Reynolds v. Citadel Securities LLC — Entry #39: MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo
Case: Reynolds v. Citadel Securities LLC flsd · 1:26-cv-24485
filed June 29, 2026
What this document is
Docket entry #39 · filed August 28, 2026
MOTION to Appoint Lead Plaintiff Jordan Dario Primo by Jordan Dario Primo. Attorney Nathan C. Zipperian added to party Jordan Dario Primo(pty:mov). Responses due by 9/11/2026. (Attachments: # 1 Affidavit Declaration of Nathan Zipperian in Support of Motion of Movant JORDAN DARIO PRIMO for Appointment as Lead Plaintiff, # 2 Exhibit A - Damages Analysis, # 3 Exhibit B - Certification and Schedule A, # 4 Exhibit C - June 29, 2026 Press Release, # 5 Exhibit D - Movant Declaration, # 6 Exhibit E - Pomerantz Firm Resume, # 7 Exhibit F - Miller Shah Firm Resume, # 8 Text of Proposed Order)(Zipperian, Nathan) (Entered: 08/28/2026)
Who is involved
- Aron Reynolds
- Citadel Securities LLC
- Virtu Americas LLC
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Applied Digital: its former name “FLIGHT SAFETY TECHNOLOGIES INC” appears in a filing in this case.
…Counsel. $1.2 million. • Flight Safety Technologies, Inc., (D. Conn.). Rosen Lead Counsel. $1…
- Core Scientific: its name “Core Scientific, Inc.” appears in a filing in this case.
…Lead Counsel. Pang v. Levitt (Core Scientific, Inc.), No. 22-CV-1191-LY (W.D. Tex.). Rosen…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 07, 2026. Federal court filings are public records.
Document text
62 page(s), 221,350 characters, converted from the PDF's text layer · plain text.
Full text
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 1 of 62
EXHIBIT E=
EXHIBIT
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 2 of 62
POMERANTZ
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 3 of 62
History Pomerantz LLP is one of the most respected law firms in the United States dedicated
to representing investors. The Firm was founded in 1936 by the late Abraham L. Pomerantz,
widely regarded as a legal pioneer and “dean” of the plaintiffs’ securities bar, who helped secure
the right of investors to bring class and derivative actions.
Leadership Today, led by Managing Partner Jeremy A. Lieberman, the Firm maintains the
commitments to excellence and integrity passed down by Abe Pomerantz.
Results Pomerantz achieved a historic $3 billion settlement for defrauded investors in 2018
as well as precedent-setting legal rulings, in In re Petrobras Securities Litigation. Pomerantz
consistently shapes the law, winning landmark decisions that expand and protect investor rights
and initiating historic corporate governance reforms.
Global Expertise Beyond its three American offices, the Firm has offices in Paris,
London, and Tel Aviv. Pomerantz also partners with an extensive network of prominent law firms
across the globe to assist clients, wherever they are situated, in recovering monies lost due to
corporate misconduct and securities fraud. Our team of attorneys is collectively fluent in English,
Arabic, Cantonese, Mandarin, French, Hebrew, Italian, Portuguese, Romanian, Russian, Spanish,
and Ukrainian.
Practice Pomerantz protects, expands, and vindicates shareholder rights through our
securities litigation services and portfolio monitoring service. The Firm represents some of the
largest and most influential pension funds, asset managers and institutional investors around the
globe, monitoring assets of over $9.5 trillion and growing. Pomerantz’s practice includes
corporate governance, antitrust, and strategic consumer litigation.
Recognition Pomerantz has been recognized as a top tier firm by The Legal 500, Benchmark
Litigation, and Chambers USA, among others. In 2020, Pomerantz was named the Plaintiff Firm of
the Year by Benchmark Litigation and honored with European Pensions’ inaugural Thought
Leadership Award. Courts across the country have noted the quality of our legal work, and
Pomerantz attorneys regularly receive praise from their peers. The 2024 Benchmark Litigation
guide describes Pomerantz’s “prodigious capacity for cases and its tenacity to keep pursuing
them” as well as the Firm’s work on litigation “with more meaningful angles.” The Firm’s attorneys
have been recognized by major industry publications, including The National Law Journal, The
New York Law Journal, Law360, and Lawdragon. Among the prestigious honors received by
Pomerantz attorneys are the Benchmark Litigation Plaintiff Litigator of the Year Award (Jeremy
Lieberman, 2019; Emma Gilmore 2024), New York Law Journal Innovation Award (Jennifer Pafiti,
2023), and Law360 Titan of the Plaintiffs Bar (Murielle Steven Walsh, 2024).
Pomerantz is headquartered in New York City, with offices in
Chicago, Los Angeles, London, Paris, and Tel Aviv.
www.pomlaw.com 1
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 4 of 62
Securities Litigation
Significant Landmarks
In re Petrobras Sec. Litig., No. 14-cv-9662 (S.D.N.Y. 2018)
On January 3, 2018, in a significant victory for investors, Pomerantz, as sole Lead Counsel for the class,
along with Lead Plaintiff Universities Superannuation Scheme Limited (“USS”), achieved a historic $2.95
billion settlement with Petróleo Brasileiro S.A. (“Petrobras”) and its related entity, Petrobras International
Finance Company, as well as certain of Petrobras’ former executives and directors. On February 2, 2018,
Pomerantz and USS reached a $50 million settlement with Petrobras’ auditors, PricewaterhouseCoopers
Auditores Independentes, bringing the total recovery for Petrobras investors to $3 billion.
This is not only the largest securities class action settlement in a decade but is the largest settlement ever
in a securities class action involving a foreign issuer, the fifth-largest securities class action settlement ever
achieved in the United States, the largest securities class action settlement achieved by a foreign Lead
Plaintiff, and the largest securities class action settlement in history not involving a restatement of
financial reports.
The class action, brought on behalf of all purchasers of common and preferred American Depositary
Shares (“ADSs”) on the New York Stock Exchange, as well as purchasers of certain Petrobras debt,
principally alleged that Petrobras and its senior executives engaged in a multi-year, multi-billion-dollar
money-laundering and bribery scheme, which was concealed from investors.
In addition to the multi-billion-dollar recovery for defrauded investors, Pomerantz secured precedent-
setting decisions when the Second Circuit Court of Appeals squarely rejected defendants’ invitation to
adopt the heightened ascertainability requirement promulgated by the Third Circuit, which would have
required plaintiffs to demonstrate that determining membership in a class is “administratively feasible.”
The Second Circuit’s rejection of this standard is not only a victory for bondholders in securities class
actions, but also for plaintiffs in consumer fraud class actions and other class actions where
documentation regarding Class membership is not readily attainable. The Second Circuit also refused to
adopt a requirement, urged by defendants, that all securities class action plaintiffs seeking class
certification prove through direct evidence (i.e., an event study) that the prices of the relevant securities
moved in a particular direction in response to new information.
Pirnik v. Fiat Chrysler Automobiles N.V. et al., No. 1:15-cv-07199-JMF (S.D.N.Y)
In August 2019, Pomerantz, as Lead Counsel, achieved final approval of a $110 million settlement for the
Class in this high-profile securities class action. Plaintiffs alleged that Fiat Chrysler concealed from
investors that it improperly outfitted its diesel vehicles with “defeat device” software designed to cheat
NOx emissions regulations in the U.S. and Europe, and that regulators had accused Fiat Chrysler of
violating the emissions regulations. The Fiat Chrysler recovery provides the class of investors with as much
as 20% of recoverable damages—an excellent result when compared to historical statistics in class action
settlements, where typical recoveries for cases of this size are between 1.6% and 3.3%.
www.pomlaw.com 2
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 5 of 62
In addition to creating precedent-setting case law in successfully defending the various motions to dismiss
the Fiat Chrysler litigation, Pomerantz also significantly advanced investors’ ability to obtain critically
important discovery from regulators that are often at the center of securities actions. During the litigation,
Pomerantz sought the deposition of a former employee of the National Highway Traffic Safety
Administration (“NHTSA”). The United States Department of Transportation (“USDOT”), like most federal
agencies, has enacted a set of regulations—known as “Touhy regulations”—governing when its
employees may be called by private parties to testify in court. On their face, USDOT’s regulations apply to
both “current” and “former” employees. In response to Pomerantz’s request to depose a former
employee of NHSTA that interacted with Fiat Chrysler, NHTSA denied the request, citing the Touhy
regulation. Despite the widespread application, and assumed appropriateness, of applying these
regulations to former employees throughout the case law, Pomerantz filed an action against USDOT and
NHTSA, arguing that the statute pursuant to which the Touhy regulations were enacted speaks only of
“employees,” which should be interpreted to apply only to current employees. The court granted
summary judgment in favor of Pomerantz’s clients, holding that “USDOT’s Touhy regulations are unlawful
to the extent that they apply to former employees.” This victory will greatly shift the discovery tools
available, so that investor plaintiffs in securities class actions against highly regulated entities (for
example, companies subject to FDA regulations) will now be able to depose former employees of the
regulators that interacted with the defendants during the class period to get critical testimony concerning
the company’s violations and misdeeds.
