitrust Institute, 2018; Antitrust Trailblazer, The\nNational Law Journal, 2015; \u201cBest of the Bar,\u201d San Diego Business Journal, 2014\n\n\n\n Robbins Geller Rudman & Dowd LLP | 98\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 102 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDanielle S. Myers | Partner\nDanielle Myers is a partner in the Firm\u2019s San Diego office and focuses her practice on complex securities\nlitigation. Myers oversees the Portfolio Monitoring Program\u00ae and provides legal recommendations to\nthe Firm\u2019s institutional investor clients on their options to maximize recoveries in securities litigation, both\nwithin the United States and internationally, from inception to settlement.\n\nMyers advises the Firm\u2019s clients in connection with lead plaintiff applications and has helped secure\nappointment of the Firm\u2019s clients as lead plaintiff and the Firm\u2019s appointment as lead counsel in\nhundreds of securities class actions, which cases have yielded more than $4 billion for investors, including\n2018-2024 recoveries in In re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., No. 3:15-cv-07658 (D.N.J.) ($1.2\nbillion); In re Am. Realty Cap. Props., Inc. Litig., No. 1:15-mc-00040 (S.D.N.Y.) ($1.025 billion); In re Twitter\nInc. Sec. Litig., No. 4:16-cv-05314 (N.D. Cal.) ($809.5 million); In re Apple Inc. Sec. Litig., No. 4:19-cv-02033\n(N.D. Cal.) ($490 million); In re Under Armour Sec. Litig., No. 1:17-cv-00388 (D. Md.) ($434\nmillion); Smilovits v. First Solar, Inc., No. 2:12-cv-00555 (D. Ariz.) ($350 million); Dicker v. TuSimple\nHoldings, Inc., No. 3:22-cv-01300 (S.D. Cal.) ($189 million); Flynn v. Exelon Corp., No. 1:19-cv-08209 (N.D.\nIll.) ($173 million); City of Pontiac Gen. Ret. Sys. v. Wal-Mart Stores, Inc., No. 5:12-cv-5162 (W.D. Ark.) ($160\nmillion); Evellard v. LendingClub Corp., No. 3:16-cv-02627 (N.D. Cal.) ($125 million); La. Sheriffs\u2019 Pension &\nRelief Fund v. Cardinal Health, Inc., No. 2:19-cv-03347 (S.D. Ohio) ($109 million); Knurr v. Orbital ATK,\nInc., No. 1:16-cv-01031 (E.D. Va.) ($108 million); In re Novo Nordisk Sec. Litig., No. 3:17-cv-00209 (D.N.J.)\n($100 million); Karinski v. Stamps.com, Inc., No. 2:19-cv-01828 (C.D. Cal.) ($100 million); and Marcus v. J.C.\nPenney Co., Inc., No. 6:13-cv-00736 (E.D. Tex.) ($97.5 million). Myers is also a frequent presenter on\nsecurities fraud and corporate governance reform at conferences and events around the world.\n\n\nEducation\nB.A., University of California at San Diego, 1997; J.D., University of San Diego, 2008\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2022-2026; Future Star, Benchmark Litigation, 2019-2020,\n2023-2026; Leading Litigator in America, Lawdragon, 2026; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2026; Leading Lawyer, The Legal 500, 2020-2025; Leading Plaintiff Financial Lawyer,\nLawdragon, 2022-2025; Global Plaintiff Lawyer, Lawdragon, 2024-2025; Best Lawyer in America: One to\nWatch, Best Lawyers\u00ae, 2021-2023; Top 100 Leaders in Law Honoree, San Diego Business Journal, 2022;\nBest Lawyer in Southern California: One to Watch, Best Lawyers\u00ae, 2021; Next Generation Lawyer, The\nLegal 500, 2017-2019; Recommended Lawyer, The Legal 500, 2019; Rising Star, Super Lawyers\nMagazine, 2015-2018; One of the \u201cFive Associates to Watch in 2012,\u201d Daily Journal; Member, San Diego Law\nReview; CALI Excellence Award in Statutory Interpretation\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 99\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 103 of 159\n ATTORNEY BIOGRAPHIES\n\n\nEric I. Niehaus | Partner\nEric Niehaus is a partner in the Firm\u2019s San Diego office, where his practice focuses on complex securities\nand derivative litigation. His efforts have resulted in numerous multi-million dollar recoveries to\nshareholders and extensive corporate governance changes. Notable examples include: In re NYSE\nSpecialists Sec. Litig. (S.D.N.Y.); In re Novatel Wireless Sec. Litig. (S.D. Cal.); Batwin v. Occam Networks,\nInc. (C.D. Cal.); Commc\u2019ns Workers of Am. Plan for Employees\u2019 Pensions and Death Benefits v. CSK Auto Corp. (D.\nAriz.); Marie Raymond Revocable Trust v. Mat Five (Del. Ch.); and Kelleher v. ADVO, Inc. (D. Conn.). He most\nrecently prosecuted a case against Stamps.com in the Central District of California that resulted in a $100\nmillion settlement for shareholders of the company\u2019s stock. Before joining the Firm, Niehaus worked as a\nMarket Maker on the American Stock Exchange in New York and the Pacific Stock Exchange in San\nFrancisco.\n\n\nEducation\nB.S., University of Southern California, 1999; J.D., California Western School of Law, 2005\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015-2016; J.D., Cum Laude, California Western School of Law, 2005;\nMember, California Western Law Review\n\n\n\nErika Oliver | Partner\nErika Oliver is a partner in the Firm\u2019s San Diego office. Before joining the Firm, Erika served as a judicial\nlaw clerk to the Honorable Anthony J. Battaglia of the Southern District of California. At the Firm, her\npractice focuses on complex securities litigation. Most recently, Erika and Luke Brooks defeated\ndefendants\u2019 motion to dismiss securities fraud claims arising from purchases on Israel\u2019s Tel Aviv Stock\nExchange in In re Teva Sec. Litig. (D. Conn.). Erika was also a member of the litigation teams of Robbins\nGeller attorneys that successfully recovered hundreds of millions of dollars for investors in securities class\nactions, including Purple Mountain Trust v. Wells Fargo & Co. (N.D. Cal.) ($300 million recovery), Evanston\nPolice Pension Fund v. McKesson Corp. (N.D. Cal.) ($141 million recovery), In re Novo Nordisk Sec.\nLitig. (D.N.J.) ($100 million recovery), Fleming v. Impax Labs. Inc. (N.D. Cal.) ($33 million recovery), and In\nre Banc of California Sec. Litig. (C.D. Cal.) ($19.75 million recovery).\n\n\nEducation\nB.S., San Diego State University, 2009; J.D., University of San Diego School of Law, 2015\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; 40 & Under List, Benchmark Litigation, 2023-2025;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2023-2025; Rising Star, Super Lawyers Magazine,\n2024-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae, 2021-2024; Top 40 Under 40, Daily\nJournal, 2023; 500 X \u2013 The Next Generation, Lawdragon, 2023; Rising Star, Law360, 2023; Best Lawyer in\nSouthern California: One to Watch, Best Lawyers\u00ae, 2021; J.D., Magna Cum Laude, University of San Diego\nSchool of Law, 2015; B.S., Cum Laude, San Diego State University, 2009\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 100\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 104 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLucas F. Olts | Partner\nLuke Olts is a partner in the Firm\u2019s San Diego office, where his practice focuses on securities litigation on\nbehalf of individual and institutional investors. Olts recently served as lead counsel in In re Facebook\nBiometric Info. Privacy Litig., a cutting-edge class action concerning Facebook\u2019s alleged privacy violations\nthrough its collection of users\u2019 biometric identifiers without informed consent that resulted in a $650\nmillion settlement. Olts has focused on litigation related to residential mortgage-backed securities, and\nhas served as lead counsel or co-lead counsel in some of the largest recoveries arising from the collapse of\nthe mortgage market. For example, he was a member of the team that recovered $388 million for\ninvestors in J.P. Morgan residential mortgage-backed securities in Fort Worth Emps.\u2019 Ret. Fund v. J.P.\nMorgan Chase & Co., and a member of the litigation team responsible for securing a $272 million\nsettlement on behalf of mortgage-backed securities investors in NECA-IBEW Health & Welfare Fund v.\nGoldman Sachs & Co. Olts also served as co-lead counsel in In re Wachovia Preferred Sec. & Bond/Notes Litig.,\nwhich recovered $627 million under the Securities Act of 1933. He also served as lead counsel in\nSiracusano v. Matrixx Initiatives, Inc., in which the U.S. Supreme Court unanimously affirmed the decision\nof the Ninth Circuit that plaintiffs stated a claim for securities fraud under \u00a710(b) of the Securities\nExchange Act of 1934 and SEC Rule 10b-5. Olts also served on the litigation team in In re Deutsche Bank\nAG Sec. Litig., in which the Firm obtained a $18.5 million settlement in a case against Deutsche Bank and\ncertain of its officers alleging violations of the Securities Act of 1933. Before joining the Firm, Olts served\nas a Deputy District Attorney for the County of Sacramento, where he tried numerous cases to verdict,\nincluding crimes of domestic violence, child abuse, and sexual assault.\n\n\nEducation\nB.A., University of California, Santa Barbara, 2001; J.D., University of San Diego School of Law, 2004\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2018-2020, 2023-2026; Global Plaintiff Lawyer, Lawdragon, 2024; Next\nGeneration Lawyer, The Legal 500, 2017; Top Litigator Under 40, Benchmark Litigation, 2017; Under 40\nHotlist, Benchmark Litigation, 2016\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 101\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 105 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSteven W. Pepich | Partner\nSteve Pepich is a partner in the Firm\u2019s San Diego office. His practice has focused primarily on securities\nclass action litigation, but has also included a wide variety of complex civil cases, including representing\nplaintiffs in mass tort, royalty, civil rights, human rights, ERISA, and employment law actions. Pepich has\nparticipated in the successful prosecution of numerous securities class actions, including: Carpenters Health\n& Welfare Fund v. Coca-Cola Co. ($137.5 million recovery); In re Fleming Cos. Inc. Sec. & Derivative\nLitig. ($95 million recovered); In re Boeing Sec. Litig.($92 million recovery); In re Louisiana-Pacific Corp. Sec.\nLitig. ($65 million recovery); Haw. Structural Ironworkers Pension Trust Fund v. Calpine Corp. ($43 million\nrecovery); In re Advanced Micro Devices Sec. Litig. ($34 million recovery); and Gohler v. Wood, ($17.2 million\nrecovery). Pepich was a member of the plaintiffs\u2019 trial team in Mynaf v. Taco Bell Corp., which settled after\ntwo months of trial on terms favorable to two plaintiff classes of restaurant workers for recovery of unpaid\nwages. He was also a member of the plaintiffs\u2019 trial team in Newman v. Stringfellow where, after a nine-\nmonth trial in Riverside, California, all claims for exposure to toxic chemicals were ultimately resolved for\n$109 million.\n\n\nEducation\nB.S., Utah State University, 1980; J.D., DePaul University, 1983\n\n\n\nDaniel J. Pfefferbaum | Partner\nDaniel Pfefferbaum is a partner in the Firm\u2019s San Francisco office, where his practice focuses on complex\nsecurities litigation. He has been a member of litigation teams that have recovered more than $750\nmillion for investors, including: In re Apple Inc. Sec. Litig. ($490 million recovery); City of Westland Police &\nFire Ret. Sys. v. Metlife Inc. ($84 million recovery); Garden City Emps.\u2019 Ret. Sys. v. Psychiatric Sols., Inc. ($65\nmillion recovery); In re Prudential Fin., Inc. Sec. Litig. ($35 million recovery); In re PMI Grp., Inc. Sec.\nLitig. ($31.25 million recovery); Hessefort v. Super Micro Computer, Inc. ($18.25 million recovery); and Xiang\nv. Inovalon Holdings, Inc. ($17 million recovery). Pfefferbaum was a member of the litigation team that\nsecured a historic recovery on behalf of Trump University students in two class actions against President\nDonald J. Trump. The settlement provides $25 million to approximately 7,000 consumers. This result\nmeans individual class members are eligible for upwards of $35,000 in restitution. He represented the\nclass on a pro bono basis.\n\n\nEducation\nB.A., Pomona College, 2002; J.D., University of San Francisco School of Law, 2006; LL.M. in Taxation,\nNew York University School of Law, 2007\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2018-2020, 2023-2026; 40 & Under Hot List, Benchmark Litigation,\n2016-2020; Top 40 Under 40, Daily Journal, 2017; Rising Star, Super Lawyers Magazine, 2013-2017\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 102\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 106 of 159\n ATTORNEY BIOGRAPHIES\n\n\nTheodore J. Pintar | Partner\nTed Pintar is a partner in the Firm\u2019s San Diego office. Pintar has over 20 years of experience prosecuting\nsecurities fraud actions and derivative actions and over 15 years of experience prosecuting insurance-\nrelated consumer class actions, with recoveries in excess of $1 billion. He was part of the litigation team in\nthe AOL Time Warner state and federal court securities opt-out actions, which arose from the 2001\nmerger of America Online and Time Warner. These cases resulted in a global settlement of $618 million.\nPintar was also on the trial team in Knapp v. Gomez, which resulted in a plaintiff\u2019s verdict. Pintar has\nsuccessfully prosecuted several RICO cases involving the deceptive sale of deferred annuities, including\ncases against Allianz Life Insurance Company of North America ($250 million), American Equity\nInvestment Life Insurance Company ($129 million), Midland National Life Insurance Company ($80\nmillion), and Fidelity & Guarantee Life Insurance Company ($53 million). He has participated in the\nsuccessful prosecution of numerous other insurance and consumer class actions, including: (i) actions\nagainst major life insurance companies such as Manufacturer\u2019s Life ($555 million initial estimated\nsettlement value) and Principal Mutual Life Insurance Company ($380+ million), involving the deceptive\nsale of life insurance; (ii) actions against major homeowners insurance companies such as Allstate ($50\nmillion) and Prudential Property and Casualty Co. ($7 million); (iii) actions against automobile insurance\ncompanies such as the Auto Club and GEICO; and (iv) actions against Columbia House ($55 million) and\nBMG Direct, direct marketers of CDs and cassettes. Pintar and co-counsel recently settled a securities\nclass action for $32.8 million against Snap, Inc. in Snap Inc. Securities Cases, a case alleging violations of the\nSecurities Act of 1933. Additionally, Pintar has served as a panelist for numerous Continuing Legal\nEducation seminars on federal and state court practice and procedure.\n\n\nEducation\nB.A., University of California, Berkeley, 1984; J.D., University of Utah College of Law, 1987\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Top Lawyer in San Diego, San Diego Magazine, 2013-2022;\nSuper Lawyer, Super Lawyers Magazine, 2014-2017; CAOC Consumer Attorney of the Year Award Finalist,\n2015; Note and Comment Editor, Journal of Contemporary Law, University of Utah College of Law; Note\nand Comment Editor, Journal of Energy Law and Policy, University of Utah College of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 103\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 107 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAshley M. Price | Partner\nAshley Price is a partner in the Firm\u2019s San Diego office. Her practice focuses on complex securities\nlitigation. Price is currently serving as lead counsel in Bucks Cnty. Emps. Ret. Sys. v. Norfolk Southern\nCorp. (N.D. Ga.), a case brought on behalf of Norfolk Southern\u2019s investors following the catastrophic\nderailment of one of Norfolk Southern\u2019s freight trains outside of East Palestine, Ohio. Having prevailed\nagainst defendants\u2019 attempt to dismiss the case, the team is now pressing forward to obtain evidence for\nproving at a jury trial investors\u2019 claims that defendants fraudulently misrepresented the safety of their\nrailroad operations.\n\nPrice also served as lead counsel in In re Am. Realty Cap. Props., Inc. Litig. (S.D.N.Y.), a case arising out of\nARCP\u2019s manipulative accounting practices, and obtained a $1.025 billion recovery. For five years, she and\nthe litigation team prosecuted nine different claims for violations of the Securities Exchange Act of 1934\nand the Securities Act of 1933, involving seven different stock or debt offerings and two mergers. The\nrecovery represents the highest percentage of damages of any major PSLRA case prior to trial and\nincludes the largest personal contributions by individual defendants in history.\n\nPrice was likewise a key member of many other successful Robbins Geller litigation teams,\nincluding Monroe Cnty. Emps.\u2019 Ret. Sys. v. Southern Co. (N.D. Ga.) ($87.5 million recovery), Strathclyde\nPension Fund v. Bank OZK (E.D. Ark.) ($45 million recovery), Micholle v. Ophthotech Corp. (S.D.N.Y.) ($29\nmillion recovery), and Mart v. Tactile Sys. Tech., Inc. (D. Minn.) ($5 million recovery).\n\n\nEducation\nB.A., Duke University, 2006; J.D., Washington University in St. Louis, School of Law, 2011\n\nHonors / Awards\n40 & Under List, Benchmark Litigation, 2023-2025; Leading Plaintiff Financial Lawyer, Lawdragon,\n2023-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae, 2023-2025; 500 X \u2013 The Next\nGeneration, Lawdragon, 2023-2024; 40 & Under Hot List, Benchmark Litigation, 2021; Rising Star, Super\nLawyers Magazine, 2016-2021\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 104\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 108 of 159\n ATTORNEY BIOGRAPHIES\n\n\nWillow E. Radcliffe | Partner\nWillow Radcliffe is a partner in the Firm\u2019s San Francisco office, where she concentrates her practice in\nsecurities class action litigation in federal court. She has been significantly involved in the prosecution of\nnumerous securities fraud claims, including actions filed against Pfizer, Inc. ($400 million recovery),\nCoreCivic (Grae v. Corrections Corporation of America) ($56 million recovery), Flowserve Corp. ($55 million\nrecovery), Santander Consumer USA Holdings Inc. ($47 million), NorthWestern Corp. ($40 million\nrecovery), Ashworth, Inc. ($15.25 million recovery), and Allscripts Healthcare Solutions, Inc. ($9.75\nmillion recovery). Additionally, Radcliffe has represented plaintiffs in other complex actions, including a\nclass action against a major bank regarding the adequacy of disclosures made to consumers in California\nrelated to access checks. Before joining the Firm, she clerked for the Honorable Maria-Elena James,\nMagistrate Judge for the United States District Court for the Northern District of California.\n\n\nEducation\nB.A., University of California, Los Angeles 1994; J.D., Seton Hall University School of Law, 1998\n\nHonors / Awards\nLeading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2021-2025; Best Lawyer in Northern California: One to Watch, Best Lawyers\u00ae, 2021; Plaintiffs\u2019\nLawyer Trailblazer, The National Law Journal, 2020; J.D., Cum Laude, Seton Hall University School of Law,\n1998; Most Outstanding Clinician Award; Constitutional Law Scholar Award\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 105\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 109 of 159\n ATTORNEY BIOGRAPHIES\n\n\nFrank A. Richter | Partner\nFrank Richter is a partner in the Firm\u2019s Chicago office, where he focuses on shareholder, antitrust, and\nclass action litigation.\n\nRichter was an integral member of the Robbins Geller team that secured a $1.21 billion settlement in In re\nValeant Pharms. Int\u2019l, Inc. Sec. Litig. (D.N.J.), which is the ninth-largest securities class action settlement in\nhistory and the largest ever against a pharmaceutical manufacturer. More recently, Richter\u2019s\nrepresentative matters include Exelon (N.D. Ill., $173 million settlement), which resolved securities claims\nstemming from the alleged concealment of an eight-year scheme to bribe a public official, as well\nas Nutanix (N.D. Cal., $71 million settlement), Oak Street Health (N.D. Ill., $60 million\nsettlement), and Grubhub (N.D. Ill., $42 million settlement). In addition, Richter was a member of\nlitigation teams that secured significant settlements in HCA (E.D. Tenn., $215 million), Sprint (D. Kan.,\n$131 million), Orbital ATK (E.D. Va., $108 million), Dana Corp. (N.D. Ohio, $64 million), Diplomat (N.D.\nIll., $15.5 million), LJM Funds (N.D. Ill., $12.85 million), and Camping World (N.D. Ill., $12.5 million).\n\nRichter also works on antitrust matters, including serving on the Plaintiffs\u2019 Steering Committee in In re\nDealer Mgmt. Sys. Antitrust Litig. (N.D. Ill.), and he represents plaintiffs as local counsel in class action and\nderivative shareholder litigation in Illinois state and federal courts.\n\n\nEducation\nB.A., Truman State University, 2007; M.M., DePaul University School of Music, 2009; J.D., DePaul\nUniversity College of Law, 2012\n\nHonors / Awards\n40 & Under List, Benchmark Litigation, 2023-2025; 500 X \u2013 The Next Generation, Lawdragon, 2023-2025;\nRising Star, Super Lawyers Magazine, 2017-2022; 40 & Under Hot List, Benchmark Litigation, 2021; J.D.,\nSumma Cum Laude, Order of the Coif, CALI Award for highest grade in seven courses, DePaul University\nCollege of Law, 2012\n\n\n\nDarren J. Robbins | Partner\nDarren Robbins is a founding partner of Robbins Geller Rudman & Dowd LLP. Over the last two\ndecades, Robbins has served as lead counsel in more than 100 securities class actions and has recovered\nbillions of dollars for investors. Robbins served as lead counsel in In re Am. Realty Cap. Props., Inc. Litig., a\nsecurities class action arising out of improper accounting practices, recovering more than $1 billion for\nclass members. The American Realty settlement represents the largest recovery as a percentage of damages\nof any major class action brought pursuant to the Private Securities Litigation Reform Act of 1995 and\nresolved prior to trial. The $1+ billion settlement included the largest personal contributions ($237.5\nmillion) ever made by individual defendants to a securities class action settlement.\n\nRobbins also led Robbins Geller\u2019s prosecution of wrongdoing related to the sale of residential mortgage-\nbacked securities (RMBS) prior to the global financial crisis, including an RMBS securities class action\nagainst Goldman Sachs that yielded a $272 million recovery for investors. Robbins served as co-lead\ncounsel in connection with a $627 million recovery for investors in In re Wachovia Preferred Securities &\nBond/Notes Litig., one of the largest securities class action settlements ever involving claims brought solely\nunder the Securities Act of 1933.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 106\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 110 of 159\n ATTORNEY BIOGRAPHIES\n\nOne of the hallmarks of Robbins\u2019 practice has been his focus on corporate governance reform.\nIn UnitedHealth, a securities fraud class action arising out of an options backdating scandal,\nRobbins represented lead plaintiff CalPERS and obtained the cancellation of more than 3.6 million stock\noptions held by the company\u2019s former CEO and secured a record $925 million cash recovery for\nshareholders. He also negotiated sweeping corporate governance reforms, including the election of a\nshareholder-nominated director to the company\u2019s board of directors, a mandatory holding period for\nshares acquired via option exercise, and compensation reforms that tied executive pay to performance.\nRecently, Robbins led a shareholder derivative action brought by several pension funds on behalf of\nCommunity Health Systems, Inc. that yielded a $60 million payment to Community Health as well as\ncorporate governance reforms that included two shareholder-nominated directors, the creation and\nappointment of a Healthcare Law Compliance Coordinator, the implementation of an executive\ncompensation clawback in the event of a restatement, the establishment of an insider trading controls\ncommittee, and the adoption of a political expenditure disclosure policy.\n\n\nEducation\nB.S., University of Southern California, 1990; M.A., University of Southern California, 1990; J.D.,\nVanderbilt Law School, 1993\n\nHonors / Awards\nLitigation Star, Benchmark Litigation, 2023-2026; Best Lawyer in America, Best Lawyers\u00ae, 2010-2026; Hall\nof Fame, The Legal 500, 2023-2025; Ranked by Chambers USA, 2014-2025; California - Litigation\nStar, Benchmark Litigation, 2024-2025; Lawyer of the Year: Litigation \u2013 Securities, Best Lawyers\u00ae, 2023,\n2025; California Lawyer Attorney of the Year (CLAY), Daily Journal, 2022, 2024; Top 10 Lawyers in San\nDiego, Super Lawyers Magazine, 2024; Leading Lawyer, The Legal 500, 2020-2022; Top 50 Lawyers in San\nDiego, Super Lawyers Magazine, 2015, 2021; Litigator of the Week, The American Lawyer, 2021; Southern\nCalifornia Best Lawyer, Best Lawyers\u00ae, 2012-2021; Local Litigation Star, Benchmark Litigation, 2013-2018,\n2020; Recommended Lawyer, The Legal 500, 2011, 2017, 2019; Benchmark California Star, Benchmark\nLitigation, 2019; State Litigation Star, Benchmark Litigation, 2019; Lawyer of the Year, Best Lawyers\u00ae, 2017;\nInfluential Business Leader, San Diego Business Journal, 2017; Litigator of the Year, Our City San\nDiego, 2017; One of the Top 100 Lawyers Shaping the Future, Daily Journal; One of the \u201cYoung Litigators\n45 and Under,\u201d The American Lawyer; Attorney of the Year, California Lawyer; Managing Editor, Vanderbilt\nJournal of Transnational Law, Vanderbilt Law School\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 107\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 111 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRobert J. Robbins | Partner\nRobert Robbins is a partner in the Firm\u2019s Boca Raton office. He focuses his practice on investigating\nsecurities fraud, initiating securities class actions, and helping institutional and individual shareholders\nlitigate their claims to recover investment losses caused by fraud. Representing shareholders in all aspects\nof class actions brought pursuant to the federal securities laws, Robbins provides counsel in numerous\nsecurities fraud class actions across the country, helping secure significant recoveries for investors.\n\nRecently, Robbins was a key member of the Robbins Geller litigation team that secured a $1.21 billion\nsettlement in In re Valeant Pharms. Int\u2019l, Inc. Sec. Litig., a case that Vanity Fair reported as \u201cthe corporate\nscandal of its era\u201d that had raised \u201cfundamental questions about the functioning of our health-care system,\nthe nature of modern markets, and the slippery slope of ethical rationalizations.\u201d This is the ninth largest\nsecurities class action settlement ever and the largest against a pharmaceutical manufacturer. Robbins has\nalso been a member of Robbins Geller litigation teams responsible for securing hundreds of millions of\ndollars in securities class action settlements, including: Hospira ($60 million recovery); 3D Systems ($50\nmillion); CVS Caremark ($48 million recovery); Baxter International ($42.5 million recovery); Grubhub ($42\nmillion); R.H. Donnelley ($25 million recovery); Spiegel ($17.5 million recovery); TECO Energy ($17.35\nmillion recovery); AFC Enterprises ($17.2 million recovery); Accretive Health ($14 million recovery); Lender\nProcessing Services ($14 million recovery); Lexmark Int\u2019l ($12 million); Imperial Holdings ($12 million\nrecovery); Mannatech ($11.5 million recovery); Newpark Resources ($9.24 million recovery); CURO\nGroup ($8.98 million); Gilead Sciences ($8.25 million recovery); TCP International ($7.175 million\nrecovery); Cryo Cell International ($7 million recovery); Gainsco ($4 million recovery); and Body\nCentral ($3.425 million recovery).\n\n\nEducation\nB.S., University of Florida, 1999; J.D., University of Florida College of Law, 2002\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; Leading Plaintiff Financial Lawyer, Lawdragon,\n2019-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024; Rising Star, Super Lawyers\nMagazine, 2015-2017; J.D., High Honors, University of Florida College of Law, 2002; Member, Journal of\nLaw and Public Policy, University of Florida College of Law; Member, Phi Delta Phi, University of Florida\nCollege of Law; Pro bono certificate, Circuit Court of the Eighth Judicial Circuit of Florida; Order of the\nCoif\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 108\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 112 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDavid A. Rosenfeld | Partner\nDavid Rosenfeld, a partner in the Firm\u2019s Melville office, has focused his legal practice for more than 20\nyears in the area of securities litigation. He has argued in courts throughout the country, has been\nappointed lead counsel in dozens of securities fraud lawsuits, and has successfully recovered hundreds of\nmillions of dollars for defrauded shareholders.\n\nRosenfeld works on all stages of litigation, including drafting pleadings, arguing motions, and negotiating\nsettlements. Most recently, he led the teams of Robbins Geller attorneys in recovering $95 million for\nshareholders of Tableau Software, Inc., $90 million for shareholders of Altria Group, Inc., $40 million for\nshareholders of BRF S.A, $20 million for shareholders of Grana y Montero (where shareholders\nrecovered more than 90% of their losses), and $34.5 million for shareholders of L-3 Communications\nHoldings, Inc.\n\nRosenfeld also led the Robbins Geller team in recovering in excess of $34 million for investors in Overseas\nShipholding Group, which represented an outsized recovery of 93% of bond purchasers\u2019 damages and\n28% of stock purchasers\u2019 damages. The creatively structured settlement included more than $15 million\npaid by a bankrupt entity. Rosenfeld also led the effort that resulted in the recovery of nearly 90% of\nlosses for investors in Austin Capital, a sub-feeder fund of Bernard Madoff. In connection with this\nlawsuit, Rosenfeld met with and interviewed Madoff in federal prison in Butner, North Carolina.\n\nRosenfeld has also achieved remarkable recoveries against companies in the financial industry. In\naddition to being appointed lead counsel in the securities fraud lawsuit against First BanCorp ($74.25\nmillion recovery), he recovered $70 million for investors in Credit Suisse Group and $14 million for\nBarclays investors.\n\n\nEducation\nB.S., Yeshiva University, 1996; J.D., Benjamin N. Cardozo School of Law, 1999\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2016-2020, 2023-2026; Super Lawyer, Super Lawyers Magazine,\n2014-2025; Recommended Lawyer, The Legal 500, 2018; Rising Star, Super Lawyers Magazine, 2011-2013\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 109\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 113 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRobert M. Rothman | Partner\nRobert Rothman is a partner in the Firm\u2019s New York office and a member of the Firm\u2019s Management\nCommittee. He has recovered well in excess of $1 billion on behalf of victims of investment fraud,\nconsumer fraud, and antitrust violations.\n\nRecently, Rothman served as lead counsel in In re Am. Realty Cap. Props., Inc. Litig. where he obtained a\n$1.025 billion cash recovery on behalf of investors. Rothman and the litigation team prosecuted nine\ndifferent claims for violations of the Securities Exchange Act of 1934 and the Securities Act of 1933,\ninvolving seven different stock or debt offerings and two mergers. The recovery represents the highest\npercentage of damages ever obtained in a major PSLRA case before trial and includes the largest personal\ncontributions by individual defendants in history. Additionally, Rothman has recovered hundreds of\nmillions of dollars for investors in cases against First Bancorp, Doral Financial, Popular, iStar, Autoliv,\nCVS Caremark, Fresh Pet, The Great Atlantic & Pacific Tea Company (A&P), NBTY, Spiegel, American\nSuperconductor, Iconix Brand Group, Black Box, OSI Pharmaceuticals, Gravity, Caminus, Central\nEuropean Distribution Corp., OneMain Holdings, The Children\u2019s Place, CNinsure, Covisint, FleetBoston\nFinancial, Interstate Bakeries, Hibernia Foods, Jakks Pacific, Jarden, Portal Software, Ply Gem Holdings,\nOrion Energy, Tommy Hilfiger, TD Banknorth, Teletech, Unitek, Vicuron, Xerium, W Holding, and\ndozens of others.\n\nRothman also has achieved significant monetary recoveries for shareholders in connection with going-\nprivate transactions and tender offers. In addition, he also actively litigates consumer fraud cases,\nincluding a case alleging false advertising where the defendant agreed to a settlement valued in excess of\n$67 million.\n\n\nEducation\nB.A., State University of New York at Binghamton, 1990; J.D., Hofstra University School of Law, 1993\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2025-2026; Super Lawyer, Super Lawyers Magazine, 2011,\n2013-2025; Leading Plaintiff Financial Lawyer, Lawdragon, 2022-2025; Global Plaintiff Lawyer, Lawdragon,\n2024-2025; Northeast Trailblazer, The American Lawyer, 2022; New York Trailblazer, New York Law Journal,\n2020; Dean\u2019s Academic Scholarship Award, Hofstra University School of Law; J.D., with Distinction,\nHofstra University School of Law, 1993; Member, Hofstra Law Review, Hofstra University School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 110\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 114 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSamuel H. Rudman | Partner\nSam Rudman is a founding member of the Firm, a member of the Firm\u2019s Management Committee, and\nmanages the Firm\u2019s New York offices. His 26-year securities practice focuses on recognizing and\ninvestigating securities fraud, and initiating securities and shareholder class actions to vindicate\nshareholder rights and recover shareholder losses. Rudman is also part of the Firm\u2019s SPAC Task Force,\nwhich is dedicated to rooting out and prosecuting fraud on behalf of injured investors in special purpose\nacquisition companies. A former attorney with the SEC, Rudman has recovered hundreds of millions of\ndollars for shareholders, including a $200 million recovery in Motorola, a $129 million recovery in Doral\nFinancial, an $85 million recovery in Blackstone, a $74 million recovery in First BanCorp, a $65 million\nrecovery in Forest Labs, a $62.5 million recovery in SQM, a $50 million recovery in TD Banknorth, a $48\nmillion recovery in CVS Caremark, a $34.5 million recovery in L-3 Communications Holdings, a $32.8 million\nrecovery in Snap, Inc., and a $18.5 million recovery in Deutsche Bank.\n\n\nEducation\nB.A., Binghamton University, 1989; J.D., Brooklyn Law School, 1992\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2016-2022, 2025-2026; Litigation Star, Benchmark Litigation, 2013,\n2017-2019, 2023-2026; National Practice Area Star, Benchmark Litigation, 2019-2020, 2024-2026; Leading\nLitigator in America, Lawdragon, 2026; Super Lawyer, Super Lawyers Magazine, 2007-2025; Recommended\nLawyer, The Legal 500, 2018-2019, 2023-2025; Ranked by Chambers USA, 2014-2025; Leading Plaintiff\nFinancial Lawyer, Lawdragon, 2019-2025; Global Plaintiff Lawyer, Lawdragon, 2025; Top 10 Most\nInfluential Securities Litigation Attorney in New York, Business Today, 2023; New York Trailblazer, New\nYork Law Journal, 2020; Plaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2020; Local Litigation\nStar, Benchmark Litigation, 2013-2020; Dean\u2019s Merit Scholar, Brooklyn Law School; Moot Court Honor\nSociety, Brooklyn Law School; Member, Brooklyn Journal of International Law, Brooklyn Law School\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 111\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 115 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJoseph Russello | Partner\nJoseph Russello is a partner in the Firm\u2019s Melville office. He began his career as a defense lawyer and\nnow represents investors in securities class actions at the trial and appellate levels.\n\nRusello spearheaded the team that recovered $85 million in litigation against The Blackstone Group,\nLLC, a case that yielded a landmark decision from the Second Circuit Court of Appeals on \u201cmateriality\u201d in\nsecurities actions. Litwin v. Blackstone Grp., L.P., 634 F.3d 706 (2d Cir. 2011). He also led the team\nresponsible for partially defeating dismissal and achieving a $50 million settlement in litigation against\nBHP Billiton, an Australia-based mining company accused of concealing safety issues at a Brazilian iron-\nore dam. In re BHP Billiton Ltd. Sec. Litig., 276 F. Supp. 3d 65 (S.D.N.Y. 2017).\n\nRecently, Rusello was co-counsel in a lawsuit against Allied Nevada Gold Corporation, recovering $14.5\nmillion for investors after the Ninth Circuit Court of Appeals reversed two dismissal decisions. In re Allied\nNev. Gold Corp. Sec. Litig., 743 F. App\u2019x 887 (9th Cir. 2018). He was also instrumental in obtaining a\nsettlement and favorable appellate decision in litigation against SAIC, Inc., a defense contractor embroiled\nin a decade-long overbilling fraud against the City of New York. Ind. Pub. Ret. Sys. v. SAIC, Inc., 818 F.3d\n85 (2d Cir. 2016). Other notable recent decisions include: In re Qudian Sec. Litig.,189 A.D. 3d 449 (N.Y.\nApp. Div., 1st Dep\u2019t 2020); Kazi v. XP Inc., 2020 WL 4581569 (N.Y. Sup. Ct. Aug. 5, 2020); In re Dentsply\nSirona, Inc. S\u2019holders Litig., 2019 WL 3526142 (N.Y. Sup. Ct. Aug. 2, 2019); and Matter of PPDAI Grp. Sec.\nLitig., 64 Misc. 3d 1208(A), 2019 WL 2751278 (N.Y. Sup. Ct. 2019). Other notable settlements\ninclude: NBTY, Inc. ($16 million); LaBranche & Co., Inc. ($13 million); The Children\u2019s Place Retail Stores, Inc.\n($12 million); and Prestige Brands Holdings, Inc. ($11 million).\n\n\nEducation\nB.A., Gettysburg College, 1998; J.D., Hofstra University School of Law, 2001\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2014-2020, 2023-2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; Law360 Securities Editorial Advisory Board, 2017-2022\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 112\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 116 of 159\n ATTORNEY BIOGRAPHIES\n\n\nScott H. Saham | Partner\nScott Saham is a partner in the Firm\u2019s San Diego office, where his practice focuses on complex securities\nlitigation. He is licensed to practice law in both California and Michigan. Most recently, Saham was a\nmember of the litigation team that obtained a $125 million settlement in In re LendingClub Sec. Litig., a\nsettlement that ranked among the top ten largest securities recoveries ever in the Northern District of\nCalifornia. He was also part of the litigation teams in Schuh v. HCA Holdings, Inc., which resulted in a\n$215 million recovery for shareholders, the largest securities class action recovery ever in Tennessee,\nand Luna v. Marvell Tech. Grp., Ltd., which resulted in a $72.5 million settlement that represents\napproximately 24% to 50% of the best estimate of classwide damages suffered by investors. He also served\nas lead counsel prosecuting the Pharmacia securities litigation in the District of New Jersey, which resulted\nin a $164 million recovery. Additionally, Saham was lead counsel in the In re Coca-Cola Sec. Litig. in the\nNorthern District of Georgia, which resulted in a $137.5 million recovery after nearly eight years of\nlitigation. He also obtained reversal from the California Court of Appeal of the trial court\u2019s initial\ndismissal of the landmark Countrywide mortgage-backed securities action. This decision is reported\nas Luther v. Countrywide Fin. Corp., 195 Cal. App. 4th 789 (2011), and following this ruling that revived the\naction the case settled for $500 million.\n\n\nEducation\nB.A., University of Michigan, 1992; J.D., University of Michigan Law School, 1995\n\nHonors / Awards\nLeading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Distinguished Pro Bono Attorney of the Year,\nCasa Cornelia Law Center, 2022\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 113\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 117 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJuan Carlos Sanchez | Partner\nJuan Carlos \u201cJ.C.\u201d Sanchez is a partner in the Firm\u2019s San Diego office. He specializes in complex securities\nlitigation and has extensive experience advising investors on their exposure to securities fraud and\nadvising them on their litigation options for recovering losses. He has advised institutional and retail\ninvestors in more than 70 securities class actions that yielded more than $1.5 billion in class-wide\nrecoveries.\n\nSanchez was a key member of the litigation team that secured the largest shareholder derivative recovery\never in Tennessee and the Sixth Circuit and unprecedented corporate governance reforms in In re\nCommunity Health Sys., Inc. S\u2019holder Derivative Litig. More recently, Sanchez was a member of the Robbins\nGeller litigation team that ultimately obtained a $434 million settlement in In re Under Armour Sec. Litig., a\ncase that was previously dismissed with prejudice in 2019 but then resurrected through a highly unusual\nprocedural maneuver \u2013 a successful motion asking the federal judge who had dismissed the case to issue\nan indicative opinion informing the Fourth Circuit that he would revive the original case if it were\nremanded to him. The $434 million recovery is the second largest securities fraud settlement ever in the\nFourth Circuit and is among the top 50 largest such recoveries in U.S. history. Beyond securities\nlitigation, Sanchez\u2019s representation of California passengers in a landmark consumer and civil rights case\nagainst Greyhound Lines, Inc. led to a ruling recognizing that transit passengers do not check their rights\nand dignity at the bus door. Law360 honored Sanchez and the Greyhound litigation team as a Consumer\nProtection Group of the Year in 2019.\n\nBefore joining Robbins Geller, Sanchez served as a judicial law clerk to the Honorable Nelva Gonzales\nRamos of the U.S. District Court for the Southern District of Texas.