Karimi v. Deutsche Bank AG, 1:22-cv-02854 (S.D.N.Y.)
On September 27, 2022, Pomerantz reached a $26.25 million settlement on behalf of defrauded investors
in a securities class action against Deutsche Bank AG. The settlement represents over 49% of estimated
recoverable damages, far in excess of the 1.8% median recovery in similar cases.
The complaint alleges that Deutsche Bank failed to properly adhere to its own Know Your Customer
(“KYC”) policies when dealing with customers it considered high-risk, such as accused sex offender Jeffrey
Epstein, Russian oligarchs and politically exposed persons (“PEPs”) reportedly engaged in criminal
activities. The Bank repeatedly assured investors that it had “developed effective procedures for assessing
clients and processes for accepting new clients in order to facilitate comprehensive compliance” with
these policies. In reality, however, during the Class Period, defendants repeatedly exempted high net-
worth individuals and PEPs from any meaningful due diligence, further enabling their crimes through the
use of the Bank’s facilities.
For example, in 2013, Deutsche Bank took on Jeffrey Epstein as a client, despite his previous convictions
for and new allegations of child sex trafficking and abuse. Because Epstein was regarded as a “high-risk”
customer, he should have been subject to the strict due diligence required by the Bank’s KYC program;
however, he was instead classified as an “Honorary PEP,” and his activities within the Bank were allowed
to continue, largely due to the business he could generate for the Bank. Prior to his onboarding as a client,
“40 underage girls had come forward with testimony of Epstein sexually assaulting them,” and despite
these allegations, Deutsche Bank remained “comfortable with things continuing.”
www.pomlaw.com 3
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 6 of 62
Howard v. Arconic et al., No. 2:17-cv-01057 (W.D.Pa.)
In August 2023, Pomerantz, as Co-Lead Counsel, achieved final approval of a $74 million settlement on
behalf of defrauded investors in a securities class action against the American industrial company Arconic.
On June 14, 2017, a devastating fire broke out in the Grenfell Tower block of flats in London, United
Kingdom, resulting in the deaths of 72 people and injuries to more than 70 other tenants. In the wake of
the tragedy, numerous investigations were conducted, ultimately revealing that, while an electrical fault
within the building instigated the blaze, Arconic’s Reynobond PE panels, which covered the outside of the
building, likely acted as an accelerant, contributing to the rapid spread of the flames to the floors above.
In August 2017, Pomerantz filed a securities class action against Arconic alleging that its stock price was
artificially inflated during the Class Period by the company’s misstatements about the safety of its
Reynobond PE insulating panels. Following a partial dismissal, Pomerantz filed a second amended
complaint, which cited numerous instances in which Arconic sold Reynobond PE panels for use in other
high-rise towers in the UK and across the globe.
Notably, despite the United States’ near universal ban of combustible Reynobond for buildings taller than
twelve meters (40 feet), plaintiffs found that Arconic had sold these panels for use in the construction of
numerous structures measuring twelve meters or higher throughout the country, including a terminal at
the Dallas/Fort Worth airport and Ohio’s Cleveland Browns stadium. The complaint also pointed to at
least eighteen other instances in which deadly fires had spread through exterior wall assemblies, most of
which involved high-rise buildings. The new allegations included in the second amended complaint
convinced Chief U.S. District Judge Mark R. Hornak to not only change his mind on many of the claims he
had previously dismissed, but also to make new law in plaintiffs favor on several significant issues,
including the element of scienter, i.e., intent to deceive investors.
The $74 million settlement represents approximately 22% of recoverable damages for defrauded Arconic
shareholders, an amount far exceeding the 1.8% median recovery for all securities class action settlements
in 2022.
Kaplan v. S.A.C. Capital Advisors, L.P, No. 12-cv-9350 (S.D.N.Y.)
In May 2017, Pomerantz, as Co-Lead Counsel, achieved final approval of a $135 million recovery for the
Class in this securities class action that stemmed from what has been called the most profitable insider
trading scheme in U.S. history. After years of vigorous litigation, billionaire Steven A. Cohen's former
hedge fund, S.A.C. Capital Advisors LP, agreed to settle the lawsuit by investors in the drug maker Elan
Corp, who said they lost money because of insider trading by one of his portfolio managers.
In re BP p.l.c. Securities Litigation, MDL No. 2185 (S.D. Tex.)
Beginning in 2012, Pomerantz pursued ground-breaking individual lawsuits for institutional investors to
recover losses in BP p.l.c.’s London-traded common stock and NYSE-traded American Depository Shares
(ADSs) arising from its 2010 Gulf of Mexico oil spill. Over nine years, Pomerantz briefed and argued every
significant dispute on behalf of 125+ institutional plaintiffs, successfully opposed three motions to dismiss,
won other contested motions, oversaw e-discovery of 1.75 million party and non-party documents, led
www.pomlaw.com 4
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 7 of 62
the Individual Action Plaintiffs Steering Committee, served as sole Liaison with BP and the Court, and
worked tirelessly with our clients’ outside investment management firms to develop crucial case evidence.
A threshold challenge was how to litigate in U.S. court given the U.S. Supreme Court’s decision in Morrison
v. National Australia Bank, 130 S. Ct. 2869 (2010), which barred recovery for losses in foreign-traded
securities under the U.S. federal securities laws. In 2013 and 2014, Pomerantz won significant victories in
defeating BP’s forum non conveniens arguments, which sought to force dismissal of the English common
law claims from U.S. courts for refiling in English courts, first as regards U.S. institutions and, later, foreign
institutions. Pomerantz also defeated BP’s attempt to extend the U.S. federal Securities Litigation Uniform
Standards Act of 1998 to reach, and dismiss, these foreign law claims in deference to non-existent
remedies under the U.S. federal securities laws. These rulings paved the way for 125+ global institutional
investors to pursue their claims and marked the first time, post-Morrison, that U.S. and foreign investors,
pursuing foreign claims seeking recovery for losses in a foreign company’s foreign-traded securities, did
so in a U.S. court. In 2017, Pomerantz earned an important victory that expanded investor rights under
English law, permitting certain BP investors to pursue a “holder claim” theory seeking to recover losses in
securities held, rather than purchased anew, in reliance on the alleged fraud—a theory barred under the
U.S. federal securities laws since Blue Chip Stamps v. Manor Drug Stores, 421 U.S. 723 (1975). This win
was significant, given the dearth of precedent from anywhere recognizing the viability of a “holder claim”
under any non-U.S. law and holding that a given plaintiff alleged facts sufficiently evidencing reliance and
documenting the resulting retention of an identifiable amount of shares on a date certain.
In Q1 2021, Pomerantz secured confidential, favorable monetary settlements from BP for our nearly three
dozen clients, including public and private pension funds, money management firms, partnerships, and
investment trusts from the U.S., Canada, the U.K., France, the Netherlands, and Australia.
In re Comverse Technology, Inc. Sec. Litig., No. 06-CV-1825 (E.D.N.Y.)
In June 2010, Judge Nicholas G. Garaufis of the U.S. District Court for the Eastern District of New York
granted final approval of a $225 million settlement proposed by Pomerantz and Lead Plaintiff the Menora
Group, with Comverse Technology and certain of Comverse’s former officers and directors, after four
years of highly contested litigation. The Comverse settlement is one of the largest securities class action
settlements reached since the passage of the Private Securities Litigation Reform Act (“PSLRA”).1 It is the
second-largest recovery in a securities litigation involving the backdating of options, as well as one of the
largest recoveries—$60 million—from an individual officer-defendant, Comverse’s founder and former
CEO, Kobi Alexander.
Other Significant Settlements
Even before the enactment of the PSLRA, Pomerantz represented state agencies in securities class
actions, including the Treasurer of the Commonwealth of Pennsylvania (recovered $100 million) against
a major investment bank. In re Salomon Brothers Treasury Litig., No. 91-cv-5471 (S.D.N.Y.).