\n\n\nEducation\nB.S., University of California, Davis, 2005; J.D., University of California, Berkeley School of Law (Boalt\nHall), 2014\n\nHonors / Awards\nLeading Litigator in America, Lawdragon, 2024-2026; 500 X - The Next Generation, Lawdragon,\n2025; Leading Plaintiff Financial Lawyer, Lawdragon, 2023-2025\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 114\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 118 of 159\n ATTORNEY BIOGRAPHIES\n\n\nVincent M. Serra | Partner\nVincent Serra is a partner in the Firm\u2019s Melville office. His practice focuses primarily on complex\nsecurities and consumer actions, but has also included antitrust, employment, insurance, and\nenvironmental litigation. His efforts have contributed to the recovery of billions of dollars on behalf of\naggrieved plaintiffs and class members and significant injunctive relief for individuals and municipalities\nthroughout the country. Notably, Serra has contributed to several noteworthy recoveries, including Dahl\nv. Bain Cap. Partners, LLC ($590.5 million recovery), an antitrust action against the world\u2019s largest private\nequity firms alleging collusive practices in multi-billion dollar leveraged buyouts, and Samit v. CBS Corp.\n($14.75 million recovery), a securities action alleging that defendants made false and misleading\nstatements about their knowledge of former CEO Leslie Moonves\u2019s exposure to the #MeToo movement.\n\nAdditionally, Serra was a member of the litigation team that obtained a $22.75 million settlement fund on\nbehalf of route drivers in Veliz v. Cintas Corp., an action asserting violations of federal and state overtime\nlaws. He was also part of the successful trial team in Lebrilla v. Farmers Grp., Inc., which involved Farmers\u2019\npractice of using inferior imitation parts when repairing insureds\u2019 vehicles. Other notable cases include In\nre Payment Card Interchange Fee and Merchant Discount Antitrust Litig. ($5.5 billion recovery), In re DouYu Int\u2019l\nHoldings Ltd. Sec. Litig. ($15 million state court securities recovery) and Kail v. Wolf Appliance, Inc.\n(confidential settlement in breach of warranty actions involving faulty blue porcelain oven cavities).\n\nSerra has litigated several actions against manufacturers and retailers alleging the improper marketing\nand sale of purportedly \u201cflushable\u201d wipes products, including consumer fraud, nuisance, and strict\nproduct liability claims. For example, in Commissioners of Public Works of the City of Charleston (d.b.a.\nCharleston Water System) v. Costco Wholesale Corp., Serra led the prosecution of seven defendants resulting in\nindustrywide settlements that secured commitments from the leading flushable wipes manufacturers and\nretailers to meet the national municipal wastewater standard for flushability and enhance \u201cdo not flush\u201d\nlabeling for non-flushable wipes, helping to meaningfully reduce wipes-related sewer impacts for\nmunicipalities and wastewater utilities nationwide. Serra also recently helped secure additional\nnationwide relief on behalf of the Charleston Water System in an analogous settlement with Dude\nProducts Inc.\n\n\nEducation\nB.A., University of Delaware, 2001; J.D., California Western School of Law, 2005\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024-2025; Wiley W. Manuel Award for Pro Bono\nLegal Services, State Bar of California\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 115\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 119 of 159\n ATTORNEY BIOGRAPHIES\n\n\nTaeva C. Shefler | Partner\nTaeva Shefler is a partner in the Firm\u2019s San Francisco office and focuses her practice on consumer and\nsecurities fraud litigation. Along with other Robbins Geller attorneys, Shefler worked on behalf of cities\nand counties around the country in In re National Prescription Opiate Litigation. In 2022, Shefler\nparticipated on the trial team in a federal bench trial in San Francisco in a case that had been selected as a\nbellwether in the multi-district litigation. The trial has resulted in combined settlements of over $350\nmillion for San Francisco, including a nearly $230 million settlement with Walgreens, and more than $50\nbillion nationally from multiple pharmaceutical companies who were defendants in the national litigation.\n\nShefler also worked to address the opioid crisis on behalf of cities and counties across the country in\nanother multi-district litigation, In re McKinsey Prescription Opiate Consultant Litigation, seeking to hold\nMcKinsey & Co., Inc., one of the world\u2019s leading business consultants, accountable for playing a \u201ccentral\nrole in the unfolding, propagation, and exploitation of the opioid crisis by advising multiple opioid\nmanufacturers and other industry participants how to sell as many opioids as conceivably possible,\u201d\naccording to the complaint. On February 2, 2024, the court granted final approval over a $230 million\nsettlement between McKinsey, government subdivisions, and school districts to resolve claims about its\nrole in facilitating the U.S. opioid crisis.\n\nShefler was also part of the team on the national Juul litigation, In re Juul Labs, Inc., Marketing, Sales\nPractices, and Product Liability Litigation. On September 19, 2023, the plaintiffs, for which Robbins\nGeller serves on the steering committee, secured final approval of a $255 million class action settlement\nwith JUUL Labs, Inc. in the e-cigarette youth vaping predatory advertising, fraud, addiction, and injury\nmulti-district litigation. The settlement with JUUL is part of a series of settlements on behalf of class,\npersonal injury, and subdivision plaintiffs with cases in the multi-district litigation. Separately, a $235\nmillion settlement with Altria received final approval in March 2024. The settlement was reached shortly\nafter the plaintiffs\u2019 case was presented in a bellwether trial in San Francisco.\n\nBefore joining Robbins Geller, Shefler spent years representing whistleblowers in cases alleging fraud\nagainst federal and state governments in the areas of environmental cleanup, government contracting,\nand healthcare. She has also represented public and private water suppliers in mass tort cases alleging\ncontamination of drinking water due to the use of toxic chemicals in agricultural areas across California.\n\n\nEducation\nB.A., University of Oregon Clark Honors College, 2007; J.D., New York University School of Law, 2013\n\nHonors / Awards\n500 X - The Next Generation, Lawdragon, 2023-2025; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2024-2025; Rising Star, Super Lawyers Magazine, 2022-2023; J.D., Cum Laude, New York\nUniversity School of Law, 2013; B.A., Magna Cum Laude, University of Oregon Clark Honors College,\n2007\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 116\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 120 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSam S. Sheldon | Partner\nSam Sheldon is a partner in the Firm\u2019s San Diego office, where he focuses on securities fraud and other\ncomplex civil litigation. Before joining the Firm in January 2024, Sheldon served more than five years as\na United States Magistrate Judge in the Southern District of Texas, primarily in Houston. He wrote\nopinions in almost every area of the law, including securities fraud, intellectual property, class actions,\nlabor and employment, False Claims Act, and criminal law.\n\nMost recently, Sheldon was a part of a team of Robbins Geller attorneys that successfully obtained a $434\nmillion settlement in In re Under Armour Sec. Litig. The case settled just weeks before a jury trial was set to\nbegin in Baltimore, Maryland. The $434 million recovery is the second largest securities fraud settlement\never in the Fourth Circuit and is among the top 50 largest such recoveries in U.S. history.\n\nBefore taking the federal bench, Sheldon was a partner with Quinn Emanuel in the Washington, D.C.\noffice and headed the firm\u2019s Health Care Practice Group. He represented plaintiffs in landmark cases\nbrought under the federal False Claims Act.\n\nSheldon previously served as Chief of the Health Care Fraud Unit in the DOJ Criminal Division in\nWashington, D.C., where he oversaw the prosecution of federal health care fraud throughout the United\nStates. He also was an Assistant United States Attorney in Texas. Earlier in his career, Sheldon was a\npartner with Cozen O\u2019Connor in the San Diego office. Sheldon has tried 25 cases as a federal prosecutor\nand civil litigator. He received numerous awards for his successful federal prosecutions from the DOJ\nand other federal agencies including the Special Achievement Award presented by the United States\nAttorney General.\n\n\nEducation\nB.A., University of Southern California, 1992; M.A., University of Southern California, 1994; J.D.,\nUniversity of Houston Law Center, 1997\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2026; Leading Litigator in America, Lawdragon, 2026; Leading\nPlaintiff Financial Lawyer, Lawdragon, 2024-2025; Prosecutor Leadership Award presented by the\nInspector General for the United States Department of Health and Human Services, 2013; Special Award\nfrom the Director of the FBI for excellent work with the Medicare Fraud Taskforce, 2013; Exceptional\nService Award presented by the United States Assistant Attorney General, 2011; Special Achievement\nAward presented by the United States Attorney General for Sustained Superior Performance of Duty,\n2010; International Achievement Award from the Assistant Director of the Department of Homeland\nSecurity for prosecuting the first illegal exportation of goods case in the Southern District of Texas (under\n18 U.S.C. \u00a7554), 2010; Special Award from the Director of the FBI for prosecuting the first agricultural\nfraud case in the United States (under 7 U.S.C. \u00a77711), 2009\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 117\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 121 of 159\n ATTORNEY BIOGRAPHIES\n\n\nArthur L. Shingler III | Partner\nArthur Shingler is a partner in the Firm\u2019s San Diego office. Shingler has successfully represented both\npublic and private sector clients in hundreds of complex, multi-party actions with billions of dollars in\ndispute. Throughout his career, he has obtained outstanding results for those he has represented in cases\ngenerally encompassing shareholder derivative and securities litigation, unfair business practices and\nantitrust litigation, publicity rights and advertising litigation, ERISA litigation, and other insurance, health\ncare, employment, and commercial disputes.\n\nRepresentative matters in which Shingler has served as a core member of the litigation team or settlement\ncounsel include, among others: In re EpiPen (Epinephrine Injection, USP) Marketing, Sales Practices &\nAntitrust Litig., No. 2:17-md-02785 (D. Kan.) ($609 million total recovery achieved weeks prior to trial in\ncertified class action alleging antitrust claims involving the illegal reverse payment settlement to delay the\ngeneric EpiPen, which allowed the prices of the life-saving EpiPen to rise over 600% in 9 years); In re\nRemicade Antitrust Litig., No. 2:17-cv-04326 (E.D. Pa.) ($25 million recovery for indirect purchasers in\nantitrust action); In re Liquid Aluminum Sulfate Antitrust Litig., No. 2:16-md-02687 (D.N.J.) (direct\npurchaser class settled in excess of $100 million); NECA-IBEW Health & Welfare Fund v. Goldman Sachs &\nCo., No. 1:08-cv-10783 (S.D.N.Y.) ($272 million recovery); In re Royal Dutch/Shell ERISA Litig., No.\n3:04-cv-00374 (D.N.J.) ($90 million settlement); In re Priceline.com Sec. Litig., No. 3:00-cv-01884 (D. Conn.)\n($80 million settlement); In re General Motors ERISA Litig., No. 05-71085 (E.D. Mich.) ($37.5 million\nsettlement, in addition to significant revision of retirement plan administration); Wood v. Ionatron, Inc.,\nNo. 4:06-cv-00354 (D. Ariz.) ($6.5 million settlement); In re Lattice Semiconductor Corp. Derivative Litig., No.\nC 043327CV (Or. Cir. Ct., Wash. Cnty.) (corporate governance settlement, including substantial revision\nof board policies and executive management); In re 360networks Class Action Sec. Litig., No. 1:02-cv-04837\n(S.D.N.Y.) ($7 million settlement); and Rothschild v. Tyco Int\u2019l (US), Inc., 83 Cal. App. 4th 488 (2000)\n(shaped scope of California\u2019s Unfair Practices Act as related to limits of State\u2019s False Claims Act).\n\nIn addition, Shingler is currently working on behalf of plaintiffs in several class actions, including, for\nexample, In re National Prescription Opiate Litig., No. 1:17-md-02804 (N.D. Ohio), and In re American\nAirlines/JetBlue Antitrust Litig., No. 1:22-cv-07374 (E.D.N.Y.).\n\n\nEducation\nB.A., Point Loma Nazarene College, 1989; J.D., Boston University School of Law, 1995\n\nHonors / Awards\nB.A., Cum Laude, Point Loma Nazarene College, 1989\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 118\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 122 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJessica T. Shinnefield | Partner\nJessica Shinnefield is a partner in the Firm\u2019s San Diego office. Currently, her practice focuses on\ninitiating, investigating, and prosecuting securities fraud class actions. Shinnefield served as lead counsel\nin In re Am. Realty Cap. Props., Inc. Litig., a case arising out of ARCP\u2019s manipulative accounting practices,\nand obtained a $1.025 billion recovery. For five years, she and the litigation team prosecuted nine\ndifferent claims for violations of the Securities Exchange Act of 1934 and the Securities Act of 1933,\ninvolving seven different stock or debt offerings and two mergers. The recovery represents the highest\npercentage of damages of any major PSLRA case prior to trial and includes the largest personal\ncontributions by individual defendants in history. Shinnefield also served as lead counsel in Smilovits v.\nFirst Solar, Inc., and obtained a $350 million settlement on the eve of trial. The settlement is fifth-largest\nPSLRA settlement ever recovered in the Ninth Circuit.\n\nShinnefield was also a member of the litigation team prosecuting actions against investment banks and\nleading national credit rating agencies for their roles in structuring and rating structured investment\nvehicles backed by toxic assets in Abu Dhabi Commercial Bank v. Morgan Stanley & Co. Incorporated and King\nCounty, Washington v. IKB Deutsche Industriebank AG. These cases were among the first to successfully allege\nfraud against the rating agencies, whose ratings have traditionally been protected by the First\nAmendment. Shinnefield also litigated individual opt-out actions against AOL Time Warner \u2013 Regents of\nthe Univ. of Cal. v. Parsons and Ohio Pub. Emps. Ret. Sys. v. Parsons (recovery more than $600 million).\nAdditionally, she litigated an action against Omnicare, in which she helped obtain a favorable ruling for\nplaintiffs from the United States Supreme Court. Shinnefield has also successfully appealed lower court\ndecisions in the Second, Seventh, and Ninth Circuit Courts of Appeals.\n\n\nEducation\nB.A., University of California at Santa Barbara, 2001; J.D., University of San Diego School of Law, 2004\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2026; Future Star, Benchmark Litigation, 2023-2026; Leading\nPlaintiff Financial Lawyer, Lawdragon, 2019-2025; California Lawyer Attorney of the Year (CLAY), Daily\nJournal, 2024; Top Woman Lawyer, Daily Journal, 2024; Best Lawyer in America: One to Watch, Best\nLawyers\u00ae, 2023; Plaintiffs\u2019 Lawyers Trailblazer, The National Law Journal, 2021; Litigator of the Week, The\nAmerican Lawyer, 2020; Rising Star, Super Lawyers Magazine, 2015-2019; 40 & Under Hot List, Benchmark\nLitigation, 2018-2019; B.A., Phi Beta Kappa, University of California at Santa Barbara, 2001\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 119\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 123 of 159\n ATTORNEY BIOGRAPHIES\n\n\nElizabeth A. Shonson | Partner\nElizabeth Shonson is a partner in the Firm\u2019s Boca Raton office. She concentrates her practice on\nrepresenting investors in class actions brought pursuant to the federal securities laws. Shonson has\nlitigated numerous securities fraud class actions nationwide, helping achieve significant recoveries for\naggrieved investors. She was a member of the litigation teams responsible for recouping millions of\ndollars for defrauded investors, including: In re Massey Energy Co. Sec. Litig. (S.D. W.Va.) ($265 million);\nNieman v. Duke Energy Corp. (W.D.N.C.) ($146.25 million recovery); In re ADT Inc. S\u2019holder Litig. (Fla. Cir.\nCt., 15th Jud. Cir.) ($30 million settlement); Eshe Fund v. Fifth Third Bancorp (S.D. Ohio) ($16 million); City\nof St. Clair Shores Gen. Emps. Ret. Sys. v. Lender Processing Servs., Inc. (M.D. Fla.) ($14 million); and In re\nSynovus Fin. Corp. (N.D. Ga.) ($11.75 million).\n\n\nEducation\nB.A., Syracuse University, 2001; J.D., University of Florida Levin College of Law, 2005\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2016-2019; J.D., Cum Laude, University of Florida Levin College of\nLaw, 2005; Editor-in-Chief, Journal of Technology Law & Policy; Phi Delta Phi; B.A., with Honors, Summa\nCum Laude, Syracuse University, 2001; Phi Beta Kappa\n\n\n\nTrig Smith | Partner\nTrig Smith is a partner in the Firm\u2019s San Diego office where he focuses his practice on complex securities\nlitigation. He has been involved in the prosecution of numerous securities class actions that have resulted\nin over a billion dollars in recoveries for investors. His cases have included: In re Cardinal Health, Inc. Sec.\nLitig. ($600 million recovery); Jones v. Pfizer Inc. ($400 million recovery); Silverman v. Motorola, Inc. ($200\nmillion recovery); and City of Livonia Emps.\u2019 Ret. Sys. v. Wyeth ($67.5 million). Most recently, he was a\nmember of the Firm\u2019s trial team in Hsu v. Puma Biotechnology, Inc., a securities fraud class action that\nresulted in a verdict in favor of investors after a two-week jury trial.\n\n\nEducation\nB.S., University of Colorado, Denver, 1995; M.S., University of Colorado, Denver, 1997; J.D., Brooklyn\nLaw School, 2000\n\nHonors / Awards\nBest Lawyer in America, Best Lawyers\u00ae, 2024-2026; Member, Brooklyn Journal of International Law,\nBrooklyn Law School; CALI Excellence Award in Legal Writing, Brooklyn Law School\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 120\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 124 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMark Solomon | Partner\nMark Solomon is a founding and managing partner of the Firm and leads its international litigation\npractice. Over the last 32 years, he has regularly represented United States and United Kingdom-based\npension funds and asset managers in class and non-class securities litigation in federal and state courts\nthroughout the United States. He was first admitted to the Bar of England and Wales as a Barrister (he is\nnon-active) and is an active member of the Bars of Ohio, California, and various United States federal\ndistrict and appellate courts.\n\nSince joining the practice in 1993, Solomon has spearheaded the prosecution of many significant\nsecurities fraud cases, recovering billions of dollars for defrauded investors. The recoveries are the\nproduct of multi-million and multi-hundred million dollar pre-trial settlements his teams and his clients\nhave been able to achieve, enhanced by a track record of taking such cases successfully through jury trial\nwhere necessary. An additional feature of his practice is the significant corporate governance reforms\ndesigned to limit recidivism and promote appropriate standards that he has introduced in the resolution\nof major cases.\n\nSolomon currently is counsel to a number of U.K. pension funds that are serving or have served as lead\nplaintiffs in cases throughout the United States in the last ten years. He represented Norfolk Pension\nFund in the securities fraud class action against Apple Inc. and Apple executives in In re Apple Inc. Sec.\nLitig. in the federal district court for the Northern District of California, which resulted in a settlement\nshortly before trial of $490 million payable by the defendants to the investor class \u2013 the third-largest ever\nsecurities fraud recovery in the Northern District and the fifth-largest in the Ninth Circuit. He\nrepresented North East Scotland Pension Fund in the securities fraud class action against Under Armour\nand Under Armour executives In re Under Armour Sec. Litig. in the federal district court for the District of\nMaryland, which resulted in a settlement shortly before trial of $434 million payable by the defendants to\nthe investor class \u2013 the second-largest ever securities fraud recovery in the Fourth Circuit. In addition, the\nmonetary recovery was accompanied by important governance reforms, including the separation of the\nCEO and BOD Chair and restraints on restricted stock awards to senior executives. He represented the\nBritish Coal Staff Superannuation Scheme and the Mineworkers\u2019 Pension Scheme in Smilovits v. First Solar,\nInc. in the federal district court for the District of Arizona in which the class recovered $350 million on the\neve of trial. That settlement resulted in the largest-ever securities fraud recovery in the District of Arizona\nand the seventh-largest in the Ninth Circuit. He represented the U.K.\u2019s Norfolk Pension Fund in Hsu v.\nPuma Biotechnology, Inc. where, in the federal district court for the Central District of California, after three\nweeks of trial, the Fund obtained a jury verdict valued at over $54 million in favor of the class against the\ncompany and its CEO. He represented Strathclyde Pension Fund in Strathclyde Pension Fund v. Bank OZK,\na class action against Bank OZK and its CEO, in the federal district court for the Eastern District of\nArkansas in which the class recovered $45 million. He represented Strathclyde Pension Fund in In re Ply\nGem Holdings, Inc. Sec. Litig. where the class recovered $26 million. Before all of those cases, in a case in\n2000 against Helionetics, Inc. and its senior executives, Solomon had presented to a jury, and won, one of\nthe very few securities fraud class actions ever taken to trial.\n\nIn ongoing litigation, Solomon represents Los Angeles County Employees Retirement Association and the\nclass in a securities fraud class action pending against FirstEnergy Corp. and FirstEnergy executives in the\nfederal district court for the Southern District of Ohio and he represents Norfolk Pension Fund and the\nputative class in the securities fraud class action In re Anadarko Petroleum Corp. Sec. Litig. against Anadarko\nPetroleum Corporation and former Anadarko executives, pending in the federal district court for the\nSouthern District of Texas.\n\n\nEducation\n\n Robbins Geller Rudman & Dowd LLP | 121\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 125 of 159\n ATTORNEY BIOGRAPHIES\n\nB.A., Trinity College, Cambridge University, England, 1985; L.L.M., Harvard Law School, 1986; Inns of\nCourt School of Law, Degree of Utter Barrister, England, 1987\n\nHonors / Awards\nBest Lawyer in America, Best Lawyers\u00ae, 2025-2026; Outstanding Individual Contribution - Service\nProvider, LGC Investment Awards, Local Government Chronicle, 2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; Global Plaintiff Lawyer, Lawdragon, 2024-2025; Litigator of the Week, The\nAmLaw Litigation Daily, 2024; Super Lawyer, Super Lawyers Magazine, 2017-2018; Recommended\nLawyer, The Legal 500, 2016-2017; Lizette Bentwich Law Prize, Trinity College, 1983 and 1984; Hollond\nTravelling Studentship, 1985; Harvard Law School Fellowship, 1985-1986; Member and Hardwicke\nScholar of the Honourable Society of Lincoln\u2019s Inn\n\n\n\nHillary B. Stakem | Partner\nHillary Stakem is a partner in the Firm\u2019s San Diego office, where her practice focuses on complex\nsecurities litigation. Stakem was a member of the litigation team in Jaffe v. Household Int\u2019l, Inc., a securities\nclass action that obtained a record-breaking $1.575 billion settlement after 14 years of litigation, including\na six-week jury trial in 2009 that resulted in a verdict for plaintiffs. She was also a member of the\nlitigation teams that secured a $388 million recovery for investors in J.P. Morgan residential mortgage-\nbacked securities in Fort Worth Employees\u2019 Retirement Fund v. J.P. Morgan Chase & Co., and that obtained a\n$350 million settlement on the eve of trial in Smilovits v. First Solar, Inc., the fifth-largest PSLRA settlement\never recovered in the Ninth Circuit. Stakem also helped secure a $131 million recovery in favor of\nplaintiffs in Bennett v. Sprint Nextel Corp, a $100 million settlement for shareholders in Karinski v.\nStamps.com, a $97.5 million recovery in Marcus v. J.C. Penney Company, Inc., and an $87.5 million settlement\nin Monroe County Employees\u2019 Retirement System v. The Southern Company.\n\n\nEducation\nB.A., College of William and Mary, 2009; J.D., UCLA School of Law, 2012\n\nHonors / Awards\n40 & Under List, Benchmark Litigation, 2023-2025; 500 X \u2013 The Next Generation, Lawdragon,\n2023-2025; California Lawyer Attorney of the Year (CLAY), Daily Journal, 2024; Rising Star, Super Lawyers\nMagazine, 2021-2022; 40 & Under Hot List, Benchmark Litigation, 2021; B.A., Magna Cum Laude, College of\nWilliam and Mary, 2009\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 122\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 126 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJeffrey J. Stein | Partner\nJeffrey Stein is a partner in the Firm\u2019s San Diego office, where he practices securities fraud litigation and\nother complex matters. He was a member of the litigation team that secured a historic recovery on behalf\nof Trump University students in two class actions against President Donald J. Trump. The settlement\nprovides $25 million to approximately 7,000 consumers. This result means individual class members are\neligible for upwards of $35,000 in restitution. Stein represented the class on a pro bono basis.\n\nBefore joining the Firm, Stein focused on civil rights litigation, with special emphasis on the First, Fourth,\nand Eighth Amendments. In this capacity, he helped his clients secure successful outcomes before the\nUnited States Supreme Court and the Ninth Circuit Court of Appeals.\n\n\nEducation\nB.S., University of Washington, 2005; J.D., University of San Diego School of Law, 2009\n\n\n\nChristopher D. Stewart | Partner\nChristopher Stewart is a partner in the Firm\u2019s San Diego office. His practice focuses on complex securities\nand shareholder derivative litigation. Stewart served as lead counsel in In re Am. Realty Cap. Props., Inc.\nLitig., a case arising out of ARCP\u2019s manipulative accounting practices, and obtained a $1.025 billion\nrecovery. For five years, he and the litigation team prosecuted nine different claims for violations of the\nSecurities Exchange Act of 1934 and the Securities Act of 1933, involving seven different stock or debt\nofferings and two mergers. The recovery represents the highest percentage of damages of any major\nPSLRA case prior to trial and includes the largest personal contributions by individual defendants in\nhistory. Most recently, Stewart served as lead counsel in Smilovits v. First Solar, Inc., and obtained a $350\nmillion settlement on the eve of trial. The settlement is fifth-largest PSLRA settlement ever recovered in\nthe Ninth Circuit.\n\nHe was also part of the litigation team that obtained a $67 million settlement in City of Westland Police &\nFire Ret. Sys. v. Stumpf, a shareholder derivative action alleging that Wells Fargo participated in the mass-\nprocessing of home foreclosure documents by engaging in widespread robo-signing. Stewart also served\non the litigation team in In re Deutsche Bank AG Sec. Litig., in which the Firm obtained a $18.5 million\nsettlement in a case against Deutsche Bank and certain of its officers alleging violations of the Securities\nAct of 1933.\n\n\nEducation\nB.S., Santa Clara University, 2004; M.B.A., University of San Diego School of Business Administration,\n2009; J.D., University of San Diego School of Law, 2009\n\nHonors / Awards\nCalifornia Lawyer Attorney of the Year (CLAY), Daily Journal, 2024; Rising Star, Super Lawyers Magazine,\n2015-2020; J.D., Magna Cum Laude, Order of the Coif, University of San Diego School of Law, 2009;\nMember, San Diego Law Review\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 123\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 127 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSabrina E. Tirabassi | Partner\nSabrina Tirabassi is a partner in the Firm\u2019s Boca Raton office, where her practice focuses on complex\nsecurities litigation, including the Firm\u2019s lead plaintiff motion practice. In this role, Tirabassi remains at\nthe forefront of litigation trends and issues arising under the Private Securities Litigation Reform Act of\n1995. Further, Tirabassi has been an integral member of the litigation teams responsible for securing\nsignificant monetary recoveries on behalf of shareholders, including: Villella v. Chemical and Mining\nCompany of Chile Inc., No. 1:15-cv-02106 (S.D.N.Y.); In re ADT Inc. S\u2019holder Litig., No.\n502018CA003494XXXXMB-AG (Fla. Cir. Ct., 15th Jud. Cir.); KBC Asset Mgmt. NV v. Aegerion Pharms.,\nInc., No. 1:14-cv-10105-MLW (D. Mass.); Sohal v. Yan, No. 1:15-cv-00393-DAP (N.D. Ohio); McGee v.\nConstant Contact, Inc., No. 1:15-cv-13114-MLW (D. Mass.); and Schwartz v. Urban Outfitters, Inc., No.\n2:13-cv-05978-MAK (E.D. Pa.).\n\n\nEducation\nB.A., University of Florida, 2000; J.D., Nova Southeastern University Shepard Broad College of Law,\n2006, Magna Cum Laude\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024-2025; Rising Star, Super Lawyers Magazine,\n2010, 2015-2018; J.D., Magna Cum Laude, Nova Southeastern University Shepard Broad College of Law,\n2006\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 124\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 128 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMichael A. Troncoso | Partner\nMichael Troncoso is a partner with the Firm. His practice focuses on securities fraud class action litigation\nand advising institutional investors in the United States and European Union on corporate governance\nand global policy issues. Prior to joining the Firm, Troncoso served as a prosecutor, senior in-house\ncounsel, and legal and policy advisor across numerous sectors. He served as chief counsel and chief of\npublic policy to then-California Attorney General Kamala D. Harris, overseeing the office\u2019s priority\nlitigation, enforcement, and legislative matters. In this role, he served as lead counsel for the State of\nCalifornia in securing the National Mortgage Settlement, the largest consumer financial protection\nsettlement in state history that brought $20 billion in loan relief and direct payments to California\nhomeowners. He led the state\u2019s Mortgage Fraud Task Force and its investigations of securities law\nviolations arising from the issuance of residential mortgage-backed securities. His team recovered nearly\n$1 billion in RMBS-related losses for California public pension funds.\n\nEarlier in his career, Troncoso served for nearly six years as a trial attorney and assistant chief attorney\nfor policy in the San Francisco District Attorney\u2019s office, where he tried multiple criminal cases to jury\nverdict and led the office\u2019s mortgage and investment fraud team, where he was responsible for\ninvestigating and prosecuting complex financial crimes from initial report through charging and trial.\n\nTroncoso most recently served as Vice President at the Chan Zuckerberg Initiative, a philanthropic\norganization, where he led bipartisan policy and advocacy efforts nationwide. He also served in the\nUniversity of California\u2019s Office of General Counsel as managing counsel for health affairs and technology\nlaw and chief campus counsel, where he oversaw various litigation, regulatory, and data protection\nmatters.\n\n\nEducation\nB.A., University of California at Berkeley, 1999; J.D., Georgetown University Law Center, 2002\n\nHonors / Awards\nTop 20 Under 40, Daily Journal, 2012\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 125\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 129 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDouglas Wilens | Partner\nDouglas Wilens is a partner in the Firm\u2019s Boca Raton office. Wilens is a member of the Firm\u2019s Appellate\nPractice Group, participating in numerous appeals in federal and state courts across the country. Most\nnotably, Wilens handled successful and precedent-setting appeals in Ind. Pub. Ret. Sys. v. SAIC, Inc., 818\nF.3d 85 (2d Cir. 2016) (addressing duty to disclose under SEC Regulation Item 303 in \u00a710(b) case), Mass.\nRet. Sys. v. CVS Caremark Corp., 716 F.3d 229 (1st Cir. 2013) (addressing pleading of loss causation\nin \u00a710(b) case), and Lormand v. US Unwired, Inc., 565 F.3d 228 (5th Cir. 2009) (addressing pleading of\nfalsity, scienter, and loss causation in \u00a710(b) case).\n\nBefore joining the Firm, Wilens was an associate at a nationally recognized firm, where he litigated\ncomplex actions on behalf of numerous professional sports leagues, including the National Basketball\nAssociation, the National Hockey League, and Major League Soccer. He has also served as an adjunct\nprofessor at Florida Atlantic University and Nova Southeastern University, where he taught\nundergraduate and graduate-level business law classes.\n\n\nEducation\nB.S., University of Florida, 1992; J.D., University of Florida College of Law, 1995\n\nHonors / Awards\nBook Award for Legal Drafting, University of Florida College of Law; J.D., with Honors, University of\nFlorida College of Law, 1995\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 126\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 130 of 159\n ATTORNEY BIOGRAPHIES\n\n\nShawn A. Williams | Partner\nShawn Williams, a founding partner of the Firm, is the managing partner of the Firm\u2019s San Francisco\noffice and a member of the Firm\u2019s Management Committee. Williams specializes in complex commercial\nlitigation focusing on securities litigation and has served as lead counsel in a range of precedent-setting\nactions that recovered billions of dollars for investors and consumers. Williams recently served as lead\ncounsel in a globally watched securities class action case against Apple, In re Apple Inc. Sec. Litig. He and\nthe trial team secured a $490 million recovery for injured investors. Williams was among lead counsel\nin In re Facebook Biometric Info. Privacy Litig., charging Facebook with violations of the Illinois Biometric\nInformation Privacy Act, resulting in a $650 million recovery for injured Facebook users, which was then\nthe largest ever biometric class action.\n\nWilliams also led the team of Robbins Geller attorneys in the investigation and drafting of comprehensive\nsecurities fraud claims in Hefler v. Wells Fargo & Co., alleging widespread opening of unauthorized and\nundisclosed customer accounts. The Hefler action resulted in the recovery of $480 million for Wells Fargo\ninvestors. In City of Westland Police & Fire Ret. Sys. v. Metlife, Inc., Williams led the Firm\u2019s team of lawyers\nalleging MetLife\u2019s failure to disclose and account for the scope of its use and non-use of the Social Security\nAdministration Death Master File and its impact on MetLife\u2019s financial statements. The Metlife action\nresulted in a recovery of $84 million. Williams also served as lead counsel in the following actions\nresulting in significant recoveries: Chicago Laborers Pension Fund v. Alibaba Grp. Holding Ltd. ($75 million\nrecovery); In re Krispy Kreme Doughnuts, Inc. Sec. Litig. ($75 million recovery); In re Medtronic, Inc. Sec.\nLitig. ($43 million recovery); In re Cadence Design Sys., Inc. Sec. Litig. ($38 million recovery); and City of\nSterling Heights Gen. Emps\u2019. Ret. Sys. v. Prudential Fin., Inc. ($33 million recovery).\n\nWilliams is also a member of the Firm\u2019s Shareholder Derivative Practice Group, which has secured tens of\nmillions of dollars in cash recoveries and comprehensive corporate governance reforms in a number of\nhigh-profile cases including: In re McAfee, Inc. Derivative Litig.; In re Marvell Tech. Grp. Ltd. Derivative\nLitig.; In re KLA-Tencor Corp. S\u2019holder Derivative Litig.; The Home Depot, Inc. Derivative Litig.; and City of\nWestland Police & Fire Ret. Sys. v. Stumpf (Wells Fargo & Co.).\n\nBefore joining the Firm in 2000, Williams served for 5 years as an Assistant District Attorney in the\nManhattan District Attorney\u2019s Office, where he tried over 20 cases to New York City juries.\n\n\nEducation\nB.A., The State of University of New York at Albany, 1991; J.D., University of Illinois, 1995\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2018-2026; Litigation Star, Benchmark Litigation, 2025-2026; Best\nLawyer in America, Best Lawyers\u00ae, 2022-2026; Super Lawyer, Super Lawyers Magazine, 2014-2017,\n2020-2021, 2023-2025; Recommended Lawyer, The Legal 500, 2023-2025; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; Leading Commercial Litigator, Daily Journal, 2025; Litigator of the Week,\nThe AmLaw Litigation Daily, 2024; Top Plaintiff Lawyer, Daily Journal, 2022; Most Influential Black\nLawyers, Savoy, 2022; Legend, Lawdragon, 2022; Top 100 Lawyer, Daily Journal, 2019, 2021; California\nTrailblazer, The Recorder, 2019; Titan of the Plaintiffs Bar, Law360, 2019; Plaintiffs\u2019 Lawyer\nTrailblazer, The National Law Journal, 2019; Board Member, California Bar Foundation, 2012-2014\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 127\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 131 of 159\n ATTORNEY BIOGRAPHIES\n\n\nChristopher M. Wood | Partner\nChristopher Wood is the partner in charge of Robbins Geller Rudman & Dowd LLP\u2019s Nashville office,\nwhere his practice focuses on complex securities litigation. He has been a member of litigation teams\nresponsible for recoveries totaling hundreds of millions of dollars for investors, including some of the\nlargest securities class action recoveries in Tennessee history. His cases include: In re Massey Energy Co.\nSec. Litig. ($265 million recovery); In re Envision Healthcare Co. Sec. Litig. ($177.5 million recovery); In re\nVeriFone Holdings, Inc. Sec. Litig. ($95 million recovery); Garden City Emps.\u2019 Ret. Sys. v. Psychiatric Solutions,\nInc. ($65 million recovery); Grae v. Corrections Corporation of America ($56 million recovery); In re Micron\nTech., Inc. Sec. Litig. ($42 million recovery); Jackson Cnty. Emps.\u2019 Ret. Sys. v. Ghosn ($36 million recovery);\nand Winslow v. BancorpSouth, Inc. ($29.5 million recovery).\n\nWorking together with the ACLU of Tennessee and Public Funds Public Schools (a national campaign\nfounded by the Southern Poverty Law Center and Education Law Center), Wood is litigating an action\nchallenging Tennessee\u2019s school voucher program, which diverts critically needed funds from public\nschool students in Nashville and Memphis. Wood has also provided pro bono legal services through\nTennessee Justice for Our Neighbors, Volunteer Lawyers & Professionals for the Arts, the Ninth Circuit\u2019s\nPro Bono Program, and the San Francisco Bar Association\u2019s Volunteer Legal Services Program.\n\n\nEducation\nB.A., Vanderbilt University, 2003; J.D., University of San Francisco School of Law, 2006\n\nHonors / Awards\nFuture Star, Benchmark Litigation, 2023-2026; Best Lawyer in America, Best Lawyers\u00ae, 2025-2026; Leading\nPlaintiff Financial Lawyer, Lawdragon, 2024-2025; Best Lawyer in America: One to Watch, Best Lawyers\u00ae,\n2023-2024; 40 & Under Hot List, Benchmark Litigation, 2021; Rising Star, Super Lawyers\nMagazine, 2011-2013, 2015-2020\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 128\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 132 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDebra J. Wyman | Partner\nDebra Wyman is a partner in the Firm\u2019s San Diego office. She specializes in securities litigation and has\nlitigated numerous cases against public companies in state and federal courts that have resulted in over $2\nbillion in securities fraud recoveries. Wyman served as lead counsel in In re Am. Realty Cap. Props., Inc.\nLitig., a case arising out of ARCP\u2019s manipulative accounting practices, and obtained a $1.025 billion\nrecovery. For five years, she and the litigation team prosecuted nine different claims for violations of the\nSecurities Exchange Act of 1934 and the Securities Act of 1933, involving seven different stock or debt\nofferings and two mergers. The recovery represents the highest percentage of damages of any major\nPSLRA case prior to trial and includes the largest personal contributions by individual defendants in\nhistory. Most recently, Wyman was part of the litigation team in Monroe County Employees\u2019 Retirement System\nv. The Southern Company in which an $87.5 settlement was reached after three years of litigation. The\nsettlement resolved claims for violations of the Securities Exchange Act of 1934 stemming from\ndefendants\u2019 issuance of materially misleading statements and omissions regarding the status of\nconstruction of a first-of-its-kind \u201cclean coal\u201d power plant that was designed to transform coal into\nsynthetic gas that could then be used to fuel the power plant.\n\nWyman was also a member of the trial team in Schuh v. HCA Holdings, Inc., which resulted in a $215\nmillion recovery for shareholders, the largest securities class action recovery ever in Tennessee. The\nrecovery achieved represents more than 30% of the aggregate classwide damages, far exceeding the\ntypical recovery in a securities class action. Wyman prosecuted the complex securities and accounting\nfraud case In re HealthSouth Corp. Sec. Litig., one of the largest and longest-running corporate frauds in\nhistory, in which $671 million was recovered for defrauded HealthSouth investors. She was also part of\nthe trial team that litigated In re AT&T Corp. Sec. Litig., which was tried in the United States District Court,\nDistrict of New Jersey, and settled after only two weeks of trial for $100 million. Wyman was also part of\nthe litigation team that secured a $64 million recovery for Dana Corp. shareholders in Plumbers &\nPipefitters National Pension Fund v. Burns, in which the Firm\u2019s Appellate Practice Group successfully\nappealed to the Sixth Circuit Court of Appeals twice, reversing the district court\u2019s dismissal of the action.\n\n\nEducation\nB.A., University of California Irvine, 1990; J.D., University of San Diego School of Law, 1997\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2020-2026; Litigation Star, Benchmark Litigation, 2023-2026;\nNational Practice Area Star, Benchmark Litigation, 2024-2026; Leading Plaintiff Financial\nLawyer, Lawdragon, 2019-2025; California - Litigation Star, Benchmark Litigation, 2024-2025; California\nLawyer Attorney of the Year (CLAY), Daily Journal, 2024; Top 250 Women in Litigation, Benchmark\nLitigation, 2021, 2023-2024; San Diego Litigator of the Year, Benchmark Litigation, 2021; Plaintiff Litigator\nof the Year, Benchmark Litigation, 2021; Top Woman Lawyer, Daily Journal, 2017, 2020; MVP, Law360,\n2020; Litigator of the Week, The American Lawyer, 2020; Litigator of the Year, Our City San Diego, 2017;\nSuper Lawyer, Super Lawyers Magazine, 2016-2017\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 129\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 133 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSusan K. Alexander | Of Counsel\nSusan Alexander is Of Counsel to the Firm and is based in the San Francisco office. Alexander\u2019s practice\nspecializes in federal appeals of securities fraud class actions on behalf of investors. With nearly 30 years\nof federal appellate experience, she has argued on behalf of defrauded investors in circuit courts\nthroughout the United States. Among her most notable cases are Mineworkers\u2019 Pension Scheme v. First Solar\nInc. ($350 million recovery), In re VeriFone Holdings, Inc. Sec. Litig. ($95 million recovery), and the\nsuccessful appellate ruling in Alaska Elec. Pension Fund v. Flowserve Corp. ($55 million recovery). Other\nrepresentative results include: Stoyas v. Toshiba Corp., 896 F.3d 933 (9th Cir. 2018) (reversing dismissal of\nsecurities fraud action and holding that the Exchange Act applies to unsponsored American Depositary\nShares); W. Va. Pipe Trades Health & Welfare Fund v. Medtronic, Inc., 845 F.3d 384 (8th Cir. 2016)\n(reversing summary judgment of securities fraud action on statute of limitations grounds); In re Ubiquiti\nNetworks, Inc. Sec. Litig., 669 F. App\u2019x 878 (9th Cir. 2016) (reversing dismissal of \u00a711 claim); Carpenters\nPension Tr. Fund of St. Louis v. Barclays PLC, 750 F.3d 227 (2d Cir. 2014) (reversing dismissal of securities\nfraud complaint, focused on loss causation); Panther Partners Inc. v. Ikanos Commc\u2019ns, Inc., 681 F.3d 114 (2d\nCir. 2012) (reversing dismissal of \u00a711 claim); City of Pontiac Gen. Emps.\u2019 Ret. Sys. v. MBIA, Inc., 637 F.3d\n169 (2d Cir. 2011) (reversing dismissal of securities fraud complaint, focused on statute of limitations); In\nre Gilead Scis. Sec. Litig., 536 F.3d 1049 (9th Cir. 2008) (reversing dismissal of securities fraud complaint,\nfocused on loss causation); Barrie v. Intervoice-Brite, Inc., 397 F.3d 249 (5th Cir.) (reversing dismissal of\nsecurities fraud complaint, focused on scienter), reh\u2019g denied and op. modified, 409 F.3d 653 (5th Cir. 2005);\nand Pirraglia v. Novell, Inc., 339 F.3d 1182 (10th Cir. 2003) (reversing dismissal of securities fraud\ncomplaint, focused on scienter). Alexander\u2019s prior appellate work was with the California Appellate\nProject (\u201cCAP\u201d), where she prepared appeals and petitions for writs of habeas corpus on behalf of\nindividuals sentenced to death. At CAP, and subsequently in private practice, she litigated and consulted\non death penalty direct and collateral appeals for ten years.\n\n\nEducation\nB.A., Stanford University, 1983; J.D., University of California, Los Angeles, 1986\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; Super Lawyer, Super Lawyers Magazine,\n2015-2021; American Academy of Appellate Lawyers; California Academy of Appellate Lawyers; Ninth\nCircuit Advisory Rules Committee; Appellate Delegate, Ninth Circuit Judicial Conference; ABA Council of\nAppellate Lawyers\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 130\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 134 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLaura M. Andracchio | Of Counsel\nLaura Andracchio is Of Counsel in the Firm\u2019s San Diego office. Having joined the Firm in 1997, she was\na Robbins Geller partner before her role as Of Counsel. As a partner with the Firm, Andracchio led\ndozens of securities fraud cases against public companies throughout the country, recovering hundreds of\nmillions of dollars for injured investors. Her current focus remains securities fraud litigation under the\nfederal securities laws.\n\nMost recently, Andracchio was a member of the litigation team that obtained a $350 million recovery for\nthe class in 2024 in In re Alphabet, Inc. Sec. Litig. (N.D. Cal.). Andracchio was also part of the litigation\nteams in In re American Realty Cap. Props., Inc. Litig. (S.D.N.Y.), in which a $1.025 billion recovery was\nobtained; City of Pontiac Gen. Emps.\u2019 Ret. Sys. v. Wal-Mart Stores, Inc. (W.D. Ark.), recovering $160 million\nfor Wal-Mart investors; and In re Cardinal Health, Inc. Sec. Litig. (S.D. Ohio) ($109 million).\n\nAndracchio was also a lead member of the trial team in In re AT&T Corp. Sec. Litig., recovering $100\nmillion for the class after two weeks of trial in district court in New Jersey. Before trial, she managed and\nlitigated the case for four years. She also led the trial team in Brody v. Hellman, a case against Qwest and\nformer directors of U.S. West seeking an unpaid dividend, recovering $50 million for the class, which was\nlargely comprised of U.S. West retirees. Some of Andracchio\u2019s other cases include Fort Worth Emps.\u2019 Ret.\nFund v. J.P. Morgan Chase & Co. (S.D.N.Y.) ($388 million on behalf of investors in residential mortgage-\nbacked securities); City of Hialeah Emps.\u2019 Ret. Sys. v. Toll Bros., Inc.; Ross v. Abercrombie & Fitch Co.; In re\nGMH Cmtys. Tr. Sec. Litig.; In re Vicuron Pharms., Inc. Sec. Litig.; and In re Navarre Corp. Sec. Litig.\n\n\nEducation\nB.A., Bucknell University, 1986; J.D., Duquesne University School of Law, 1989\n\nHonors / Awards\nOrder of the Barristers, J.D., with honors, Duquesne University School of Law, 1989\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 131\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 135 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJason M. Avellino | Of Counsel\nJason Avellino is Of Counsel in the Firm\u2019s Wilmington office. He focuses his practice on corporate\ngovernance, shareholder rights, and complex securities litigation.\n\nBefore joining Robbins Geller, Avellino practiced at a prominent Delaware law firm, where he was a\nsignificant part of litigation teams that achieved substantial recoveries and meaningful governance\nreforms for investors. He also spent more than a decade representing major product manufacturers,\ncontractors, marine terminal operators, retail establishments, and sports venues (including several\nFortune 500 companies) in the evaluation and defense of commercial matters and civil lawsuits. During\nthat time, Avellino was a member of the International Association of Defense Counsel (IADC), a group of\napproximately 2,500 invitation-only, peer-reviewed members comprised of the world\u2019s leading corporate\nand insurance lawyers and insurance executives.\n\n\nEducation\nB.S., Bloomsburg University, 2007; J.D., Villanova University School of Law, 2010\n\nHonors / Awards\nB.S., Magna Cum Laude, Bloomsburg University, 2007\n\n\n\nMatthew J. Balotta | Of Counsel\nMatt Balotta is Of Counsel in the Firm\u2019s San Diego office, where his practice focuses on securities fraud\nlitigation. Balotta earned his Bachelor of Arts degree in History, summa cum laude, from the University of\nPittsburgh and his Juris Doctor degree from Harvard Law School. During law school, Balotta was a\nsummer associate with the Firm and interned at the National Consumer Law Center. He also\nparticipated in the Employment Law and Delivery of Legal Services Clinics and served on the General\nBoard of the Harvard Civil Rights-Civil Liberties Law Review.\n\n\nEducation\nB.A., University of Pittsburgh, 2005; J.D., Harvard Law School, 2015\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2026; B.A., Summa Cum Laude, University of\nPittsburgh, 2005\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 132\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 136 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRandi D. Bandman | Of Counsel\nRandi Bandman is Of Counsel in the Firm\u2019s San Diego office. Throughout her career, she has\nrepresented and advised hundreds of clients, including pension funds, managers, banks, and hedge\nfunds, such as the Directors Guild of America, Screen Actors Guild, Writers Guild of America, and\nTeamster funds. Bandman\u2019s cases have yielded billions of dollars of recoveries. Notable cases include the\nAOL Time Warner, Inc. merger ($629 million), In re Enron Corp. Sec. Litig. ($7.2 billion), Private Equity\nlitigation (Dahl v. Bain Cap. Partners, LLC) ($590.5 million), In re WorldCom Sec. Litig. ($657 million), and In\nre Facebook Biometric Info. Privacy Litig. ($650 million).\n\nBandman is currently representing plaintiffs in the Foreign Exchange Litigation pending in the Southern\nDistrict of New York which alleges collusive conduct by the world\u2019s largest banks to fix prices in the $5.3\ntrillion a day foreign exchange market and in which billions of dollars have been recovered to date for\ninjured plaintiffs. Bandman is part of the Robbins Geller Co-Lead Counsel team representing the class in\nthe \u201cHigh Frequency Trading\u201d case, which accuses stock exchanges of giving unfair advantages to high-\nspeed traders versus all other investors, resulting in billions of dollars being diverted. Bandman was\ninstrumental in the landmark state settlement with the tobacco companies for $12.5 billion. Bandman\nalso led an investigation with congressional representatives on behalf of artists into allegations of \u201cpay for\nplay\u201d tactics, represented Emmy winning writers with respect to their claims involving a long-running\ntelevision series, represented a Hall of Fame sports figure, and negotiated agreements in connection with\na major motion picture. Recently, Bandman was chosen to serve on the Law Firm Advisory Board of the\nAssociation of Media & Entertainment Counsel, an organization made up of thousands of attorneys from\nstudios, networks, guilds, talent agencies, and top media companies, dealing with protecting content\ndistributed through a variety of formats worldwide.\n\n\nEducation\nB.A., University of California, Los Angeles; J.D., University of Southern California\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 133\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 137 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMary K. Blasy | Of Counsel\nMary Blasy is Of Counsel to the Firm and is based in the Firm\u2019s Melville and Washington, D.C. offices.\nHer practice focuses on the investigation, commencement, and prosecution of securities fraud class\nactions and shareholder derivative suits. Blasy has recovered hundreds of millions of dollars for investors\nin securities fraud class actions against Reliance Acceptance Corp. ($66 million); Sprint Corp. ($50\nmillion); Titan Corporation ($15+ million); Martha Stewart Omni-Media, Inc. ($30 million); and Coca-\nCola Co. ($137.5 million). Blasy has also been responsible for prosecuting numerous complex\nshareholder derivative actions against corporate malefactors to address violations of the nation\u2019s\nsecurities, environmental, and labor laws, obtaining corporate governance enhancements valued by the\nmarket in the billions of dollars.\n\nIn 2014, the Presiding Justice of the Appellate Division of the Second Department of the Supreme Court\nof the State of New York appointed Blasy to serve as a member of the Independent Judicial Election\nQualification Commission, which until December 2018 reviewed the qualifications of candidates seeking\npublic election to New York State Supreme Courts in the 10th Judicial District. She also served on the\nLaw360 Securities Editorial Advisory Board from 2015 to 2016.\n\n\nEducation\nB.A., California State University, Sacramento, 1996; J.D., UCLA School of Law, 2000\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2016-2020, 2023-2025; Law360 Securities Editorial Advisory\nBoard, 2015-2016; Member, Independent Judicial Election Qualification Commission, 2014-2018\n\n\n\nM. Lamontt Bowens | Of Counsel\nLamontt Bowens is Of Counsel to Robbins Geller in the Firm\u2019s Washington, D.C. office. He is a member\nof the Firm\u2019s client outreach team where his focus is working with the Firm\u2019s institutional investor clients.\n\nBowens began his career with Robbins Geller working in the fax and mailroom while attending college\nand law school at night. After his first year of law school, he worked as a summer associate with the Firm.\nFollowing his second year of law school, Bowens worked as a summer intern in the office of the San Diego\nCounty Public Defender, where he worked at the direction of his supervising attorneys representing\nindigent clients. After graduating from law school and passing the bar exam, Bowens was a Staff Attorney\nwhere he worked on securities, antitrust, and consumer cases in Robbins Geller\u2019s San Diego office.\n\nBowens has written and regularly speaks about his challenging experiences as a youth in the inner city\nand his unorthodox journey to becoming a lawyer. He has been a mentor to at-risk youth and is an\nadvocate for programs designed to promote second chances for the formerly incarcerated.\n\nBowens is a dedicated member of the National Association of Securities Professionals (NASP) and the\nNational Bar Association (NBA).\n\n\nEducation\nB.S., University of Phoenix, 2004; J.D., Golden Gate University School of Law, 2010\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 134\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 138 of 159\n ATTORNEY BIOGRAPHIES\n\n\nWilliam K. Cavanagh, Jr. | Of Counsel\nBill Cavanagh is Of Counsel in the Firm\u2019s Washington, D.C. office. Cavanagh concentrates his practice in\nemployee benefits law and works with the Firm\u2019s Institutional Outreach Team. Prior to joining Robbins\nGeller, Cavanagh was employed by Ullico for the past nine years, most recently as President of Ullico\nCasualty Group. The Ullico Casualty Group is the leading provider of fiduciary liability insurance for\ntrustees in both the private as well as the public sector. Prior to that he was President of the Ullico\nInvestment Company.\n\nPreceding Cavanagh\u2019s time at Ullico, he was a partner at the labor and employee benefits firm Cavanagh\nand O\u2019Hara in Springfield, Illinois for 28 years. In that capacity, Cavanagh represented public pension\nfunds, jointly trusteed Taft-Hartley, health, welfare, pension, and joint apprenticeship funds advising on\nfiduciary and compliance issues both at the Board level as well as in administrative hearings, federal\ndistrict courts, and the United States Courts of Appeals. During the course of his practice, Cavanagh had\nextensive trial experience in state and the relevant federal district courts. Additionally, Cavanagh served\nas co-counsel on a number of cases representing trustees seeking to recover plan assets lost as a result of\nfraud in the marketplace.\n\n\nEducation\nB.A., Georgetown University, 1974; J.D., John Marshall Law School, 1978\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell\n\n\n\nChristopher Collins | Of Counsel\nChristopher Collins is Of Counsel in the Firm\u2019s San Diego office and his practice focuses on antitrust and\nconsumer protection. Collins served as co-lead counsel in Wholesale Elec. Antitrust Cases I & II, charging an\nantitrust conspiracy by wholesale electricity suppliers and traders of electricity in California\u2019s newly\nderegulated wholesale electricity market wherein plaintiffs secured a global settlement for California\nconsumers, businesses, and local governments valued at more than $1.1 billion. He was also involved in\nCalifornia\u2019s tobacco litigation, which resulted in the $25.5 billion recovery for California and its local\nentities. Collins is currently counsel on the California Energy Manipulation antitrust litigation, the\nMemberworks upsell litigation, as well as a number of consumer actions alleging false and misleading\nadvertising and unfair business practices against major corporations. He formerly served as a Deputy\nDistrict Attorney for Imperial County where he was in charge of the Domestic Violence Unit.\n\n\nEducation\nB.A., Sonoma State University, 1988; J.D., Thomas Jefferson School of Law, 1995\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 135\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 139 of 159\n ATTORNEY BIOGRAPHIES\n\n\nVicki Multer Diamond | Of Counsel\nVicki Multer Diamond is Of Counsel to the Firm and is based in the Firm\u2019s Melville office. She has over\n25 years of experience as an investigator and attorney. Her practice at the Firm focuses on the initiation,\ninvestigation, and prosecution of securities fraud class actions. Diamond played a significant role in the\nfactual investigations and successful oppositions to the defendants\u2019 motions to dismiss in a number of\ncases, including Tableau, One Main, Valeant, and Orbital ATK.\n\nDiamond has served as an investigative consultant to several prominent law firms, corporations, and\ninvestment firms. Before joining the Firm, she was an Assistant District Attorney in Brooklyn, New York,\nwhere she served as a senior Trial Attorney in the Felony Trial Bureau, and was special counsel to the\nSpecial Commissioner of Investigations for the New York City schools, where she investigated and\nprosecuted crime and corruption within the New York City school system.\n\n\nEducation\nB.A., State University of New York at Binghamton, 1990; J.D., Hofstra University School of Law, 1993\n\nHonors / Awards\nMember, Hofstra Property Law Journal, Hofstra University School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 136\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 140 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMichael J. Dowd | Of Counsel\nMike Dowd was a founding partner of the Firm. He has practiced in the area of securities litigation for 20\nyears, prosecuting dozens of complex securities cases and obtaining significant recoveries for investors in\ncases such as American Realty ($1.025 billion), UnitedHealth ($925 million), WorldCom ($657 million), AOL\nTime Warner ($629 million), Qwest ($445 million), Under Armour ($434 million), and Pfizer ($400 million).\n\nDowd served as lead trial counsel in Jaffe v. Household International in the Northern District of Illinois, a\nsecurities class action that obtained a record-breaking $1.575 billion settlement after 14 years of litigation,\nincluding a six-week jury trial in 2009 that resulted in a verdict for plaintiffs. Dowd also served as the\nlead trial lawyer in In re AT&T Corp. Sec. Litig., which was tried in the District of New Jersey and settled\nafter only two weeks of trial for $100 million. Dowd served as an Assistant United States Attorney in the\nSouthern District of California from 1987-1991, and again from 1994-1998, where he handled dozens of\njury trials and was awarded the Director's Award for Superior Performance.\n\n\nEducation\nB.A., Fordham University, 1981; J.D., University of Michigan Law School, 1984\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Director\u2019s Award for Superior Performance, United States\nAttorney\u2019s Office; Best Lawyer in America, Best Lawyers\u00ae, 2015-2026; Recommended Lawyer, The Legal\n500, 2016-2019, 2023-2025; Leading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Hon. David H.\nBartick Award for Civility and Professionalism, U.S. District Court for the Southern District of California,\n2024; Top Lawyer in San Diego, San Diego Magazine, 2013-2022; Southern California Best Lawyer, Best\nLawyers\u00ae, 2015-2021; Super Lawyer, Super Lawyers Magazine, 2010-2020; Lawyer of the Year, Best\nLawyers\u00ae, 2020; Hall of Fame, Lawdragon, 2018; Litigator of the Year, Our City San Diego, 2017; Leading\nLawyer in America, Lawdragon, 2014-2016; Litigator of the Week, The American Lawyer, 2015; Litigation\nStar, Benchmark Litigation 2013; Directorship 100, NACD Directorship, 2012; Attorney of the Year,\nCalifornia Lawyer, 2010; Top 100 Lawyers, Daily Journal, 2009; B.A., Magna Cum Laude, Fordham\nUniversity, 1981\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 137\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 141 of 159\n ATTORNEY BIOGRAPHIES\n\n\nTravis E. Downs III | Of Counsel\nTravis Downs is Of Counsel to the Firm in the Firm\u2019s San Diego office. His areas of expertise include\nprosecution of shareholder and securities litigation, including complex shareholder derivative actions.\nDowns is a member of the Firm\u2019s Delaware Practice Group. Downs led a team of lawyers who successfully\nprosecuted over 65 stock option backdating derivative actions in federal and state courts across the\ncountry, resulting in hundreds of millions in financial givebacks for the plaintiffs and extensive corporate\ngovernance enhancements, including annual directors elections, majority voting for directors, and\nshareholder nomination of directors. Notable cases include: In re Community Health Sys., Inc. S\u2019holder\nDerivative Litig. ($60 million in financial relief and unprecedented corporate governance reforms); In re\nMarvell Tech. Grp. Ltd. Derivative Litig. ($54 million in financial relief and extensive corporate governance\nenhancements); In re McAfee, Inc. Derivative Litig. ($30 million in financial relief and extensive corporate\ngovernance enhancements); In re Affiliated Computer Servs. Derivative Litig. ($30 million in financial relief\nand extensive corporate governance enhancements); In re KB Home S\u2019holder Derivative Litig. ($30 million in\nfinancial relief and extensive corporate governance enhancements); In re Juniper Networks Derivative Litig.\n($22.7 million in financial relief and extensive corporate governance enhancements); In re Nvidia Corp.\nDerivative Litig. ($15 million in financial relief and extensive corporate governance\nenhancements); and City of Pontiac Gen. Emps.\u2019 Ret. Sys. v. Langone (achieving landmark corporate\ngovernance reforms for investors).\n\nDowns was also part of the litigation team that obtained a $67 million settlement in City of Westland Police\n& Fire Ret. Sys. v. Stumpf, a shareholder derivative action alleging that Wells Fargo participated in the mass-\nprocessing of home foreclosure documents by engaging in widespread robo-signing, and a $250 million\nsettlement in In re Google, Inc. Derivative Litig., an action alleging that Google facilitated in the improper\nadvertising of prescription drugs. Downs is a frequent speaker at conferences and seminars and has\nlectured on a variety of topics related to shareholder derivative and class action litigation.\n\n\nEducation\nB.A., Whitworth University, 1985; J.D., University of Washington School of Law, 1990\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Best Lawyer in America, Best Lawyers\u00ae, 2018-2026;\nRecommended Lawyer, The Legal 500, 2023-2024; Leading Plaintiff Financial Lawyer, Lawdragon,\n2019-2024; Top 100 Leaders in Law Honoree, San Diego Business Journal, 2022; Top Lawyer in San Diego,\nSan Diego Magazine, 2013-2022; Southern California Best Lawyer, Best Lawyers\u00ae, 2018-2021; Super\nLawyer, Super Lawyers Magazine, 2008; B.A., Honors, Whitworth University, 1985\n\n\n\nJason A. Forge | Of Counsel\nJason Forge is Of Counsel in the Firm\u2019s San Diego office. He specializes in complex investigations,\nlitigation, and trials. As a federal prosecutor and private practitioner, Forge has conducted and\nsupervised scores of jury and bench trials in federal and state courts, including the month-long trial of a\ndefense contractor who conspired with Congressman Randy \u201cDuke\u201d Cunningham in the largest bribery\nscheme in congressional history. He recently obtained a $350 million settlement with Alphabet, Inc.,\nwhich was made possible only by first winning a unanimous published appellate decision, reversing a\ndistrict court order that had dismissed the entire case. This is the largest ever post-reversal securities\nfraud recovery in the Ninth Circuit.\n\n\n\n Robbins Geller Rudman & Dowd LLP | 138\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 142 of 159\n ATTORNEY BIOGRAPHIES\n\nIn addition to Alphabet, Forge has secured nine-figure payouts from other corporate goliaths, including\nWal-Mart ($160 million) and Pfizer ($400 million). City of Pontiac General Employees\u2019 Retirement System v.\nWal-Mart Stores, Inc. was the first successful securities fraud case against Wal-Mart. And in the case against\nPfizer, Forge led an investigation that uncovered key documents that Pfizer had not produced in\ndiscovery. Although fact discovery in the case had already closed, the district judge ruled that the\ndocuments had been improperly withheld and ordered that discovery be reopened, including reopening\nthe depositions of Pfizer\u2019s former CEO, CFO, and General Counsel. Less than six months after\ncompleting these depositions, Pfizer settled the case for $400 million.\n\nForge also was a key member of the Firm\u2019s winning trial team in Hsu v. Puma Biotechnology, Inc. \u2013 one of\nonly 13 securities fraud class action verdicts for investors in nearly 30 years. After that trial victory, Forge\njoined a Robbins Geller litigation team that had defeated 12 motions for summary judgment against 40\ndefendants and was about to depose 17 experts in the home stretch to trial. Forge led the effort to use\nthese depositions to disprove a truth-on-the-market argument that nine defense experts had embraced.\nAfter the last of these expert depositions, the defendants dropped their lead truth-on-the-market expert\nand the Robbins Geller team secured a $1.025 billion settlement from American Realty Capital Properties\nand other defendants that included a record $237 million contribution from individual defendants and\nrepresented more than twice the recovery rate obtained by several funds that had opted out of the class.\n\nForge was a key member of the litigation team that secured a historic recovery on behalf of Trump\nUniversity students in two class actions, including a federal RICO charge, against President Donald J.\nTrump. The settlement returned over 90% of the money thousands of students paid to \u201cenroll\u201d in Trump\nUniversity. He represented the class on a pro bono basis. Forge successfully prosecuted another federal\nRICO case against Scotts Miracle-Gro, resulting in full refunds (totaling over $40 million) for customers\nwho purchased bird feed that Scotts had illegally treated with a pesticide known to be hazardous to birds.\nHe was also a member of the litigation team that obtained a $125 million settlement in In re LendingClub\nSecurities Litigation, a settlement that ranked among the top ten largest securities recoveries ever in the\nNorthern District of California.\n\n\nEducation\nB.B.A., The University of Michigan Ross School of Business, 1990; J.D., The University of Michigan Law\nSchool, 1993\n\nHonors / Awards\nLeading Lawyer in America, Lawdragon, 2022-2026; Litigation Star, Benchmark Litigation, 2023-2026;\nNational Practice Area Star, Benchmark Litigation, 2026; Leading Litigator in America, Lawdragon, 2026;\nLeading Plaintiff Financial Lawyer, Lawdragon, 2019-2025; Plaintiff Litigator of the Year, Benchmark\nLitigation, 2025; Impact Case Award: In re Alphabet, Inc. Securities Litigation, Benchmark Litigation, 2025;\nRecommended Lawyer, The Legal 500, 2023-2024; Best Lawyer in America, Best Lawyers\u00ae, 2019-2023;\nSouthern California Best Lawyer, Best Lawyers\u00ae, 2019-2021; Local Litigation Star, Benchmark Litigation,\n2020; Plaintiffs\u2019 Lawyer Trailblazer, The National Law Journal, 2018; Top 100 Lawyer, Daily Journal, 2017;\nLitigator of the Year, Our City San Diego, 2017; Two-time recipient of Department of Justice\u2019s Director's\nAward for Superior Performance by Litigation Team; numerous commendations from Federal Bureau of\nInvestigation (including commendation from FBI Director Robert Mueller III), Internal Revenue Service,\nand Defense Criminal Investigative Service; J.D., Magna Cum Laude, Order of the Coif, The University of\nMichigan Law School, 1993; B.B.A., High Distinction, The University of Michigan Ross School of\nBusiness, 1990\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 139\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 143 of 159\n ATTORNEY BIOGRAPHIES\n\n\nChristopher T. Gilroy | Of Counsel\nChristopher Gilroy is Of Counsel in the Firm\u2019s Manhattan office. His practice focuses on complex\nsecurities litigation. Since joining the Firm, Gilroy has played a significant role in the following\nlitigations: Landmen Partners, Inc. v. The Blackstone Grp., L.P ($85 million recovery on the eve of trial); In re\nOSG Sec. Litig. ($34 million recovery, representing 87% of the maximum Section 11 damages); City of\nAustin Police Ret. Sys. v. Kinross Gold Corp. ($33 million recovery); Citiline Holdings, Inc. v. iStar Fin. Inc. ($29\nmillion recovery); City of Pontiac Gen. Emps. Ret. Sys. v. Lockheed Martin Corp. ($19.5 million\nrecovery); Carpenters Pension Tr. Fund of St. Louis v. Barclays PLC ($14 million recovery); Beaver Cnty. Emps\u2019\nRet. Fund v. Tile Shop Holdings, Inc. ($9.5 million recovery); IBEW Loc. 90 Pension Fund v. Deutsche Bank\nAG (confidential settlement); In re Ply Gem Holdings, Inc., Sec. Litig. ($25.9 million recovery); In re BRF S.A.\nSec. Litig. ($40 million recovery pending final approval); and In re SandRidge Energy, Inc. Sec.\nLitig. (successfully obtaining class certification in an ongoing litigation). Gilroy also performed an\nexhaustive factual investigation in In re Satcon Tech. Corp., on behalf of Satcon\u2019s Chapter 7 Bankruptcy\nTrustee, resulting in a seven-figure settlement in an action alleging breaches of fiduciary duties against\nformer Satcon directors and officers.\n\n\nEducation\nB.A., City University of New York at Queens College, 2005; J.D., Brooklyn Law School, 2010\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2019-2021; B.A., Cum Laude, City University of New York at Queens\nCollege, 2005\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 140\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 144 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJonah H. Goldstein | Of Counsel\nJonah Goldstein is Of Counsel in the Firm\u2019s San Diego office and is responsible for prosecuting complex\nsecurities cases and obtaining recoveries for investors. He also represents corporate whistleblowers who\nreport violations of the securities laws. Goldstein has achieved significant settlements on behalf of\ninvestors including in In re HealthSouth Sec. Litig. (over $670 million recovered against HealthSouth, UBS\nand Ernst & Young), In re Cisco Sec. Litig. (approximately $100 million), and Marcus v. J.C. Penney\nCompany, Inc. ($97.5 million recovery). Goldstein also served on the Firm\u2019s trial team in In re AT&T Corp.\nSec. Litig., MDL No. 1399 (D.N.J.), which settled after two weeks of trial for $100 million, and aided in the\n$65 million recovery in Garden City Emps.\u2019 Ret. Sys. v. Psychiatric Solutions, Inc., the fourth-largest securities\nrecovery ever in the Middle District of Tennessee and one of the largest in more than a decade. Most\nrecently, he was part of the litigation team in Luna v. Marvell Tech. Grp., Ltd., resulting in a $72.5 million\nsettlement that represents approximately 24% to 50% of the best estimate of classwide damages suffered\nby investors. Before joining the Firm, Goldstein served as a law clerk for the Honorable William H.\nErickson on the Colorado Supreme Court and as an Assistant United States Attorney for the Southern\nDistrict of California, where he tried numerous cases and briefed and argued appeals before the Ninth\nCircuit Court of Appeals.\n\n\nEducation\nB.A., Duke University, 1991; J.D., University of Denver College of Law, 1995\n\nHonors / Awards\nRecommended Lawyer, The Legal 500, 2018-2019; Comments Editor, University of Denver Law Review,\nUniversity of Denver College of Law\n\n\n\nRichard W. Gonnello | Of Counsel\nRichard Gonnello is Of Counsel in the Firm\u2019s Manhattan office. He has two decades of experience\nlitigating complex securities actions.\n\nGonnello has successfully represented institutional and individual investors. He has obtained substantial\nrecoveries in numerous securities class actions, including In re Royal Ahold Sec. Litig. (D. Md.) ($1.1 billion)\nand In re Tremont Sec. Law, State Law & Ins. Litig. (S.D.N.Y.) ($100 million). Gonnello has also obtained\nfavorable recoveries for institutional investors pursuing direct opt-out claims, including cases against\nQwest Communications International, Inc. ($175 million) and Tyco International Ltd ($21 million).\n\nGonnello has co-authored the following articles appearing in the New York Law Journal: \u201cStaehr Hikes\nBurden of Proof to Place Investor on Inquiry Notice\u201d and \u201cPotential Securities Fraud: \u2018Storm Warnings\u2019\nClarified.\u201d\n\n\nEducation\nB.A., Rutgers University, 1995; J.D., UCLA School of Law, 1998\n\nHonors / Awards\nB.A., Summa Cum Laude, Rutgers University, 1995\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 141\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 145 of 159\n ATTORNEY BIOGRAPHIES\n\n\nMitchell D. Gravo | Of Counsel\nMitchell Gravo is Of Counsel to the Firm and is a member of the Firm\u2019s institutional investor client\nservices group. With more than 30 years of experience as a practicing attorney, he serves as liaison to the\nFirm\u2019s institutional investor clients throughout the United States and Canada, advising them on securities\nlitigation matters.\n\nGravo\u2019s clients include Anchorage Economic Development Corporation, Anchorage Convention and\nVisitors Bureau, UST Public Affairs, Inc., International Brotherhood of Electrical Workers, Alaska\nSeafood International, Distilled Spirits Council of America, RIM Architects, Anchorage Police Department\nEmployees Association, Fred Meyer, and the Automobile Manufacturer\u2019s Association. Prior to joining the\nFirm, he served as an intern with the Municipality of Anchorage, and then served as a law clerk to\nSuperior Court Judge J. Justin Ripley.\n\n\nEducation\nB.A., Ohio State University; J.D., University of San Diego School of Law\n\n\n\nBailie L. Heikkinen | Of Counsel\nBailie Heikkinen is Of Counsel in the Firm\u2019s Boca Raton office. Her practice focuses on complex class\nactions, including securities, corporate governance, and consumer fraud litigation.\n\nHeikkinen has been an integral member of the litigation teams responsible for securing monetary\nrecoveries on behalf of shareholders that collectively exceed $100 million. Notable cases include: Medoff v.\nCVS Caremark Corp., No. 1:09-cv-00554 (D.R.I.); City of Lakeland Emps. Pension Plan v. Baxter Int\u2019l Inc., No.\n1:10-cv-06016 (N.D. Ill.); Wong v. Accretive Health, Inc., No. 1:12-cv-03102 (N.D. Ill.); and Loc. 731 I.B. of\nT. Excavators & Pavers Pension Tr. Fund v. Swanson, No. 1:09-cv-00799 (D. Del.).\n\n\nEducation\nB.A., University of Florida, 2004; J.D., South Texas College of Law, 2007\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2023-2025; Rising Star, Super Lawyers Magazine,\n2014, 2018\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 142\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 146 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDennis J. Herman | Of Counsel\nDennis Herman is Of Counsel in the Firm\u2019s San Francisco office where he focuses his practice on\nsecurities class actions. He has led or been significantly involved in the prosecution of numerous\nsecurities fraud claims that have resulted in substantial recoveries for investors, including settled actions\nagainst Massey Energy ($265 million), Coca-Cola ($137 million), VeriSign ($78 million), Psychiatric\nSolutions, Inc. ($65 million), St. Jude Medical, Inc. ($50 million), NorthWestern ($40 million),\nBancorpSouth ($29.5 million), America Service Group ($15 million), Specialty Laboratories ($12 million),\nStellent ($12 million), and Threshold Pharmaceuticals ($10 million).\n\n\nEducation\nB.S., Syracuse University, 1982; J.D., Stanford Law School, 1992\n\nHonors / Awards\nBest Lawyer in America, Best Lawyers\u00ae, 2018-2026; Northern Californa Best Lawyer, Best Lawyers\u00ae,\n2018-2021; Super Lawyer, Super Lawyers Magazine, 2017-2018; Order of the Coif, Stanford Law School;\nUrban A. Sontheimer Award (graduating second in his class), Stanford Law School; Award-winning\nInvestigative Newspaper Reporter and Editor in California and Connecticut\n\n\n\nHelen J. Hodges | Of Counsel\nHelen Hodges is Of Counsel in the Firm\u2019s San Diego office. She specializes in securities fraud litigation.\nHodges has been involved in numerous securities class actions, including: Dynegy, which was settled for\n$474 million; Thurber v. Mattel, which was settled for $122 million; Nat\u2019l Health Labs, which was settled for\n$64 million; and Knapp v. Gomez, Civ. No. 87-0067-H(M) (S.D. Cal.), in which a plaintiffs\u2019 verdict was\nreturned in a Rule 10b-5 class action. Additionally, beginning in 2001, Hodges focused on the\nprosecution of Enron, where a record $7.2 billion recovery was obtained for investors.\n\n\nEducation\nB.S., Oklahoma State University, 1979; J.D., University of Oklahoma, 1983\n\nHonors / Awards\nRated AV by Martindale-Hubbell; Hall of Fame, Oklahoma State University, 2022; Top Lawyer in San\nDiego, San Diego Magazine, 2013-2022; served on the Oklahoma State University Foundation Board of\nTrustees, 2013-2021; Philanthropist of the Year, Women for OSU at Oklahoma State University, 2020;\nSuper Lawyer, Super Lawyers Magazine, 2007\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 143\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 147 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDavid J. Hoffa | Of Counsel\nDavid Hoffa is Of Counsel in the Firm\u2019s Washington D.C. office. He has served as a liaison to over 110\ninstitutional investors in portfolio monitoring, securities litigation, and claims filing matters. His practice\nfocuses on providing a variety of legal and consulting services to U.S. state and municipal employee\nretirement systems and single and multi-employer U.S. Taft-Hartley benefit funds. In addition to serving\nas a leader on the Firm\u2019s Israel Institutional Investor Outreach Team, Hoffa also serves as a member of\nthe Firm\u2019s lead plaintiff advisory team, and advises public and multi-employer pension funds around the\ncountry on issues related to fiduciary responsibility, legislative and regulatory updates, and \u201cbest practices\u201d\nin the corporate governance of publicly traded companies.\n\nEarly in his legal career, Hoffa worked for a law firm based in Birmingham, Michigan, where he appeared\nregularly in Michigan state court in litigation pertaining to business, construction, and employment\nrelated matters. Hoffa has also appeared before the Michigan Court of Appeals on several occasions.\n\n\nEducation\nB.A., Michigan State University, 1993; J.D., Michigan State University College of Law, 2000\n\n\n\nNancy M. Juda | Of Counsel\nNancy Juda is Of Counsel to the Firm and is based in the Firm\u2019s Washington, D.C. office. Her practice\nfocuses on advising Taft-Hartley pension and welfare funds on issues related to corporate fraud in the\nUnited States securities markets. Juda\u2019s experience as an ERISA attorney provides her with unique\ninsight into the challenges faced by pension fund trustees as they endeavor to protect and preserve their\nfunds\u2019 assets.\n\nPrior to joining Robbins Geller, Juda was employed by the United Mine Workers of America Health &\nRetirement Funds, where she began her practice in the area of employee benefits law. She was also\nassociated with a union-side labor law firm in Washington, D.C., where she represented the trustees of\nTaft-Hartley pension and welfare funds on qualification, compliance, fiduciary, and transactional issues\nunder ERISA and the Internal Revenue Code.\n\nUsing her extensive experience representing employee benefit funds, Juda advises trustees regarding\ntheir options for seeking redress for losses due to securities fraud. She currently advises trustees of funds\nproviding benefits for members of unions affiliated with North America\u2019s Building Trades of the AFL-\nCIO. Juda also represents funds in ERISA class actions involving breach of fiduciary claims.\n\n\nEducation\nB.A., St. Lawrence University, 1988; J.D., American University, 1992\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 144\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 148 of 159\n ATTORNEY BIOGRAPHIES\n\n\nFrancis P. Karam | Of Counsel\nFrank Karam is Of Counsel to the Firm and is based in the Firm\u2019s Melville office. Karam is a trial lawyer\nwith 30 years of experience. His practice focuses on complex class action litigation involving\nshareholders\u2019 rights and securities fraud. He also represents a number of landowners and royalty owners\nin litigation against large energy companies. He has tried complex cases involving investment fraud and\ncommercial fraud, both on the plaintiff and defense side, and has argued numerous appeals in state and\nfederal courts. Throughout his career, Karam has tried more than 100 cases to verdict.\n\nKaram has served as a partner at several prominent plaintiffs\u2019 securities firms. From 1984 to 1990,\nKaram was an Assistant District Attorney in the Bronx, New York, where he served as a senior Trial\nAttorney in the Homicide Bureau. He entered private practice in 1990, concentrating on trial and\nappellate work in state and federal courts.