Pomerantz recovered $50 million for the Treasurer of the State of New Jersey and several New Jersey
pension funds in an individual action. This was a substantially higher recovery than what our clients
1 Institutional Shareholder Services, SCAS Top 100 Settlements Quarterly Report (Sept. 30, 2010).
www.pomlaw.com 5
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 8 of 62
would have obtained had they remained in a related federal class action. Treasurer of State of New
Jersey v. AOL Time Warner, Inc. (N.J. Super. Ct. Law Div., Mercer Cty.).
Pomerantz has litigated numerous cases for the Louisiana School Employees’ Retirement System. For
example, as Lead Counsel, Pomerantz recovered $74.75 million in a securities fraud class action against
Citigroup, its CEO Sanford Weill, and its now infamous telecommunications analyst Jack Grubman. In re
Salomon Analyst AT&T Litig., No. 02-cv-6801 (S.D.N.Y.) Also, the Firm played a major role in a complex
antitrust and securities class action which settled for over $1 billion. In re NASDAQ Market-Makers
Antitrust Litig., MDL No. 1023 (S.D.N.Y.). Pomerantz was a member of the Executive Committee in In re
Transkaryotic Therapies, Inc. Securities Litigation, C.A. No. 03-10165 (D. Mass.), helping to win a $50
million settlement for the class.
In 2008, together with Co-Counsel, Pomerantz identified a substantial opportunity for recovery of losses
in Countrywide mortgage-backed securities ("MBS") for three large New Mexico funds (New Mexico
State Investment Council, New Mexico Public Employees' Retirement Association, and New Mexico
Educational Retirement Board), which had been overlooked by all of the firms then in their securities
litigation pool. We then filed the first non-class lawsuit by a public institution with respect to
Countrywide MBS. See N.M. State Inv. Council v. Countrywide Fin. Corp., No. D-0101-CV-2008-02289
(N.M. 1st Dist. Ct.). In Fall 2010, we negotiated for our clients an extremely favorable but confidential
settlement.
Over its long history, Pomerantz has achieved significant settlements in numerous cases, a sampling of
which appears below:
• In re Petrobras Sec. Litig., No. 14-cv-9662 (S.D.N.Y. 2018)
$3 billion settlement of securities class action in which Pomerantz was Lead Counsel.
• Pirnik v. Fiat Chrysler Automobiles N.V. et al., No. 1:15-cv-07199-JMF (S.D.N.Y)
$110 million settlement of securities class action in which Pomerantz was Lead Counsel
• In re Yahoo!, Inc. Sec. Litig., No. 17-cv-00373 (N.D. Cal. 2018)
$80 million settlement of securities class action in which Pomerantz was Co-Lead Counsel
• In re Libor Based Financial Instruments Antitrust Litig., 1:11-md-2262
$31 million partial settlement with three defendants in this multi-district litigation in which
Pomerantz represents the Berkshire Bank and the Government Development Bank for Puerto Rico
• Kaplan v. S.A.C. Capital Advisors, L.P., No. 12-cv-9350 (S.D.N.Y. 2017)
$135 million settlement of class action in which Pomerantz was Co-Lead Counsel.
• In re Groupon, Inc. Sec. Litig., No. 12-cv-02450 (N.D. Ill. 2015)
$45 million settlement of class action in which Pomerantz was sole Lead Counsel.
• In re Elan Corp. Sec. Litig., No. 05-cv-2860 (S.D.N.Y. 2005)
$75 million settlement in class action arising out of alleged accounting manipulations.
• In re Safety-Kleen Corp. Stockholders Litig., No. 00-cv-736-17 (D.S.C. 2004)
$54.5 million in total settlements in class action alleging accounting manipulations by corporate
officials and auditors; last settlement reached on eve of trial.
• Duckworth v. Country Life Ins. Co., No. 1998-CH-01046 (Ill. Cir. Ct., Cook Cty. 2000)
$45 million recovery.
www.pomlaw.com 6
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 9 of 62
• Snyder v. Nationwide Ins. Co., No. 97/0633 (N.Y. Sup. Ct. Onondaga Cty. 1998)
Settlement valued at $100 million in derivative case arising from injuries to consumers purchasing
life insurance policies.
• In re National Health Lab., Inc. Sec. Litig., No. CV 92-1949 (S.D. Cal. 1995)
$64 million recovery.
• In re First Executive Corp. Sec. Litig., No. 89-cv-07135 (C.D. Cal. 1994)
$102 million recovery for the class, exposing a massive securities fraud arising out of the Michael
Milken debacle.
• In re Boardwalk Marketplace Sec. Litig., MDL No. 712 (D. Conn. 1994)
Over $66 million benefit in securities fraud action.
• In re Telerate, Inc. S’holders Litig., C.A. No. 1115 (Del. Ch. 1989)
$95 million benefit in case alleging violation of fiduciary duty under state law.
Pomerantz has also obtained stellar results for private institutions and Taft-Hartley funds. Below are a
few examples:
• In re Charter Commc’ns, Inc. Sec. Litig., No. 02-cv-1186 (E.D. Mo. 2005) (sole Lead Counsel for Lead
Plaintiff StoneRidge Investment Partners LLC); $146.25 million class settlement, where Charter also
agreed to enact substantive improvements in corporate governance.
• In re Am. Italian Pasta Sec. Litig., No. 05-cv-865 (W.D. Mo. 2008) (sole Lead Counsel for Lead Plaintiff
Ironworkers Locals 40, 361 and 417; $28.5 million aggregate settlements).
• Richardson v. Gray, No. 116880/1995 (N.Y. Sup. Ct. N.Y. Cty. 1999); and In re Summit Metals, No. 98-
2870 (Bankr. D. Del. 2004) (two derivative actions where the Firm represented C.C. Partners Ltd. and
obtained judgment of contempt against controlling shareholder for having made “extraordinary”
payments to himself in violation of a preliminary injunction; persuaded the court to jail him for two
years upon his refusal to pay; and, in a related action, won a $43 million judgment after trial and
obtained turnover of stock of two companies).
Shaping the Law
Not only has Pomerantz established a long track record of obtaining substantial monetary recoveries for
our clients; whenever appropriate, we also pursue corporate governance reforms on their behalf. In In re
Chesapeake Shareholders Derivative Litigation, No. CJ-2009-3983 (Okla. Dist. Ct., Okla. Cty. 2011), for
example, the Firm served as Co-Lead Counsel, representing a public pension client in a derivative case
arising from an excessive compensation package granted to Chesapeake’s CEO and founder. This was a
derivative action, not a class action. Yet it is illustrative of the results that can be obtained by an
institutional investor in the corporate governance arena. There we obtained a settlement which called for
the repayment of $12.1 million and other consideration by the CEO. The Wall Street Journal (Nov. 3, 2011)
characterized the settlement as “a rare concession for the 52-year-old executive, who has run the
company largely by his own rules since he co-founded it in 1989.” The settlement also included
comprehensive corporate governance reforms.
The Firm has won many landmark decisions that have enhanced shareholders’ rights and improved
corporate governance. These include decisions that established that:
www.pomlaw.com 7
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 10 of 62
• defendants seeking to rebut the Basic presumption of reliance on an efficient market must do so by a
preponderance of the evidence. Waggoner v. Barclays PLC, 875 F.3d 79 (2d Cir. 2017) (Strougo v.
Barclays PLC, in the court below);
• plaintiffs have no burden to show price impact at the class certification stage. Waggoner v. Barclays
PLC, 875 F.3d 79 (2d Cir. 2017) (Strougo v. Barclays PLC, in the court below);
• the ascertainability doctrine requires only that a class be defined using objective criteria that establish
a membership with definite boundaries. Universities Superannuation Scheme Ltd. v. Petróleo
Brasileiro S.A. Petrobras, 862 F.3d 250 (2d Cir. 2017);
• companies cannot adopt bylaws to regulate the rights of former stockholders. Strougo v. Hollander,
C.A. No. 9770-CB (Del. Ch. 2015);
• a temporary rise in share price above its purchase price in the aftermath of a corrective disclosure
does not eviscerate an investor’s claim for damages. Acticon AG v. China Ne. Petroleum Holdings Ltd.,
692 F.3d 34 (2d Cir. 2012);
• an MBS holder may bring claims if the MBS price declines even if all payments of principal and interest
have been made. Transcript of Proceedings, N.M. State Inv. Council v. Countrywide Fin. Corp., No. D-
0101-CV-2008-02289 (N.M. 1st Dist. Ct. Mar. 25, 2009);
• when a court selects a Lead Plaintiff under the Private Securities Litigation Reform Act (“PSLRA”), the
standard for calculating the “largest financial interest” must take into account sales as well as
purchases. In re Comverse Tech., Inc. Sec. Litig., No. 06-cv-1825, 2007 U.S. Dist. LEXIS 14878 (E.D.N.Y.