\n\n\nEducation\nA.B., College of the Holy Cross; J.D., Tulane University School of Law\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2019-2025; \u201cWho\u2019s Who\u201d for Securities Lawyers, Corporate\nGovernance Magazine, 2015\n\n\n\nArthur C. Leahy | Of Counsel\nArt Leahy is a founding partner in the Firm\u2019s San Diego office and a member of the Firm\u2019s Management\nCommittee. He has over 20 years of experience successfully litigating securities actions and derivative\ncases. Leahy has recovered well over two billion dollars for the Firm\u2019s clients and has negotiated\ncomprehensive pro-investor corporate governance reforms at several large public companies. Most\nrecently, Leahy helped secure a $272 million recovery on behalf of mortgage-backed securities investors\nin NECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co. In the Goldman Sachs case, he helped\nachieve favorable decisions in the Second Circuit Court of Appeals on behalf of investors of Goldman\nSachs mortgage-backed securities and again in the Supreme Court, which denied Goldman Sachs\u2019\npetition for certiorari, or review, of the Second Circuit\u2019s reinstatement of the plaintiff\u2019s case. He was also\npart of the Firm\u2019s trial team in the AT&T securities litigation, which AT&T and its former officers paid\n$100 million to settle after two weeks of trial. Prior to joining the Firm, he served as a judicial extern for\nthe Honorable J. Clifford Wallace of the United States Court of Appeals for the Ninth Circuit, and served\nas a judicial law clerk for the Honorable Alan C. Kay of the United States District Court for the District of\nHawaii.\n\n\nEducation\nB.A., Point Loma Nazarene University, 1987; J.D., University of San Diego School of Law, 1990\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Best Lawyer in America, Best Lawyers\u00ae, 2024-2026; Top\nLawyer in San Diego, San Diego Magazine, 2013-2022; Leading Plaintiff Financial Lawyer, Lawdragon,\n2019-2021; Super Lawyer, Super Lawyers Magazine, 2016-2017; J.D., Cum Laude, University of San Diego\nSchool of Law, 1990; Managing Editor, San Diego Law Review, University of San Diego School of Law\n\n\n\n Robbins Geller Rudman & Dowd LLP | 145\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 149 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAvital O. Malina | Of Counsel\nAvital Malina is Of Counsel in the Firm\u2019s Melville office, where her practice focuses on complex securities\nlitigation.\n\nMalina has been recognized as a Rising Star by Super Lawyers Magazine for the New York Metro area\nnumerous times. Before joining the Firm, she was an associate in the New York office of a large\ninternational law firm, where her practice focused on complex commercial litigations.\n\n\nEducation\nB.A., Barnard College, 2005, J.D., Fordman University School of Law, 2009\n\nHonors / Awards\nRising Star, Super Lawyers Magazine, 2015-2021; B.A., Magna Cum Laude, Barnard College, 2005\n\n\n\nJerry E. Martin | Of Counsel\nJerry Martin is Of Counsel in the Firm\u2019s Nashville office. He specializes in representing individuals who\nwish to blow the whistle to expose fraud and abuse committed by federal contractors, health care\nproviders, tax cheats, or those who violate the securities laws. Martin was a member of the litigation team\nthat obtained a $65 million recovery in Garden City Emps.\u2019 Ret. Sys. v. Psychiatric Solutions, Inc., the fourth-\nlargest securities recovery ever in the Middle District of Tennessee and one of the largest in more than a\ndecade.\n\nBefore joining the Firm, Martin served as the presidentially appointed United States Attorney for the\nMiddle District of Tennessee from May 2010 to April 2013. As U.S. Attorney, he made prosecuting\nfinancial, tax, and health care fraud a top priority. During his tenure, Martin co-chaired the Attorney\nGeneral\u2019s Advisory Committee\u2019s Health Care Fraud Working Group. Martin has been recognized as a\nnational leader in combatting fraud and has addressed numerous groups and associations, such as\nTaxpayers Against Fraud and the National Association of Attorneys General, and was a keynote speaker at\nthe American Bar Association\u2019s Annual Health Care Fraud Conference.\n\n\nEducation\nB.A., Dartmouth College, 1996; J.D., Stanford University, 1999\n\nHonors / Awards\nSuper Lawyer, Super Lawyers Magazine, 2016-2019\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 146\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 150 of 159\n ATTORNEY BIOGRAPHIES\n\n\nRuby Menon | Of Counsel\nRuby Menon is Of Counsel to the Firm and is a member of the Firm\u2019s legal, advisory, and business\ndevelopment group. She also serves as the liaison to the Firm\u2019s many institutional investor clients in the\nUnited States and abroad.\n\nMenon began her legal career as an Assistant Prosecuting Attorney, gaining extensive training in trials\nand litigation. Later, for over 12 years, she served as the Chief Legal Counsel to two large multi-employer\nretirement plans, developing her expertise in many areas of employee benefits and pension\nadministration, including legislative initiatives and regulatory affairs, investments, tax, fiduciary\ncompliance, and plan administration. During her career as Chief Legal Counsel, Menon was a frequent\ninstructor for several certificate and training programs and seminars for pension fund trustees,\nadministrators, and other key decision makers of pension and employee benefits plans. She is a member\nof various legal and professional organizations in the United States and abroad.\n\nMenon currently serves as a co-chair on the National Association of Public Pension Attorneys Membership\nCommittee and as a board member on the Corporate Advisory Committee of the National Council on\nTeacher Retirement (NCTR). She has previously served as an advisory board member for the Sovereign\nWealth Fund Institute and as a committee member on the International Pension Employee & Benefits\nLawyers Association. Menon also organized and participated in the ACAP Shareholder sessions in\nSingapore and Hong Kong.\n\n\nEducation\nB.A., Indiana University, 1985; J.D., Indiana University School of Law, 1988\n\nHonors / Awards\nGlobal Plaintiff Lawyer, Lawdragon, 2024-2025\n\n\n\nSara B. Polychron | Of Counsel\nSara Polychron is Of Counsel in the Firm\u2019s San Diego office, where her practice focuses on complex\nsecurities litigation. She is part of the litigation team prosecuting actions against investment banks and\nthe leading credit rating agencies for their role in the structuring and rating of residential mortgage-\nbacked securities and their subsequent collapse.\n\nSara earned her Bachelor of Arts degree with honors from the University of Minnesota, where she\nstudied Sociology with an emphasis in Criminology and Law. As an undergraduate she interned with the\nHennepin County Attorney\u2019s Office, where she advocated for victims of domestic violence and assisted in\nsentencing negotiations in Juvenile Court. Sara received her Juris Doctor degree from the University of\nSan Diego School of Law, where she was the recipient of two academic scholarships. While in law school,\nshe interned with the Center for Public Interest Law and was a contributing author and assistant editor to\nthe California Regulatory Law Reporter. She also worked as a legal research assistant at the law school\nand clerked for two San Diego law firms.\n\n\nEducation\nB.A., University of Minnesota, 1999; J.D., University of San Diego School of Law, 2005\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 147\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 151 of 159\n ATTORNEY BIOGRAPHIES\n\n\nSvenna Prado | Of Counsel\nSvenna Prado is Of Counsel in the Firm\u2019s San Diego office, where she focuses on various aspects of\ninternational securities and consumer litigation. She was part of the litigation teams that secured\nsettlements against German defendant IKB, as well as Deutsche Bank and Deutsche Bank/West LB for\ntheir role in structuring residential mortgage-backed securities and their subsequent collapse. Before\njoining the Firm, Prado was Head of the Legal Department for a leading international staffing agency in\nGermany where she focused on all aspects of employment litigation and corporate governance. After she\nmoved to the United States, Prado worked with an internationally oriented German law firm as Counsel\nto corporate clients establishing subsidiaries in the United States and Germany. As a law student, Prado\nworked directly for several years for one of the appointed Trustees winding up Eastern German\noperations under receivership in the aftermath of the German reunification. Utilizing her experience in\nthis area of law, Prado later helped many clients secure successful outcomes in U.S. Bankruptcy Court.\n\n\nEducation\nJ.D., University of Erlangen-Nuremberg, Germany, 1996; Qualification for Judicial Office, Upper\nRegional Court Nuremberg, Germany, 1998; New York University, \u201cU.S. Law and Methodologies,\u201d 2001\n\n\n\nHarini P. Raghupathi | Of Counsel\nHarini Raghupathi is Of Counsel in the Firm\u2019s San Diego office. She is a member of the Firm\u2019s Appellate\nPractice Group.\n\nBefore joining the Firm, Harini represented victims of serious injury in federal and state appellate courts.\nHer practice areas included mass torts, consumer protection, and civil rights. Additionally, for over a\ndecade, Harini served as a federal public defender specializing in appeals. In that role, she obtained\nmultiple published reversals on behalf of her clients.\n\nIn 2012, The Recorder named Harini an \u201cAttorney of the Year\u201d for her successful appeal in United States v.\nLeal-Del Carmen, 697 F.3d 964 (9th Cir. 2012). Harini serves as the Chair of the Ninth Circuit Advisory\nCommittee on Rules of Practice. She is also a member of the San Diego Appellate Inn of Court and a\nvolunteer-mentor with The Appellate Project.\n\n\nEducation\nB.S., Stanford University, 2004; J.D., University of California, Berkeley School of Law, 2007\n\nHonors / Awards\nAttorney of the Year, The Recorder, 2012\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 148\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 152 of 159\n ATTORNEY BIOGRAPHIES\n\n\nAndrew T. Rees | Of Counsel\nAndrew Rees is Of Counsel in the Firm\u2019s Boca Raton office. His practice focuses on complex class actions,\nincluding securities, corporate governance and consumer fraud litigation. He was on the litigation team\nthat successfully obtained a $146.25 million recovery in Nieman v. Duke Energy Corp., which is the largest\nrecovery in North Carolina for a case involving securities fraud and one of the five largest recoveries in\nthe Fourth Circuit.\n\nBefore joining the Firm, Rees worked as an associate in the Washington, D.C. office of Hogan & Hartson\nLLP, where he practiced in the area of commercial transactions, including financings, stock purchases,\nasset acquisitions and mergers.\n\n\nEducation\nB.A., Pennsylvania State University, 1997; J.D., William and Mary School of Law, 2002\n\nHonors / Awards\nBest Lawyer in America: One to Watch, Best Lawyers\u00ae, 2024-2025\n\n\n\nJack Reise | Of Counsel\nJack Reise is Of Counsel in the Firm\u2019s Boca Raton office. Devoted to protecting the rights of those who\nhave been harmed by corporate misconduct, his practice focuses on class action litigation (including\nsecurities fraud, shareholder derivative actions, consumer protection, antitrust, and unfair and deceptive\ninsurance practices). Reise also dedicates a substantial portion of his practice to representing\nshareholders in actions brought under the federal securities laws. He is currently serving as lead counsel\nin more than a dozen cases nationwide. Most recently, Reise and a team of Robbins Geller attorneys\nobtained a $1.21 billion settlement in In re Valeant Pharms. Int\u2019l, Inc. Sec. Litig. (D.N.J.), a case that Vanity\nFair reported as \u201cthe corporate scandal of its era\u201d that had raised \u201cfundamental questions about the\nfunctioning of our health-care system, the nature of modern markets, and the slippery slope of ethical\nrationalizations.\u201d This is the largest securities class action settlement against a pharmaceutical\nmanufacturer and the ninth largest ever. As lead counsel, Reise has also represented investors in a series\nof cases involving mutual funds charged with improperly valuating their net assets, which settled for a\ntotal of more than $50 million. Other notable actions include: In re NewPower Holdings, Inc. Sec.\nLitig. (S.D.N.Y.) ($41 million settlement); In re ADT Inc. S\u2019holder Litig. (Fla. Cir. Ct., 15th Jud. Cir.) ($30\nmillion settlement); In re Red Hat, Inc. Sec. Litig. (E.D.N.C.) ($20 million settlement); and In re AFC Enters.,\nInc. Sec. Litig. (N.D. Ga.) ($17.2 million settlement).\n\n\nEducation\nB.A., Binghamton University, 1992; J.D., University of Miami School of Law, 1995\n\nHonors / Awards\nLeading Plaintiff Financial Lawyer, Lawdragon, 2019-2022; American Jurisprudence Book Award in\nContracts; J.D., Cum Laude, University of Miami School of Law, 1995; University of Miami Inter-American\nLaw Review, University of Miami School of Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 149\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 153 of 159\n ATTORNEY BIOGRAPHIES\n\n\nKevin S. Sciarani | Of Counsel\nKevin Sciarani is Of Counsel to the Firm and his practice focuses on complex securities litigation.\n\nKevin was a member of the litigation team that obtained a $300 million recovery in Purple Mountain Trust\nv. Wells Fargo & Company, which was reached while the parties were preparing for trial. He was also part\nof the litigation team in Karinski v. Stamps.com, Inc., which secured a $100 million recovery for investors.\n\nKevin earned Bachelor of Science and Bachelor of Arts degrees from the University of California, San\nDiego. He graduated magna cum laude from the University of California, Hastings College of the Law with\na Juris Doctor degree. During law school, Kevin interned for the U.S. Securities and Exchange\nCommission and the Antitrust Section of the California Department of Justice. In his final semester, he\nserved as an extern to the Honorable Susan Illston of the United States District Court for the Northern\nDistrict of California. Kevin also received recognition for his pro bono assistance to tenants living in bank-\nowned foreclosed residential properties due to the subprime mortgage crisis.\n\n\nEducation\nB.S., B.A., University of California, San Diego, 2005; J.D., University of California, Hastings College of\nthe Law, 2014\n\nHonors / Awards\nJ.D., Magna Cum Laude, Order of the Coif, University of California, Hastings College of the Law,\n2014; CALI Excellence Award, Senior Articles Editor, Hastings Law Journal, University of California,\nHastings College of the Law\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 150\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 154 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLeonard B. Simon | Of Counsel\nLeonard Simon is Of Counsel in the Firm\u2019s San Diego office. His practice has been devoted to litigation\nin the federal courts, including both the prosecution and the defense of major class actions and other\ncomplex litigation in the securities and antitrust fields. Simon has also handled a substantial number of\ncomplex appellate matters, arguing cases in the United States Supreme Court, several federal Courts of\nAppeals, and several California appellate courts. He has also represented large, publicly traded\ncorporations. Simon served as plaintiffs\u2019 co-lead counsel in In re Am. Cont\u2019l Corp./Lincoln Sav. & Loan Sec.\nLitig., MDL No. 834 (D. Ariz.) (settled for $240 million), and In re NASDAQ Market-Makers Antitrust Litig.,\nMDL No. 1023 (S.D.N.Y.) (settled for more than $1 billion). He was also in a leadership role in several of\nthe state court antitrust cases against Microsoft, and the state court antitrust cases challenging electric\nprices in California. He was centrally involved in the prosecution of In re Washington Pub. Power Supply\nSys. Sec. Litig., MDL No. 551 (D. Ariz.), the largest securities class action ever litigated.\n\nSimon is an Adjunct Professor of Law at Duke University, the University of San Diego, and the University\nof Southern California Law Schools. He has lectured extensively on securities, antitrust, and complex\nlitigation in programs sponsored by the American Bar Association Section of Litigation, the Practicing\nLaw Institute, and ALI-ABA, and at the UCLA Law School, the University of San Diego Law School, and\nthe Stanford Business School. He is an Editor of California Federal Court Practice and has authored a law\nreview article on the PSLRA.\n\n\nEducation\nB.A., Union College, 1970; J.D., Duke University School of Law, 1973\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Top Lawyer in San Diego, San Diego Magazine, 2016-2022;\nSuper Lawyer, Super Lawyers Magazine, 2008-2016; J.D., Order of the Coif and with Distinction, Duke\nUniversity School of Law, 1973\n\n\n\nMegan M. Sonney | Of Counsel\nMegan Sonney is Of Counsel to the Firm and is based in the San Diego office, where her practice focuses\non securities fraud litigation.\n\nMost recently, Sonney was a member of the litigation team that obtained a $434 million settlement in In re\nUnder Armour Sec. Litig. The case settled just prior to the commencement of trial in Baltimore, Maryland,\nand represents the second largest securities fraud settlement ever in the Fourth Circuit and is among the\ntop 50 largest such recoveries in U.S. history.\n\n\nEducation\nB.A., Point Loma Nazarene University, 2007; J.D., University of San Diego School of Law, 2011\n\nHonors / Awards\nB.A., cum laude, Point Loma Nazarene University, 2007\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 151\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 155 of 159\n ATTORNEY BIOGRAPHIES\n\n\nLaura S. Stein | Of Counsel\nLaura Stein is Of Counsel in the Firm\u2019s Philadelphia office. Since 1995, she has practiced in the areas of\nsecurities class action litigation, complex litigation, and legislative law. Stein has served as one of the\nFirm\u2019s and the nation\u2019s top asset recovery experts with a focus on minimizing losses suffered by\nshareholders due to corporate fraud and breaches of fiduciary duty. She also seeks to deter future\nviolations of federal and state securities laws by reinforcing the standards of good corporate governance.\nStein works with over 500 institutional investors across the nation and abroad, and her clients have served\nas lead plaintiff in successful cases where billions of dollars were recovered for defrauded investors against\nsuch companies as: Alphabet, Apple, AOL Time Warner, TYCO, Cardinal Health, AT&T, Hanover\nCompressor, 1st Bancorp, Enron, Dynegy, Inc., Honeywell International, Bridgestone, LendingClub,\nOrbital ATK, Under Armour, and Walmart, to name a few. Many of the cases led by Stein\u2019s clients have\naccomplished groundbreaking corporate governance achievements, including obtaining shareholder-\nnominated directors. She is a frequent presenter and educator on securities fraud monitoring, litigation,\nand corporate governance.\n\n\nEducation\nB.A., University of Pennsylvania, 1992; J.D., University of Pennsylvania Law School, 1995\n\nHonors / Awards\nLeading Plaintiff Financial Lawyer, Lawdragon, 2024-2025\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 152\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 156 of 159\n ATTORNEY BIOGRAPHIES\n\n\nJohn J. Stoia, Jr. | Of Counsel\nJohn Stoia is Of Counsel to the Firm and is based in the Firm\u2019s San Diego office. He is one of the\nfounding partners and former managing partner of the Firm. He focuses his practice on insurance fraud,\nconsumer fraud, and securities fraud class actions. Stoia has been responsible for over $10 billion in\nrecoveries on behalf of victims of insurance fraud due to deceptive sales practices such as \u201cvanishing\npremiums\u201d and \u201cchurning.\u201d He has worked on dozens of nationwide complex securities class actions,\nincluding In re Am. Cont\u2019l Corp./Lincoln Sav. & Loan Sec. Litig., which arose out of the collapse of Lincoln\nSavings & Loan and Charles Keating\u2019s empire. Stoia was a member of the plaintiffs\u2019 trial team that\nobtained verdicts against Keating and his co-defendants in excess of $3 billion and settlements of over\n$240 million.\n\nHe also represented numerous large institutional investors who suffered hundreds of millions of dollars\nin losses as a result of major financial scandals, including AOL Time Warner and WorldCom. Currently,\nStoia is lead counsel in numerous cases against online discount voucher companies for violations of both\nfederal and state laws including violation of state gift card statutes.\n\n\nEducation\nB.S., University of Tulsa, 1983; J.D., University of Tulsa, 1986; LL.M., Georgetown University Law\nCenter, 1987\n\nHonors / Awards\nRated AV Preeminent by Martindale-Hubbell; Top Lawyer in San Diego, San Diego Magazine, 2013-2022;\nSuper Lawyer, Super Lawyers Magazine, 2007-2017; Litigator of the Month, The National Law Journal, July\n2000; LL.M. Top of Class, Georgetown University Law Center\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 153\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 157 of 159\n ATTORNEY BIOGRAPHIES\n\n\nDavid C. Walton | Of Counsel\nDavid Walton was a founding partner of the Firm. For over 25 years, he has prosecuted class actions and\nprivate actions on behalf of defrauded investors, particularly in the area of accounting fraud. He has\ninvestigated and participated in the litigation of highly complex accounting scandals within some of\nAmerica\u2019s largest corporations, including Enron ($7.2 billion), HealthSouth ($671 million), WorldCom\n($657 million), AOL Time Warner ($629 million), Countrywide ($500 million), and Dynegy ($474\nmillion), as well as numerous companies implicated in stock option backdating.\n\nWalton is a member of the Bar of California, a Certified Public Accountant (California 1992), and is fluent\nin Spanish. In 2003-2004, he served as a member of the California Board of Accountancy, which is\nresponsible for regulating the accounting profession in California.\n\n\nEducation\nB.A., University of Utah, 1988; J.D., University of Southern California Law Center, 1993\n\nHonors / Awards\nRecommended Lawyer, The Legal 500, 2019; Super Lawyer, Super Lawyers Magazine, 2015-2016; California\nBoard of Accountancy, Member, 2003-2004; Southern California Law Review, Member, University of\nSouthern California Law Center; Hale Moot Court Honors Program, University of Southern California\nLaw Center\n\n\n\nBruce Gamble | Special Counsel\nBruce Gamble is Special Counsel to the Firm in the Firm\u2019s Washington D.C. office and is a member of the\nFirm\u2019s institutional investor client services group. He serves as liaison with the Firm\u2019s institutional\ninvestor clients in the United States and abroad, advising them on securities litigation matters. Gamble\nformerly served as Of Counsel to the Firm, providing a broad array of highly specialized legal and\nconsulting services to public retirement plans. Before working with Robbins Geller, Gamble was General\nCounsel and Chief Compliance Officer for the District of Columbia Retirement Board, where he served as\nchief legal advisor to the Board of Trustees and staff. Gamble\u2019s experience also includes serving as Chief\nExecutive Officer of two national trade associations and several senior level staff positions on Capitol Hill.\n\n\nEducation\nB.S., University of Louisville, 1979; J.D., Georgetown University Law Center, 1989\n\nHonors / Awards\nExecutive Board Member, National Association of Public Pension Attorneys, 2000-2006; American Banker\nselection as one of the most promising U.S. bank executives under 40 years of age, 1992\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 154\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 158 of 159\n ATTORNEY BIOGRAPHIES\n\n\nR. Steven Aronica | Forensic Accountant\nSteven Aronica is a Certified Public Accountant licensed in the States of New York and Georgia and is a\nmember of the American Institute of Certified Public Accountants, the Institute of Internal Auditors, and\nthe Association of Certified Fraud Examiners. Aronica has been instrumental in the prosecution of\nnumerous financial and accounting fraud civil litigation claims against companies that include Lucent\nTechnologies, Tyco, Oxford Health Plans, Computer Associates, Aetna, WorldCom, Vivendi, AOL Time\nWarner, Ikon, Doral Financial, First BanCorp, Acclaim Entertainment, Pall Corporation, iStar Financial,\nHibernia Foods, NBTY, Tommy Hilfiger, Lockheed Martin, the Blackstone Group, and Motorola. In\naddition, he assisted in the prosecution of numerous civil claims against the major United States public\naccounting firms.\n\nAronica has been employed in the practice of financial accounting for more than 30 years, including\npublic accounting, where he was responsible for providing clients with a wide range of accounting and\nauditing services; the investment bank Drexel Burnham Lambert, Inc., where he held positions with\naccounting and financial reporting responsibilities; and at the SEC, where he held various positions in the\ndivisions of Corporation Finance and Enforcement and participated in the prosecution of both criminal\nand civil fraud claims.\n\n\nEducation\nB.B.A., University of Georgia, 1979\n\n\n\nAndrew J. Rudolph | Forensic Accountant\nAndrew Rudolph is the Director of the Firm\u2019s Forensic Accounting Department, which provides in-house\nforensic accounting expertise in connection with securities fraud litigation against national and foreign\ncompanies. He has directed hundreds of financial statement fraud investigations, which were\ninstrumental in recovering billions of dollars for defrauded investors. Prominent cases include Qwest,\nHealthSouth, WorldCom, Boeing, Honeywell, Vivendi, Aurora Foods, Informix, Platinum Software, AOL Time\nWarner, and UnitedHealth.\n\nRudolph is a Certified Fraud Examiner and a Certified Public Accountant licensed to practice in\nCalifornia. He is an active member of the American Institute of Certified Public Accountants, California\u2019s\nSociety of Certified Public Accountants, and the Association of Certified Fraud Examiners. His 20 years of\npublic accounting, consulting, and forensic accounting experience includes financial fraud investigation,\nauditor malpractice, auditing of public and private companies, business litigation consulting, due\ndiligence investigations, and taxation.\n\n\nEducation\nB.A., Central Connecticut State University, 1985\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 155\n\f Case 1:23-cv-09476-KPF Document 115-4 Filed 02/17/26 Page 159 of 159\n ATTORNEY BIOGRAPHIES\n\n\n Christopher Yurcek | Forensic Accountant\n Christopher Yurcek is the Assistant Director of the Firm\u2019s Forensic Accounting Department, which\n provides in-house forensic accounting and litigation expertise in connection with major securities fraud\n litigation. He has directed the Firm\u2019s forensic accounting efforts on numerous high-profile cases,\n including In re Enron Corp. Sec. Litig. and Jaffe v. Household Int\u2019l, Inc., which obtained a record-breaking\n $1.575 billion settlement after 14 years of litigation, including a six-week jury trial in 2009 that resulted in\n a verdict for plaintiffs. Other prominent cases include HealthSouth, UnitedHealth, Vesta, Informix, Mattel,\n Coca-Cola, and Media Vision.\n\n Yurcek has over 20 years of accounting, auditing, and consulting experience in areas including financial\n statement audit, forensic accounting and fraud investigation, auditor malpractice, turn-around consulting,\n business litigation, and business valuation. He is a Certified Public Accountant licensed in California,\n holds a Certified in Financial Forensics (CFF) Credential from the American Institute of Certified Public\n Accountants, and is a member of the California Society of CPAs and the Association of Certified Fraud\n Examiners.\n\n\n Education\n B.A., University of California, Santa Barbara, 1985\n\n\n\n\n Robbins Geller Rudman & Dowd LLP | 156\n\nPowered by TCPDF (www.tcpdf.org)\n\f","ocr_status":1,"date_upload":"2026-06-22T23:05:38.127384-07:00","document_number":"115","attachment_number":4,"pacer_doc_id":"127039079705","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit D (Firm Resume)","acms_document_guid":""}],"date_created":"2026-02-17T13:09:02.956590-08:00","date_modified":"2026-02-20T12:05:41.126009-08:00","date_filed":"2026-02-17","time_filed":"14:11:59","entry_number":115,"recap_sequence_number":"2026-02-17.008","pacer_sequence_number":385,"description":"DECLARATION of Christopher M. Wood Filed on Behalf of Robbins Geller Rudman & Dowd LLP in Support re: 110 MOTION for Attorney Fees and Expenses.. Document filed by Genesee County Employees' Retirement System. (Attachments: # 1 Exhibit A (Lodestar Report), # 2 Exhibit B (Expense Summary), # 3 Exhibit C (Filing Expenses), # 4 Exhibit D (Firm Resume)).(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454083775/","id":454083775,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/468991836/","id":468991836,"tags":[],"absolute_url":"/docket/67923163/108/naclerio-v-docgo-inc/","date_created":"2026-02-17T11:09:46.600099-08:00","date_modified":"2026-03-22T05:43:52.448797-07:00","sha1":"ef6f6e5c3dd66065e418ace95c7b502d1b116b21","page_count":3,"file_size":105435,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.108.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.108.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 108 Filed 02/17/26 Page 1 of 3\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : LEAD PLAINTIFF\u2019S NOTICE OF MOTION\n : FOR FINAL APPROVAL OF CLASS\n vs. : ACTION SETTLEMENT AND APPROVAL\n : OF PLAN OF ALLOCATION\nDOCGO INC. and ANTHONY CAPONE, :\n :\n Defendants.\n :\n x\n\nTO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD\n\n PLEASE TAKE NOTICE that Court-appointed Lead Plaintiff, Genesee County Employees\u2019\n\nRetirement System, on behalf of the Class, by its undersigned counsel, will move this Court on\n\nMarch 24, 2026, at 10:00 a.m., before the Honorable Katherine Polk Failla at the Thurgood Marshall\n\nUnited States Courthouse, 40 Foley Square, New York, New York 10007, or as soon thereafter as\n\nthe parties can be heard, pursuant to Rule 23 of the Federal Rules of Civil Procedure, for entry of a\n\nFinal Judgment approving the proposed Settlement as fair, reasonable, and adequate and for entry of\n\nan Order approving the proposed Plan of Allocation for the proceeds of the Settlement as fair,\n\nreasonable, and adequate.\n\n In support of this motion, Lead Plaintiff submits and is filing herewith: (i) the Memorandum\n\nof Law in Support of Lead Plaintiff\u2019s Motion for Final Approval of Class Action Settlement and\n\nApproval of Plan of Allocation; (ii) the Declaration of Christopher M. Wood in Support of: (I) Lead\n\nPlaintiff\u2019s Motion for Final Approval of Class Action Settlement and Approval of Plan of\n\n\n\n -1-\n\f Case 1:23-cv-09476-KPF Document 108 Filed 02/17/26 Page 2 of 3\n\n\n\n\nAllocation; and (II) Lead Counsel\u2019s Motion for an Award of Attorneys\u2019 Fees and Expenses; (iii) the\n\nDeclaration of Tracy Khan; and (iv) the Declaration of Ross D. Murray.\n\n Proposed Orders will be submitted with Lead Plaintiff\u2019s reply submission on or before March\n\n17, 2026, after the deadlines for objection and seeking exclusion have passed.\n\nDATED: February 17, 2026 Respectfully submitted,\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n 200 31st Avenue North\n Nashville, TN 37203\n Telephone: 615/244-2203\n 615/252-3798 (fax)\n cwood@rgrdlaw.com\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n SAMUEL H. RUDMAN\n DAVID A. ROSENFELD\n 58 South Service Road, Suite 200\n Melville, NY 11747\n Telephone: 631/367-7100\n 631/367-1173 (fax)\n srudman@rgrdlaw.com\n drosenfeld@rgrdlaw.com\n\n\n\n\n -2-\n\fCase 1:23-cv-09476-KPF Document 108 Filed 02/17/26 Page 3 of 3\n\n\n\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n ELLEN GUSIKOFF STEWART (admitted pro hac vice)\n ERIC I. NIEHAUS (admitted pro hac vice)\n JOSEPH J. TULL (admitted pro hac vice)\n 655 West Broadway, Suite 1900\n San Diego, CA 92101\n Telephone: 619/231-1058\n 619/231-7423 (fax)\n elleng@rgrdlaw.com\n ericn@rgrdlaw.com\n jtull@rgrdlaw.com\n\n Lead Counsel for Lead Plaintiff\n\n VANOVERBEKE, MICHAUD\n & TIMMONY, P.C.\n THOMAS C. MICHAUD\n 79 Alfred Street\n Detroit, MI 48201\n Telephone: 313/578-1200\n 313/578-1201 (fax)\n tmichaud@vmtlaw.com\n\n Additional Counsel\n\n\n\n\n -3-\n\f","ocr_status":2,"date_upload":"2026-03-17T13:17:04.658370-07:00","document_number":"108","attachment_number":null,"pacer_doc_id":"127039079470","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Settlement","acms_document_guid":""}],"date_created":"2026-02-17T11:09:46.566833-08:00","date_modified":"2026-02-20T12:05:40.746925-08:00","date_filed":"2026-02-17","time_filed":"13:54:00","entry_number":108,"recap_sequence_number":"2026-02-17.001","pacer_sequence_number":363,"description":"MOTION for Settlement for Final Approval and Approval of Plan of Allocation. Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454083761/","id":454083761,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/468991822/","id":468991822,"tags":[],"absolute_url":"/docket/67923163/109/naclerio-v-docgo-inc/","date_created":"2026-02-17T11:09:44.202245-08:00","date_modified":"2026-06-23T03:25:54.735601-07:00","sha1":"46c1b353ed842a2c6d9d0397c07af3474937114e","page_count":31,"file_size":297779,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.109.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.109.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 1 of 31\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : MEMORANDUM OF LAW IN SUPPORT\n : OF LEAD PLAINTIFF\u2019S MOTION FOR\n vs. : FINAL APPROVAL OF CLASS ACTION\n : SETTLEMENT AND APPROVAL OF PLAN\nDOCGO INC. and ANTHONY CAPONE, : OF ALLOCATION\n :\n Defendants.\n :\n x\n\n\n\n\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 2 of 31\n\n\n\n TABLE OF CONTENTS\n\n Page\n\n\nI. PRELIMINARY STATEMENT .........................................................................................1\n\nII. FACTUAL AND PROCEDURAL BACKGROUND.........................................................3\n\nIII. THE SETTLEMENT WARRANTS FINAL APPROVAL .................................................3\n\n A. The Legal Standards for Final Approval Under Rule 23(e) and Grinnell ...............3\n\n B. The Settlement Is Fair, Reasonable, and Adequate in Light of the Rule 23\n and Grinnell Factors ................................................................................................6\n\n 1. The Class Was Adequately Represented .....................................................6\n\n 2. The Proposed Settlement Was Negotiated by Experienced Counsel\n at Arm\u2019s Length Before an Experienced Mediator ......................................8\n\n 3. The Relief Provided by the Settlement Is Adequate in Light of the\n Litigation Risks, Costs, and Delays of Trial and Appeal .............................9\n\n a. The Complexity, Expense, and Likely Duration of\n Litigation ..........................................................................................9\n\n b. The Risks of Establishing Liability and Damages at Trial ............10\n\n 4. Stage of the Proceedings and the Amount of Discovery Completed .........12\n\n 5. The Recovery Is Reasonable in Light of the Best Possible\n Recovery and Attendant Risks of Litigation..............................................13\n\n 6. The Reaction of the Class Supports Final Approval ..................................13\n\n 7. Maintaining Class-Action Status Through Trial ........................................15\n\n 8. Defendants\u2019 Ability to Withstand Greater Judgment.................................15\n\n 9. Other Rule 23(e)(2) Factors Support Final Approval ................................16\n\n a. The Proposed Method of Distributing Relief Is Effective .............16\n\n b. The Proposed Award of Attorneys\u2019 Fees Is Fair and\n Reasonable .....................................................................................16\n\n c. Identification of Agreements in Connection with the\n Settlement ......................................................................................17\n\n -i-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 3 of 31\n\n\n\n\n Page\n\n d. The Settlement Treats All Class Members Equally Relative\n to One Another ...............................................................................18\n\nIV. THE PLAN OF ALLOCATION IS FAIR AND REASONABLE AND SHOULD\n BE APPROVED BY THE COURT ..................................................................................18\n\nV. THE COURT SHOULD FINALLY CERTIFY THE CLASS FOR PURPOSES\n OF EFFECTUATING THE SETTLEMENT ....................................................................19\n\nVI. THE NOTICE OF SETTLEMENT SATISFIES RULE 23 AND DUE PROCESS\n REQUIREMENTS.............................................................................................................20\n\nVII. CONCLUSION ..................................................................................................................22\n\n\n\n\n - ii -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 4 of 31\n\n\n\n TABLE OF AUTHORITIES\n\n Page\n\nCASES\n\nCastagna v. Madison Square Garden, L.P.,\n 2011 WL 2208614 (S.D.N.Y. June 7, 2011) ...........................................................................15\n\nChristine Asia Co., Ltd. v. Yun Ma,\n 2019 WL 5257534 (S.D.N.Y. Oct. 16, 2019) .................................................................. passim\n\nCity of Providence v. Aeropostale, Inc.,\n 2014 WL 1883494 (S.D.N.Y. May 9, 2014),\n aff\u2019d sub nom. Arbuthnot v. Pierson,\n 607 F. App\u2019x 73 (2d Cir. 2015) .........................................................................................14, 15\n\nD\u2019Amato v. Deutsche Bank,\n 236 F.3d 78 (2d Cir. 2001).........................................................................................................8\n\nDetroit v. Grinnell Corp.,\n 495 F.2d 448 (2d Cir. 1974),\n abrogated by Goldberger v. Integrated Res., Inc.,\n 209 F.3d 43 (2d Cir. 2000)............................................................................................... passim\n\nDura Pharms., Inc. v. Broudo,\n 544 U.S. 336 (2005) .................................................................................................................10\n\nGuevoura Fund Ltd. v. Sillerman,\n 2019 WL 6889901 (S.D.N.Y. Dec. 18, 2019) .........................................................................18\n\nIn re Advanced Battery Techs., Inc. Sec. Litig.,\n 298 F.R.D. 171 (S.D.N.Y. 2014) .........................................................................................3, 18\n\nIn re Bear Stearns Cos., Inc. Sec., Derivative, & ERISA Litig.,\n 909 F. Supp. 2d 259 (S.D.N.Y. 2012)..................................................................................8, 13\n\nIn re Chrysler-Dodge-Jeep Ecodiesel Mktg., Sales Pracs., & Prods. Liab. Litig.,\n 2019 WL 2554232 (N.D. Cal. May 3, 2019) .............................................................................5\n\nIn re Citigroup Inc. Bond Litig.,\n 296 F.R.D. 147 (S.D.N.Y. 2013) .............................................................................................18\n\nIn re Facebook, Inc. IPO Sec. & Deriv. Litig.,\n 2015 WL 6971424 (S.D.N.Y. Nov. 9, 2015),\n aff\u2019d, 674 F. App\u2019x 37 (2d Cir. 2016) ......................................................................................11\n\n\n\n - iii -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 5 of 31\n\n\n\n\n Page\n\nIn re Facebook, Inc., IPO Sec. & Derivative Litig.,\n 343 F. Supp. 3d 394 (S.D.N.Y. 2018),\n aff\u2019d, 822 F. App\u2019x 40 (2d Cir. 2020) ......................................................................8, 13, 14, 18\n\nIn re FLAG Telecom Holdings, Ltd. Sec. Litig.,\n 2010 WL 4537550 (S.D.N.Y. Nov. 8, 2010) .............................................................................9\n\nIn re Giant Interactive Grp., Inc. Sec. Litig.,\n 279 F.R.D. 151 (S.D.N.Y. 2011) .............................................................................................13\n\nIn re Glob. Crossing Sec. & ERISA Litig.,\n 225 F.R.D. 436 (S.D.N.Y. 2004) .............................................................................................10\n\nIn re GSE Bonds Antitrust Litig.,\n 2020 WL 3250593 (S.D.N.Y. June 16, 2020) .....................................................................5, 14\n\nIn re GSE Bonds Antitrust Litig.,\n 414 F. Supp. 3d 686 (S.D.N.Y. 2019)............................................................................9, 10, 15\n\nIn re Hi-Crush Partners L.P. Sec. Litig.,\n 2014 WL 7323417 (S.D.N.Y. Dec. 19, 2014) ...................................................................13, 18\n\nIn re IMAX Sec. Litig.,\n 283 F.R.D. 178 (S.D.N.Y. 2012) .............................................................................................11\n\nIn re Jernigan Cap., Inc. Sec. Litig.,\n No. 1:20-cv-09575-JLR-KHP, ECF 95\n (S.D.N.Y. June 12, 2023).....................................................................................................6, 17\n\nIn re Merrill Lynch Tyco Rsch. Sec. Litig.,\n 249 F.R.D. 124 (S.D.N.Y. 2008) .............................................................................................20\n\nIn re Namenda Direct Purchaser Antitrust Litig.,\n 462 F. Supp. 3d 307 (S.D.N.Y. 2020)....................................................................................4, 9\n\nIn re Patriot Nat\u2019l, Inc. Sec. Litig.,\n 828 F. App\u2019x 760 (2d Cir. 2020) ...............................................................................................6\n\nIn re Payment Card Interchange Fee & Merch. Disc. Antitrust Litig.,\n 330 F.R.D. 11 (E.D.N.Y. 2019) .................................................................................................5\n\nIn re Signet Jewelers Ltd. Sec. Litig.,\n 2020 WL 4196468 (S.D.N.Y. July 21, 2020) .................................................................. passim\n\n\n - iv -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 6 of 31\n\n\n\n\n Page\n\nIn re Sony SXRS Rear Projection Television Class Action Litig.,\n 2008 WL 1956267 (S.D.N.Y. May 1, 2008) ...........................................................................15\n\nIn re Telik, Inc. Sec. Litig.,\n 576 F. Supp. 2d 570 (S.D.N.Y. 2008)......................................................................................12\n\nIn re Veeco Instruments Inc. Sec. Litig.,\n 2007 WL 4115809 (S.D.N.Y. Nov. 7, 2007) .....................................................................14, 19\n\nIn re Waste Mgmt. Sec. Litig.,\n 775 F. Supp. 3d 742 (S.D.N.Y. 2025)........................................................................................7\n\nIn re XL Fleet Corp. Sec. Litig.,\n 2024 WL 1884483 (S.D.N.Y. Apr. 30, 2024)..........................................................................17\n\nMaley v. Del Glob. Techs. Corp.,\n 186 F. Supp. 2d 358 (S.D.N.Y. 2002)................................................................................14, 17\n\nMart\u00ednek v. Antitrust Fin. Servs.,\n 2022 WL 16960903 (S.D.N.Y. Nov. 16, 2022) .......................................................................17\n\nMcIntosh v. Katapult Holdings,\n 2024 WL 5118192 (S.D.N.Y. Dec. 13, 2024) ................................................................. passim\n\nMikhlin v. Oasmia Pharm. AB,\n 2021 WL 1259559 (E.D.N.Y. Jan. 6, 2021) ............................................................................11\n\nOleniak v. Time Warner Cable,\n 2013 WL 12447094 (S.D.N.Y. Dec. 17, 2013) .......................................................................14\n\nPearlstein v. BlackBerry Ltd.,\n 2022 WL 4554858 (S.D.N.Y. Sept. 29, 2022) ...............................................................3, 17, 21\n\nRodriguez v. CPI Aerostructures, Inc.,\n 2023 WL 2184496 (E.D.N.Y. Feb. 16, 2023)......................................................................9, 21\n\nSynder v. Ocwen Loan Servicing, LLC,\n 2019 WL 2103379 (N.D. Ill. May 14, 2019) .............................................................................5\n\nThompson v. Metro. Life Ins. Co.,\n 216 F.R.D. 55 (S.D.N.Y. 2003) .................................................................................................5\n\nVargas v. Cap. One Fin. Advisors,\n 559 F. App\u2019x 22 (2d Cir. 2014) ...............................................................................................20\n\n -v-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 7 of 31\n\n\n\n\n Page\n\nWal-Mart Stores, Inc. v. Visa U.S.A., Inc.,\n 396 F.3d 96 (2d Cir. 2005),\n superseded by rule as stated in Moses v. N.Y. Times Co.,\n 79 F.4th 235 (2d Cir. 2023) .................................................................................................3, 20\n\nYang v. Focus Media Holding,\n 2014 WL 4401280 (S.D.N.Y. Sept. 4, 2014).............................................................................3\n\nYuzary v. HSBC Bank USA, N.A.,\n 2013 WL 5492998 (S.D.N.Y. Oct. 2, 2013) ............................................................................14\n\nSTATUTES, RULES, AND REGULATIONS\n\n15 U.S.C.\n \u00a778j(b) ................................................................................................................................10, 19\n \u00a778u-4(a)(7) .............................................................................................................................21\n\nFederal Rules of Civil Procedure\n Rule 23 .........................................................................................................................5, 6, 9, 21\n Rule 23(a)...........................................................................................................................19, 20\n Rule 23(b)(3)......................................................................................................................19, 20\n Rule 23(c)(1)(C).......................................................................................................................15\n Rule 23(c)(2)(B).................................................................................................................20, 21\n Rule 23(e).........................................................................................................................1, 3, 20\n Rule 23(e)(1)(B).......................................................................................................................20\n Rule 23(e)(2) .................................................................................................................... passim\n Rule 23(e)(2)(A) ........................................................................................................................6\n Rule 23(e)(2)(B).........................................................................................................................8\n Rule 23(e)(2)(C)(i) .....................................................................................................................9\n Rule 23(e)(2)(C)(ii) ..................................................................................................................16\n Rule 23(e)(2)(C)(iii).................................................................................................................16\n Rule 23(e)(2)(C)(iv) .................................................................................................................16\n Rule 23(e)(2)(D) ..................................................................................................................5, 16\n\nSECONDARY AUTHORITIES\n\nRecent Trends in Securities Class Action Litigation:\n 2025 Full-Year Review (NERA Jan. 21, 2026)\n Edward Flores, Svetlana Starykh, and Ivelina Velikova .........................................................13\n\n\n\n\n - vi -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 8 of 31\n\n\n\n\n Pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, lead plaintiff Genesee County\n\nEmployees\u2019 Retirement System (\u201cLead Plaintiff\u201d) respectfully submits this memorandum of law in\n\nsupport of its motion for final approval of the Settlement and approval of the Plan of Allocation.1\n\nI. PRELIMINARY STATEMENT\n\n After extensive litigation and arm\u2019s-length negotiations overseen by an experienced\n\nmediator, Lead Plaintiff and Lead Counsel obtained a $12.5 million cash recovery (the \u201cSettlement\u201d)\n\nfor the Class. The Settlement represents an excellent result for the Class and should be approved as\n\nfair, reasonable, and adequate.\n\n Over the course of over two years, Lead Plaintiff and Lead Counsel diligently prosecuted this\n\nAction on behalf of the Class; drafting and filing a detailed amended complaint; successfully in part\n\ndefeating Defendants\u2019 motion to dismiss; moving for class certification; obtaining and analyzing tens\n\nof thousands of pages of documents produced by Defendants and third parties; and participating in\n\narm\u2019s-length negotiations overseen by Miles Ruthberg, a highly experienced mediator with Philips\n\nADR Enterprises. Through these efforts, Lead Plaintiff and Lead Counsel developed a deep and\n\nthorough understanding of the facts and the relative strengths and weaknesses of Lead Plaintiff\u2019s\n\nclaims.\n\n While Lead Plaintiff and Lead Counsel believe in the merits of the claims asserted in this\n\nAction, they recognized that continued litigation posed significant risks, including because\n\nDefendants vehemently denied liability and damages. Defendants argued that Lead Plaintiff would\n\n\n\n1\n Unless otherwise noted, capitalized terms have the meanings ascribed to them in the Stipulation\nof Settlement filed on November 12, 2025 (ECF 101-1) (the \u201cStipulation\u201d) or in the accompanying\nDeclaration of Christopher M. Wood in Support of: (I) Lead Plaintiff\u2019s Motion for Final Approval of\nClass Action Settlement and Approval of Plan of Allocation; and (II) Lead Counsel\u2019s Motion for an\nAward of Attorneys\u2019 Fees and Expenses (the \u201cWood Declaration\u201d or \u201cWood Decl.\u201d). Unless\notherwise noted, citations are omitted and emphasis is added.\n\n -1-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 9 of 31\n\n\n\n\nnot be able to prove loss causation or damages because DocGo\u2019s stock price declined as a result of\n\nnonactionable factors unrelated to the alleged misstatements and omissions. Wood Decl., \u00b6\u00b659-65.\n\nIf Defendants prevailed on any of their defenses at summary judgment or trial, the Class stood to\n\nrecover no (or significantly reduced) damages. Moreover, even if the Class did ultimately prevail,\n\nits ability to collect a judgment was uncertain.\n\n With the foregoing in mind, and based on years of experience prosecuting securities fraud\n\nclass actions, Lead Counsel supports the Settlement. The Settlement recovers over 20% of\n\nreasonably recoverable damages. Wood Decl., \u00b66. Moreover, Lead Plaintiff supports the\n\nSettlement, and, although the deadline to object to the Settlement has not yet passed, there have been\n\nno objections thus far.2 Nor have any Class Members sought exclusion from the Class. See\n\nDeclaration of Ross D. Murray Regarding: (A) Notice Dissemination; (B) Publication; (C)\n\nEstablishment of Call Center Services and Website; and (D) Requests for Exclusion Received to\n\nDate (\u201cMurray Decl.\u201d), \u00b616, submitted herewith.\n\n Lead Plaintiff also requests that the Court approve the proposed Plan of Allocation. The Plan\n\nof Allocation was developed in consultation with Lead Counsel\u2019s damages expert and was detailed\n\nin the Court-approved Notice of Pendency and Proposed Settlement of Class Action (\u201cNotice\u201d). The\n\nPlan of Allocation treats Class Members equitably. The Plan of Allocation provides for the pro rata\n\ndistribution of the Net Settlement Fund to Authorized Claimants based on their recognized losses\n\nwhile taking into account the Court\u2019s holdings in the motion to dismiss order. The Plan of\n\nAllocation calculates the Recognized Loss Amount based on the Net Settlement Fund divided by the\n\n\n\n\n2\n The deadline to object to the Settlement and Plan of Allocation is March 3, 2026. If any\nobjections are timely filed, Lead Counsel will respond in its reply brief, to be filed on March 17,\n2026.\n\n -2-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 10 of 31\n\n\n\n\ntotal number of shares represented by the valid Claims of Authorized Claimants. Wood Decl., \u00b6\u00b675-\n\n79. To date, there have been no objections to the proposed Plan of Allocation.\n\n For these and the reasons set forth below, the Court should grant final approval of the\n\nSettlement and approve the Plan of Allocation.\n\nII. FACTUAL AND PROCEDURAL BACKGROUND\n\n The Wood Declaration is an integral part of this submission and, for the sake of brevity, the\n\nCourt is respectfully referred to it for a detailed description of, inter alia: the factual background and\n\nprocedural history of the Action; the nature of the claims asserted; the negotiations leading to the\n\nSettlement; the risks and uncertainties of continued litigation; and the terms of the Plan of Allocation\n\nof the Net Settlement Fund.\n\nIII. THE SETTLEMENT WARRANTS FINAL APPROVAL\n\n A. The Legal Standards for Final Approval Under Rule 23(e) and\n Grinnell\n\n Rule 23(e) of the Federal Rules of Civil Procedure provides for final approval of a class\n\naction settlement that is \u201cfair, reasonable, and adequate.\u201d Fed. R. Civ. P. 23(e)(2). In the Second\n\nCircuit there is a \u201c\u2018strong judicial policy in favor of settlements, particularly in the class action\n\ncontext.\u2019\u201d See Wal-Mart Stores, Inc. v. Visa U.S.A., Inc., 396 F.3d 96, 116-17 (2d Cir. 2005),\n\nsuperseded by rule as stated in Moses v. N.Y. Times Co., 79 F.4th 235 (2d Cir. 2023); see also\n\nPearlstein v. BlackBerry Ltd., 2022 WL 4554858, at *2 (S.D.N.Y. Sept. 29, 2022) (\u201c\u2018The law favors\n\ncompromise and settlement of class action suits.\u2019\u201d); Yang v. Focus Media Holding, 2014 WL\n\n4401280, at *3 (S.D.N.Y. Sept. 4, 2014) (citation modified) (\u201cWhen exercising discretion to approve\n\na settlement, courts are mindful of the strong judicial policy in favor of settlements.\u201d); In re\n\nAdvanced Battery Techs., Inc. Sec. Litig., 298 F.R.D. 171, 174 (S.D.N.Y. 2014) (\u201cThe law favors\n\n\n\n -3-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 11 of 31\n\n\n\n\nsettlement, particularly in class actions and other complex cases where substantial resources can be\n\nconserved by avoiding the time, cost, and rigor of prolonged litigation.\u201d).\n\n In determining whether a proposed settlement is \u201cfair, reasonable, and adequate,\u201d courts\n\nconsider whether:\n\n (A) the class representatives and class counsel have adequately represented the\n class;\n\n (B) the proposal was negotiated at arm\u2019s length;\n\n (C) the relief provided for the class is adequate, taking into account:\n\n (i) the costs, risks, and delay of trial and appeal;\n\n (ii) the effectiveness of any proposed method of distributing relief to the\n class, including the method of processing class-member claims;\n\n (iii) the terms of any proposed award of attorney\u2019s fees, including timing\n of payment; and\n\n (iv) any agreement required to be identified under Rule 23(e)(3); and\n\n (D) the proposal treats class members equitably relative to each other.\n\nFed. R. Civ. P. 23(e)(2). Courts in the Second Circuit also consider the following factors, which\n\noverlap with the Rule 23(e)(2) factors, in determining whether to grant final approval of a class\n\naction settlement:\n\n (1) the complexity, expense and likely duration of the litigation; (2) the reaction of\n the class to the settlement; (3) the stage of the proceedings and the amount of\n discovery completed; (4) the risks of establishing liability; (5) the risks of\n establishing damages; (6) the risks of maintaining the class action through the trial;\n (7) the ability of the defendants to withstand a greater judgment; (8) the range of\n reasonableness of the settlement fund in light of the best possible recovery; and\n (9) the range of reasonableness of the settlement fund . . . in light of all the attendant\n risks of litigation.\n\nDetroit v. Grinnell Corp., 495 F.2d 448, 463 (2d Cir. 1974), abrogated by Goldberger v. Integrated\n\nRes., Inc., 209 F.3d 43 (2d Cir. 2000); see also In re Namenda Direct Purchaser Antitrust Litig., 462\n\nF. Supp. 3d 307, 311 (S.D.N.Y. 2020) (\u201c\u2018The factors set forth in Rule 23(e)(2) have been applied in\n\n -4-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 12 of 31\n\n\n\n\ntandem with the Second Circuit\u2019s Grinnell factors . . . .\u2019\u201d); In re Payment Card Interchange Fee &\n\nMerch. Disc. Antitrust Litig., 330 F.R.D. 11, 29 (E.D.N.Y. 2019) (\u201c[T]here is significant overlap\n\nbetween the Grinnell factors and the Rule 23(e)(2)(C-D) factors, as they both guide a court\u2019s\n\nsubstantive, as opposed to procedural, analysis.\u201d).\n\n The Rule 23(e)(2) and Grinnell factors are analyzed holistically. See Moses, 79 F.4th at 243\n\n(\u201cCourts . . . must consider the four factors outlined in Rule 23(e)(2) holistically . . . .\u201d); McIntosh v.\n\nKatapult Holdings, 2024 WL 5118192, at *8 (S.D.N.Y. Dec. 13, 2024) (alteration in original)\n\n(\u201cImportantly, \u2018not every factor must weigh in favor of [the] settlement, rather the court should\n\nconsider the totality of these factors in light of the particular circumstances.\u2019\u201d); Thompson v. Metro.\n\nLife Ins. Co., 216 F.R.D. 55, 61 (S.D.N.Y. 2003) (\u201cAll nine factors need not be satisfied, rather, the\n\ncourt should consider the totality of these factors in light of the particular circumstances.\u201d).\n\n The Court considered and found these factors to have been satisfied at the preliminary\n\napproval stage. See ECF 106. The Court\u2019s \u201cconclusions [at preliminary approval] stand and counsel\n\nequally in favor of final approval now.\u201d See In re Chrysler-Dodge-Jeep Ecodiesel Mktg., Sales\n\nPracs., & Prods. Liab. Litig., 2019 WL 2554232, at *2 (N.D. Cal. May 3, 2019); see also In re GSE\n\nBonds Antitrust Litig., 2020 WL 3250593, at *1 (S.D.N.Y. June 16, 2020) (\u201cThe Court in its opinion\n\nand orders providing the basis for its preliminary approval[] . . . . has already explained in detail why\n\nthe Rule 23 and Grinnell factors support approval . . . . The Court re-adopts that analysis here, and\n\nlimits its focus to those few developments since . . . preliminary approval[] . . . .\u201d); see also Synder v.\n\nOcwen Loan Servicing, LLC, 2019 WL 2103379, at*4 (N.D. Ill. May 14, 2019) (noting at final\n\napproval that \u201c[s]ignificant portions of the Court\u2019s [preliminary approval] analysis remain materially\n\nunchanged\u201d).\n\n\n\n\n -5-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 13 of 31\n\n\n\n\n B. The Settlement Is Fair, Reasonable, and Adequate in Light of the\n Rule 23 and Grinnell Factors\n\n 1. The Class Was Adequately Represented\n\n In approving a settlement, courts are required to consider whether the \u201cclass representatives\n\nand class counsel have adequately represented the class.\u201d Fed. R. Civ. P. 23(e)(2)(A). The\n\nadequacy assessment typically \u201c\u2018entails inquiry as to whether: 1) plaintiffs\u2019 interests are antagonistic\n\nto the interest[s] of other members of the class and 2) plaintiffs\u2019 attorneys are qualified, experienced\n\nand able to conduct the litigation.\u2019\u201d In re Signet Jewelers Ltd. Sec. Litig., 2020 WL 4196468, at *2\n\n(S.D.N.Y. July 21, 2020); see also In re Patriot Nat\u2019l, Inc. Sec. Litig., 828 F. App\u2019x 760, 764 (2d\n\nCir. 2020) (\u201c[T]he primary factors [in assessing adequacy] are whether the class representatives have\n\nany \u2018interests antagonistic to the interests of other class members\u2019 and whether the representatives\n\n\u2018have an interest in vigorously pursuing the claims of the class.\u2019\u201d).\n\n These requirements are readily satisfied here. Lead Plaintiff\u2019s claims \u201care typical of and\n\ncoextensive with those of other Class Members and [it] has no interests antagonistic to those of other\n\nClass Members.\u201d Signet, 2020 WL 4196468, at *2. Like all other Class Members, Lead Plaintiff is\n\nalleged to have suffered losses as a result of Defendants\u2019 false and misleading statements. Lead\n\nPlaintiff purchased over 22,000 DocGo shares during the Class Period (ECF 17-2) and was\n\n\u201csufficiently motivated\u201d to obtain the largest possible recovery for the Class. See Patriot, 828 F.\n\nApp\u2019x at 764 (finding adequacy where \u201clead plaintiffs were sufficiently motivated to recover as\n\nmuch as possible for each class member\u201d); see also In re Jernigan Cap., Inc. Sec. Litig., No.\n\n1:20-cv-09575-JLR-KHP, ECF 95 at 8 (S.D.N.Y. June 12, 2023) (Report & Recommendation\n\nadopted by ECF 103 (Sept. 14, 2023)) (\u201c[Lead Plaintiff] had a large number of shares in JCAP and is\n\ninterested in maximizing the financial recovery obtained through this suit \u2013 an interest shared by the\n\nproposed class.\u201d).\n\n -6-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 14 of 31\n\n\n\n\n As detailed in Lead Plaintiff\u2019s declaration, Lead Plaintiff actively participated in the\n\nprosecution of this Action, including by reviewing pleadings, providing document discovery, and\n\nparticipating in numerous discussions with Lead Counsel regarding the evidentiary record, case\n\ndevelopments, litigation strategy, and settlement negotiations. See Declaration of Tracy Khan in\n\nSupport of Lead Plaintiff\u2019s Motion for Final Approval of Settlement and Award of Attorneys\u2019 Fees\n\nand Expenses (\u201cKhan Decl.\u201d), \u00b6\u00b64-5, submitted herewith.\n\n Lead Counsel has extensive experience litigating complex class actions. See accompanying\n\nDeclaration of Christopher M. Wood Filed on Behalf of Robbins Geller Rudman & Dowd LLP in\n\nSupport of Application for Award of Attorneys\u2019 Fees and Expenses, Ex. D (firm r\u00e9sum\u00e9). Lead\n\nCounsel has substantial experience in securities class actions, including in this District, and has been\n\nfound adequate in a multitude of cases. See, e.g., In re Waste Mgmt. Sec. Litig., 775 F. Supp. 3d\n\n742, 766 (S.D.N.Y. 2025) (\u201cRobbins Geller has substantial experience in prosecuting securities fraud\n\nclass actions, having served as lead or co-lead counsel in many securities class actions.\u201d).\n\n Lead Counsel also adequately represented the Class in this Action, vigorously prosecuting\n\nthis case for over two years. See generally Wood Decl. Lead Counsel drafted and filed an amended\n\ncomplaint. Lead Counsel also defeated in large part Defendants\u2019 motion to dismiss and moved for\n\nclass certification. Lead Counsel also aggressively pursued discovery, including propounding\n\ndiscovery requests, interrogatories, and requests for admissions on Defendants, serving 11 non-party\n\nsubpoenas, reviewing and analyzing over 20,000 pages of documents, and participating in numerous\n\nmeet and confers to address the scope of discovery. Lead Counsel also participated in settlement\n\nnegotiations and drafted the settlement-related documents. See generally Wood Decl. Through\n\nthese efforts, Lead Counsel was able to obtain an excellent recovery for the Class.\n\n\n\n\n -7-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 15 of 31\n\n\n\n\n Accordingly, the adequacy factor is satisfied and weighs in favor of final approval of the\n\nSettlement.\n\n 2. The Proposed Settlement Was Negotiated by Experienced\n Counsel at Arm\u2019s Length Before an Experienced Mediator\n\n Rule 23(e)(2)(B), which analyzes whether the settlement was the product of arm\u2019s length\n\nnegotiations, favors approval. See Moses, 79 F.4th 235 at 243 (\u201c[T]he arms-length quality of the\n\nnegotiations remain a factor in favor of approving the settlement (one whose absence would count\n\nsignificantly against approval).\u201d).\n\n Here, the proposed Settlement was the result of arm\u2019s-length negotiations, and was only\n\nreached after two years of hard fought litigation, and with the benefit of a comprehensive\n\ndocumentary record. On September 9, 2025, the Parties participated in a full-day mediation\n\noverseen by Miles Ruthberg, an experienced mediator. In advance of the mediation, the Parties\n\nsubmitted and exchanged mediation statements. During the mediation session, the Parties engaged\n\nin substantive discussions regarding the documentary evidence and their respective positions on\n\nliability and damages. A settlement was not reached during that session. Nevertheless, the Parties,\n\naided by Mr. Ruthberg, continued their settlement negotiations. In the weeks that followed, the\n\nParties, with a thorough understanding of the strengths and weaknesses of their respective positions,\n\naccepted Mr. Ruthberg\u2019s recommendation to settle the Action for $12.5 million in cash.\n\n Accordingly, the Settlement warrants approval because it was the result of arm\u2019s-length\n\nnegotiations by experienced counsel overseen by a mediator, whose involvement \u201chelps to ensure\n\nthat the proceedings were free of collusion and undue pressure.\u201d See D\u2019Amato v. Deutsche Bank,\n\n236 F.3d 78, 85 (2d Cir. 2001); see also In re Facebook, Inc., IPO Sec. & Derivative Litig., 343 F.\n\nSupp. 3d 394, 408-09 (S.D.N.Y. 2018) (settlement was procedurally fair where it was \u201cbased on the\n\nsuggestion by a neutral mediator\u201d), aff\u2019d, 822 F. App\u2019x 40 (2d Cir. 2020); In re Bear Stearns Cos.,\n -8-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 16 of 31\n\n\n\n\nInc. Sec., Derivative, & ERISA Litig., 909 F. Supp. 2d 259, 265 (S.D.N.Y. 2012) (finding settlement\n\nprocedurally fair where the parties engaged in arm\u2019s-length negotiations before an experienced\n\nmediator).\n\n 3. The Relief Provided by the Settlement Is Adequate in Light of\n the Litigation Risks, Costs, and Delays of Trial and Appeal\n\n Courts must consider the adequacy of a settlement in light of \u201cthe costs, risks, and delay of\n\ntrial and appeal\u201d and other factors. Fed. R. Civ. P. 23(e)(2)(C)(i). This Rule 23 factor overlaps with\n\nthe first, fourth, and fifth Grinnell factors (i.e., the complexity, expense and likely duration of the\n\nlitigation; the risks of establishing liability; and the risks of establishing damages). See Rodriguez v.\n\nCPI Aerostructures, Inc., 2023 WL 2184496, at *11 (E.D.N.Y. Feb. 16, 2023) (\u201c\u2018The first factor set\n\nforth under Rule 23(e)(2)(C), \u201cthe costs, risks, and delay of trial and appeal,\u201d \u201csubsumes several\n\nGrinnell factors,\u201d including the complexity, expense and likely duration of litigation, the risks of\n\nestablishing liability, the risks of establishing damages . . .\u2019\u201d); Namenda, 462 F. Supp. 3d at 311\n\n(\u201c\u2018The factors set forth in Rule 23(e)(2) have been applied in tandem with the Second Circuit\u2019s\n\nGrinnell factors . . . .\u2019\u201d); In re GSE Bonds Antitrust Litig., 414 F. Supp. 3d 686, 693-94 (S.D.N.Y.\n\n2019) (analyzing the adequacy factor alongside the first, fourth, and fifth Grinnell factors). As\n\ndetailed below, each of these factors weigh in favor of final approval.\n\n a. The Complexity, Expense, and Likely Duration of\n Litigation\n\n \u201cCourts recognize that \u2018securities class actions are generally complex and expensive to\n\nprosecute,\u2019\u201d and litigating such actions \u201cis notably difficult and notoriously uncertain.\u201d Signet, 2020\n\nWL 4196468, at *4 (citation modified); Christine Asia Co., Ltd. v. Yun Ma, 2019 WL 5257534, at\n\n*10 (S.D.N.Y. Oct. 16, 2019); see also In re FLAG Telecom Holdings, Ltd. Sec. Litig., 2010 WL\n\n4537550, at *15 (S.D.N.Y. Nov. 8, 2010) (same). This Action is no different.\n\n\n -9-\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 17 of 31\n\n\n\n\n This case involved complex and disputed issues concerning, among other things, materiality,\n\nscienter, loss causation, and damages. This case arose from alleged misrepresentations concerning\n\nDocGo\u2019s former CEO Capone\u2019s educational background, DocGo\u2019s purported involvement in signing\n\nmigrants up for New York State Medicaid, and a purported $4 billion contract with U.S. Customs\n\nand Border Patrol (\u201cCBP\u201d). The Defendants and Former Defendants argued that the alleged\n\nmisrepresentations were immaterial, or that they lacked sufficient scienter with respect to them.\n\nAlthough the Court largely denied the motion to dismiss, it dismissed the Former Defendants from\n\nthe case entirely, and dismissed the CBP statements for failing to adequately allege any Defendants\u2019\n\nscienter with respect to them. Wood Decl., \u00b6\u00b628-30. Whether Lead Plaintiff would ultimately\n\nsucceed at summary judgment or at trial on the remaining claims against the remaining defendants\n\nwas by no means guaranteed. This Settlement eliminates the risks of unfavorable outcomes at\n\nfurther stages of the case.\n\n b. The Risks of Establishing Liability and Damages at\n Trial\n\n In assessing the fairness, reasonableness, and adequacy of a settlement, \u201c[a] court \u2018should\n\nbalance the benefits afforded the Class, including immediacy and certainty of recovery, against the\n\ncontinuing risks of litigation.\u2019\u201d GSE, 414 F. Supp. 3d at 694; see also In re Glob. Crossing Sec. &\n\nERISA Litig., 225 F.R.D. 436, 459 (S.D.N.Y. 2004) (\u201c[T]he Court need only assess the risks of\n\nlitigation against the certainty of recovery under the proposed settlement.\u201d).\n\n To prevail on a \u00a710(b) claim, Lead Plaintiff must establish all elements of the claim,\n\nincluding falsity, materiality, loss causation, and scienter. Dura Pharms., Inc. v. Broudo, 544 U.S.\n\n336, 341-42 (2005). Defendants need to succeed on only one defense to defeat the entire case.\n\n As detailed herein and in the Wood Declaration, Defendants vehemently disputed liability.\n\nThey argued that Lead Plaintiff would be unable to prove materiality for statements regarding\n - 10 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 18 of 31\n\n\n\n\nCapone\u2019s education. Wood Decl., \u00b659. They also argued that investors did not understand Capone\n\nto mean that DocGo was literally signing asylum seekers up for New York State Medicaid, but rather\n\nthat it was facilitating signups through United Healthcare. Id. In addition, Defendants would likely\n\ncontend that Lead Plaintiff would not be able to establish loss causation, including because a portion\n\nof the final drop in DocGo\u2019s stock price was caused by the revelation that the CBP contract was not\n\nas high as Capone claimed and that claim was dismissed from the case. Id., \u00b661. Defendants would\n\nalso likely contend that it was Capone\u2019s departure as CEO, and not the revelation of his educational\n\nbackground, that was the sole cause of DocGo\u2019s stock price drop, and that measuring that drop over\n\nmultiple days would be inappropriate. Id. While Lead Plaintiff and Lead Counsel believe they had\n\nmeritorious responses, they recognized that Defendants\u2019 success on any one of these arguments\n\nposed risks to the Class\u2019s ability to recover if the Litigation continued.\n\n To prove loss causation and damages, Lead Plaintiff would have relied heavily on expert\n\ntestimony. This would have invariably led to Daubert challenges and a \u201cbattle of the experts\u201d with\n\nunpredictable results. See Mikhlin v. Oasmia Pharm. AB, 2021 WL 1259559, at *6 (E.D.N.Y. Jan. 6,\n\n2021) (\u201cBoth parties would present expert testimony on the issue of damages, which makes it\n\n\u2018virtually impossible to predict\u2019 which side\u2019s testimony would be found more credible, as well as\n\n\u2018which damages would be found to have been caused by actionable, rather than the myriad\n\nnonactionable factors such as general market conditions.\u2019\u201d); In re Facebook, Inc. IPO Sec. & Deriv.\n\nLitig., 2015 WL 6971424, at *5 (S.D.N.Y. Nov. 9, 2015) (alteration in original) (\u2018\u201c[D]amages would\n\nbe subject to a battle of the experts, with the possibility that a jury could be swayed by experts for\n\nDefendants, who could minimize or eliminate the amount Plaintiffs\u2019 losses.\u2019\u201d), aff\u2019d, 674 F. App\u2019x\n\n37 (2d Cir. 2016); In re IMAX Sec. Litig., 283 F.R.D. 178, 193 (S.D.N.Y. 2012) (\u201c[I]t is well\n\nestablished that damages calculations in securities class actions often descend into a battle of\n\n - 11 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 19 of 31\n\n\n\n\nexperts.\u201d); In re Telik, Inc. Sec. Litig., 576 F. Supp. 2d 570, 579-80 (S.D.N.Y. 2008) (\u201c\u2018In this\n\n\u201cbattle of experts,\u201d it is virtually impossible to predict with any certainty which testimony would be\n\ncredited, and ultimately, which damages would be found . . . .\u2019\u201d).\n\n In sum, the Settlement provides the Class with a substantial and immediate cash benefit while\n\navoiding the risks and costs of continued litigation, which would have included litigating class\n\ncertification, completing fact discovery, expert discovery, summary judgment, trial, and a possible\n\nappeal. Thus, this factor weighs in favor of final approval.\n\n 4. Stage of the Proceedings and the Amount of Discovery\n Completed\n\n The stage of the proceedings factor examines \u201c\u2018whether the parties . . . counsel possessed a\n\nrecord sufficient to permit evaluation of the merits of Plaintiffs\u2019 claims, the strengths of the defenses\n\nasserted by Defendants, and the value of Plaintiffs\u2019 causes of action for purposes of settlement.\u2019\u201d\n\nSignet, 2020 WL 4196468, at *7 (ellipsis in original). Here, Lead Plaintiff and Lead Counsel had\n\nmore than enough information to assess the strengths and weaknesses of Lead Plaintiff\u2019s claims, and\n\nthe propriety of the Settlement. By the time the Settlement was reached, the Litigation was well\n\nunderway: Lead Counsel had largely defeated Defendants\u2019 motion to dismiss; moved for class\n\ncertification; commenced party and non-party discovery; reviewed and analyzed over 20,000 pages\n\nof documents; consulted with an expert on damages; and participated in settlement negotiations with\n\nmediator Miles Ruthberg. Therefore, Lead Plaintiff and Lead Counsel \u201chad a sufficient record to\n\nintelligently assess the strengths and weaknesses of their claims and the value of the case,\u201d id., which\n\nsupports final approval of the Settlement.\n\n\n\n\n - 12 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 20 of 31\n\n\n\n\n 5. The Recovery Is Reasonable in Light of the Best Possible\n Recovery and Attendant Risks of Litigation\n\n The adequacy of a recovery \u201cmay not be judged \u2018in comparison with the possible recovery in\n\nthe best of all possible worlds, but rather in light of the strengths and weaknesses of plaintiffs\u2019\n\ncase.\u2019\u201d In re Giant Interactive Grp., Inc. Sec. Litig., 279 F.R.D. 151, 162 (S.D.N.Y. 2011).\n\nMoreover, when there are \u201cserious challenges to establishing liability,\u201d the best recovery must be\n\nadjudged against \u201cthe risk of non-recovery.\u201d Facebook, 343 F. Supp. 3d at 414; see also Bear\n\nStearns, 909 F. Supp. 2d at 270.\n\n Here, the $12.5 million Settlement represents an outstanding recovery. The Settlement\n\nrepresents over 20% of reasonably recoverable damages. This result far exceeds the median\n\nsettlement recovery of 1.5% of \u201cNERA-Defined Investor Losses\u201d in securities cases revolved in\n\n2025. Edward Flores, Svetlana Starykh, and Ivelina Velikova, Recent Trends in Securities Class\n\nAction Litigation: 2025 Full-Year Review at 28 fig. 24 (NERA Jan. 21, 2026).3 Finally, the $12\n\nmillion Settlement is within the range of reasonableness because it was \u201cagreed upon\u201d by Lead\n\nCounsel after \u201ccareful consideration\u201d of the substantial risks of no recovery. See Facebook, 343 F.\n\nSupp. 3d at 414 (finding agreed upon $35 million settlement within the range of reasonable where\n\nthere was a risk of obtaining zero or minimal damages).\n\n 6. The Reaction of the Class Supports Final Approval\n\n \u201c\u2018The favorable reaction of the overwhelming majority of class members to the Settlement is\n\nperhaps the most significant factor in [the] Grinnell inquiry\u2019 into the fairness and adequacy of the\n\nSettlement.\u201d Signet, 2020 WL 4196468, at *6 (alteration in original); see also In re Hi-Crush\n\n\n\n3\n In cases with investor losses of between $50 and $99 million, where this case falls, the median\nsettlement value as a percentage of NERA-Defined Investor Losses between 2016 and 2025 was\n4.4%. Id. at 27, fig. 23. This Settlement recovers approximately five times that percentage.\n\n - 13 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 21 of 31\n\n\n\n\nPartners L.P. Sec. Litig., 2014 WL 7323417, at *6 (S.D.N.Y. Dec. 19, 2014) (\u201cThe reaction of\n\nthe . . . Class to the Settlement is a significant factor in assessing its fairness and adequacy.\u201d The\n\nabsence of objections and opt outs \u201cprovides evidence of Class Members\u2019 approval of the terms of\n\nthe Settlement and desire to share in the proceeds thereof.\u201d); In re Veeco Instruments Inc. Sec. Litig.,\n\n2007 WL 4115809, at *7 (S.D.N.Y. Nov. 7, 2007) (\u201cIt is \u2018well-settled\u2019 that the reaction of the class\n\nto a settlement is considered perhaps \u2018the most significant factor to be weighed in considering its\n\nadequacy.\u2019\u201d); Maley v. Del Glob. Techs. Corp., 186 F. Supp. 2d 358, 362 (S.D.N.Y. 2002) (\u201c[T]he\n\nreaction of the class to the settlement is perhaps the most significant factor to be weighed in\n\nconsidering its adequacy.\u201d).\n\n While the deadline for submitting objections has not yet passed, there have been no\n\nobjections to, or requests for exclusion from, the Settlement. See Murray Decl., \u00b616. The Class\u2019s\n\nreaction thus far weighs in favor of approval. See City of Providence v. Aeropostale, Inc., 2014 WL\n\n1883494, at *5 (S.D.N.Y. May 9, 2014) (citation modified) (\u201c[T]he absence of objections may itself\n\nbe taken as evidencing the fairness of a settlement.\u201d), aff\u2019d sub nom. Arbuthnot v. Pierson, 607 F.\n\nApp\u2019x 73 (2d Cir. 2015); see also GSE, 2020 WL 3250593, at *2 (\u201c\u2018A favorable reception by the\n\nClass constitutes \u201cstrong evidence\u201d that a proposed settlement is fair.\u2019\u201d); Oleniak v. Time Warner\n\nCable, 2013 WL 12447094, at *6 (S.D.N.Y. Dec. 17, 2013) (Failla J.) (\u201c\u2018The fact that the vast\n\nmajority of class members neither objected nor opted out is a strong indication\u2019 of fairness.\u201d);\n\nYuzary v. HSBC Bank USA, N.A., 2013 WL 5492998, at *6 (S.D.N.Y. Oct. 2, 2013) (\u201cThis favorable\n\nresponse [i.e., no objections and only eight opt outs] demonstrates that the class approves of the\n\nsettlement and supports final approval.\u201d); Facebook, 343 F. Supp. 3d at 410 (\u201cThe overwhelmingly\n\npositive reaction \u2013 or absence of a negative reaction \u2013 weighs strongly in favor of [final approval].\u201d).\n\n\n\n\n - 14 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 22 of 31\n\n\n\n\n 7. Maintaining Class-Action Status Through Trial\n\n A class certification order \u201cmay be altered or amended before final judgment.\u201d See Fed. R.\n\nCiv. P. 23(c)(1)(C). Consequently, courts routinely find that this factor weighs in favor of final\n\napproval when there is a risk that defendants would oppose class certification. See, e.g., Christine\n\nAsia, 2019 WL 5257534, at *13 (finding this factor weighed in favor of approval where there\n\nremained a risk that defendants would oppose class certification if the case went to trial); GSE, 414\n\nF. Supp. 3d at 694 (alterations in original) (\u201cAlthough the \u2018risk of maintaining a class through trial is\n\npresent in [every] class action,\u2019 \u2018this factor [nevertheless] weighs in favor of settlement\u2019 where \u2018it is\n\nlikely that defendants would oppose class certification\u2019 if the case were to be litigated.\u201d).\n\n Lead Plaintiff\u2019s opening class certification motion was filed at the time the settlement was\n\nreached. Defendants would likely have vigorously opposed the motion. Failure to obtain class\n\ncertification would effectively end the case. Therefore, this factor supports class certification.\n\n 8. Defendants\u2019 Ability to Withstand Greater Judgment\n\n A defendant\u2019s ability to withstand a potentially larger settlement \u201cdoes not necessarily\n\npreclude a finding that the settlement is fair.\u201d McIntosh, 2024 WL 5118192, at *11; see also\n\nCastagna v. Madison Square Garden, L.P., 2011 WL 2208614, at *7 (S.D.N.Y. June 7, 2011)\n\n(\u201c\u2018[D]efendant\u2019s ability to withstand a greater judgment, standing alone, does not suggest that the\n\nsettlement is unfair.\u2019\u201d); Aeropostale, 2014 WL 1883494, at *9 (\u201cCourts . . . generally do not find the\n\nability of a defendant to withstand a greater judgment to be an impediment to settlement when the\n\nother factors favor the settlement.\u201d). Moreover, a \u201cdefendant is not required to \u2018empty its coffers\u2019\n\nbefore a settlement can be found adequate.\u201d In re Sony SXRS Rear Projection Television Class\n\nAction Litig., 2008 WL 1956267, at *8 (S.D.N.Y. May 1, 2008).\n\n\n\n\n - 15 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 23 of 31\n\n\n\n\n Here, there was substantial doubt about Defendants\u2019 ability to satisfy a judgment. Indeed,\n\nDocGo stock is currently trading at under $1 a share, and it appears it would be unable to pay a\n\nsubstantial judgment entered against it.\n\n 9. Other Rule 23(e)(2) Factors Support Final Approval\n\n Rule 23(e)(2) requires courts to consider the following additional factors: (i) the effectiveness\n\nof the proposed method of distributing relief to the class; (ii) the terms of any proposed award of\n\nattorneys\u2019 fees, including the timing of payment; (iii) any agreement made in connection with the\n\nproposed settlement; and (iv) the equitable treatment of class members. See Fed. R. Civ. P.\n\n23(e)(2)(C)(i)-(iv); Fed. R. Civ. P. 23(e)(2)(D). Each of these factors support final approval of the\n\nproposed Settlement.\n\n a. The Proposed Method of Distributing Relief Is Effective\n\n The methods for processing Class Members\u2019 Claims and distributing relief to Authorized\n\nClaimants is well-established and effective. Here, the Court-appointed Claims Administrator, Verita\n\nGlobal, see ECF 106, \u00b69, will review and process Claims under the guidance of Lead Counsel, allow\n\nclaimants the opportunity to cure any deficiencies in their Claims or request the Court\u2019s review of a\n\ndenial of their Claims, and mail or wire Authorized Claimants their pro rata share of the Net\n\nSettlement Fund pursuant to the proposed Plan of Allocation. See Stipulation, ECF 101-1, \u00b6\u00b65.6-\n\n5.10. This proposed method of distributing settlement proceeds is \u201cstandard in securities and other\n\nclass actions and is effective.\u201d Christine Asia, 2019 WL 5257534, at *14.\n\n b. The Proposed Award of Attorneys\u2019 Fees Is Fair and\n Reasonable\n\n As discussed in the accompanying Memorandum of Law in Support of Lead Counsel\u2019s\n\nMotion for an Award of Attorneys\u2019 Fees and Expenses (\u201cFee Memorandum\u201d), Lead Counsel is\n\napplying for an award of 33% of the Settlement Amount as compensation for the services it rendered\n\n - 16 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 24 of 31\n\n\n\n\non behalf of the Class, as well as payment of litigation costs and expenses in the amount of\n\n$183,676.18. The attorneys\u2019 fees requested by counsel are reasonable in light of the work performed\n\nand the results obtained, and a 33% fee award is consistent with fees awarded by courts in the\n\nSecond Circuit, including in this District, in similar common-fund cases. See, e.g., Jernigan, ECF\n\n95; Mart\u00ednek v. Antitrust Fin. Servs., 2022 WL 16960903, at *2-*3 (S.D.N.Y. Nov. 16, 2022)\n\n(Failla, J.) (awarding 33%\u2153 fee in $13 million settlement); In re XL Fleet Corp. Sec. Litig., 2024\n\nWL 1884483, at *1 (S.D.N.Y. Apr. 30, 2024) (awarding attorneys\u2019 fees of 33\u2153% of the settlement\n\nfund); McIntosh, 2024 WL 5118192, at *11-*13 (awarding attorneys\u2019 fees of 33\u2153% of the\n\nsettlement fund); Pearlstein, 2022 WL 4554858, at *10 (\u201cClass counsel\u2019s request for one-third of the\n\ngross settlement fund is reasonable within this circuit.