Mar. 2, 2007);
• a managing underwriter can owe fiduciary duties of loyalty and care to an issuer in connection with a
public offering of the issuer stock, even in the absence of any contractual agreement. Professor John
C. Coffee, a renowned Columbia University securities law professor, commenting on the ruling, stated:
“It’s going to change the practice of all underwriting.” EBC I, Inc. v. Goldman Sachs & Co., 5 N.Y. 3d 11
(2005);
• purchasers of options have standing to sue under federal securities laws. In re Green Tree Fin. Corp.
Options Litig., No. 97-2679, 2002 U.S. Dist. LEXIS 13986 (D. Minn. July 29, 2002);
• shareholders have a right to a jury trial in derivative actions. Ross v. Bernhard, 396 U.S. 531 (1970);
• a company may have the obligation to disclose to shareholders its Board’s consideration of important
corporate transactions, such as the possibility of a spin-off, even before any final decision has been
made. Kronfeld v. Trans World Airlines, Inc., 832 F.2d 726 (2d Cir. 1987);
• specific standards for assessing whether mutual fund advisors breach fiduciary duties by charging
excessive fees. Gartenberg v. Merrill Lynch Asset Mgmt., Inc., 740 F.2d 190 (2d Cir. 1984);
• investment advisors to mutual funds are fiduciaries who cannot sell their trustee positions for a profit.
Rosenfeld v. Black, 445 F.2d 1337 (2d Cir. 1971); and
• management directors of mutual funds have a duty to make full disclosure to outside directors “in
every area where there was even a possible conflict of interest.” Moses v. Burgin, 445 F.2d 369 (1st
Cir. 1971).
Comments from the Courts
Throughout its history, courts time and again have acknowledged the Firm’s ability to vigorously pursue
and successfully litigate actions on behalf of investors.
U.S. District Judge Noel L. Hillman, in approving the In re Toronto-Dominion Bank Securities Litigation
settlement in October 2019, stated:
www.pomlaw.com 8
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 11 of 62
I commend counsel on both sides for their hard work, their very comprehensive and
thoughtful submissions during the motion practice aspect of this case . . . It’s clear to me
that this was comprehensive, extensive, thoughtful, meaningful litigation leading up to
the settlement . . . This settlement appears to have been obtained through the hard work
of the Pomerantz firm . . . It was through their efforts and not piggybacking on any other
work that resulted in this settlement.
In approving the settlement in Strougo v. Barclays PLC in June 2019, Judge Victor Marrero of the Southern
District of New York wrote:
Let me thank counsel on both sides for the extraordinary work both sides did in bringing
this matter to a reasonable conclusion. As the parties have indicated, the matter was
intensely litigated, but it was done in the most extraordinary fashion with cooperation,
collaboration, and high levels of professionalism on both sides, so I thank you.
In approving the $3 billion settlement in In re Petrobras Securities Litigation in June 2018, Judge Jed S.
Rakoff of the Southern District of New York wrote:
[T]he Court finds that Class Counsel's performance was in many respects exceptional, with
the result that, as noted, the class is poised to enjoy a substantially larger per share
recovery [65%] than the recovery enjoyed by numerous large and sophisticated plaintiffs
who separately settled their claims.
At the hearing for preliminary approval of the settlement in In re Petrobras Securities Litigation in February
2018, Judge Rakoff stated:
[T]he lawyers in this case [are] some of the best lawyers in the United States, if not in the
world.
Two years earlier, in certifying two Classes in In re Petrobras Securities Litigation in February 2016, Judge
Rakoff wrote:
[O]n the basis not only of USS’s counsel’s prior experience but also the Court’s
observation of its advocacy over the many months since it was appointed Lead Counsel,
the Court concludes that Pomerantz, the proposed class counsel, is “qualified,
experienced and able to conduct the litigation.” . . . [T]he Pomerantz firm has both the
skill and resources to represent the Classes adequately.
In approving the settlement in Thorpe v. Walter Investment Management Corp., No. 14-cv-20880, 2016
U.S. Dist. LEXIS 144133 (S.D. Fla. Oct. 14, 2016) Judge Ursula Ungaro wrote:
Class Counsel has developed a reputation for zealous advocacy in securities class actions
. . . The settlement amount of $24 million is an outstanding result.
www.pomlaw.com 9
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 12 of 62
At the May 2015 hearing wherein the court approved the settlement in Courtney v. Avid Technology, Inc.,
No. 13-cv-10686 (D. Mass. May 12, 2015), following oral argument by Jeremy A. Lieberman, Judge William
G. Young stated:
This has been very well litigated. It is always a privilege. I don't just say that as a matter
of form. And I thank you for the vigorous litigation that I've been permitted to be a part
of. [Tr. at 8-9.]
At the January 2012 hearing wherein the court approved the settlement in In re Chesapeake Energy Corp.
Shareholder Derivative Litigation, No. CJ-2009-3983 (Okla. Dist. Ct., Okla. Cty. Jan. 30, 2012), following
oral argument by Marc I. Gross, Judge Daniel L. Owens stated:
Counsel, it’s a pleasure, and I mean this and rarely say it. I think I’ve said it two times in
25 years. It is an extreme pleasure to deal with counsel of such caliber. [Tr. at 48.])
In approving the $225 million settlement in In re Comverse Technology, Inc. Securities Litigation, No. 06-
CV-1825 (E.D.N.Y.) in June 2010, Judge Nicholas G. Garaufis stated:
As outlined above, the recovery in this case is one of the highest ever achieved in this type
of securities action . . . The court also notes that, throughout this litigation, it has been
impressed by Lead Counsel’s acumen and diligence. The briefing has been thorough,
clear, and convincing, and . . . Lead Counsel has not taken short cuts or relaxed its efforts
at any stage of the litigation.
In approving a $146.25 million settlement in In re Charter Communications Securities Litigation, No. 02-
CV-1186, 2005 U.S. Dist. LEXIS 14772 (E.D. Mo. June 30, 2005), in which Pomerantz served as sole Lead
Counsel, Judge Charles A. Shaw praised the Firm’s efforts, citing “the vigor with which Lead Counsel . . .
investigated claims, briefed the motions to dismiss, and negotiated the settlement.” He further stated:
This Court believes Lead Plaintiff achieved an excellent result in a complex action, where
the risk of obtaining a significantly smaller recovery, if any, was substantial.
In approving a $24 million settlement in In re Force Protection, Inc., No. 08 CV 845 (D.S.C. 2011), Judge C.
Weston Houk described the Firm as “attorneys of great ability and great reputation” and commended the
Firm for having “done an excellent job.”
In certifying a class in a securities fraud action against analysts in DeMarco v. Robertson Stephens, Inc.,
228 F.R.D. 468 (S.D.N.Y. 2005), Judge Gerard D. Lynch stated that Pomerantz had “ably and zealously
represented the interests of the class.”
Numerous courts have made similar comments:
x Appointing Pomerantz Lead Counsel in American Italian Pasta Co. Securities Litigation, No 05-CV-0725
(W.D. Mo.), a class action that involved a massive fraud and restatements spanning several years, the
District Court observed that the Firm “has significant experience (and has been extremely effective)
www.pomlaw.com 10
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 13 of 62
litigating securities class actions, employs highly qualified attorneys, and possesses ample resources
to effectively manage the class litigation and protect the class’s interests.”
x In approving the settlement in In re Wiring Devices Antitrust Litigation, MDL No. 331 (E.D.N.Y. Sept.