\u201d); Maley, 186 F. Supp. 2d at 370\n\n(\u201cPetitioners\u2019 request [for 33\u2153% of the class settlement fund] is well within th[e range of fees\n\nawarded by courts in the Second Circuit] and falls comfortably within the range of fees typically\n\nawarded in securities class actions.\u201d). Notably, the Court\u2019s consideration of the requested attorneys\u2019\n\nfees is separate from its consideration of approval of the Settlement, the Settlement is not subject to\n\ntermination based on the Court\u2019s ruling on attorneys\u2019 fees, and the Class was notified of the terms of\n\nthe proposed award of attorneys\u2019 fees, including the timing of such payments. See Stipulation, ECF\n\n101-1, \u00b6\u00b66.1, 6.4.\n\n c. Identification of Agreements in Connection with the\n Settlement\n\n As previously disclosed, the Settling Parties have entered into a confidential supplemental\n\nagreement pursuant to which DocGo may terminate the Settlement if requests for exclusion (i.e., opt-\n\nouts) reach a certain threshold. See Stipulation, \u00b67.3. This type of agreement is standard in\n\nsecurities class action settlements and has \u201cno negative impact on the fairness of the Settlement.\u201d\n\nChristine Asia, 2019 WL 5257534, at *15.\n - 17 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 25 of 31\n\n\n\n\n d. The Settlement Treats All Class Members Equally\n Relative to One Another\n\n The Settlement treats Class Members equally. Under the proposed Plan of Allocation, each\n\nAuthorized Claimant will receive his, her, their, or its pro rata share of the Net Settlement Fund\n\nbased on their recognized losses as calculated by the Plan of Allocation. Lead Plaintiff is subject to\n\nthe same distribution formula as every other Class Member.\n\n In sum, the Rule 23(e)(2) and Grinnell factors support final approval of the Settlement.\n\nIV. THE PLAN OF ALLOCATION IS FAIR AND REASONABLE AND\n SHOULD BE APPROVED BY THE COURT\n\n The standard for approving a plan of allocation is the same as the standard for approving a\n\nsettlement \u2013 namely, the plan must be \u201cfair, reasonable, and adequate.\u201d Signet, 2020 WL 496468 at\n\n*13; see also Guevoura Fund Ltd. v. Sillerman, 2019 WL 6889901, at *10 (S.D.N.Y. Dec. 18,\n\n2019); In re Citigroup Inc. Bond Litig., 296 F.R.D. 147, 157-58 (S.D.N.Y. 2013) (\u201cThe plan of\n\nallocation is subject to the same test of fairness, reasonableness, and adequacy as the settlement\n\nitself.\u201d). A plan of allocation \u201c\u2018need only have a reasonable, rational basis, particularly if\n\nrecommended by experienced and competent class counsel.\u2019\u201d McIntosh, 2024 WL 5118192, at *11;\n\nChristine Asia, 2019 WL 5257534, at *15; see also Advanced Battery, 298 F.R.D. at 180 (\u201c\u2018When\n\nformulated by competent and experienced class counsel,\u2019 a plan for allocation of net settlement\n\nproceeds \u2018need have only a reasonable, rational basis.\u2019\u201d); In re Hi-Crush Partners L.P., 2014 WL\n\n7323417, at *10 (same).\n\n Here, the proposed Plan of Allocation, which was developed in consultation with Lead\n\nCounsel\u2019s damages expert, is fair, reasonable, and adequate. See Wood Decl., \u00b6\u00b675-79; Facebook,\n\n343 F. Supp. 3d at 414 (\u201cPlaintiffs\u2019 Plan of Allocation was prepared by experienced counsel along\n\nwith a damages expert \u2013 both indicia of reasonableness.\u201d). The proposed Plan of Allocation\n\n\n - 18 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 26 of 31\n\n\n\n\nprovides that the Net Settlement Fund will be distributed to Authorized Claimants on a pro rata\n\nbasis based on their recognized losses. Wood Decl., \u00b6\u00b675-79; see also McIntosh, 2024 WL 5118192,\n\nat *11 (approving plan of allocation that distributed settlement funds to class members on a pro rata\n\nbasis to class members as appropriate and consistent with prior cases). The proposed Plan of\n\nAllocation is consistent with the \u00a710(b) claims alleged in the Action, and accounts for the findings in\n\nthe Court\u2019s motion to dismiss order. Wood Decl., \u00b676. Moreover, the Plan of Allocation was set\n\nforth in the Notice and, to date, no objections to the Plan of Allocation have been filed. This\n\nfavorable response from the Class supports approval of the Plan of Allocation as fair and reasonable.\n\nSee Signet, 2020 WL 4196468, at *6 (\u201cThe reaction of the Class also supports approval of the Plan\n\nof Allocation.\u201d); Vecco, 2007 WL 4115809, at *14 (\u201c[N]ot one class member has objected to the\n\nPlan of Allocation which was fully explained in the Notice of Settlement sent to all Class Members.\n\nThis favorable reaction of the Class supports approval of the Plan of Allocation.\u201d).\n\nV. THE COURT SHOULD FINALLY CERTIFY THE CLASS FOR\n PURPOSES OF EFFECTUATING THE SETTLEMENT\n\n In its motion for preliminary approval of the Settlement, Lead Plaintiff requested that the\n\nCourt certify the Class for settlement purposes so that notice of the Settlement, the Settlement\n\nHearing, and the rights of Class Members to object to the Settlement, request exclusion from the\n\nClass, or submit Proofs of Claim, could be issued. See ECF 100. In the Preliminary Approval\n\nOrder, the Court addressed the requirements for class certification as set forth in Rules 23(a) and\n\n23(b)(3) of the Federal Rules of Civil Procedure. The Court found that Lead Plaintiff had met the\n\nrequirements for certification of the Class for purposes of settlement. ECF 106, \u00b63. In addition, the\n\nCourt preliminarily certified Lead Plaintiff as Class Representative and Lead Counsel as Class\n\nCounsel. Id., \u00b64.\n\n\n\n - 19 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 27 of 31\n\n\n\n\n Nothing has changed since the Court\u2019s entry of the Preliminary Approval Order to alter the\n\npropriety of the Court\u2019s preliminary certification of the Class for settlement purposes. Thus, for all\n\nof the reasons stated in Lead Plaintiff\u2019s motion for preliminary approval (incorporated herein by\n\nreference), Lead Plaintiff respectfully requests that the Court affirm its preliminary certification and\n\nfinally certify the Class for purposes of carrying out the Settlement pursuant to Federal Rules of\n\nCivil Procedure 23(a) and 23(b)(3), and appoint Lead Plaintiff as Class Representative and Lead\n\nCounsel as Class Counsel.\n\nVI. THE NOTICE OF SETTLEMENT SATISFIES RULE 23 AND DUE\n PROCESS REQUIREMENTS\n\n Rule 23(e) requires that notice of a proposed class action settlement be given to class\n\nmembers in a \u201creasonable manner,\u201d Fed. R. Civ. P. 23(e)(1)(B), and that the notice be \u201cthe best\n\nnotice . . . practicable under the circumstances, including individual notice to all members who can\n\nbe identified through reasonable effort[s].\u201d Fed. R. Civ. P. 23(c)(2)(B). In addition, a notice of\n\nsettlement must satisfy due process and include the information outlined in Rule 23(c)(2)(B) and the\n\nPrivate Securities Litigation Reform Act of 1995 (\u201cPSLRA\u201d), 15 U.S.C. \u00a778u-4(a)(7). A notice that\n\nfairly apprises \u201c\u2018members of the class of the terms of the proposed settlement and of the options that\n\nare open to them in connection with the proceedings\u2019\u201d satisfies Rule 23(e) and due process. Wal-\n\nMart, 396 F.3d at 114; Vargas v. Cap. One Fin. Advisors, 559 F. App\u2019x 22, 26-27 (2d Cir. 2014);\n\nsee also In re Merrill Lynch Tyco Rsch. Sec. Litig., 249 F.R.D. 124, 133 (S.D.N.Y. 2008) (\u201cNotice is\n\ngenerally deemed reasonable if the average person understands the terms of the proposed settlement\n\nand the options provided to class members thereunder.\u201d) The notice plan used here satisfies these\n\nrequirements.\n\n In accordance with the Preliminary Approval Order, the Claims Administrator, Verita\n\nGlobal, disseminated 13,280 copies of the Court-approved Postcard Notice to potential Class\n - 20 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 28 of 31\n\n\n\n\nMembers and nominees. Murray Decl., \u00b611. The Claims Administrator also published the Summary\n\nNotice in The Wall Street Journal and transmitted it over Business Wire. Id., \u00b612. In addition, the\n\nClaims Administrator provided potential Class Members with the Court-approved Notice online\n\nthrough the Settlement website. Id., \u00b614.\n\n The Court-approved Notice provides Class Members with the necessary information to make\n\nan informed decision about the proposed Settlement. The Notice provides recipients with\n\ninformation concerning: (i) the nature of the Action and the claims asserted therein; (ii) the definition\n\nof the Class; (iii) the essential terms of the Settlement; (iv) the proposed Plan of Allocation and\n\nestimated average per share recovery; (v) the maximum amount of attorneys\u2019 fees and expenses that\n\nwill be sought; (vi) Class Members\u2019 rights to request exclusion from the Class or to object to the\n\nSettlement, the Plan of Allocation, and/or a request for attorneys\u2019 fees or expenses (including the\n\nmethod and timing for requesting exclusion or objecting to the Settlement); (vii) the binding effect of\n\na judgment on Class Members; and (viii) the contact information for Lead Counsel and the Claims\n\nAdministrator. See Fed. R. Civ. P. 23(c)(2)(B); 15 U.S.C. \u00a778u-4(a)(7). The Notice also provides\n\ninformation concerning how to submit a Proof of Claim and Release and the date, time, and location\n\nof the Settlement Hearing.\n\n Here, the Court-approved notice plan, which combines individual email or First-Class Mail\n\nnotice with publication of a Summary Notice in a widely-circulated publication and internet\n\nnewswire, satisfies the requirements of Rule 23, due process, and the PSLRA, and constitutes the\n\n\u201cbest notice . . . practicable under the circumstances.\u201d See Fed. R. Civ. P. 23(c)(2)(B); see also\n\nRodriguez, 2023 WL 2184496, at *9-*10 (finding First-Class Mail combined with print and internet-\n\nbased publication of settlement was \u201cthe best notice practicable under the circumstances\u201d);\n\nPearlstein, 2022 WL 4554858, at *8-*9 (Rule 23(c)(2)(B) satisfied where notice plan provided for\n\n - 21 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 29 of 31\n\n\n\n\nmail and/or email notice and publication notice); Signet, 2020 WL 4196468, at *14 (alteration in\n\noriginal) (\u201cTh[e] combination of individual mail to all Class Members . . . supplement[ed] by notice\n\nin an appropriate, widely circulated publication, transmitted over the newswire, and set forth on\n\ninternet websites, was the \u2018best notice . . . practicable under the circumstances.\u2019\u201d).\n\nVII. CONCLUSION\n\n For the foregoing reasons, Lead Plaintiff respectfully requests that the Court grant final\n\napproval of the proposed Settlement and Plan of Allocation, and certify the Class for settlement\n\npurposes.\n\nDATED: February 17, 2026 Respectfully submitted,\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n 200 31st Avenue North\n Nashville, TN 37203\n Telephone: 615/244-2203\n 615/252-3798 (fax)\n cwood@rgrdlaw.com\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n SAMUEL H. RUDMAN\n DAVID A. ROSENFELD\n 58 South Service Road, Suite 200\n Melville, NY 11747\n Telephone: 631/367-7100\n 631/367-1173 (fax)\n srudman@rgrdlaw.com\n drosenfeld@rgrdlaw.com\n\n\n\n\n - 22 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 30 of 31\n\n\n\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n ELLEN GUSIKOFF STEWART (admitted pro hac vice)\n ERIC I. NIEHAUS (admitted pro hac vice)\n JOSEPH J. TULL (admitted pro hac vice)\n 655 West Broadway, Suite 1900\n San Diego, CA 92101\n Telephone: 619/231-1058\n 619/231-7423 (fax)\n elleng@rgrdlaw.com\n ericn@rgrdlaw.com\n jtull@rgrdlaw.com\n\n Lead Counsel for Lead Plaintiff\n\n VANOVERBEKE, MICHAUD\n & TIMMONY, P.C.\n THOMAS C. MICHAUD\n 79 Alfred Street\n Detroit, MI 48201\n Telephone: 313/578-1200\n 313/578-1201 (fax)\n tmichaud@vmtlaw.com\n\n Additional Counsel\n\n\n\n\n - 23 -\n4907-2355-1117.v1\n\f Case 1:23-cv-09476-KPF Document 109 Filed 02/17/26 Page 31 of 31\n\n\n\n\n CERTIFICATION PURSUANT TO LOCAL RULE 7.1(c)\n\n I, Christopher M. Wood, hereby declare that this document contains 6,738 words,\n\nand complies with the word-count limitation provided by Local Rule 7.1(c).\n\nDATED: February 17, 2026\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n\n - 24 -\n4907-2355-1117.v1\n\f","ocr_status":2,"date_upload":"2026-06-22T23:06:43.036050-07:00","document_number":"109","attachment_number":null,"pacer_doc_id":"127039079518","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Memorandum of Law in Support of Motion","acms_document_guid":""}],"date_created":"2026-02-17T11:09:44.166976-08:00","date_modified":"2026-02-20T12:05:40.814499-08:00","date_filed":"2026-02-17","time_filed":"13:57:03","entry_number":109,"recap_sequence_number":"2026-02-17.002","pacer_sequence_number":365,"description":"MEMORANDUM OF LAW in Support re: 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation. . Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454083754/","id":454083754,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/468991815/","id":468991815,"tags":[],"absolute_url":"/docket/67923163/110/naclerio-v-docgo-inc/","date_created":"2026-02-17T11:09:43.460148-08:00","date_modified":"2026-06-23T03:25:50.998845-07:00","sha1":"3852d4902241d69504b7bac5b237a468e5f58434","page_count":3,"file_size":105877,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.110.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.110.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 110 Filed 02/17/26 Page 1 of 3\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : LEAD COUNSEL\u2019S NOTICE OF MOTION\n : FOR AN AWARD OF ATTORNEYS\u2019 FEES\n vs. : AND EXPENSES\n :\nDOCGO INC. and ANTHONY CAPONE, :\n :\n Defendants.\n :\n x\n\nTO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD\n\n PLEASE TAKE NOTICE that Robbins Geller Rudman & Dowd LLP, Court-appointed Lead\n\nCounsel in the above-captioned class action (the \u201cAction\u201d), will move this Court on March 24, 2026,\n\nat 10:00 a.m., before the Honorable Katherine Polk Failla at the Thurgood Marshall United States\n\nCourthouse, 40 Foley Square, New York, New York 10007, or as soon thereafter as the parties can\n\nbe heard, for entry of an Order, pursuant to Rule 23 of the Federal Rules of Civil Procedure: (i)\n\nawarding attorneys\u2019 fees; and (ii) paying litigation expenses incurred in prosecuting the Action.\n\n In support of this motion, Lead Counsel submits and is filing herewith: (i) the Memorandum\n\nof Law in Support of Lead Counsel\u2019s Motion for an Award of Attorneys\u2019 Fees and Expenses; (ii) the\n\nDeclaration of Christopher M. Wood in Support of: (I) Lead Plaintiff\u2019s Motion for Final Approval of\n\nClass Action Settlement and Approval of Plan of Allocation; and (II) Lead Counsel\u2019s Motion for an\n\nAward of Attorneys\u2019 Fees and Expenses; (iii) the Declaration of Tracy Khan; (iv) the Declaration of\n\nRoss D. Murray; and (v) the Declaration of Lead Counsel.\n\n\n\n -1-\n\f Case 1:23-cv-09476-KPF Document 110 Filed 02/17/26 Page 2 of 3\n\n\n\n\n A proposed Order will be submitted with Lead Counsel\u2019s reply submission on or before\n\nMarch 17, 2026, after the deadline for objecting has passed.\n\nDATED: February 17, 2026 Respectfully submitted,\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n 200 31st Avenue North\n Nashville, TN 37203\n Telephone: 615/244-2203\n 615/252-3798 (fax)\n cwood@rgrdlaw.com\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n SAMUEL H. RUDMAN\n DAVID A. ROSENFELD\n 58 South Service Road, Suite 200\n Melville, NY 11747\n Telephone: 631/367-7100\n 631/367-1173 (fax)\n srudman@rgrdlaw.com\n drosenfeld@rgrdlaw.com\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n ELLEN GUSIKOFF STEWART (admitted pro hac vice)\n ERIC I. NIEHAUS (admitted pro hac vice)\n JOSEPH J. TULL (admitted pro hac vice)\n 655 West Broadway, Suite 1900\n San Diego, CA 92101\n Telephone: 619/231-1058\n 619/231-7423 (fax)\n elleng@rgrdlaw.com\n ericn@rgrdlaw.com\n jtull@rgrdlaw.com\n\n Lead Counsel for Lead Plaintiff\n\n\n -2-\n\fCase 1:23-cv-09476-KPF Document 110 Filed 02/17/26 Page 3 of 3\n\n\n\n\n VANOVERBEKE, MICHAUD\n & TIMMONY, P.C.\n THOMAS C. MICHAUD\n 79 Alfred Street\n Detroit, MI 48201\n Telephone: 313/578-1200\n 313/578-1201 (fax)\n tmichaud@vmtlaw.com\n\n Additional Counsel\n\n\n\n\n -3-\n\f","ocr_status":1,"date_upload":"2026-06-22T23:06:40.597149-07:00","document_number":"110","attachment_number":null,"pacer_doc_id":"127039079531","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Attorney Fees","acms_document_guid":""}],"date_created":"2026-02-17T11:09:43.426571-08:00","date_modified":"2026-02-20T12:05:40.863368-08:00","date_filed":"2026-02-17","time_filed":"13:58:31","entry_number":110,"recap_sequence_number":"2026-02-17.003","pacer_sequence_number":368,"description":"MOTION for Attorney Fees and Expenses. Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454083732/","id":454083732,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/468991793/","id":468991793,"tags":[],"absolute_url":"/docket/67923163/111/naclerio-v-docgo-inc/","date_created":"2026-02-17T11:09:42.037785-08:00","date_modified":"2026-06-23T03:25:52.409480-07:00","sha1":"77c855070a3eb4d3a117304677b1bca4161494ba","page_count":27,"file_size":285808,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.111.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.111.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 1 of 27\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : MEMORANDUM OF LAW IN SUPPORT\n : OF LEAD COUNSEL\u2019S MOTION FOR AN\n vs. : AWARD OF ATTORNEYS\u2019 FEES AND\n : EXPENSES\nDOCGO INC. and ANTHONY CAPONE, :\n :\n Defendants.\n :\n x\n\n\n\n\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 2 of 27\n\n\n TABLE OF CONTENTS\n Page\n\nI. INTRODUCTION ...............................................................................................................1\n\nII. ARGUMENT .......................................................................................................................3\n\n A. Lead Counsel Is Entitled to an Award of Attorneys\u2019 Fees and Expenses\n from the Common Fund ...........................................................................................3\n\n B. The Court Should Apply the Percentage Method in Awarding Attorneys\u2019\n Fees to Lead Counsel ...............................................................................................4\n\n C. The Requested 33% Fee Is Consistent with Fee Awards in Common Fund\n Cases in Courts in the Second Circuit......................................................................5\n\n D. The Lodestar Cross-Check Confirms the Reasonableness of the Requested\n Attorneys\u2019 Fees ........................................................................................................7\n\n E. The Goldberger Factors Confirm that the Requested Fee Is Reasonable ................9\n\n 1. The Time and Labor Expended by Counsel ................................................9\n\n 2. The Magnitude and Complexity of the Litigation .....................................11\n\n 3. The Risk of the Litigation ..........................................................................12\n\n a. Contingent Nature of Lead Counsel\u2019s Representation...................12\n\n b. Risk of Establishing Liability ........................................................13\n\n c. Risk of Establishing Loss Causation and Damages .......................14\n\n 4. The Quality of Representation Supports the Requested Fee .....................15\n\n 5. The Requested Fee in Relation to the Settlement ......................................15\n\n 6. Public Policy Considerations .....................................................................16\n\n 7. The Class\u2019s Reaction to the Fee Request Supports the Requested\n Fee ..............................................................................................................16\n\n 8. The Fee Request Is Supported by Lead Plaintiff .......................................17\n\nIII. LEAD COUNSEL\u2019S EXPENSES ARE REASONABLE AND WERE\n NECESSARY TO THE PROSECUTION OF THE ACTION..........................................17\n\nIV. CONCLUSION ..................................................................................................................18\n\n\n -i-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 3 of 27\n\n\n\n TABLE OF AUTHORITIES\n\n Page\n\nCASES\n\nAnwar v. Fairfield Greenwich Ltd.,\n 2012 WL 1981505 (S.D.N.Y. June 1, 2012) .............................................................................7\n\nBlum v. Stenson,\n 465 U.S. 886 (1984) ...................................................................................................................6\n\nBoeing Co. v. Van Gemert,\n 444 U.S. 472 (1980) ...................................................................................................................3\n\nBurns v. FalconStor Software, Inc.,\n 2014 WL 12917621 (E.D.N.Y. Apr. 10, 2014) .........................................................................8\n\nChristine Asia Co., Ltd. v. Yun Ma,\n 2019 WL 5257534 (S.D.N.Y. Oct. 16, 2019) ..........................................................................11\n\nCity of Providence v. Aeropostale, Inc.,\n 2014 WL 1883494 (S.D.N.Y. May 9, 2014),\n aff\u2019d sub nom. Arbuthnot v. Pierson,\n 607 F. App\u2019x 73 (2d Cir. 2015) ...................................................................................3, 6, 8, 11\n\nDavis v. J.P. Morgan Chase & Co.,\n 827 F. Supp. 2d 172 (W.D.N.Y. 2011) ..................................................................................5, 9\n\nFresno Cnty. Emps.\u2019 Ret. Ass\u2019n. v. Isaacson/Weaver Fam. Tr.,\n 925 F.3d 63 (2d Cir. 2019).........................................................................................................3\n\nGoldberger v. Integrated Res., Inc.,\n 209 F.3d 43 (2d Cir. 2000)............................................................................................... passim\n\nGuevoura Fund Ltd. v. Sillerman,\n 2019 WL 6889901 (S.D.N.Y. Dec. 18, 2019) ...........................................................6, 9, 11, 12\n\nHaw. Structural Ironworkers Pension Tr. Fund v. AMC Ent. Holdings,\n 2022 WL 4136175 (S.D.N.Y. Feb. 14, 2022) ............................................................................6\n\nHayes v. Harmony Gold Mining Co.,\n 509 F. App\u2019x 21 (2d Cir. 2013) .................................................................................................4\n\nHicks v. Stanley,\n 2005 WL 2757792 (S.D.N.Y. Oct. 24, 2005) ............................................................................4\n\n\n\n - ii -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 4 of 27\n\n\n\n\n Page\n\n\nIn re Akari Therapeutics PLC Sec. Litig.,\n No. 1:17-cv-03577 (KPF), ECF 24\n (S.D.N.Y. Nov. 28, 2018) ..........................................................................................................7\n\nIn re Am. Bank Note Holographics, Inc.,\n 127 F. Supp. 2d 418 (S.D.N.Y. 2001)..................................................................................5, 12\n\nIn re AOL Time Warner, Inc.,\n 2006 WL 903236 (S.D.N.Y. Apr. 6, 2006)........................................................................11, 14\n\nIn re Chic. Bridge & Iron Co. N.V. Sec. Litig.,\n 2022 WL 3220783 (S.D.N.Y. Aug. 5, 2022) .............................................................................6\n\nIn re China Sunergy Sec. Litig.,\n 2011 WL 1899715 (S.D.N.Y. May 13, 2011) .........................................................................17\n\nIn re Colgate-Palmolive Co. ERISA Litig.,\n 36 F. Supp. 3d 344 (S.D.N.Y. 2014)......................................................................................7, 9\n\nIn re Comverse Tech., Inc. Sec. Litig.,\n 2010 WL 2653354 (E.D.N.Y. June 24, 2010) ...........................................................................8\n\nIn re Deutsche Bank AG Sec. Litig.,\n 2020 WL 3162980 (S.D.N.Y. June 11, 2020) ...........................................................................6\n\nIn re Facebook, Inc. IPO Sec. & Deriv. Litig.,\n 2015 WL 6971424 (S.D.N.Y. Nov. 9, 2015),\n aff\u2019d, 674 F. App\u2019x 37 (2d Cir. 2016) ..............................................................................6, 9, 10\n\nIn re FLAG Telecom Holdings, Ltd. Sec. Litig.,\n 2010 WL 4537550 (S.D.N.Y. Nov. 8, 2010) .....................................................................12, 17\n\nIn re Glob. Crossing Sec. & ERISA Litig.,\n 225 F.R.D. 436 (S.D.N.Y. 2004) .........................................................................................8, 18\n\nIn re GSE Bonds,\n 2020 WL 3250593 (S.D.N.Y. June 16, 2020) .............................................................12, 16, 18\n\nIn re Hi-Crush Partners L.P. Sec. Litig.,\n 2014 WL 7323417 (S.D.N.Y. Dec. 19, 2014) ...........................................................................8\n\nIn re Indep. Energy Holdings PLC Sec. Litig.,\n 302 F. Supp. 2d 180 (S.D.N.Y. 2003)......................................................................................17\n\n - iii -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 5 of 27\n\n\n\n\n Page\n\n\nIn re Jernigan Cap., Inc. Sec. Litig.,\n No. 1:20-cv-09575-JLR-KHP, ECF 154\n (S.D.N.Y May 29, 2025)............................................................................................................6\n\nIn re Marsh ERISA Litig.,\n 265 F.R.D. 128 (S.D.N.Y. 2010) .......................................................................................13, 15\n\nIn re NYSE Specialists Sec. Litig.,\n No. 03-cv-8264, ECF 38\n (S.D.N.Y. June 10, 2013)...........................................................................................................6\n\nIn re PPDAI Grp. Inc. Sec. Litig.,\n 2022 WL 198491 (E.D.N.Y. Jan. 21, 2022) ..............................................................................6\n\nIn re Parking Heaters, Antitrust Litig.,\n 2019 WL 8137325 (E.D.N.Y. Aug. 15, 2019)...........................................................................4\n\nIn re Payment Card Interchange Fee & Merch. Disc. Antitrust Litig.,\n 991 F. Supp. 2d 437 (E.D.N.Y. 2014) ...................................................................................4, 5\n\nIn re Perrigo Co. PLC Sec. Litig.,\n 2022 WL 500913 (S.D.N.Y. Feb. 18, 2022) ..............................................................................7\n\nIn re Prudential Sec. Inc. Ltd. P\u2019ships Litig.,\n 985 F. Supp. 410 (S.D.N.Y. 1997)...........................................................................................12\n\nIn re Signet Jewelers Ltd. Sec. Litig.,\n 2020 WL 4196468 (S.D.N.Y. July 21, 2020) ....................................................................15, 16\n\nIn re Veeco Instruments Inc. Sec. Litig.,\n 2007 WL 4115808 (S.D.N.Y. Nov. 7, 2007) ...........................................................5, 13, 15, 17\n\nIn re XL Fleet Corp. Sec. Litig.,\n 2024 WL 1884483 (S.D.N.Y. Apr. 30, 2024)............................................................................6\n\nKelwin Inkwel, LLC v. PNC Merch. Servs. Co.,\n 2022 WL 3127633 (E.D.N.Y. Apr. 12, 2022) ...........................................................................7\n\nKohari v. Met-Life Grp.,\n 2025 WL 100898 (S.D.N.Y. Jan. 15, 2025) ........................................................................7, 16\n\nLea v. Tal Educ. Grp.,\n 2021 WL 5578665 (S.D.N.Y. Nov. 30, 2021) .........................................................................12\n\n - iv -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 6 of 27\n\n\n\n\n Page\n\n\nLeach v. NBC Universal Media, LLC,\n 2017 WL 10435878 (S.D.N.Y. Aug. 24, 2017) .........................................................................9\n\nLeBlanc-Sternberg v. Fletcher,\n 143 F.3d 748 (2d Cir. 1988).......................................................................................................8\n\nMaley v. Del Glob. Techs. Corp.,\n 186 F. Supp. 2d 358 (S.D.N.Y. 2002)..........................................................................5, 7, 8, 17\n\nMartinek v. Amtrust Fin. Servs.,\n 2022 WL 16960903 (S.D.N.Y. Nov. 16, 2022) .........................................................................6\n\nMcIntosh v. Katapult Holdings,\n 2024 WL 5118192 (S.D.N.Y. Dec. 13, 2024) ...............................................................7, 11, 16\n\nMo. v. Jenkins by Agyei,\n 491 U.S. 274 (1989) ...............................................................................................................5, 8\n\nNichols v. Noom, Inc.,\n 2022 WL 2705354 (S.D.N.Y. July 12, 2022) ........................................................................4, 7\n\nOleniak v. Time Warner Cable,\n 2013 WL 12447094 (S.D.N.Y. Dec. 17, 2013) .....................................................................4, 7\n\nPearlstein v. BlackBerry Ltd.,\n 2022 WL 4554858 (S.D.N.Y. Sept. 29, 2022)...........................................................................7\n\nSavoie v. Merchs. Bank,\n 166 F.3d 456 (2d Cir. 1999).......................................................................................................5\n\nShapiro v. JPMorgan Chase & Co.,\n 2014 WL 1224666 (S.D.N.Y. Mar. 24, 2014) ...................................................................12, 14\n\nStrougo v. Bassini,\n 258 F. Supp. 2d 254 (S.D.N.Y. 2003)........................................................................................5\n\nTaft v. Ackermans,\n 2007 WL 414493 (S.D.N.Y. Jan. 31, 2007) ............................................................................15\n\nWal-Mart Stores, Inc. v. Visa U.S.A., Inc.,\n 396 F.3d 96 (2d Cir. 2005), superseded by rule as stated in\n Moses v. N.Y. Times Co.,\n 79 F.4th 235 (2d Cir. 2023) ...................................................................................................4, 8\n\n -v-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 7 of 27\n\n\n\n\n Page\n\n\nWoburn Ret. Sys. v. Salix Pharms., Ltd.,\n 2017 WL 3579892 (S.D.N.Y. Aug. 18, 2017) .........................................................................16\n\nSTATUTES, RULES, AND REGULATIONS\n\n15 U.S.C.\n \u00a778u-4(a)(6) ...............................................................................................................................5\n \u00a778j(b) ......................................................................................................................................11\n \u00a778t(a) ......................................................................................................................................11\n\n\n\n\n - vi -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 8 of 27\n\n\n\n\n Lead Counsel respectfully submits this memorandum of law in support of its motion for\n\nattorneys\u2019 fees and expenses.1\n\nI. INTRODUCTION\n\n Through diligence and unwavering advocacy, Lead Counsel secured a $12.5 million cash\n\nrecovery (the \u201cSettlement\u201d) for the benefit of the Class. As detailed in the Wood Declaration and in\n\nthe Settlement Memorandum, Lead Counsel devoted considerable resources and brought a high level\n\nof skill and experience to the prosecution of this Action. Lead Counsel, among other things:\n\n(1) drafted and filed a detailed amended complaint, based on an extensive investigation into the facts\n\nand potential claims and defenses; (2) successfully in part opposed Defendants\u2019 motion to dismiss;\n\n(3) moved for class certification and responded to discovery propounded by Defendants; (4) began\n\nconducting extensive fact discovery, including serving discovery requests on Defendants and 11\n\nnon-parties and propounding interrogatories and requests for admissions; (5) reviewed and analyzed\n\nover 20,000 pages of documents; (6) engaged in numerous meet and confers with Defendants and\n\nnon-parties regarding the scope of discovery; (7) engaged in settlement negotiations, including a\n\nfull-day mediation session with an experienced mediator, which included the exchange of mediation\n\nstatements that set forth the Parties\u2019 respective positions on liability and damages; (8) negotiated and\n\nobtained the instant Settlement; (9) drafted and negotiated the Parties\u2019 term sheet; (10) drafted and\n\n\n\n\n1\n Unless otherwise noted, capitalized terms have the meanings ascribed to them in the Stipulation\nof Settlement filed on November 12, 2025 (ECF 101-1) (the \u201cStipulation\u201d), the accompanying\nDeclaration of Christopher M. Wood in Support of: (I) Lead Plaintiff\u2019s Motion for Final Approval of\nClass Action Settlement and Approval of Plan of Allocation; and (II) Lead Counsel\u2019s Motion for an\nAward of Attorneys\u2019 Fees and Expenses (the \u201cWood Declaration\u201d or \u201cWood Decl.\u201d), and in the\nMemorandum of Law in Support of Lead Plaintiff\u2019s Motion for Final Approval of Class Action\nSettlement and Approval of Plan of Allocation (\u201cSettlement Memorandum\u201d), submitted concurrently\nherewith. Unless otherwise noted, all internal citations and quotation marks have been omitted and\nemphasis has been added.\n\n -1-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 9 of 27\n\n\n\n\nnegotiated the Stipulation and supporting documents; and (11) moved for preliminary approval of\n\nthe Settlement. See generally Wood Decl.\n\n Having obtained a substantial recovery on behalf of the Class, Lead Counsel now\n\nrespectfully moves this Court for an award of attorneys\u2019 fees equal to 33% of the Settlement Amount\n\nand payment of $183,676.18 in litigation expenses, together with interest on both amounts. The\n\nrequested fee is fair and reasonable under the standards set forth in Goldberger v. Integrated Res.,\n\nInc., 209 F.3d 43 (2d Cir. 2000), and is fully supported by both the percentage-of-the-fund method\n\nand the lodestar cross-check. Lead Counsel\u2019s fee request is also consistent with fees awarded by\n\ncourts in the Second Circuit in similar common fund cases, and the litigation expenses sought by\n\nLead Counsel were reasonably incurred in connection with the prosecution of the Action.\n\n The requested fee is also supported by the significant risks undertaken by Lead Counsel.\n\nLead Counsel pursued this Action on behalf of the Class on a contingent fee basis, dedicating over\n\n1,930 hours of time in the case and $183,676.18 in expenses without any promise of recovery,\n\npayment, or reimbursement. See Wood Decl., \u00b6\u00b687-88. Lead Counsel has not received any payment\n\nfor the services it has performed and the expenses it has incurred over the course of over two years\n\nof litigation. The risk of no recovery was particularly pronounced here, where highly skilled and\n\nexperienced defense counsel fiercely contested Lead Plaintiff\u2019s ability to establish materiality,\n\nscienter, loss causation, and damages.\n\n Lead Plaintiff supports the Settlement and Lead Counsel\u2019s request for attorneys\u2019 fees and\n\nexpenses. See Declaration of Tracy Khan in Support of Lead Plaintiff\u2019s Motion for Final Approval\n\nof Settlement and Award of Attorneys\u2019 Fees and Expenses (\u201cKhan Decl.\u201d), \u00b6\u00b65-6, submitted\n\nherewith. Moreover, to date, there have been no objections to the requested attorneys\u2019 fees and\n\n\n\n\n -2-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 10 of 27\n\n\n\n\nexpenses. The absence of objections from the Class supports a finding that Lead Counsel\u2019s request\n\nfor fees and expenses is fair and reasonable.2\n\n Accordingly, Lead Counsel respectfully submits that the Court should grant its Motion for an\n\nAward of Attorneys\u2019 Fees and Expenses.\n\nII. ARGUMENT\n\n A. Lead Counsel Is Entitled to an Award of Attorneys\u2019 Fees and\n Expenses from the Common Fund\n\n An attorney who creates a common fund for the benefit of a class is entitled to reasonable\n\nfees from the fund. See, e.g., Boeing Co. v. Van Gemert, 444 U.S. 472, 478 (1980) (\u201c[A] litigant or a\n\nlawyer who recovers a common fund for the benefit of persons other than himself or his client is\n\nentitled to a reasonable attorney\u2019s fee from the fund.\u201d); see also Goldberger, 209 F.3d at 47\n\n(\u201c[A]ttorneys whose efforts created the fund are entitled to a reasonable fee \u2013 set by the court \u2013 to be\n\ntaken from the fund.\u201d); Fresno Cnty. Emps.\u2019 Ret. Ass\u2019n. v. Isaacson/Weaver Fam. Tr., 925 F.3d 63,\n\n68 (2d Cir. 2019). The common fund doctrine is designed to \u201cfairly and adequately compensate\n\nclass counsel for services rendered and to ensure that all class members contribute equally towards\n\nthe costs associated with litigation pursued on their behalf.\u201d See City of Providence v. Aeropostale,\n\nInc., 2014 WL 1883494, at *10 (S.D.N.Y. May 9, 2014) (citing Goldberger, 209 F.3d at 47), aff\u2019d\n\nsub nom. Arbuthnot v. Pierson, 607 F. App\u2019x 73 (2d Cir. 2015).\n\n Here, Lead Counsel created a $12.5 million common fund for the Class and is entitled to\n\nreasonable attorneys\u2019 fees from the fund. See Boeing, 444 U.S. at 478; see also Goldberger, 209\n\nF.3d at 47. Moreover, fairly compensating Lead Counsel for the risks associated with pursuing this\n\n\n\n2\n The deadline to object to the Settlement, Plan of Allocation, and Lead Counsel\u2019s requests for\nattorneys\u2019 fees and expenses is March 3, 2026. If any objections are timely filed, Lead Counsel will\nrespond in its reply brief to be filed on March 17, 2026.\n\n -3-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 11 of 27\n\n\n\n\nLitigation is vital to the pursuit of \u201c[s]uch actions\u201d which \u201ccould not be sustained if plaintiffs\u2019\n\ncounsel were not to receive remuneration from the settlement fund for their efforts on behalf of the\n\nclass.\u201d Hicks v. Stanley, 2005 WL 2757792, at *9 (S.D.N.Y. Oct. 24, 2005).\n\n B. The Court Should Apply the Percentage Method in Awarding\n Attorneys\u2019 Fees to Lead Counsel\n\n The trend in the Second Circuit has been to award attorneys\u2019 fees based on a percentage of\n\nthe common fund. See Wal-Mart Stores, Inc. v. Visa U.S.A., Inc., 396 F.3d 96, 121 (2d Cir. 2005)\n\n(\u201cThe trend in this Circuit is toward the percentage method . . . .\u201d), superseded by rule as stated in\n\nMoses v. N.Y. Times Co., 79 F.4th 235 (2d Cir. 2023); Nichols v. Noom, Inc., 2022 WL 2705354, at\n\n*10 (S.D.N.Y. July 12, 2022) (\u201c\u2018The trend in this circuit is toward the percentage method, which\n\ndirectly aligns the interests of the class and its counsel and provides a powerful incentive for the\n\nefficient prosecution and early resolution of litigation.\u2019\u201d) (quoting In re Parking Heaters, Antitrust\n\nLitig., 2019 WL 8137325, at *7 (E.D.N.Y. Aug. 15, 2019)); Oleniak v. Time Warner Cable, 2013\n\nWL 12447094, at *8 (S.D.N.Y. Dec. 17, 2013) (Failla, J.) (\u201cThe Court finds that the amount of fees\n\nrequested is fair and reasonable using the \u2018percentage-of-recovery\u2019 method, which is consistent with\n\nthe \u2018trend in this Circuit.\u2019\u201d).\n\n Courts in the Second Circuit have recognized that the percentage method \u201c\u2018directly aligns the\n\ninterests of the class and its counsel and provides a powerful incentive for the efficient prosecution\n\nand early resolution of litigation.\u2019\u201d Wal-Mart, 396 F.3d at 121; see also Hayes v. Harmony Gold\n\nMining Co., 509 F. App\u2019x 21, 24 (2d Cir. 2013) (\u201c[T]he prospect of a percentage fee award from a\n\ncommon settlement fund . . . aligns the interests of class counsel with those of the class.\u201d); In re\n\nPayment Card Interchange Fee & Merch. Disc. Antitrust Litig., 991 F. Supp. 2d 437, 440 (E.D.N.Y.\n\n2014) (\u201cThe percentage method better aligns the incentives of plaintiffs\u2019 counsel with those of the\n\nclass members because it bases the attorneys\u2019 fees on the results they achieve for their clients . . . .\u201d).\n -4-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 12 of 27\n\n\n\n\nCourts have also recognized that the percentage method avoids some of the pitfalls of the lodestar\n\nmethod (see Goldberger, 209 F.3d at 48-49; Savoie v. Merchs. Bank, 166 F.3d 456, 460 (2d Cir.\n\n1999)), and \u201cis consistent with and, indeed, is intended to mirror, practice in the private\n\nmarketplace.\u201d Strougo v. Bassini, 258 F. Supp. 2d 254, 262 (S.D.N.Y. 2003); see also Payment\n\nCard Interchange, 991 F. Supp. 2d at 440 (\u201cThe percentage method also accords with the\n\noverwhelming prevalence of contingency fees in the market for plaintiffs\u2019 counsel . . . .\u201d); Davis v.\n\nJ.P. Morgan Chase & Co., 827 F. Supp. 2d 172, 184 (W.D.N.Y. 2011) (\u201c[T]he percentage\n\nmethod . . . is consistent with the system typically used by individual clients to compensate their\n\nattorneys.\u201d).\n\n The text of the Private Securities Litigation Reform Act of 1995 (\u201cPSLRA\u201d) also supports\n\nthe use of the percentage-of-the-fund method. The PSLRA states: \u201c[t]otal attorneys\u2019 fees and\n\nexpenses awarded by the court to counsel for the plaintiff class shall not exceed a reasonable\n\npercentage of the amount\u201d recovered for the class. 15 U.S.C. \u00a778u-4(a)(6). Courts have interpreted\n\nthis provision of the PSLRA as indicating Congress\u2019 preference for the percentage method in\n\ncommon fund cases. See In re Veeco Instruments Inc. Sec. Litig., 2007 WL 4115808, at *3\n\n(S.D.N.Y. Nov. 7, 2007); Maley v. Del Glob. Techs. Corp., 186 F. Supp. 2d 358, 370 (S.D.N.Y.\n\n2002); In re Am. Bank Note Holographics, Inc., 127 F. Supp. 2d 418, 430 (S.D.N.Y. 2001).\n\n In light of the foregoing, the Court should award attorneys\u2019 fees to Lead Counsel based on\n\nthe percentage method.\n\n C. The Requested 33% Fee Is Consistent with Fee Awards in Common\n Fund Cases in Courts in the Second Circuit\n\n In assessing the reasonableness of a fee award, the Supreme Court has recognized that an\n\nappropriate fee is intended to approximate what counsel would receive if they were bargaining for\n\ntheir services in the marketplace. Mo. v. Jenkins by Agyei, 491 U.S. 274, 285 (1989). \u201c\u2018In tort suits,\n -5-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 13 of 27\n\n\n\n\nan attorney might receive one-third of whatever amount the [Lead Plaintiff] recovers. In those cases,\n\ntherefore, the fee is directly proportional to the recovery.\u2019\u201d Blum v. Stenson, 465 U.S. 886, 903 n*\n\n(1984).\n\n Lead Counsel\u2019s request for attorneys\u2019 fees equal to 33% of the Settlement Amount is well\n\nwithin the range of percentage fees awarded by courts in the Second Circuit, as well as courts in this\n\nDistrict, including this Court. See, e.g., Martinek v. Amtrust Fin. Servs., 2022 WL 16960903, at *1\n\n(S.D.N.Y. Nov. 16, 2022) (Failla, J.) (awarding fee of 33-1/3% of $13 million settlement); In re\n\nJernigan Cap., Inc. Sec. Litig., No. 1:20-cv-09575-JLR-KHP, ECF 154 at 1-2 (S.D.N.Y May 29,\n\n2025) (awarding 33-1/3% of $12 million settlement) (attached hereto as Exhibit B); In re XL Fleet\n\nCorp. Sec. Litig., 2024 WL 1884483, at *1 (S.D.N.Y. Apr. 30, 2024) (awarding attorneys\u2019 fees of\n\n33-1/3% of $19.5 million settlement); In re Chic. Bridge & Iron Co. N.V. Sec. Litig., 2022 WL\n\n3220783 at *1 (S.D.N.Y. Aug. 5, 2022) (awarding fee of 33-1/3% of $44 million settlement); Haw.\n\nStructural Ironworkers Pension Tr. Fund v. AMC Ent. Holdings, 2022 WL 4136175, at *1 (S.D.N.Y.\n\nFeb. 14, 2022) (awarding attorneys\u2019 fees of $6 million, plus interest, of $18 million settlement); In re\n\nPPDAI Grp. Inc. Sec. Litig., 2022 WL 198491 (E.D.N.Y. Jan. 21, 2022) (awarding 33-1/3% of $9\n\nmillion settlement fund); In re Deutsche Bank AG Sec. Litig., 2020 WL 3162980 (S.D.N.Y. June 11,\n\n2020) (awarding 33-1/3% of $18.5 million settlement); Guevoura Fund Ltd. v. Sillerman, 2019 WL\n\n6889901, at *1, *14-*22 (S.D.N.Y. Dec. 18, 2019) (awarding attorneys\u2019 fees of 33-1/3% of $7.5\n\nmillion settlement); In re Facebook, Inc. IPO Sec. & Deriv. Litig., 2015 WL 6971424, at *9, *11-\n\n*12 (S.D.N.Y. Nov. 9, 2015) (awarding attorneys\u2019 fees of 33% of $26.5 million settlement), aff\u2019d,\n\n674 F. App\u2019x 37 (2d Cir. 2016); Aeropostale, 2014 WL 1883494, at *20 (awarding attorneys\u2019 fees of\n\n33% of $15 million settlement); In re NYSE Specialists Sec. Litig., No. 03-cv-8264, ECF 38, \u00b619\n\n(S.D.N.Y. June 10, 2013) (awarding attorneys\u2019 fees of 41% of $18.5 million settlement) (attached\n\n -6-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 14 of 27\n\n\n\n\nhereto as Exhibit C); Maley, 186 F. Supp. 2d at 370 (awarding attorneys\u2019 fees of 33-1/3% of $11.5\n\nmillion settlement and finding requested fees fell \u201ccomfortably within the range of fees typically\n\nawarded in securities class actions\u201d); Kelwin Inkwel, LLC v. PNC Merch. Servs. Co., 2022 WL\n\n3127633, at *4 (E.D.N.Y. Apr. 12, 2022) (awarding attorneys\u2019 fees of one-third of $10 million as\n\n\u201creasonable and consistent with awards in similar cases in this Circuit\u201d); Oleniak, 2013 WL\n\n1244709, at *27 (Failla, J.) (\u201cClass Counsel\u2019s request for one-third of the Qualified Settlement Fund,\n\nor the Maximum Settlement Amount . . . , is reasonable and \u2018consistent with the norms of class\n\nlitigation in this Circuit.\u2019\u201d); In re Akari Therapeutics PLC Sec. Litig., No. 1:17-cv-03577 (KPF),\n\nECF 24, \u00b61(S.D.N.Y. Nov. 28, 2018) (awarding one-third of the Settlement Fund) (attached hereto\n\nas Exhibit A).3\n\n D. The Lodestar Cross-Check Confirms the Reasonableness of the\n Requested Attorneys\u2019 Fees\n\n Courts may use the value of services on an hourly basis or lodestar as a \u201c\u2018cross check,\u2019\u201d\n\nGoldberger, 209 F.3d at 50, \u201cto ensure that an otherwise reasonable percentage fee would not lead to\n\na windfall.\u201d In re Colgate-Palmolive Co. ERISA Litig., 36 F. Supp. 3d 344, 353 (S.D.N.Y. 2014).\n\nThe lodestar method involves a two-part analysis,\n\n first, to determine the lodestar, the court multiplies the number of hours each attorney\n spent on the case by each attorney\u2019s reasonable hourly rate; and second, the court\n\n3\n See also Kohari v. Met-Life Grp., 2025 WL 100898, at *11 (S.D.N.Y. Jan. 15, 2025) (awarding\nattorneys\u2019 fees of 33-1/3%); McIntosh v. Katapult Holdings, 2024 WL 5118192, at *1 (S.D.N.Y.\nDec. 13, 2024) (awarding attorneys\u2019 fees of 33-1/3%); Pearlstein v. BlackBerry Ltd., 2022 WL\n4554858, at *10 (S.D.N.Y. Sept. 29, 2022) (\u201cClass counsel\u2019s request for one-third of the gross\nsettlement fund is reasonable within this circuit.\u201d); Noom, 2022 WL 2705354, at *10 (\u201cA fee equal\nto one-third of a settlement fund is routinely approved in this Circuit.\u201d); In re Perrigo Co. PLC Sec.\nLitig., 2022 WL 500913, at *1 (S.D.N.Y. Feb. 18, 2022) (awarding attorneys\u2019 fees of 33-1/3% of\n$31.9 million settlement); Anwar v. Fairfield Greenwich Ltd., 2012 WL 1981505, at *3 (S.D.N.Y.\nJune 1, 2012) (awarding attorneys\u2019 fees of 33% of the approximately $7.7 million settlement and\nfinding award \u201cwell within the percentage range that courts within the Second Circuit have awarded\nin other complex litigations\u201d).\n\n -7-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 15 of 27\n\n\n\n\n adjusts that lodestar figure (by applying a multiplier) to reflect such factors as the\n risk and contingent nature of the litigation, the result obtained, and the quality of the\n attorney\u2019s work.\n\nAeropostale, 2014 WL 1883494, at *13. \u201cThe multiplier represents the risk of the litigation, the\n\ncomplexity of the issues, the contingent nature of the engagement, the skill of the attorneys, and\n\nother factors.\u201d In re Glob. Crossing Sec. & ERISA Litig., 225 F.R.D. 436, 468 (S.D.N.Y. 2004); In\n\nre Comverse Tech., Inc. Sec. Litig., 2010 WL 2653354, at *5 (E.D.N.Y. June 24, 2010)\n\n(\u201cWhere . . . counsel has litigated a complex case under a contingency fee arrangement, they are\n\nentitled to a fee in excess of the[ir] lodestar.\u201d). Here, the lodestar method confirms the\n\nreasonableness of Lead Counsel\u2019s fee request.\n\n In the aggregate, Lead Counsel has spent over 1,930 hours of attorney and paraprofessional\n\ntime, amounting to $1,440,804.50 in lodestar based on Lead Counsel\u2019s current hourly rates in\n\ncontingent cases, which are consistent with rates charged by firms performing comparable work on\n\nbehalf of plaintiffs and defendants.4 Lead Counsel\u2019s request for attorneys\u2019 fees equal to 33% of the\n\nSettlement Amount represents a lodestar multiplier of 2.86, which is well within the range of\n\nmultipliers approved in securities class actions and other complex litigation. See Wal-Mart, 396\n\nF.3d at 123 (upholding multiplier of 3.5 as reasonable on appeal); Maley, 186 F. Supp. 2d at 369\n\n(awarding fee equal to 4.65 multiplier, which was \u201cwell within the range awarded by courts in this\n\nCircuit and courts throughout the country\u201d); Burns v. FalconStor Software, Inc., 2014 WL\n\n12917621, at *10 (E.D.N.Y. Apr. 10, 2014) (finding fee award of 33% \u201creasonable\u201d based on cross-\n\n\n\n4\n \u201c[T]he use of current rates to calculate the lodestar figure has been endorsed repeatedly by the\nSupreme Court, the Second Circuit and district courts within the Second Circuit as a means of\naccounting for the . . . inflation.\u201d In re Hi-Crush Partners L.P. Sec. Litig., 2014 WL 7323417, at\n*15 (S.D.N.Y. Dec. 19, 2014); Jenkins, 491 U.S. at 283-84; LeBlanc-Sternberg v. Fletcher, 143 F.3d\n748, 764 (2d Cir. 1988) (\u201c[C]urrent rates, rather than historical rates, should be applied in order to\ncompensate for the delay in payment.\u201d).\n\n -8-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 16 of 27\n\n\n\n\ncheck multiplier of 4.75); Davis, 827 F. Supp. 2d at 185 (awarding fee representing a multiplier of\n\n5.3, which was \u201cnot atypical\u201d in similar cases).5 Moreover, \u201c[t]he fact that Class Counsel\u2019s fee\n\naward will not only compensate them for time and effort already expended, but for [the] time that\n\nthey will be required to spend administering the settlement going forward, also supports their fee\n\nrequest.\u201d Leach v. NBC Universal Media, LLC, 2017 WL 10435878, \u00b649 (S.D.N.Y. Aug. 24, 2017);\n\nFacebook, 2015 WL 6971424, at *10.\n\n E. The Goldberger Factors Confirm that the Requested Fee Is\n Reasonable\n\n In Goldberger, the Second Circuit identified several factors that district courts should\n\nconsider in assessing the reasonableness of a fee award in common fund cases, under either the\n\nmultiplier or lodestar methods. These factors include: (1) the time and labor expended by counsel;\n\n(2) the magnitude and complexity of the litigation; (3) the risks of the litigation; (4) the quality of\n\nrepresentation; (5) the requested fee in relation to the settlement; and (6) public policy\n\nconsiderations. See Goldberger, 209 F.3d at 50. Each of these factors supports the reasonableness\n\nof the fee request here.\n\n 1. The Time and Labor Expended by Counsel\n\n Lead Counsel devoted significant time and resources to the prosecution of this Action. Over\n\nthe course of more than two years of litigation, Lead Counsel and its paraprofessionals devoted more\n\nthan 1,930 hours to the prosecution of this Action, on a wholly contingent basis, with no guarantee\n\nof compensation. As detailed in the Wood Declaration, which is being submitted herewith, Lead\n\nCounsel performed significant work throughout the Litigation. Lead Counsel, among other things:\n\n\n\n5\n See also Colgate-Palmolive, 36 F. Supp. 3d at 353 (awarding fee representing a multiplier of 5.2,\nwhich was \u201clarge, but not unreasonable\u201d); Guevoura, 2019 WL 6889901, at *18 (\u201c[M]ultipliers of\nbetween three and four times . . . have been routinely awarded in this Circuit.\u201d).\n\n -9-\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 17 of 27\n\n\n\n\n \u2022 conducted an extensive legal and factual investigation and drafted the amended\n complaint;\n\n \u2022 opposed and defeated in part Defendants\u2019 motion to dismiss;\n\n \u2022 moved for class certification and responded to Defendants\u2019 discovery requests;\n\n \u2022 engaged in discovery, including serving document requests, interrogatories and\n requests for admissions on Defendants, serving subpoenas on 11 third parties, and\n participating in numerous discovery conferences concerning the scope of discovery\n and the production of documents;\n\n \u2022 reviewed and analyzed over 20,000 pages of documents;\n\n \u2022 consulted with a financial expert regarding loss causation and damages;\n\n \u2022 participated in a full-day mediation session overseen by an experienced mediator,\n Miles Ruthberg of Phillips ADR Enterprises;\n\n \u2022 worked with a damages expert to develop a Plan of Allocation that treats the Lead\n Plaintiff and the other Class Members fairly and equally;\n\n \u2022 drafted and negotiated the terms of the Stipulation (including the exhibits thereto)\n and the Supplemental Agreement;\n\n \u2022 drafted the preliminary approval motion and supporting materials submitted\n therewith;\n\n \u2022 worked with the Court appointed Claims Administrator to provide notice to the\n Class; and\n\n \u2022 drafted the final approval motion and supporting materials submitted therewith.\n\nSee generally Wood Decl. Moreover, Lead Counsel will continue to provide services to the Class in\n\nconnection with the implementation and administration of the Settlement, including responding to\n\nClass Members\u2019 inquiries, helping with the completion and submission of Proof of Claim and\n\nRelease forms, overseeing the claims administration process, and working with the Claims\n\nAdministrator to resolve any issues that may arise. Lead Counsel\u2019s provision of these additional\n\nservices further supports the reasonableness of the requested fee. See Facebook, 2015 WL 6971424,\n\nat *10 (\u201cConsidering that the work in this matter is not yet concluded for Plaintiffs\u2019 counsel who will\n\n - 10 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 18 of 27\n\n\n\n\nnecessarily need to oversee the claims process, respond to inquiries, and assist Class Members in\n\nsubmitting their Proof of Claims, the time and labor expended by counsel in this matter support a\n\nconclusion that a 33% fee award in this matter is reasonable.\u201d); see also McIntosh, 2024 WL\n\n5118192, at *12 (noting that counsel \u201cwill incur additional time in connection with implementation\n\nof the Settlement\u201d).\n\n In sum, Lead Counsel\u2019s commitment of over 1,930 hours to the prosecution of this Action\n\nand procurement of a $12.5 million cash recovery strongly supports a finding that the 33% fee\n\nrequest is reasonable.\n\n 2. The Magnitude and Complexity of the Litigation\n\n Courts in this District recognize that securities class actions are \u201cnotorious[ly] complex[].\u201d\n\nIn re AOL Time Warner, Inc., 2006 WL 903236, at *8 (S.D.N.Y. Apr. 6, 2006); see also Guevoura,\n\n2019 WL 6889901, at *5 (Securities class actions are by their very nature complicated, and courts in\n\nthis Circuit have long recognized that securities class actions are \u201cnotably difficult and notoriously\n\nuncertain\u201d to litigate.) (citation modified); Christine Asia Co., Ltd. v. Yun Ma, 2019 WL 5257534, at\n\n*18 (S.D.N.Y. Oct. 16, 2019) (\u201cSecurities class actions in particular are \u2018notably difficult and\n\nnotoriously uncertain.\u201d) (citation modified). This Action was no different.\n\n Lead Plaintiff\u2019s claims under \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934\n\ninvolved complex, contested issues concerning, among other things, the elements of materiality,\n\nscienter, and loss causation. Moreover, Defendants heavily disputed Lead Plaintiff\u2019s ability to prove\n\ndamages, which would have been the subject of expert testimony and factual disputes. As detailed\n\nin the Settlement Memorandum, navigating these contested and complex factual and legal issues\n\nrequired significant skill, diligence, and expertise from Lead Counsel to achieve the current\n\nSettlement. Thus, this factor weighs in favor of the requested fee. See Aeropostale, 2014 WL\n\n\n - 11 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 19 of 27\n\n\n\n\n1883494, at *16 (finding second Goldberger factor favored settlement where case involved\n\n\u201cdifficult, complex, hotly disputed, and expert-intensive issues\u201d).\n\n 3. The Risk of the Litigation\n\n \u201cCourts have held that this factor [i.e., the risk of litigation] is often \u2018the most important\n\nGoldberger factor.\u2019\u201d In re GSE Bonds, 2020 WL 3250593, at *4 (S.D.N.Y. June 16, 2020). Here,\n\nthe risk of litigation was substantial, including because Lead Plaintiff pursued this case as a class\n\naction, on a contingency basis. See Lea v. Tal Educ. Grp., 2021 WL 5578665, at *12 (S.D.N.Y.\n\nNov. 30, 2021) (\u201c\u2018Little about litigation is risk-free, and class actions confront even more substantial\n\nrisks than other forms of litigation.\u2019\u201d).\n\n a. Contingent Nature of Lead Counsel\u2019s Representation\n\n \u201cThe Second Circuit . . . recognize[s] that courts should consider the risks associated with . . .\n\nundertaking a case on a contingent fee basis.\u201d Shapiro v. JPMorgan Chase & Co., 2014 WL\n\n1224666, at *21 (S.D.N.Y. Mar. 24, 2014); In re FLAG Telecom Holdings, Ltd. Sec. Litig., 2010 WL\n\n4537550, at *27 (S.D.N.Y. Nov. 8, 2010) (\u201cCourts in the Second Circuit have recognized that the\n\nrisk associated with a case undertaken on a contingent fee basis is an important factor in determining\n\nan appropriate fee award.\u201d); Bank Note Holographics, 127 F. Supp. 2d at 433 (finding it \u201cappropriate\n\nto take [contingent-fee] risk into account in determining the appropriate fee\u201d); In re Prudential Sec.\n\nInc. Ltd. P\u2019ships Litig., 985 F. Supp. 410, 417 (S.D.N.Y. 1997) (\u201cNumerous courts have recognized\n\nthat the attorney\u2019s contingent fee risk is an important factor in determining the fee award.\u201d).\n\n Lead Counsel pursued this Action on a contingency basis, assuming significant risks without\n\nany guarantee of recovery. See Guevoura, 2019 WL 6889901, at *19 (\u201cLead Counsel understood\n\nfrom the outset that they were embarking on a complex, and potentially expensive and lengthy\n\nlitigation, which would require the investment of thousands of hours of attorney time, with no\n\n\n - 12 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 20 of 27\n\n\n\n\nguarantee of ever being compensated for their investment of such time and money.\u201d). The risk of no\n\nrecovery in securities class actions, including this Action, is real. \u201cThere are numerous class actions\n\nin which counsel expended thousands of hours and yet received no remuneration whatsoever despite\n\ntheir diligence and expertise.\u201d See Veeco, 2007 WL 4115808, at *6.\n\n Lead Counsel\u2019s assumption of the contingency-fee risk strongly supports the reasonableness\n\nof the requested fee. See In re Marsh ERISA Litig., 265 F.R.D. 128, 148 (S.D.N.Y. 2010) (\u201cThere\n\nwas significant risk of non-payment in this case, and Plaintiffs\u2019 Counsel should be rewarded for\n\nhaving borne and successfully overcome that risk.\u201d).\n\n b. Risk of Establishing Liability\n\n Lead Plaintiff believes that there was evidentiary support for its claim that statements\n\nregarding DocGo\u2019s former CEO\u2019s educational background, DocGo\u2019s purported involvement in\n\nsigning migrants up for New York State Medicaid, and a purported $4 billion contract with U.S.\n\nCustoms and Border Patrol (\u201cCBP\u201d) were materially false and misleading. More specifically, Lead\n\nPlaintiff alleged that DocGo and Capone falsely represented that Capone had earned a triple summa\n\ncum laude undergraduate degree from SUNY Potsdam and had earned a Masters of Computational\n\nLearning Theory from Clarkson University. Wood Decl., \u00b621. Lead Plaintiff also alleged that\n\nCapone misled investors by telling them that: (i) DocGo had secured a five-year contract with CBP\n\nfor over $4 billion to allow DocGo to treat asylum seekers after crossing the border; and (ii) DocGo\n\nhad been working with UnitedHealthcare to sign up over 3,000 asylum seekers and counting onto\n\nNew York State Medicaid. Id., \u00b622. Lead Plaintiff alleged that as a result of these material\n\nmisrepresentations, the price of DocGo common stock was artificially inflated until the truth\n\nregarding Capone\u2019s educational background and the CBP and New York State Medicaid contracts\n\nwas revealed, causing the Company\u2019s stock price to drop and damaging Class Members.\n\n\n - 13 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 21 of 27\n\n\n\n\nNevertheless, Defendants disputed liability. At summary judgment and trial, Defendants would have\n\nargued, as they did at the motion to dismiss stage, that the statements at issue were not materially\n\nfalse and misleading, and that they did not possess the requisite scienter for certain statements. See\n\nWood Decl., \u00b6\u00b625, 59; Settlement Memorandum at III.B.3.\n\n c. Risk of Establishing Loss Causation and Damages\n\n \u201cProof of damages in complex class actions is always complex and difficult and often subject\n\nto expert testimony.\u201d JPMorgan, 2014 WL 1224666, at *11; see also AOL, 2006 WL 903236, at *9\n\n(\u201c[T]he legal requirements for recovery under the securities laws present considerable challenges,\n\nparticularly with respect to loss causation and the calculation of damages.\u201d). This case is no\n\nexception.\n\n Even if Lead Plaintiff established that the allegedly false and misleading statements were\n\nmaterial and made with scienter, Defendants would have continued to vigorously attack Lead\n\nPlaintiff\u2019s ability to prove loss causation and establish damages. See Wood Decl., \u00b6\u00b661-63,\n\nSettlement Memorandum at III.B.3. Defendants would likely argue that a portion of the final drop in\n\nDocGo\u2019s stock price was caused by the revelation that the CBP contract was not as high as Capone\n\nclaimed, and that claim was dismissed from the Complaint. Wood Decl., \u00b661. Defendants would\n\nalso likely assert that it was Capone\u2019s departure as CEO, not the revelation of his educational\n\nbackground, that was the sole cause of DocGo\u2019s stock price drop. Id. Defendants would also assert\n\nthat Lead Plaintiff and the Class were only entitled to recover the portion of the stock price declines\n\nbetween September 10 and September 15, 2023, if any, that Lead Plaintiff could prove was\n\nattributable to the revelations about Capone\u2019s education and the New York State Medicaid issue,\n\nwhich may have been a small fraction of the stock price drop. Id., \u00b662. Defendants\u2019 success on any\n\nof these arguments posed significant risk to the Class\u2019s ability to obtain any recovery.\n\n\n - 14 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 22 of 27\n\n\n\n\n 4. The Quality of Representation Supports the Requested Fee\n\n In assessing the quality of counsel\u2019s representation, courts consider, among other things, \u201cthe\n\nrecovery obtained and the backgrounds of the lawyers involved in the lawsuit.\u201d Taft v. Ackermans,\n\n2007 WL 414493, at *10 (S.D.N.Y. Jan. 31, 2007). Lead Counsel is recognized as a leader in\n\nsecurities class actions and complex litigations. See accompanying Declaration of Christopher M.\n\nWood Filed on Behalf of Robbins Geller Rudman & Dowd LLP in Support of Application for\n\nAward of Attorneys\u2019 Fees and Expenses (\u201cFee Decl.\u201d), Ex. D (firm r\u00e9sum\u00e9). Lead Counsel\n\nrespectfully submits that this factor is best illustrated by the result achieved. In a case where liability\n\nand damages were heavily contested, Lead Counsel, through a high-level of skill, hard work, and\n\ndetermination, secured a $12.5 million cash recovery for the Class.\n\n Courts also consider the quality of the adversary when evaluating counsel\u2019s performance.\n\nSee, e.g., Marsh, 265 F.R.D. at 148 (\u201cThe high quality of defense counsel opposing Plaintiffs\u2019 efforts\n\nfurther proves the caliber of representation that was necessary to achieve the Settlement.\u201d); Veeco,\n\n2007 WL 4115808, at *7 (among the factors supporting a fee award was that defendants were\n\nrepresented by \u201cone of the country\u2019s largest law firms\u201d). Lead Counsel was opposed in this\n\nLitigation by experienced and skilled defense counsel at Gibson, Dunn & Crutcher LLP and Finn\n\nDixon & Herling LLP, who employed a number of defenses, arguments, and strategies in an attempt\n\nto obtain the dismissal of this case and were expected at class certification. In the face of this\n\nformidable opposition, Lead Counsel persisted and obtained an excellent result for the Class.\n\n 5. The Requested Fee in Relation to the Settlement\n\n \u201cWhen determining whether a fee request is reasonable in relation to a settlement amount, the\n\ncourt compares the fee application to fees awarded in similar securities class-action settlements of\n\ncomparable value.\u201d In re Signet Jewelers Ltd. Sec. Litig., 2020 WL 4196468, at *20 (S.D.N.Y. July\n\n\n - 15 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 23 of 27\n\n\n\n\n21, 2020) (citation modified). As discussed in detail in \u00a7II.C, supra, the requested fee of 33% of the\n\nSettlement Amount is well within the range of percentage fee awards that courts in this Circuit have\n\nawarded in comparable cases. Accordingly, the fee requested is reasonable in relation to the\n\nSettlement.\n\n 6. Public Policy Considerations\n\n Public policy supports rewarding Lead Counsel for taking on the risk of pursuing this private\n\nsecurities class action. See Kohari, 2025 WL 100898, at *12 (\u201cCourts in this Circuit have\n\nrecognized the importance of private enforcement actions and the corresponding need to incentivize\n\nattorneys to pursue such actions on a contingency fee basis.\u201d); McIntosh, 2024 WL 5118192, at *12\n\n(same); Signet, 2020 WL 4196468, at *21 (\u201cA strong public policy concern exists for rewarding\n\nfirms for bringing successful securities litigation.\u201d); GSE, 2020 WL 3250593, at *5 (\u201cGenerally,\n\npublic policy is served by ensuring a fee is large enough to incentivize lawyers to bring meritorious\n\nclass actions in the future.\u201d); Woburn Ret. Sys. v. Salix Pharms., Ltd., 2017 WL 3579892, at *7\n\n(S.D.N.Y. Aug. 18, 2017) (fee award was \u201cappropriate, and not excessive, to encourage future\n\nsecurities class actions\u201d).\n\n 7. The Class\u2019s Reaction to the Fee Request Supports the\n Requested Fee\n\n The Claims Administrator has disseminated a total of 13,280 Postcard Notices to potential\n\nClass Members and nominees. See accompanying Declaration of Ross D. Murray Regarding: (A)\n\nNotice Dissemination; (B) Publication; (C) Establishment of Call Center Services and Website; and\n\n(D) Requests for Exclusion Received to Date, \u00b611. The time to object to Lead Counsel\u2019s fee request\n\nexpires on March 3, 2026. To date, no Class Member has objected to the fee and expense amounts\n\nset forth in the Postcard Notice and Notice. The Class\u2019s reaction supports a finding that the\n\nrequested fee is fair and reasonable. See, e.g., Signet, 2020 WL 4196468, at *21 (\u201cThe absence of\n\n - 16 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 24 of 27\n\n\n\n\nany objections to the requested attorneys\u2019 fees . . . supports a finding that the request is fair and\n\nreasonable.\u201d).6\n\n 8. The Fee Request Is Supported by Lead Plaintiff\n\n Lead Plaintiff, which has overseen Lead Counsel\u2019s litigation activities since the inception of\n\nthe case, supports the fee request. See Khan Decl., \u00b66. Lead Plaintiff\u2019s endorsement of Lead\n\nCounsel\u2019s fee request supports approval of the request. See, e.g., Veeco, 2007 WL 4115808, at *8\n\n(\u201c[P]ublic policy considerations support the award in this case because the Lead Plaintiff . . .\n\nconscientiously supervised the work of lead counsel and has approved the fee request.\u201d).\n\n All of these factors weigh in favor of Lead Counsel\u2019s fee request.\n\nIII. LEAD COUNSEL\u2019S EXPENSES ARE REASONABLE AND WERE\n NECESSARY TO THE PROSECUTION OF THE ACTION\n\n Lead Counsel respectfully requests an award of $183,676.18 in reasonable costs, charges,\n\nand expenses in connection with the prosecution of this Action. See In re China Sunergy Sec. Litig.,\n\n2011 WL 1899715, at *6 (S.D.N.Y. May 13, 2011) (In a class action, attorneys should be\n\ncompensated \u201cfor reasonable out-of-pocket expenses incurred and customarily charged to their\n\nclients, as long as they were incidental and necessary to the representation.\u201d) (citation modified);\n\nFlag Telecom, 2010 WL 4537550, at *30 (\u201cIt is well accepted that counsel who create a common\n\nfund are entitled to the reimbursement of expenses that they advanced to a class.\u201d); In re Indep.\n\nEnergy Holdings PLC Sec. Litig., 302 F. Supp. 2d 180, 183 n.3 (S.D.N.Y. 2003) (\u201cAttorneys may be\n\ncompensated for reasonable out-of-pocket expenses incurred and customarily charged to their\n\n\n\n6\n Flag Telecom, 2010 WL 4537550, at *29 (\u201cIf th[e] important public policy [of enforcing the\nsecurities laws] is to be carried out, the courts should award fees which will adequately compensate\nLead Counsel for the value of their efforts, taking into account the enormous risks they undertook.\u201d);\nMaley, 186 F. Supp. 2d at 373 (\u201cIn considering an award of attorney\u2019s fees, the public policy of\nvigorously enforcing the federal securities laws must be considered.\u201d).\n\n - 17 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 25 of 27\n\n\n\n\nclients, as long as they were incidental and necessary to the representation of those clients.\u201d)\n\n(citation modified).\n\n Lead Counsel\u2019s expenses are consistent with the stage of the Action at the time the\n\nSettlement was reached, and include, for example, expert and consultant fees, document\n\nmanagement costs, legal research costs, mediation fees, and filing fees. These fees are routinely\n\ncharged and awarded in common fund cases. See, e.g., GSE, 2020 WL 3250593, at *6 (awarding\n\ncounsel for, among other things, expert-related expenses, copying costs, online research, and filing\n\nand service fees); Glob. Crossing, 225 F.R.D. at 468 (\u201cThe expenses incurred \u2013 which include\n\ninvestigative and expert witnesses, filing fees, service of process, travel, legal research and document\n\nproduction and review \u2013 are the type for which \u2018the paying, arms\u2019 length market\u2019 reimburses\n\nattorneys. For this reason, they are properly chargeable to the Settlement fund.\u201d).\n\n The expenses incurred by Lead Counsel are described in detail in the accompanying Fee\n\nDecl. To date, there have been no objections to Lead Counsel\u2019s expense request.\n\nIV. CONCLUSION\n\n For all of the foregoing reasons, Lead Counsel respectfully requests that the Court grant its\n\nmotion for an award of attorneys\u2019 fees of 33% of the Settlement Amount, payment of $183,676.18 in\n\nlitigation expenses, plus interest on both amounts at the same rate as earned by the Settlement Fund.\n\nDATED: February 17, 2026 Respectfully submitted,\n\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n CHRISTOPHER M. WOOD (admitted pro hac vice)\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n - 18 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 26 of 27\n\n\n\n\n 200 31st Avenue North\n Nashville, TN 37203\n Telephone: 615/244-2203\n 615/252-3798 (fax)\n cwood@rgrdlaw.com\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n SAMUEL H. RUDMAN\n DAVID A. ROSENFELD\n 58 South Service Road, Suite 200\n Melville, NY 11747\n Telephone: 631/367-7100\n 631/367-1173 (fax)\n srudman@rgrdlaw.com\n drosenfeld@rgrdlaw.com\n ROBBINS GELLER RUDMAN\n & DOWD LLP\n ELLEN GUSIKOFF STEWART (admitted pro hac vice)\n ERIC I. NIEHAUS (admitted pro hac vice)\n JOSEPH J. TULL (admitted pro hac vice)\n 655 West Broadway, Suite 1900\n San Diego, CA 92101\n Telephone: 619/231-1058\n 619/231-7423 (fax)\n elleng@rgrdlaw.com\n ericn@rgrdlaw.com\n jtull@rgrdlaw.com\n Lead Counsel for Lead Plaintiff\n VANOVERBEKE, MICHAUD\n & TIMMONY, P.C.\n THOMAS C. MICHAUD\n 79 Alfred Street\n Detroit, MI 48201\n Telephone: 313/578-1200\n 313/578-1201 (fax)\n tmichaud@vmtlaw.com\n Additional Counsel\n\n\n\n\n - 19 -\n4911-7273-6140.v1\n\f Case 1:23-cv-09476-KPF Document 111 Filed 02/17/26 Page 27 of 27\n\n\n\n\n CERTIFICATION PURSUANT TO LOCAL RULE 7.1(c)\n\n I, Christopher M. Wood, hereby declare that this document contains 5,824 words,\n\nand complies with the word-count limitation provided by Local Rule 7.1(c).\n\nDATED: February 17, 2026\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n\n - 20 -\n4911-7273-6140.v1\n\f","ocr_status":2,"date_upload":"2026-06-22T23:06:39.882090-07:00","document_number":"111","attachment_number":null,"pacer_doc_id":"127039079552","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Memorandum of Law in Support of Motion","acms_document_guid":""}],"date_created":"2026-02-17T11:09:42.000019-08:00","date_modified":"2026-02-20T12:05:40.911818-08:00","date_filed":"2026-02-17","time_filed":"14:00:47","entry_number":111,"recap_sequence_number":"2026-02-17.004","pacer_sequence_number":370,"description":"MEMORANDUM OF LAW in Support re: 110 MOTION for Attorney Fees and Expenses. . Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454083711/","id":454083711,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/468991773/","id":468991773,"tags":[],"absolute_url":"/docket/67923163/112/naclerio-v-docgo-inc/","date_created":"2026-02-17T11:09:40.987875-08:00","date_modified":"2026-06-23T03:25:49.099929-07:00","sha1":"44b1900ed70deb6682c3e81570d4bd4479943e52","page_count":25,"file_size":220014,"filepath_local":"recap/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.112.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nysd.609186/gov.uscourts.nysd.609186.112.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 1 of 25\n\n\n\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\n\n x\nGENESEE COUNTY EMPLOYEES\u2019 : Civil Action No. 1:23-cv-09476-KPF\nRETIREMENT SYSTEM, Individually and on :\nBehalf of All Others Similarly Situated, : CLASS ACTION\n :\n Plaintiff, : DECLARATION OF CHRISTOPHER M.\n : WOOD IN SUPPORT OF: (I) LEAD\n vs. : PLAINTIFF\u2019S MOTION FOR FINAL\n : APPROVAL OF CLASS ACTION\nDOCGO INC. and ANTHONY CAPONE, : SETTLEMENT AND APPROVAL OF PLAN\n : OF ALLOCATION; AND (II) LEAD\n Defendants. COUNSEL\u2019S MOTION FOR AN AWARD\n :\n x OF ATTORNEYS\u2019 FEES AND EXPENSES\n\n\n\n\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 2 of 25\n\n\n\n\n I, CHRISTOPHER M. WOOD, declare as follows:\n\n 1. I am a partner at the law firm of Robbins Geller Rudman & Dowd LLP (\u201cRobbins\n\nGeller\u201d or \u201cLead Counsel\u201d), counsel to Lead Plaintiff Genesee County Employees\u2019 Retirement\n\nSystem (the \u201cFund\u201d) in the above-captioned action (the \u201cAction\u201d or \u201cLitigation\u201d), and am admitted\n\npro hac vice to practice before this Court.1\n\n 2. I submit this declaration, pursuant to Rule 23 of the Federal Rules of Civil Procedure,\n\nin support of: (i) Lead Plaintiff\u2019s motion for final approval of the all-cash settlement of $12,500,000\n\n(the \u201cSettlement Amount\u201d) and approval of the proposed Plan of Allocation; and (ii) Lead Counsel\u2019s\n\nmotion for an award of attorneys\u2019 fees and expenses.\n\n 3. I was actively involved in the prosecution of this Action, am familiar with its\n\nproceedings, and have personal knowledge of the matters set forth herein based upon my supervision\n\nof, and participation in, all material aspects of the Action. If called upon, I could and would\n\ncompetently testify that the following facts are true and correct.\n\nI. INTRODUCTION AND OVERVIEW\n\n 4. The Settling Parties have entered into a settlement of Lead Plaintiff\u2019s claims alleged\n\nin this securities class action against defendants DocGo Inc. (\u201cDocGo\u201d or the \u201cCompany\u201d) and\n\nAnthony Capone (collectively, \u201cDefendants\u201d).\n\n 5. The Settlement is a very favorable result for the Class. The Stipulation provides for\n\nthe non-reversionary payment of $12,500,000 in cash to the Class in exchange for a release of the\n\nReleased Plaintiff\u2019s Claims (as defined in the Stipulation) against the Released Defendant Parties (as\n\ndefined in the Stipulation). As described herein, the Settlement is the product of Lead Plaintiff\u2019s and\n\n\n\n1\n Unless otherwise defined herein, capitalized terms and acronyms have the meaning ascribed to\nthem in the Stipulation of Settlement, filed on November 12, 2025 (ECF 101-1) (\u201cStipulation\u201d).\n\n -1-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 3 of 25\n\n\n\n\nLead Counsel\u2019s careful analysis and vigorous litigation of the claims, as well as extensive arm\u2019s-\n\nlength settlement negotiations between the parties, which took place during and after a mediation\n\nsession supervised by Miles Ruthberg, of Philips ADR (the \u201cMediator\u201d), a mediator with extensive\n\nexperience in securities class actions.\n\n 6. The benefit to the Class must be weighed against the significant chance that it might\n\nobtain a much smaller recovery after years of protracted litigation \u2013 or none at all. If at any stage of\n\nthe Litigation, Defendants were to prevail on their various arguments disputing liability or seeking to\n\nreduce or eliminate the Class\u2019s damages, the Class would have been left with little or no recovery.\n\nThe Settlement Amount represents a recovery of over 20% of reasonably recoverable damages. The\n\nSettlement provides for a substantial monetary benefit to the Class now, and is an excellent recovery\n\nin light of the significant risks involved in continued litigation.\n\n 7. As detailed herein, the Settlement is the product of a comprehensive investigation,\n\ndetailed analysis, and extensive arm\u2019s-length negotiations by experienced counsel, which involved\n\nthe assistance of an experienced mediator. Lead Counsel, working closely with Lead Plaintiff,\n\nnegotiated the Settlement with a thorough understanding of the strengths and weaknesses of the\n\nclaims asserted against each of the Defendants. This understanding was based on Lead Counsel\u2019s\n\nvigorous efforts, which included, inter alia: (a) successfully moving for the Fund\u2019s appointment as\n\nLead Plaintiff; (b) undertaking an extensive investigation of the facts alleged in the Amended\n\nComplaint for Violations of the Federal Securities Laws (ECF 43) (the \u201cComplaint\u201d);\n\n(c) successfully opposing Defendants\u2019 motion to dismiss as to certain claims; (d) moving for class\n\ncertification; (e) commencing fact discovery, including the review and analysis of more than 20,000\n\npages of documents produced by Defendants and numerous third parties; (f) responding to document\n\nrequests propounded by Defendants; and (g) drafting a detailed mediation statement. As a result of\n\n -2-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 4 of 25\n\n\n\n\nthese efforts, Lead Counsel and Lead Plaintiff were fully informed regarding the strengths and\n\nweaknesses of the case against each of the Defendants before agreeing to the Settlement.\n\n 8. As discussed herein, Lead Plaintiff faced serious risks in going forward with the\n\nLitigation. Lead Plaintiff faced the significant risk that Defendants could ultimately be successful in\n\nshowing, among other things, that: (i) they did not make any actionable, material misstatements or\n\nomissions; (ii) they did not act with the requisite scienter with respect to certain claims; and\n\n(iii) certain of the Class\u2019s damages were caused by nonactionable factors unrelated to the alleged\n\nmisstatements and omissions. Accordingly, while Lead Counsel believes that the Class\u2019s claims\n\nhave merit, there was a significant chance that one or more of Defendants\u2019 arguments may have\n\nultimately proved successful \u2013 and the Class may have ended up with little or no recovery. The\n\nsignificance of these risks was heightened by the prospect of continued, costly litigation, including\n\nimminent fact depositions, expert discovery, dispositive motions, a trial, and almost certain ensuing\n\nappeals. The Settlement avoids these and other risks while providing a substantial and immediate\n\nmonetary benefit to the Class.\n\n 9. The other terms of the Settlement are the product of careful negotiations between the\n\nparties and are set forth in the Stipulation. For all of the reasons stated herein, Lead Counsel\n\nbelieves that the Settlement is fair, reasonable and adequate, is in the best interests of the Class, and\n\nshould be approved. Furthermore, the Settlement has the full support of the Lead Plaintiff.\n\n 10. Lead Counsel seeks attorneys\u2019 fees of 33% of the Settlement Amount, plus litigation\n\nexpenses of $183,676.18, with interest thereon earned at the same rate as the Settlement Fund. The\n\nfee request has Lead Plaintiff\u2019s full support. The requested fee amounts to a 2.86 multiple of Lead\n\nCounsel\u2019s collective \u201clodestar\u201d (i.e., Lead Counsel\u2019s hourly rates multiplied by the hours spent on\n\nprosecuting and settling this Action).\n\n -3-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 5 of 25\n\n\n\n\n 11. Pursuant to the Court\u2019s Order Preliminarily Approving Settlement and Providing for\n\nNotice, dated November 18, 2025 (ECF 106) (the \u201cPreliminary Approval Order\u201d), the Postcard\n\nNotice was mailed or emailed to all Class Members who could be identified with reasonable effort,\n\nand the Summary Notice was published in The Wall Street Journal and over Business Wire.\n\n 12. The Postcard Notice directed Class Members to the Notice, which advised all\n\nrecipients of, among other things: (i) the terms of the Settlement; (ii) the definition of the Class;\n\n(iii) their right to exclude themselves from the Class; (iv) their right to object to any aspect of the\n\nSettlement, including the Plan of Allocation and Lead Counsel\u2019s request for attorneys\u2019 fees and\n\nexpenses; and (v) the procedures and deadline for submitting a Proof of Claim and Release in order\n\nto be eligible for a payment from the proceeds of the Settlement.\n\n 13. The Court-ordered deadline for filing objections to the Settlement is March 3, 2026,\n\nthe same deadline for requesting exclusion from the Class. No objections to any aspect of the\n\nSettlement have been filed, and to-date, no requests for exclusion from the Class have been received.\n\n 14. Verita Global (\u201cVerita\u201d), which has been retained by Lead Counsel and approved by\n\nthe Court as Claims Administrator, has advised that as of February 12, 2026, a total of 13,280\n\nPostcard Notices have been mailed or emailed to potential Class Members and their nominees.\n\nAdditionally, the Notice, Proof of Claim and Release, Stipulation, and Preliminary Approval Order\n\nhave been posted on the website established for the Settlement: www.DocGo\n\nSecuritiesSettlement.com.\n\n 15. The following is a summary of the principal events that occurred during the course of\n\nthe Litigation and the legal services provided by Lead Counsel.\n\n\n\n\n -4-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 6 of 25\n\n\n\n\nII. LEAD PLAINTIFF\u2019S PROSECUTION OF THE CASE\n\n A. The Commencement of the Action and Appointment of Lead Plaintiff\n and Lead Counsel\n\n 16. On October 27, 2023, the initial class action complaint in this Litigation was filed in\n\nthe United States District Court for the Southern District of New York (the \u201cCourt\u201d) alleging\n\nviolations of \u00a7\u00a710(b) and 20(a) of the Securities Exchange Act of 1934 (the \u201cExchange Act\u201d).\n\nECF 1.