9, 1980), Chief Judge Jack B. Weinstein stated that “Counsel for the plaintiffs I think did an excellent
job . . . They are outstanding and skillful. The litigation was and is extremely complex. They assumed
a great deal of responsibility. They recovered a very large amount given the possibility of no recovery
here which was in my opinion substantial.”
x In Snyder v. Nationwide Insurance Co., No. 97/0633, (N.Y. Supreme Court, Onondaga Cty.), a case
where Pomerantz served as Co-Lead Counsel, Judge Tormey stated, “It was a pleasure to work with
you. This is a good result. You’ve got some great attorneys working on it.”
x In Steinberg v. Nationwide Mutual Insurance Co. (E.D.N.Y. 2004), Judge Spatt, granting class
certification and appointing the Firm as class counsel, observed: “The Pomerantz firm has a strong
reputation as class counsel and has demonstrated its competence to serve as class counsel in this
motion for class certification.” (224 F.R.D. 67, 766.)
x In Mercury Savings & Loan, No. 90-cv-00087 LHM (C.D. Cal. 1993), Judge McLaughlin commended the
Firm for the “absolutely extraordinary job in this litigation.”
x In Boardwalk Marketplace Securities Litigation, MDL No. 712 (D. Conn.), Judge Eginton described the
Firm’s services as “exemplary,” praised it for its “usual fine job of lawyering . . . [in] an extremely
complex matter,” and concluded that the case was “very well-handled and managed.” (Tr. at 6,
5/20/92; Tr. at 10, 10/10/92.)
x In Nodar v. Weksel, No. 84 Civ. 3870 (S.D.N.Y.), Judge Broderick acknowledged “that the services
rendered [by Pomerantz] were excellent services from the point of view of the class represented,
[and] the result was an excellent result.” (Tr. at 21-22, 12/27/90.)
x In Klein v. A.G. Becker Paribas, Inc., No. 83 Civ. 6456 (S.D.N.Y.), Judge Goettel complimented the Firm
for providing “excellent . . . absolutely top-drawer representation for the class, particularly in light of
the vigorous defense offered by the defense firm.” (Tr. at 22, 3/6/87.)
x In Digital Securities Litigation, No. 83-3255 (D. Mass.), Judge Young lauded the Firm for its “[v]ery fine
lawyering.” (Tr. at 13, 9/18/86.)
x In Shelter Realty Corp. v. Allied Maintenance Corp., 75 F.R.D. 34, 40 (S.D.N.Y. 1977), Judge Frankel,
referring to Pomerantz, said: “Their experience in handling class actions of this nature is known to the
court and certainly puts to rest any doubt that the absent class members will receive the quality of
representation to which they are entitled.”
x In Rauch v. Bilzerian, No. 88 Civ. 15624 (N.J. Sup. Ct.), the court, after trial, referred to Pomerantz
partners as “exceptionally competent counsel,” and as having provided “top drawer, topflight
[representation], certainly as good as I’ve seen in my stay on this court.”
Corporate Governance Litigation
Pomerantz is committed to ensuring that companies adhere to responsible business practices and practice
good corporate citizenship. We strongly support policies and procedures designed to give shareholders
the ability to oversee the activities of a corporation. We vigorously pursue corporate governance reform,
particularly in the area of excess compensation, where it can address the growing disparity between the
salaries of executives and the workers of major corporations. We have successfully utilized litigation to
bring about corporate governance reform in numerous cases, and always consider whether such reforms
are appropriate before any case is settled.
www.pomlaw.com 11
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 14 of 62
Pomerantz’s Corporate Governance Practice Group, led by Partner Gustavo F. Bruckner, enforces
shareholder rights and prosecutes actions challenging corporate transactions that arise from an unfair
process or result in an unfair price for shareholders.
In September 2017, New Jersey Superior Court Judge Julio Mendez, of Cape May County Chancery
Division, approved Pomerantz’s settlement in a litigation against Ocean Shore Holding Co. The settlement
provided non-pecuniary benefits for a non-opt out class. In so doing, Judge Mendez became the first New
Jersey state court judge to formally adopt the Third Circuit’s nine-part Girsh factors, Girsh v. Jepson, 521
F.2d 153 (3d Cir. 1975). There has never before been a published New Jersey state court opinion setting
out the factors a court must consider in evaluating whether a class action settlement should be
determined to be fair and adequate. After conducting an analysis of each of the nine Girsh factors and
holding that “class actions settlements involving non-monetary benefits to the class are subject to more
exacting scrutiny,” Judge Mendez held that the proposed settlement provided a material benefit to the
shareholders.
In February 2018, the Maryland Circuit Court, Montgomery County, approved a $17.5 million settlement
that plaintiffs achieved as additional consideration on behalf of a class of shareholders of American
Capital, Ltd. In re Am. Capital, Ltd. S’holder Litig., C.A. No. 422598-V (2018). The settlement resolved
Plaintiffs’ claims regarding a forced sale of American Capital.
Pomerantz filed an action challenging the sale of American Capital, a Delaware corporation with its
headquarters in Maryland. Among other things, American Capital’s board of directors (the “Board”)
agreed to sell the company at a price below what two other bidders were willing to offer. Worse, the
merger price was even below the amount that shareholders would have received in the company’s
planned phased liquidation, which the company was considering under pressure from Elliott
Management, an activist hedge fund and holder of approximate 15% of American Capital stock. Elliott was
not originally named as a defendant, but after initial discovery showed the extent of its involvement in
the Board’s breaches of fiduciary duty, Elliott was added as a defendant in an amended complaint under
the theory that Elliott exercised actual control over the Board’s decision-making. Elliott moved to dismiss
on jurisdictional grounds and additionally challenged its alleged status as a controller of American Capital.
In June 2017, minutes before the hearing on defendants’ motion to dismiss, a partial settlement was
entered into with the members of the Board for $11.5 million. The motion to dismiss hearing proceeded
despite the partial settlement, but only as to Elliott. In July 2017, the court denied the motion to dismiss,
finding that Elliott, “by virtue solely of its own conduct, . . . has easily satisfied the transacting business
prong of the Maryland long arm statute.” The court also found that the “amended complaint in this case
sufficiently pleads that Elliott was a controller with respect to” the sale, thus implicating a higher standard
of review. Elliott subsequently settled the remaining claims for an additional $6 million. Pomerantz served
as Co-Lead Counsel.
In May 2017, the Circuit Court of the State of Oregon approved the settlement achieved by Pomerantz
and co-counsel of a derivative action brought by two shareholders of Lithia Motors, Inc. The lawsuit
alleged breach of fiduciary duties by the board of directors in approving, without any meaningful review,
the Transition Agreement between Lithia Motors and Sidney DeBoer, its founder, controlling shareholder,
CEO, and Chairman, who was stepping down as CEO. DeBoer and his son, the current CEO, Bryan DeBoer,
negotiated virtually all the material terms of the Agreement, by which the company agreed to pay the
www.pomlaw.com 12
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 15 of 62
senior DeBoer $1,060,000 and a $42,000 car allowance annually for the rest of his life, plus other benefits,
in addition to the $200,000 per year that he would receive for continuing to serve as Chairman.
The Lithia settlement extracted corporate governance therapeutics that provide substantial benefits to
Lithia and its shareholders and redress the wrongdoing alleged by plaintiffs. The board will now be
required to have at least five independent directors—as defined under the New York Stock Exchange
rules—by 2020; a number of other new protocols will be in place to prevent self-dealing by board
members. Further, the settlement calls for the Transition Agreement to be reviewed by an independent
auditor who will determine whether the annual payments of $1,060,000 for life to Sidney DeBoer are
reasonable. Lithia has agreed to accept whatever decision the auditor makes.
In January 2017, the Group received approval of the Delaware Chancery Court for a $5.6 million
settlement it achieved on behalf of a class of shareholders of Physicians Formula Holdings, Inc. over an
ignored merger offer in 2012. In re Physicians Formula Holdings, Inc., C.A. No. 7794-VCL (Del. Ch.).
The Group obtained a landmark ruling in Strougo v. Hollander, C.A. No. 9770-CB (Del. Ch.), that fee-shifting
bylaws adopted after a challenged transaction do not apply to shareholders affected by the transaction.
They were also able to obtain a 25% price increase for members of the class cashed out in the going private
transaction.
In Miller v. Bolduc, No. SUCV 2015-00807 (Mass. Super. Ct.), the Group caused Implant Sciences to hold
its first shareholder annual meeting in five years and put an important compensation grant up for a
shareholder vote.
In Smollar v. Potarazu, C.A. No. 10287-VCN (Del. Ch.), the Group pursued a derivative action to bring about
the appointment of two independent members to the board of directors, retention of an independent
auditor, dissemination of financials to shareholders and the holding of first ever in-person annual meeting,
among other corporate therapeutics.
In Hallandale Beach Police Officers & Firefighters' Personnel Retirement Fund vs. Lululemon athletica, Inc.,
C.A. No. 8522-VCP (Del. Ch.), in an issue of first impression in Delaware, the Chancery Court ordered the
production of the chairman’s 10b5-1 stock trading plan. The court found that a stock trading plan
established by the company's chairman, pursuant to which a broker, rather than the chairman himself,
would liquidate a portion of the chairman's stock in the company, did not preclude potential liability for
insider trading.
In Strougo v. North State Bancorp, No. 15 CVS 14696 (N.C. Super. Ct.), the Group caused the Merger
Agreement to be amended to provide a “majority of the minority” provision for the holders of North State
Bancorp’s common stock in connection with the shareholder vote on the merger. As a result of the Action,
common shareholders could stop the merger if they did not wish it to go forward.