\n\n 17. In accordance with the Private Securities Litigation Reform Act of 1995 (\u201cPSLRA\u201d),\n\nnotice of the pendency of the action was published, and on December 26, 2023, the Fund moved for\n\nappointment as lead plaintiff. ECF 15. On January 11, 2024, the only other lead plaintiff movant\n\nfiled a notice of non-opposition. ECF 20. By Order dated January 17, 2024, the Court appointed:\n\n(i) the Fund as Lead Plaintiff; and (ii) its chosen counsel, Robbins Geller Rudman & Dowd LLP, as\n\nLead Counsel. ECF 30.\n\n B. Lead Counsel\u2019s Investigation and Filing of the Complaint\n\n 18. Lead Counsel conducted an extensive investigation prior to filing the Complaint.\n\nThis investigation included, but was not limited to, a review and analysis of: (i) DocGo\u2019s public\n\nfilings with the SEC; (ii) transcripts of DocGo\u2019s public conference calls; (iii) DocGo\u2019s press\n\nreleases; (iv) reports of securities analysts following DocGo; (v) independent media and social media\n\nreports and posts regarding DocGo and its executives; (vi) economic analyses of DocGo\u2019s stock\n\nprice movement and pricing and volume data; and (vii) other publicly available information. As part\n\nof its investigation, Lead Counsel also contacted former employees of DocGo who might have had\n\ninformation relevant to Lead Counsel\u2019s investigation.\n\n 19. Based on this investigation, Lead Counsel prepared a detailed amended Complaint on\n\nbehalf of Lead Plaintiff and all persons, other than Defendants and other excluded individuals and\n\n -5-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 7 of 25\n\n\n\n\nentities, who purchased the common stock of DocGo during the period from November 5, 2021 and\n\nSeptember 15, 2023, inclusive (the \u201cClass Period\u201d). Lead Plaintiff filed the Complaint on March 20,\n\n2024, asserting claims against Defendants and former defendants Stan Vashovsky and Andre\n\nOberholzer (\u201cFormer Defendants\u201d) under \u00a7\u00a710(b) and 20(a) of the Exchange Act. ECF 43.\n\n C. The Complaint and a Summary of the Class\u2019s Allegations\n\n 20. The Complaint alleged that, in violation of \u00a7\u00a710(b) and 20(a) of the Exchange Act\n\nand Rule 10b-5 promulgated thereunder, defendants made materially false and misleading statements\n\nconcerning DocGo\u2019s former CEO Capone\u2019s educational background, DocGo\u2019s purported\n\ninvolvement in signing migrants up for New York State Medicaid, and a purported $4 billion\n\ncontract with U.S. Customs and Border Patrol (\u201cCBP\u201d).\n\n 21. The Complaint alleged that during the Class Period, DocGo and Capone falsely\n\nrepresented that Capone had earned a triple summa cum laude undergraduate degree from SUNY\n\nPotsdam and had earned a Masters of Computational Learning Theory from Clarkson University.\n\nDefendants touted Capone\u2019s purported educational background as a supposed competitive advantage\n\nin using artificial intelligence for traditional ambulance services and meeting the contract\n\nrequirements to provide healthcare services to underserved populations.\n\n 22. Additionally, as alleged in the Complaint, near the end of the Class Period, Capone\n\nmisled investors by stating that: (i) DocGo was in the running to secure a five-year contract with\n\nCBP for over $4 billion to allow DocGo to treat asylum seekers after crossing the border; and\n\n(ii) DocGo had been working with UnitedHealthcare to sign up over 3,000 asylum seekers and\n\ncounting onto New York State Medicaid.\n\n 23. The Complaint alleged that the truth about these false and misleading statements\n\nbegan to be revealed on September 10, 2023, when the Times Union published an article casting\n\n\n -6-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 8 of 25\n\n\n\n\ndoubt on Capone\u2019s statements about the purported CBP contract and the New York contract. The\n\narticles quoted a spokeswoman from CBP to report that the CBP contract was worth under $2\n\nbillion, and reported via an individual from UnitedHealthcare that UnitedHealthcare did not have a\n\ncontract with DocGo in New York. In response to this news, the price of DocGo common stock\n\ndropped over 10%, causing losses for Lead Plaintiff and other Class Members.\n\n 24. Less than a week later, the Times Union published another article reporting that there\n\nwas no record that Capone had earned a graduate degree. The Times Union updated the article the\n\nnext day to report that Capone admitted he did not have a graduate degree. In response to this news,\n\nthe price of DocGo common stock dropped over 25%, causing additional losses for Lead Plaintiff\n\nand other Class Members.\n\n D. Defendants\u2019 Motion to Dismiss\n\n 25. On June 21, 2024, DocGo and the Former Defendants moved to dismiss the\n\nComplaint pursuant to Federal Rules of Civil Procedure 12(b)(6) and 9(b), and the PSLRA. ECF 60-\n\n62.2 Defendants and Former Defendants argued, among other things, that statements about Capone\u2019s\n\neducation were not material to investors, that the Former Defendants did not have the requisite\n\nscienter for all claims, that Capone did not have scienter regarding the CBP contract statements, and\n\nthat the New York healthcare claims were inactionable because investors would not have understood\n\nCapone to mean that DocGo was literally signing asylum seekers up for New York State Medicare,\n\nbut rather that DocGo was facilitating signups through UnitedHealthcare.\n\n 26. On August 20, 2024, Lead Plaintiff filed its memorandum of law in opposition to the\n\nmotion to dismiss, contending that because Capone repeatedly touted his purported educational\n\n\n\n2\n Capone filed a motion to dismiss joining DocGo\u2019s and the Former Defendants\u2019 motion to\ndismiss, and making supplemental argument. ECF 63.\n\n -7-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 9 of 25\n\n\n\n\nbackground as a competitive advantage to DocGo\u2019s business, these statements were material to\n\ninvestors. ECF 65. Lead Plaintiff also argued that Capone focused on DocGo\u2019s ability to sign up\n\nasylum seekers onto New York State Medicaid as a way to generate long term revenue to assuage\n\ninvestor concerns about potential revenue cliffs.\n\n 27. Defendants and Former Defendants filed their respective replies on September 19,\n\n2024. ECF 68, 72.\n\n E. The Court Largely Sustains the Complaint\n\n 28. On March 28, 2025, the Court issued an Opinion & Order granting in part and\n\ndenying in part Defendants\u2019 motion to dismiss. ECF 77 (the \u201cMTD Order\u201d). In particular, the Court\n\nupheld the alleged misstatements about Capone\u2019s educational background and DocGo\u2019s ability to\n\nsign up asylum seekers onto New York State Medicaid against Capone and DocGo. Id. at 50. The\n\nCourt rejected Defendants\u2019 argument that the misstatements about Capone\u2019s education were\n\nimmaterial as a matter of law because \u201cCapone strove to tether his educational background directly\n\nto DocGo\u2019s technological capabilities.\u201d Id. at 23. The Court also rejected Defendants\u2019 arguments\n\nabout what investors would have understood Capone\u2019s statements about New York State Medicaid\n\nto mean, reasoning that \u201cCapone made these statements while emphasizing DocGo\u2019s ability to\n\ntransition patients from the Company\u2019s government vertical to its payer vertical \u2018at no [additional]\n\ncost.\u2019\u201d Id. at 30.3\n\n 29. Regarding scienter, the Court found that \u201cDefendants do not contest that Capone\n\nacted with the requisite level of scienter because Capone clearly knew the Education Statements\n\nwere inaccurate.\u201d Id. at 36. The Court further found that Capone\u2019s scienter was imputed to DocGo.\n\n\n\n3\n The Court also found that certain of the CBP statements were material, but ultimately found that\nthe Complaint did not adequately plead scienter for these statements. Id. at 25-29.\n\n -8-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 10 of 25\n\n\n\n\nId. at 37. As to the New York State Medicaid statements, the Court found that the Complaint\n\nadequately alleged scienter as to Capone (and thus DocGo) because Capone presented to investors a\n\nplan for DocGo\u2019s business which \u201cwas not presented as theoretical but as actual.\u201d Id. at 39.4\n\n 30. Defendants filed their Answers to the Complaint on April 25, 2025, which generally\n\ndenied Lead Plaintiff\u2019s substantive allegations and set forth 41 separate affirmative defenses.\n\nECF 84, 85.5\n\n F. Fact Discovery\n\n 31. As set forth herein, Lead Plaintiff diligently pursued fact discovery following the\n\nresolution of Defendants\u2019 motion to dismiss. These efforts included requesting, negotiating for,\n\nobtaining and reviewing more than 20,000 pages of documents from Defendants and third parties;\n\nengaging in extensive meet and confers; obtaining an admission from Capone through a request for\n\nadmission; and gathering and producing documents responsive to Defendants\u2019 discovery requests.\n\n 32. By vigorously pursuing discovery, Lead Counsel developed evidence supporting\n\nelements of Lead Plaintiff\u2019s claims and sufficient to evaluate a potential resolution.\n\n 2. Discovery Directed to Defendants\n\n 33. Following entry of the Court\u2019s Opinion & Order, and the withdrawal of the\n\nmandatory discovery stay, Lead Counsel commenced formal discovery efforts. On April 10, 2025,\n\nLead Counsel met and conferred with counsel for Defendants pursuant to Federal Rule of Civil\n\nProcedure 26(f) concerning case management, pre-trial scheduling, and fact discovery. Lead\n\nCounsel also negotiated and prepared a Proposed Civil Case Management Plan and Scheduling\n\n\n4\n The Court found that the Complaint did not adequately allege scienter for the Former Defendants\nand granted the motion to dismiss as to the Former Defendants. Id. at 33-35.\n5\n Without admitting Lead Plaintiff\u2019s allegations, Capone admitted in his Answer that he did not\nhave the educational background he claimed to have during the Class Period. ECF 85.\n\n -9-\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 11 of 25\n\n\n\n\nOrder, which the parties submitted to the Court on May 2, 2025. ECF 86. The parties exchanged\n\nInitial Disclosures pursuant to Fed. R. Civ. P. 26(a) on June 3, 2025.\n\n 34. On April 11, 2025, Lead Plaintiff served requests for the production of documents on\n\nDefendants, consisting of 36 discrete requests germane to the claims and defenses asserted by the\n\nparties. Defendants served their responses and objections to Lead Plaintiff\u2019s document requests on\n\nMay 12, 2025, and May 27, 2025. Thereafter, the Parties began negotiating the relevant topics for\n\ndiscovery, sources to be searched, relevant time period, custodians, and search terms.\n\n 35. Lead Counsel also drafted a comprehensive protective order to govern the treatment\n\nof confidential evidence, and negotiated with Defendants\u2019 counsel over the terms of the proposed\n\norder. The Parties filed a proposed Stipulated Protective Order on May 2, 2025, which the Court\n\nentered on May 5, 2025. ECF 87, 89.\n\n 36. The Parties quickly and continually met and conferred to negotiate the appropriate\n\nscope of fact discovery, and exchanged counterproposals through detailed written correspondence\n\nand telephonic conferences. On May 29, 2025, Defendants began producing documents to Lead\n\nPlaintiff on a rolling basis, while the Parties continued to work to resolve their outstanding\n\ndisagreements.\n\n 37. In addition, Lead Plaintiff served interrogatories and a request for admission on\n\nCapone on April 11, 2025, and met and conferred with Capone concerning his responses and\n\nobjections to the interrogatories and request for admission.\n\n 3. Third-Party Discovery\n\n 38. A significant amount of relevant information in this Litigation was in the possession,\n\ncustody, or control of third parties. Commencing on April 14, 2025, Lead Counsel served document\n\nsubpoenas on 11 third parties, as follows:\n\n\n - 10 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 12 of 25\n\n\n\n\n Person/Entity Date Relationship to Litigation\n\nUnitedHealth Group Inc. 4.28.2025 Health care company through which DocGo\n purportedly signed up asylum seekers onto New\n York State Medicaid\nClarkson University 4.28.2025 University where Capone purportedly received\n his master\u2019s degree\nThe State University of New 4.28.2025 University where Capone purportedly graduated\nYork at Potsdam with triple summa cum laude\n5W Public Relations, LLC 7.08.2025 Public relations firm for Defendants\nBTIG, LLC 7.08.2025 Financial analyst firm covering DocGo\nCanaccord Genuity, LLC 7.08.2025 Financial analyst firm covering DocGo\nCantor Fitzgerald, L.P. 7.08.2025 Financial analyst firm covering DocGo\nLifeSci Advisors, LLC 4.28.2025 Financial analyst firm covering DocGo\nNeedham & Company, LLC 7.08.2025 Financial analyst firm covering DocGo\nNorthland Securities, Inc. 7.08.2025 Financial analyst firm covering DocGo\nStifel, Nicolaus & Company, 7.08.2025 Financial analyst firm covering DocGo\nIncorporated\n\n 39. Lead Counsel engaged in numerous meet-and-confers with subpoenaed nonparties to\n\ndiscuss their objections to the subpoenas, negotiate the scope of the document requests, and arrange\n\nfor the production of responsive documents. Lead Counsel expended significant resources\n\nobtaining, reviewing, and analyzing these documents.\n\n 4. Lead Counsel\u2019s Review and Analysis of Discovery Materials\n\n 40. As a result of Lead Counsel\u2019s extensive discovery efforts, Defendants and\n\nsubpoenaed third parties \u2013 combined \u2013 produced over 20,000 pages of documents.\n\n 41. To facilitate the cost and time-efficient nature of the document review process, all of\n\nthe documents were placed in an electronic database, known as Relativity, maintained in-house by\n\nRobbins Geller, for significantly less than an outside vendor would charge. This database allowed\n\nLead Counsel to more efficiently search for and review documents through the use of search terms,\n\ndate filters, custodian fields, and other metadata.\n\n 42. Lead Counsel analyzed the documents to assess their relevance and began to compile\n\nthe documents most likely to be used in depositions and at summary judgment and trial \u2013 whether by\n - 11 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 13 of 25\n\n\n\n\nLead Plaintiff or Defendants. Lead Counsel also began to identify relevant witnesses for\n\ndepositions, and established procedures for finding deficiencies in the document productions.\n\nThroughout the document review process, Lead Counsel worked diligently to assemble the evidence\n\nneeded to support Lead Plaintiff\u2019s claims and to rebut Defendants\u2019 defenses.\n\n 5. Lead Plaintiff\u2019s Document Production and Motion for Class\n Certification\n\n 43. While fact discovery was ongoing, Lead Plaintiff filed its motion for class\n\ncertification.\n\n 44. In anticipation of Lead Plaintiff\u2019s motion for class certification, Defendants served\n\nrequests for the production of documents on Lead Plaintiff on April 29, 2025. Lead Plaintiff\n\nresponded and objected to Defendants\u2019 document requests on May 29, 2025, and the parties\n\nsubsequently met and conferred, resolving their disputes. Lead Plaintiff searched for and collected\n\ndocuments potentially responsive to Defendants\u2019 requests, and produced responsive, non-privileged\n\ndocuments to Defendants on July 28, 2025.\n\n 45. Defendants also served interrogatories on Lead Plaintiff on April 29, 2025. Lead\n\nPlaintiff responded and objected to Defendants\u2019 interrogatories on May 29, 2025.\n\n 46. On July 21, 2025, Lead Plaintiff filed a motion for class certification, which requested\n\nthat the Court certify the putative Class, appoint the Fund as class representative, and appoint\n\nRobbins Geller as class counsel. ECF 91-94. The motion for class certification addressed all of the\n\nrequirements of Federal Rule of Civil Procedure 23, as well as the \u201cfraud-on-the-market\u201d\n\npresumption of reliance endorsed by the Supreme Court in Basic Inc. v. Levinson, 485 U.S. 224\n\n(1988) and Halliburton Co. v. Erica P. John Fund, Inc., 573 U.S. 258, 268 (2014).\n\n 47. In support of its motion, Lead Plaintiff submitted an expert report from Professor\n\nMatthew D. Cain, Ph.D. See ECF 94-2. Professor Cain\u2019s 65-page report (plus exhibits) explained\n - 12 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 14 of 25\n\n\n\n\nwhy all five of the Cammer v. Bloom, 711 F. Supp. 1264 (D.N.J. 1989) and all three of the Krogman\n\nv. Sterritt, 202 F.R.D. 467 (N.D. Tex. 2001) factors \u2013 which courts routinely consider in addressing\n\nclass certification \u2013 were met. Professor Cain\u2019s report also included a detailed event study\n\nconcerning DocGo\u2019s stock price movement that contributed to his opinion that DocGo common\n\nstock traded in an efficient market throughout the Class Period. Professor Cain also opined that\n\ndamages consistent with Lead Plaintiff\u2019s theory of liability could be determined on a class-wide\n\nbasis. Lead Counsel spent substantial time consulting with Professor Cain on his report.\n\n 6. Mediation and Settlement Efforts\n\n 48. The Settlement is the product of hard-fought negotiations, which were conducted at\n\narm\u2019s length between experienced counsel and supervised by Miles Ruthberg of Phillips ADR, a\n\nnationally-renowned mediation firm with extensive experience in mediating securities class actions.\n\n 49. In advance of the mediation, on August 28, 2025, the Parties submitted to Mr.\n\nRuthberg and exchanged mediation statements with detailed descriptions of the evidence and law\n\nsupporting their claims and defenses.\n\n 50. On September 9, 2025, the Parties participated in a full-day mediation session with\n\nMr. Ruthberg via Zoom. During the mediation, Lead Counsel vigorously advocated Lead Plaintiff\u2019s\n\npositions regarding liability and damages. Although the Parties made progress, no settlement was\n\nreached at the conclusion of the mediation.\n\n 51. Thereafter, the Parties engaged in post-mediation negotiations through Mr. Ruthberg.\n\nOn September 25, 2025, Mr. Ruthberg made a \u201cmediator\u2019s recommendation\u201d that the case settle for\n\n$12.5 million. Lead Counsel discussed the mediator\u2019s recommendation with Lead Plaintiff, and\n\nafter careful deliberation, Lead Plaintiff accepted the recommendation. Defendants also accepted the\n\nmediator\u2019s recommendation, and on September 26, 2025, the Parties reached an agreement-in-\n\n\n - 13 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 15 of 25\n\n\n\n\nprinciple to resolve the Litigation, subject to the negotiation of mutually acceptable terms of a\n\nsettlement agreement.\n\n 52. Once the key terms of the Settlement were agreed upon, Lead Counsel continued to\n\nnegotiate at arm\u2019s length with Defendants\u2019 counsel to work out the details of the Settlement and the\n\nStipulation, and drafted the Stipulation and supporting documents. These negotiations continued\n\nuntil November 12, 2025, when the parties executed the Stipulation.\n\n G. Preliminary Approval of the Settlement\n\n 53. On November 12, 2025, Lead Plaintiff filed its Unopposed Motion for Preliminary\n\nApproval of Settlement, Certification of the Class, and Approval of Notice to the Class. ECF 99-\n\n100. In connection therewith, Lead Plaintiff requested that the Court: (i) preliminarily approve the\n\nSettlement; (ii) certify the proposed Class; (iii) approve the form and manner of the settlement\n\nnotices to Members of the Class; and (iv) schedule a hearing on the final approval of the Settlement,\n\nproposed Plan of Allocation, and Lead Counsel\u2019s application for an award of attorneys\u2019 fees and\n\nlitigation expenses. ECF 100.\n\n 54. The Court granted Lead Plaintiff\u2019s motion for preliminary approval on November 18,\n\n2025. ECF 106. In the order, the scheduled the final settlement hearing for March 24, 2026 at\n\n10:00 a.m. Id.\n\nIII. THE SETTLEMENT IS FAIR, REASONABLE, AND ADEQUATE AND\n WARRANTS APPROVAL\n\n 55. The Settlement of $12,500,000 was the result of extensive, arm\u2019s-length negotiations\n\nbetween the Parties, with the assistance of an experienced mediator. The Settlement reflects the\n\nstrengths and weaknesses of the case, and would not have been achieved without Lead Counsel\u2019s\n\nefforts described herein.\n\n\n\n - 14 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 16 of 25\n\n\n\n\n 56. As set forth below and in the accompanying Memorandum in Support of Lead\n\nPlaintiff\u2019s Motion for Final Approval of Class Action Settlement and Approval of Plan of Allocation\n\n(\u201cSettlement Memorandum\u201d), the Settlement is a favorable result for the Class when evaluated in\n\nlight of the risks of continued litigation and all of the other circumstances that courts consider when\n\ndetermining whether to grant final approval of a proposed class action settlement under Rule 23(e) of\n\nthe Federal Rules of Civil Procedure.\n\n 57. The Settlement avoids the hurdles Lead Plaintiff would have to clear, not only with\n\nrespect to proving the full amount of the Class\u2019s damages but liability as well, and avoids the\n\nsignificant costs associated with further litigation of this complex securities action, particularly\n\nsummary judgment and trial. In view of the significant risks and additional time and expense\n\ninvolved in continuing to litigate this Action, Lead Counsel respectfully submits that the Settlement\n\nis fair, reasonable, and adequate and warrants the Court\u2019s final approval.\n\n B. The Risks to Establishing Falsity and Materiality\n\n 58. While Lead Plaintiff and Lead Counsel believe that the claims asserted against\n\nDefendants are meritorious, they also recognize that there were considerable risks that made the\n\noutcome of this Litigation uncertain. Lead Counsel carefully considered these risks throughout the\n\nLitigation and in recommending that Lead Plaintiff settle this matter.\n\n 59. For example, Lead Plaintiff faced significant risks in proving that Defendants\u2019 alleged\n\nstatements and omissions were materially misleading. Defendants would have continued to argue, as\n\nthey did in their motion to dismiss, that Lead Plaintiff would be unable to prove materiality for\n\nstatements regarding Capone\u2019s education. Likewise, Defendants would have continued to argue that\n\ninvestors did not understand Capone to mean that DocGo was literally signing asylum seekers up for\n\nNew York State Medicaid, but rather that it was facilitating signups through UnitedHealthcare.\n\n\n - 15 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 17 of 25\n\n\n\n\n 60. While the parties disagreed about the merits of these arguments, Lead Plaintiff\n\nrecognized that if the Court at summary judgment or a jury at trial found them compelling, the Class\n\nwould recover nothing.\n\n C. The Risks to Establishing Loss Causation and Damages\n\n 61. Even if Lead Plaintiff succeeded in overcoming these arguments and establishing\n\nfalsity and scienter, Defendants\u2019 arguments and defenses relating to loss causation and damages\n\npresented additional obstacles. Defendants would likely claim that Lead Plaintiff could not prove\n\nloss causation because a portion of the final drop in DocGo\u2019s stock price was caused by the\n\nrevelation that the CBP contract was not as high as Capone claimed, and that claim was dismissed\n\nfrom the Complaint. Defendants would also likely contend that it was Capone\u2019s departure as CEO,\n\nnot the revelation of his educational background, that was the sole cause of DocGo\u2019s stock price\n\ndrop.\n\n 62. Moreover, Defendants would likely contend that even if their loss causation argument\n\ndid not eliminate damages, it severely limited them. Defendants were likely to assert that Lead\n\nPlaintiff and the Class were only entitled to recover the portion of the stock price declines between\n\nSeptember 10 and September 15, 2023, if any, that Lead Plaintiff could prove was attributable to\n\nrevelations about Capone\u2019s education and the New York State Medicaid issue.\n\n 63. While Lead Plaintiff would have had the burden of identifying and isolating the\n\nfraud-related damages suffered by Class Members, Defendants only had to identify a flaw with the\n\nmethodology utilized by Lead Plaintiff\u2019s expected experts and prevail on a Daubert motion or win\n\nthe inevitable, and inherently unpredictable, \u201cbattle of the experts\u201d between the parties\u2019 loss\n\ncausation and damages experts before the jury. Defendants would have argued that the case either\n\n\n\n\n - 16 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 18 of 25\n\n\n\n\nshould not reach a jury or that the jury had no choice but to determine that there were little or no\n\ncognizable damages.\n\n 64. Although Lead Plaintiff is confident that it would have been able to support its claims\n\nwith qualified and persuasive expert testimony, jury reactions to competing experts are difficult to\n\npredict, and Defendants would surely have put forth well-credentialed experts in an effort to prove\n\ntheir loss causation and damages arguments. These risks could not be eliminated until after a\n\nsuccessful trial and the exhaustion of all appeals. Accordingly, in the absence of a settlement, there\n\nwas a very real risk that the Class would have recovered an amount significantly less than the total\n\nSettlement Amount \u2013 or even nothing at all.\n\n 65. In short, the parties disagreed on the merits of this case, including whether or not\n\ndamages were suffered and recoverable. Defendants strongly defended this lawsuit with experienced\n\nattorneys and consistently denied that they were liable in any respect. Recovery of any amount at\n\ntrial was far from certain.\n\n D. The Complexity, Expense, and Likely Duration of the Litigation\n\n 66. The continuation of this Action would be long, complex, and costly to all parties\n\ninvolved. It has already been pending since 2023. Were the Litigation to proceed, the completion of\n\nfact and expert discovery, class certification briefing, summary judgment motions, trial, and almost\n\ncertain appeals would be lengthy and would entail considerable additional costs.\n\n 67. Assuming Lead Plaintiff prevailed at trial, it is likely that Defendants would file post-\n\ntrial motions and appeals to limit or overturn any verdict in Lead Plaintiff\u2019s favor. The post-trial\n\nmotion and appeals process would likely span several years, during which time the Class would\n\nreceive no payment. In addition, an appeal of any verdict would carry with it the risk of reversal, in\n\nwhich case the Class would receive no payment despite having prevailed on its claims at trial. While\n\n\n - 17 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 19 of 25\n\n\n\n\nLead Counsel had developed strong documentary evidence, it faced both factual and legal challenges\n\nin presenting this matter to a jury and potentially on appeal.\n\n 68. Finally, there was a possibility that the Class would receive nothing even if Lead\n\nPlaintiff prevailed at every stage. Since the filing of this Action, DocGo\u2019s common stock has\n\nexperienced a precipitous decline and is now trading under $1 a share with a market cap of\n\napproximately $68 million. By the time it would take to successfully obtain a judgment in this\n\nAction, it is far from certain that DocGo would have the ability to pay a judgment for all or even a\n\nportion of Lead Plaintiff\u2019s damages Thus, under the current circumstances, there was no guarantee\n\nLead Plaintiff would be able to collect anything after a trial and the exhaustion of appeals.\n\n E. Additional Factors\n\n 68. The experience of Lead Counsel also favors the Settlement. Robbins Geller is\n\nnationally recognized for its experience and expertise in complex class action and securities\n\nlitigation. Our reputations as attorneys who are willing to zealously carry a meritorious case through\n\ntrial and appeals gave us a strong negotiating position, even under the challenging circumstances\n\npresented here. See Declaration of Christopher M. Wood Filed on Behalf of Robbins Geller Rudman\n\n& Dowd LLP in Support of Application for Award of Attorneys\u2019 Fees and Expenses (\u201cFee Decl.\u201d),\n\nEx. D, submitted herewith (firm r\u00e9sum\u00e9).\n\n 69. Finally, the lack of opposition to the Settlement also militates in favor of the\n\nSettlement. As outlined below, notice has already been widely disseminated to potential Class\n\nMembers. The absence of any objections to the Settlement or requests to opt out of the Class, weigh\n\nin favor of the Settlement.\n\n 70. Based on all of these factors, Lead Counsel and Lead Plaintiff respectfully submit that\n\nthe Settlement, which provides a very substantial recovery to Class Members, outweighs the risks of\n\n\n - 18 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 20 of 25\n\n\n\n\ncontinued litigation. The Settlement provides Class Members with a substantial benefit now, where\n\nthere is a significant likelihood of less recovery or no recovery at all if the Litigation were to\n\ncontinue.\n\nIV. MAILING AND PUBLICATION OF NOTICE OF SETTLEMENT\n\n 71. The Preliminary Approval Order, among other things, appointed Verita as the Claims\n\nAdministrator and directed it to cause the mailing or emailing of the Postcard Notice to all potential\n\nClass Members identifiable with reasonable effort, no later than December 9, 2025. ECF 106, \u00b69(b).\n\n 72. The Preliminary Approval Order also directed Verita to cause the Summary Notice to\n\nbe published once in The Wall Street Journal, and once over a national newswire service, no later\n\nthan December 16, 2025. Id., \u00b69(c).\n\n 73. The Declaration of Ross D. Murray Regarding: (A) Notice Dissemination; (B)\n\nPublication; (C) Establishment of Call Center Services and Website; and (D) Requests for Exclusion\n\nReceived to Date (\u201cMurray Decl.\u201d), submitted herewith, states that 13,280 Postcard Notices have\n\nbeen mailed or emailed to potential Class Members, banks, brokers, and nominees to date, and that\n\nthe Summary Notice was published in The Wall Street Journal and transmitted over Business Wire\n\non December 16, 2025, in compliance with the Preliminary Approval Order. Murray Decl., \u00b6\u00b611-12.\n\n 74. No objections to any aspect of the Settlement have been received, and to-date, no\n\nrequests for exclusion have been received. Id., \u00b616.\n\nV. THE PLAN OF ALLOCATION IS FAIR AND ADEQUATE\n\n 75. The Plan of Allocation is set forth in the Notice (see Murray Decl., Ex. B, Notice at 9-\n\n13) and provides that the Net Settlement Fund will be distributed to Class Members who submit a\n\nvalid and timely Proof of Claim and Release form and whose claims for recovery have been\n\npermitted under the terms of the Stipulation (\u201cAuthorized Claimants\u201d). The Plan of Allocation\n\n\n - 19 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 21 of 25\n\n\n\n\nprovides that a Class Member will be eligible to participate in the distribution of the Net Settlement\n\nFund only if the Class Member has an overall net loss on all of his, her, or its transactions in DocGo\n\ncommon stock during the Class Period.\n\n 76. For purposes of determining the amount an Authorized Claimant may recover under\n\nthe Plan of Allocation, Lead Counsel conferred with its economics and damages expert, Professor\n\nCain. The Plan of Allocation is premised on the out-of-pocket measure of damages and is designed\n\nto measure the difference between what Class Members paid for DocGo common stock during the\n\nClass Period and what the price of DocGo common stock would have been had the allegedly omitted\n\nand misstated information been accurately disclosed, while accounting for the Court\u2019s finding in the\n\nMTD Order.\n\n 77. Pursuant to the Preliminary Approval Order, and as set forth in the Notice, all Class\n\nMembers who wish to participate in the distribution of the Net Settlement Fund are required to\n\nsubmit a valid Proof of Claim and Release and all required information, postmarked or submitted\n\nonline no later than March 9, 2026. As provided in the Notice, after deduction of taxes, approved\n\ncosts, and attorneys\u2019 fees and expenses, the Net Settlement Fund will be distributed, according to the\n\nCourt-approved Plan of Allocation, to Authorized Claimants who are entitled to a distribution of at\n\nleast $10.00.\n\n 78. Verita, as the Court-approved Claims Administrator, will determine each Authorized\n\nClaimant\u2019s pro rata share of the Net Settlement Fund based on each Authorized Claimant\u2019s total\n\nRecognized Loss Amount compared to the total Recognized Loss Amounts of all Authorized\n\nClaimants. Lead Plaintiff\u2019s losses will be calculated in the same manner.\n\n 79. Lead Counsel believes that the Plan of Allocation, which is similar to hundreds of\n\nplans approved by courts over decades, provides a fair and reasonable method to equitably distribute\n\n - 20 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 22 of 25\n\n\n\n\nthe Net Settlement Fund among Authorized Claimants. To date, not a single Class Member has\n\nobjected to the proposed Plan of Allocation. The Plan of Allocation is fair and reasonable, and\n\nshould be approved.\n\nVI. LEAD COUNSEL\u2019S APPLICATION FOR ATTORNEYS\u2019 FEES AND\n EXPENSES IS REASONABLE\n\n 80. The successful prosecution of this Action required Lead Counsel\u2019s attorneys,\n\ninvestigators, paraprofessionals, and staff to perform over 1,930 hours of work and incur\n\n$183,676.18 in expenses. See Fee Decl., Exs. A-B. Based on the extensive efforts on behalf of the\n\nClass, as described above, Lead Counsel is applying for compensation from the Settlement Fund on\n\na percentage basis, and has requested a fee in the amount of 33% of the Settlement Amount, plus\n\ninterest \u2013 a fee approved by Lead Plaintiff.\n\n B. The Requested Fee Is Reasonable\n\n 81. In light of the nature and extent of the Litigation, the diligent prosecution of the\n\nAction, the complexity of the factual and legal issues presented, and the other factors described\n\nabove and in the accompanying application for attorneys\u2019 fees and expenses, Lead Counsel believes\n\nthat the requested fee of 33% of the Settlement Amount, plus interest, is fair and reasonable.\n\n 82. A 33% fee award is consistent with percentages awarded by courts in this District and\n\naround the country (see accompanying Memorandum in Support of Lead Counsel\u2019s Motion for an\n\nAward of Attorneys\u2019 Fees and Expenses (\u201cFee Memorandum\u201d) at II.C.), and is justified by the\n\nspecific facts and circumstances in this case and the substantial risks that Lead Counsel had or in the\n\nfuture would have had to overcome at the summary judgment phase of the Litigation, and at trial, as\n\nset forth herein.\n\n\n\n\n - 21 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 23 of 25\n\n\n\n\n C. The Requested Fee Is Supported by the Effort Expended and Results\n Achieved\n\n 83. As set forth herein, the $12.5 million cash Settlement was achieved as a result of\n\nextensive investigative efforts, complicated motion practice, hard-fought discovery, analysis of\n\nvoluminous evidence, and extensive mediation preparation.\n\n 84. As discussed in greater detail above, this case was fraught with significant risks\n\nconcerning liability and damages. Lead Plaintiff\u2019s success was by no means assured. Defendants\n\ndisputed whether the alleged misstatements and omissions were even actionable, asserted that they\n\ndid not act with the requisite scienter for certain claims, and sought to attribute any harm suffered to\n\nfactors unrelated to the alleged fraud. Were this Settlement not achieved, and even if Lead Plaintiff\n\nprevailed at trial, Lead Plaintiff potentially faced years of costly and risky appellate litigation, with\n\nultimate success far from certain. It is also possible that a jury could have found no liability or no\n\ndamages.\n\n 85. As a result of this Settlement, Class Members will benefit and receive compensation\n\nfor their losses and avoid the very substantial risk of no recovery in the absence of a settlement.\n\nThese factors also support Lead Counsel\u2019s request for an award of attorneys\u2019 fees of 33% of the\n\nSettlement Amount, plus interest.\n\n D. The Risk of Contingent Class Action Litigation Supports the\n Requested Fee Award\n\n 86. As set forth in the accompanying application for attorneys\u2019 fees and expenses, a\n\ndetermination of a fair fee should include consideration of the contingent nature of the fee, the time\n\nand labor expended by Lead Counsel, and the difficulties that were overcome in obtaining the\n\nSettlement.\n\n\n\n\n - 22 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 24 of 25\n\n\n\n\n 87. This Action was prosecuted by Lead Counsel on a contingent fee basis. Lead\n\nCounsel committed 1,932.90 hours of attorney and professional time and incurred $183,676.18 in\n\nexpenses in the prosecution of the Litigation, as set forth in the accompanying Fee Declaration.\n\nLead Counsel fully assumed the risk of an unsuccessful result. Lead Counsel has received no\n\ncompensation for its services during the course of this Litigation and has incurred significant\n\nexpenses in litigating for the benefit of the Class. Any fees or expenses awarded to Lead Counsel\n\nhave always been at risk and are completely contingent on the result achieved. Because the fee to be\n\nawarded in this matter is entirely contingent, the only certainty from the outset was that there would\n\nbe no fee without a successful result, and that such a result would be realized only after a lengthy\n\nand difficult effort.\n\n 88. Lead Counsel\u2019s efforts were performed on a wholly contingent basis, despite\n\nsignificant risk and in the face of determined opposition. Under these circumstances, Lead Counsel\n\nis justly entitled to the award of a reasonable percentage fee based on the benefit conferred and the\n\ncommon fund obtained for the Class. A 33% fee, plus expenses and interest, is fair and reasonable\n\nunder the circumstances present here.\n\n 89. There are numerous cases, including many handled by Robbins Geller, where class\n\ncounsel in contingent fee cases such as this, after expenditure of thousands of hours of time and\n\nincurring significant costs, have received no compensation whatsoever. The fact that Defendants\n\nand their counsel know that the leading members of the plaintiffs\u2019 bar are able to, and will, go to trial\n\neven in high-risk cases like this one gives rise to meaningful settlements in actions such as this. The\n\nlosses suffered by class counsel in other actions where insubstantial settlement offers were rejected,\n\nand where class counsel ultimately received little or no fee, should not be ignored. Lead Counsel\n\n\n\n\n - 23 -\n4923-2230-1576.v1\n\f Case 1:23-cv-09476-KPF Document 112 Filed 02/17/26 Page 25 of 25\n\n\n\n\nknows from personal experience that despite the most vigorous and competent of efforts, success in\n\ncontingent litigation is never assured.\n\n 90. Lawsuits such as this are expensive to litigate. Those unfamiliar with the efforts\n\nrequired to litigate class actions often focus on the aggregate fees awarded at the end but ignore the\n\nfact that those fees fund enormous overhead expenses incurred during the course of many years of\n\nlitigation, are taxed by federal and state authorities, are used to fund the expenses of other contingent\n\ncases prosecuted by class counsel, and help pay the salaries of the firms\u2019 attorneys and staff.\n\nVII. CONCLUSION\n\n 91. For the reasons set forth above and in the accompanying Settlement and Fee\n\nMemoranda, Lead Counsel respectfully submits that: (i) the Settlement is fair, reasonable, and\n\nadequate and should be finally approved; (ii) the Plan of Allocation represents a fair method for the\n\ndistribution of the Net Settlement Fund among Class Members and should also be approved; and\n\n(iii) the application for attorneys\u2019 fees of 33% of the Settlement Amount and expenses of\n\n$183,676.18, plus the interest earned on both amounts at the same rate and for the same period as\n\nthat earned on the Settlement Fund until paid, should be granted in its entirety.\n\n I declare under penalty of perjury that the foregoing is true and correct. Executed this 17th\n\nday of February, 2026, at Nashville, Tennessee.\n\n\n s/ Christopher M. Wood\n CHRISTOPHER M. WOOD\n\n\n\n\n - 24 -\n4923-2230-1576.v1\n\f","ocr_status":2,"date_upload":"2026-06-22T23:06:34.931552-07:00","document_number":"112","attachment_number":null,"pacer_doc_id":"127039079581","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Declaration in Support of Motion","acms_document_guid":""}],"date_created":"2026-02-17T11:09:40.950513-08:00","date_modified":"2026-02-20T12:05:40.969312-08:00","date_filed":"2026-02-17","time_filed":"14:03:21","entry_number":112,"recap_sequence_number":"2026-02-17.005","pacer_sequence_number":373,"description":"DECLARATION of Christopher M. Wood in Support re: 108 MOTION for Settlement for Final Approval and Approval of Plan of Allocation., 110 MOTION for Attorney Fees and Expenses.. Document filed by Genesee County Employees' Retirement System..(Wood, Christopher) (Entered: 02/17/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/444906260/","id":444906260,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67923163/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/459586559/","id":459586559,"tags":[],"absolute_url":"","date_created":"2025-11-21T00:29:43.796362-08:00","date_modified":"2026-02-20T12:05:40.671008-08:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2025-11-21T00:29:43.776688-08:00","date_modified":"2026-02-20T12:05:40.645311-08:00","date_filed":"2025-11-18","time_filed":null,"entry_number":null,"recap_sequence_number":"2025-11-18.002","pacer_sequence_number":null,"description":"Set/Reset Hearings: Settlement Conference set for 3/24/2026 at 10:00 AM in Courtroom 618, 40 Centre Street, New York, NY 10007 before Judge Katherine Polk Failla. 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