In Re Qurate Retail, Inc. Derivative Litigation, C.A. No. 2021-1116-SG (Del. Ch.): In a significant victory for
stockholders, Pomerantz LLP, as co-counsel, secured a groundbreaking settlement on behalf of Qurate
Retail, Inc., addressing allegations of breaches of fiduciary duty and unjust enrichment involving senior
executives Gregory B. Maffei and Dr. John C. Malone. Plaintiff filed suit on behalf of nominal defendant
Qurate following a series of allegedly sham transactions in 2021 between Maffei and Malone that resulted
www.pomlaw.com 13
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 16 of 62
in the elimination of a call right held by Qurate, for which its predecessor paid $150 million in 1998. The
litigation challenged these transactions, including stock exchanges and executive compensation
agreements, as unfair and detrimental to Qurate’s long-term interests. After defendants moved to dismiss
the case, the Court of Chancery issued rulings allowing claims against Mr. Maffei and Dr. Malone to
proceed. Pomerantz ultimately settled the action in exchange for the reimposition of the call right, an
agreement that Dr. Malone would leave the Qurate Board of Directors, and enhanced independent
oversight at the company.
Pomerantz’s commitment to advancing sound corporate governance principles is further demonstrated
by the more than 26 years that we have co-sponsored the Abraham L. Pomerantz Lecture Series with
Brooklyn Law School. These lectures focus on critical and emerging issues concerning shareholder rights
and corporate governance and bring together top academics and litigators.
Our bi-monthly newsletter, The Pomerantz Monitor, provides institutional investors updates and insights
on current issues in corporate governance.
Strategic Consumer Litigation
Pomerantz’s Strategic Consumer Litigation practice group, led by Partner Jordan Lurie, represents
consumers in actions that seek to recover monetary and injunctive relief on behalf of class members while
also advocating for important consumer rights. The attorneys in this group have successfully prosecuted
claims involving California’s Unfair Competition Law, California’s Consumers Legal Remedies Act, the Song
Beverly Consumer Warranty Act and the Song Beverly Credit Card Act. They have resolved data breach
privacy cases and cases involving unlawful recording, illegal background checks, unfair business practices,
misleading advertising, and other consumer finance related actions. All of these actions also have resulted
in significant changes to defendants’ business practices.
Pomerantz currently represents consumers in a nationwide class action against Facebook for mistargeting
ads. Plaintiff alleges that Facebook programmatically displays a material percentage of ads to users
outside the defined target market and displays ads to “serial Likers” outside the defined target audience
in order to boost Facebook’s revenue. IntegrityMessageBoards.com v. Facebook, Inc. (N.D. Cal.) Case No.
4:18-cv-05286 PJH.
Pomerantz has pioneered litigation to establish claims for public injunctive relief under California’s unfair
business practices statute. For example, Pomerantz has filed cases seeking to prevent major auto
manufacturers from unauthorized access to, and use of, drivers’ vehicle data without compensation, and
seeking to require the auto companies to share diagnostic data extracted from drivers’ vehicles. The
Strategic Consumer Litigation practice group is also prosecuting class cases against auto manufacturers
for failing to properly identify high-priced parts that must be covered in California under extended
emissions warranties.
Other consumer matters handled by Pomerantz’s Strategic Consumer Litigation practice group include
actions involving cryptocurrency, medical billing, price fixing, and false advertising of various consumer
products and services.
www.pomlaw.com 14
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 17 of 62
Antitrust Litigation
Pomerantz has earned a reputation for prosecuting complex antitrust and consumer class actions with
vigor, innovation, and success. Pomerantz’s Antitrust and Consumer Group has recovered billions of
dollars for the Firm’s business and individual clients and the classes that they represent. Time and again,
Pomerantz has protected our free-market system from anticompetitive conduct such as price fixing,
monopolization, exclusive territorial division, pernicious pharmaceutical conduct, and false advertising.
Pomerantz’s advocacy has spanned across diverse product markets, exhibiting the Antitrust and
Consumer Group’s versatility to prosecute class actions on any terrain.
Pomerantz has served and is currently serving in leadership or Co-Leadership roles in several high-profile
multi-district litigation class actions. In December 2018, the Firm achieved a $31 billion partial settlement
with three defendants on behalf of a class of U.S. lending institutions that originated, purchased or held
loans paying interest rates tied to the U.S. Dollar London Interbank Offered Rate (USD LIBOR). It is alleged
that the class suffered damages as a result of collusive manipulation by the LIBOR contributor panel banks
that artificially suppressed the USD LIBOR rate during the class period, causing the class members to
receive lower interest payments than they would have otherwise received. In re Libor Based Financial
Instruments Antitrust Litig., 1:11-md-2262.
Pomerantz represented baseball and hockey fans in a game-changing antitrust class action against Major
League Baseball and the National Hockey League, challenging the exclusive territorial division of live
television broadcasts, internet streaming, and the resulting geographic blackouts. See Laumann v. NHL
and Garber v. MLB (S.D.N.Y. 2012).
Pomerantz has spearheaded the effort to challenge harmful anticompetitive conduct by pharmaceutical
companies—including Pay-for-Delay Agreements—that artificially inflates the price of prescription drugs
by keeping generic versions off the market.
Even prior to the 2013 precedential U.S. Supreme Court decision in Actavis, Pomerantz litigated and
successfully settled the following generic-drug-delay cases:
x In re Flonase Antitrust Litig. (E.D. Pa. 2008) ($35 million);
x In re Toprol XL Antitrust Litig. (D. Del. 2006) ($11 million); and
x In re Wellbutrin SR Antitrust Litig. (E.D. Pa. 2004) ($21.5 million).
Other exemplary victories include Pomerantz’s prominent role in In re NASDAQ Market-Makers Antitrust
Litigation (S.D.N.Y.), which resulted in a settlement in excess of $1 billion for class members, one of the
largest antitrust settlements in history. Pomerantz also played prominent roles in In re Sorbates Direct
Purchaser Antitrust Litigation (N.D. Cal.), which resulted in over an $82 million recovery, and in In re
Methionine Antitrust Litigation (N.D. Cal.), which resulted in a $107 million recovery. These cases illustrate
the resources, expertise, and commitment that Pomerantz’s Antitrust Group devotes to prosecuting some
of the most egregious anticompetitive conduct.
www.pomlaw.com 15
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 18 of 62
A Global Advocate for Asset Managers
and Public and Taft-Hartley Pension Funds
Pomerantz represents some of the largest pension funds, asset managers, and institutional investors
around the globe, monitoring assets of over $9 trillion, and growing. Utilizing cutting-edge legal strategies
and the latest proprietary techniques, Pomerantz protects, expands, and vindicates shareholder rights
through our securities litigation services and portfolio monitoring program.
Pomerantz partners routinely advise foreign and domestic institutional investors on how best to evaluate
losses to their investment portfolios attributable to financial misconduct and how best to maximize their
potential recoveries worldwide. In particular, Pomerantz Partners Jeremy Lieberman and Jennifer Pafiti
regularly travel throughout the U.S. and across the globe to meet with clients on these issues and are
frequent speakers at investor conferences and educational forums in North America, Europe, and the
Middle East.
Pomerantz was honored by European Pensions with its inaugural 2020 Thought Leadership award in
recognition of significant contributions the Firm has made in the European pension environment.
Institutional Investor Services
Pomerantz offers a variety of services to institutional investors. Through the Firm’s proprietary system,
PomTrack, Pomerantz monitors client portfolios to identify and evaluate potential and pending
securities fraud, ERISA and derivative claims, and class action settlements. Monthly customized
PomTrack reports are included with the service. PomTrack currently monitors assets of over $9.4
trillion for some of the most influential institutional investors worldwide.
When a potential securities claim impacting a client is identified, Pomerantz offers to analyze the case’s
merits and provide a written analysis and recommendation. If litigation is warranted, a team of
Pomerantz attorneys will provide efficient and effective legal representation. The experience and
expertise of our attorneys—which have consistently been acknowledged by the courts—allow
Pomerantz to vigorously pursue the claims of investors, taking complex cases to trial when warranted.
Pomerantz is committed to ensuring that companies adhere to responsible business practices and
practice good corporate citizenship. The Firm strongly support policies and procedures designed to give
shareholders the ability to oversee the activities of a corporation. Pomerantz has successfully utilized
litigation to bring about corporate governance reform, and always considers whether such reforms are
appropriate before any case is settled.
Pomerantz provides clients with insightful and timely commentary on matters essential to effective fund
management in our bi-monthly newsletter, The Pomerantz Monitor and regularly sponsors conferences
and roundtable events around the globe with speakers who are experts in securities litigation and
corporate governance matters.
www.pomlaw.com 16
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 19 of 62
Attorneys
Partners
Jeremy A. Lieberman
Jeremy A. Lieberman is Pomerantz’s Managing Partner. He became associated with the Firm in August
2004 and was elevated to Partner in January 2010. The Legal 500, in honoring Jeremy as a Leading Lawyer
and Pomerantz as a 2021 and 2022 Tier 1 Plaintiffs Securities Law Firm, stated that “Jeremy Lieberman is
super impressive—a formidable adversary for any defense firm.” Among the client testimonials posted on
The Legal 500’s website: “Jeremy Lieberman led the case for us with remarkable and unrelenting energy
and aggression. He made a number of excellent strategic decisions which boosted our recovery.”
Lawdragon has named Jeremy among the Leading 500 Plaintiff Financial Lawyers in the United States each
year from 2019 to 2026. Super Lawyers® named him among the Top 100 Lawyers in the New York Metro
area in 2021. In 2020, Jeremy won a Distinguished Leader award from the New York Law Journal. He was
honored as Benchmark Litigation’s 2019 Plaintiff Attorney of the Year. In 2018, Jeremy was honored as a
Titan of the Plaintiffs Bar by Law360 and as a Benchmark Litigation Star. The Pomerantz team that Jeremy
leads was named a 2018 Securities Practice Group of the Year.
Jeremy led the securities class action litigation In re Petrobras Securities Litigation, which arose from a
multi-billion-dollar kickback and bribery scheme involving Brazil’s largest oil company, Petróleo Brasileiro
S.A.–Petrobras, in which Pomerantz was sole Lead Counsel. The biggest instance of corruption in the
history of Brazil ensnared not only Petrobras' former executives but also Brazilian politicians, including
former president Lula da Silva and one-third of the Brazilian Congress. In January and February 2018,
Jeremy achieved a historic $3 billion settlement for the Class. This is not only the largest securities class
action settlement in a decade but is the largest settlement ever in a securities class action involving a
foreign issuer, the fifth-largest securities class action settlement ever achieved in the United States, the
largest securities class action settlement achieved by a foreign Lead Plaintiff, and the largest securities
class action settlement in history not involving a restatement of financial reports.
Jeremy also secured a significant victory for Petrobras investors at the Second Circuit Court of Appeals,
when the court rejected the heightened ascertainability requirement for obtaining class certification that
had been imposed by the Third Circuit Courts of Appeals. The ruling will have a positive impact on plaintiffs
in securities fraud litigation. Indeed, the Petrobras litigation was honored in 2019 as a National Impact
Case by Benchmark Litigation.
Jeremy was Lead Counsel in Pirnik v. Fiat Chrysler Automobiles N.V. et al., No. 1:15-cv-07199-JMF
(S.D.N.Y), in which the Firm achieved a $110 million settlement for the class. Plaintiff alleged that Fiat
Chrysler concealed from investors that it improperly outfitted its diesel vehicles with “defeat device”
software designed to cheat NOx emissions regulations in the U.S. and Europe, and that regulators had
accused Fiat Chrysler of violating the emissions regulations. The Fiat Chrysler recovery provided the class
of investors with as much as 20% of recoverable damages—an excellent result when compared to
historical statistics in class action settlements, where typical recoveries for cases of this size are between
1.6% and 3.3%.
www.pomlaw.com 17
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 20 of 62
In November 2019, Jeremy achieved a critical victory for investors in the securities fraud class action
against Perrigo Co. plc when Judge Arleo of the United States District Court for the District of New Jersey
certified classes of investors that purchased Perrigo securities on both the New York Stock Exchange and
the Tel Aviv Stock Exchange. Pomerantz represents a number of institutional investors that purchased
Perrigo securities on both exchanges after an offer by Mylan N.V. to tender Perrigo shares. This is the first
time since Morrison that a U.S. court has independently analyzed the market of a security traded on a
non-U.S. exchange and found that it met the standards of market efficiency necessary allow for class
certification.
Jeremy headed the Firm’s individual action against pharmaceutical giant Teva Pharmaceutical Industries
Ltd. and Teva Pharmaceuticals USA, Inc. (together, “Teva”), and certain of Teva’s current and former
employees and officers, relating to alleged anticompetitive practices in Teva’s sales of generic drugs. Teva
is a dual-listed company, and the Firm represents several Israeli institutional investors who purchased
Teva shares on the Tel Aviv Stock Exchange. In early 2021, Pomerantz achieved a major victory for global
investors when the district court agreed to exercise supplemental jurisdiction over the Israeli law claims.
Clal Insurance Company Ltd. v. Teva Pharmaceutical Industries Ltd.
In 2019, Jeremy achieved a $27 million settlement for the Class in Strougo v. Barclays PLC, a high-profile
securities class action in which Pomerantz was Lead Counsel. Plaintiffs alleged that Barclays PLC misled
institutional investors about the manipulation of the banking giant’s so-called “dark pool” trading systems
in order to provide a trading advantage to high-frequency traders over its institutional investor clients.
This case turned on the duty of integrity owed by Barclays to its clients. In November 2017, Jeremy
achieved precedent-setting victories for investors, when the Second Circuit Court of Appeals held that
direct evidence of price impact is not always necessary to demonstrate market efficiency to invoke the
presumption of reliance, and that defendants seeking to rebut the presumption of reliance must do so by
a preponderance of the evidence rather than merely meeting a burden of production.
Jeremy led the Firm’s securities class action litigation against Yahoo!, Inc., in which Pomerantz, as Lead
Counsel, achieved an $80 million settlement for the Class in 2018. The case involved the biggest data
breaches in U.S. history, in which over 3 billion Yahoo accounts were compromised. This was the first
significant settlement to date of a securities fraud class action filed in response to a data breach.
In 2018 Jeremy achieved a $3.3 million settlement for the Class in the Firm’s securities class action against
Corinthian Colleges, one of the largest for-profit college systems in the country, for alleged
misrepresentations about its job placement rates, compliance with applicable regulations, and enrollment
statistics. Pomerantz prevailed in the motion to dismiss the proceedings, a particularly noteworthy victory
because Chief Judge George King of the Central District of California had dismissed two prior lawsuits
against Corinthian with similar allegations. Erickson v. Corinthian Colleges, Inc. (C.D. Cal.).
Jeremy led the Firm’s litigation team that in 2018 secured a $31 million partial settlement with three
defendants in In re Libor Based Financial Instruments Antitrust Litigation, a closely watched multi-district
litigation, which concerns the London Interbank Offered Rate (LIBOR) rigging scandal.
In In re China North East Petroleum Corp. Securities Litigation, Jeremy achieved a significant victory for
shareholders in the United States Court of Appeals for the Second Circuit, whereby the Appeals Court
ruled that a temporary rise in share price above its purchase price in the aftermath of a corrective
www.pomlaw.com 18
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 21 of 62
disclosure did not eviscerate an investor’s claim for damages. The Second Circuit’s decision was deemed
“precedential” by the New York Law Journal and provides critical guidance for assessing damages in a §
10(b) action.
Jeremy had an integral role in In re Comverse Technology, Inc. Securities Litigation, in which he and his
partners achieved a historic $225 million settlement on behalf of the Class, which was the second-largest
options backdating settlement to date.
Jeremy regularly consults with Pomerantz’s international institutional clients, including pension funds,
regarding their rights under the U.S. securities laws. Jeremy is working with the Firm’s international clients
to craft a response to the Supreme Court’s ruling in Morrison v. National Australia Bank, Ltd., which limited
the ability of foreign investors to seek redress under the federal securities laws.
Jeremy is a frequent lecturer worldwide regarding current corporate governance and securities litigation
issues.
Jeremy graduated from Fordham University School of Law in 2002. While in law school, he served as a
staff member of the Fordham Urban Law Journal. Upon graduation, he began his career at a major New
York law firm as a litigation associate, where he specialized in complex commercial litigation.
Jeremy is admitted to practice in New York; United States District Courts for the Northern, Southern,
Eastern, and Western Districts of New York, United States District Courts for the Northern and Southern
Districts of Texas, the District of Colorado, the Eastern District of Michigan, the Eastern District of
Wisconsin, and the Northern District of Illinois; United States Courts of Appeals for the First, Second, Third,
Fourth, Fifth, Sixth, Seventh, Ninth, Tenth, Eleventh, and D.C. Circuits; and the United States Supreme
Court.
Gustavo F. Bruckner
Gustavo F. Bruckner heads Pomerantz’s Corporate Governance practice group, which enforces
shareholder rights and prosecutes litigation challenging corporate actions that harm shareholders. Under
Gustavo’s leadership, the Corporate Governance group has achieved numerous noteworthy litigation
successes. He has been quoted on corporate governance issues by The New York Times, The Wall Street
Journal, Bloomberg, Law360, and Reuters, and was honored from 2016 through 2021 by Super Lawyers®
as a “Top-Rated Securities Litigation Attorney,” a recognition bestowed on no more than 5% of eligible
attorneys in the New York Metro area. In 2023 and 2026, he was included on Lawdragon’s list of the 500
Leading Plaintiff Financial Lawyers. Gustavo regularly appears in state and federal courts across the nation.
Gustavo presented at the prestigious Institute for Law and Economic Policy conference.
Gustavo is a fierce advocate of aggressive corporate clawback policies that allow companies to recover
damages from officers and directors for reputational and financial harm. Most recently, in McIntosh vs
Keizer, et al., Docket No. 2018-0386 (Del. Ch.), Pomerantz filed a derivative suit on behalf of Hertz Global
Holdings, Inc. shareholders, seeking to compel the Hertz board of directors to claw back millions of dollars
in unearned and undeserved payments that the Company made to former officers and directors who
significantly damaged Hertz through years of wrongdoing and misconduct. Under pressure from plaintiff’s
ligation efforts, the Hertz board of directors elected to take unprecedented action and mooted plaintiff’s
www.pomlaw.com 19
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 22 of 62
claims, initiating litigation to recover tens of millions of dollars in incentive compensation and more than
$200 million in damages from culpable former Hertz executives.
Pomerantz, through initiation and prosecution of a shareholder derivative action, forced the Hertz board
to seek clawback from former officers and directors of the company, unjustly enriched after causing the
Company to file inaccurate and false financial statements leading to a $235 million restatement and $16
million fee to the SEC.
In September 2017, Gustavo’s Corporate Governance team achieved a settlement in New Jersey Superior
Court that provided non-pecuniary benefits for a non-opt out class. In approving the settlement, Judge
Julio Mendez, of Cape May County Chancery Division, became the first New Jersey state court judge to
formally adopt the Third Circuit’s nine-part Girsh factors, Girsh v. Jepson, 521 F.2d 153 (3d Cir. 1975).
Never before has there been a published New Jersey state court opinion setting out the factors a court
must consider in evaluating whether a class action settlement should be determined to be fair and
adequate.
Gustavo successfully argued Strougo v. Hollander, C.A. No. 9770-CB (Del. Ch. 2015), obtaining a landmark
ruling in Delaware that bylaws adopted after shareholders are cashed out do not apply to shareholders
affected by the transaction. In the process, Gustavo and the Corporate Governance team beat back a fee-
shifting bylaw and were able to obtain a 25% price increase for members of the class cashed out in the
“going private” transaction. Shortly thereafter, the Delaware Legislature adopted legislation to ban fee-
shifting bylaws.
In Stein v. DeBoer (Or. Cir. Ct. 2017), Gustavo and the Corporate Governance group achieved a settlement
that provides significant corporate governance therapeutics on behalf of shareholders of Lithia Motors,
Inc. The company’s board had approved, without meaningful review, the Transition Agreement between
the company and Sidney DeBoer, its founder, controlling shareholder, CEO, and Chairman, who was
stepping down as CEO. DeBoer and his son, the current CEO, negotiated virtually all the material terms of
the Agreement, by which the company agreed to pay the senior DeBoer $1,060,000 and a $42,000 car
allowance annually for the rest of his life, plus other benefits, in addition to the $200,000 per year that he
would receive for continuing to serve as Chairman.
In Miller v. Bolduc, No. SUCV 2015-00807 (Mass. Sup. Ct. 2015), Gustavo and the Corporate Governance
group, by initiating litigation, caused Implant Sciences to hold its first shareholder annual meeting in 5
years and to place an important compensation grant up for a shareholder vote.
In Strougo v. North State Bancorp, No. 15 CVS 14696 (N.C. Super. Ct. 2015), Gustavo and the Corporate
Governance team caused the North State Bancorp merger agreement to be amended to provide a
“majority of the minority” provision for common shareholders in connection with the shareholder vote
on the merger. As a result of the action, common shareholders had the ability to stop the merger if they
did not wish it to go forward.
In Hallandale Beach Police Officers and Firefighters’ Personnel Retirement Fund vs. Lululemon Athletica,
Inc., C.A. No. 8522-VCP (Del. Ch. 2014), in an issue of first impression in Delaware, Gustavo successfully
argued for the production of the company chairman’s Rule 10b5-1 stock trading plan. The court found
that a stock trading plan established by the company's chairman, pursuant to which a broker, rather than
www.pomlaw.com 20
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 23 of 62
the chairman himself, would liquidate a portion of the chairman's stock in the company, did not preclude
potential liability for insider trading.
Gustavo was Co-Lead Counsel in In re Great Wolf Resorts, Inc. Shareholders Litigation, C.A. No. 7328-VCN
(Del. Ch. 2012), obtaining the elimination of stand-still provisions that allowed third parties to bid for
Great Wolf Resorts, Inc., resulting in the emergence of a third-party bidder and approximately $94 million
(57%) in additional merger consideration for Great Wolf shareholders.
In In Re Qurate Retail, Inc. Derivative Litigation, Gustavo secured a groundbreaking settlement on behalf
of Qurate Retail, Inc., addressing allegations of breaches of fiduciary duty and unjust enrichment involving
senior executives Gregory B. Maffei and Dr. John C. Malone. Plaintiff filed suit on behalf of nominal
defendant Qurate following a series of allegedly sham transactions in 2021 between Maffei and Malone
that resulted in the elimination of a call right held by Qurate, for which its predecessor paid $150 million
in 1998. The litigation challenged these transactions, including stock exchanges and executive
compensation agreements, as unfair and detrimental to Qurate’s long-term interests. After defendants
moved to dismiss the case, the Court of Chancery issued rulings allowing claims against Mr. Maffei and
Dr. Malone to proceed. Pomerantz ultimately settled the action in exchange for the reimposition of the
call right, an agreement that Dr. Malone would leave the Qurate Board of Directors, and enhanced
independent oversight at the company.
Gustavo received his law degree in 1992 from the Benjamin N. Cardozo School of Law, where he served
as an editor of the Moot Court Board and on the Student Council. Upon graduation, he received the award
for outstanding student service.
After graduating law school, Gustavo served as Chief-of-Staff to a New York City legislator.
Gustavo is a Mentor and Coach to the NYU Stern School of Business, Berkley Center for Entrepreneurial
Studies, New Venture Competition. He was a University Scholar at NYU where he obtained a B.S. in
Marketing and International Business in 1988 and an MBA in Finance and International Business in 1989.
Gustavo is a Trustee and former Treasurer of the Beit Rabban Day School, and an arbitrator in the Civil
Court of the City of New York.
Gustavo is admitted to practice in New York and New Jersey; the United States District Courts for the
Eastern, Northern, and Southern Districts of New York and the District of New Jersey; the United States
District Court for Connecticut; the Eastern District of Wisconsin; the United States Courts of Appeals for
the Second and Seventh Circuits; and the United States Supreme Court.
Brian Calandra
Brian Calandra joined Pomerantz in June 2019 as Of Counsel and was elevated to Partner in January 2023.
He has extensive experience in securities, antitrust, complex commercial, and white-collar matters in
federal and state courts nationwide. Brian has represented issuers, underwriters, and individuals in
securities class actions involving the financial, telecommunications, real estate, and pharmaceutical
industries. He has also represented financial institutions in antitrust class actions concerning foreign
exchange; supra-national, sub-sovereign and agency bonds; bonds issued by the government of Mexico;
www.pomlaw.com 21
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 24 of 62
and credit card fees. In 2021, Brian was honored as a Super Lawyers® “Top-Rated Securities Litigation
Attorney” and was named to Lawdragon’s 2026 Leading 500 Plaintiff Financial Lawyers.
Brian has written multiple times on developments in securities law and other topics, including co-
authoring an overview of insider trading law and enforcement for Practical Compliance & Risk
Management for the Securities Industry, co-authoring an analysis of anti-corruption compliance risks
posed by sovereign wealth funds for Risk & Compliance, and authoring an analysis of the effects of the
2005 Bankruptcy Abuse Prevention and Consumer Protection Act on women in bankruptcy for
the Women’s Rights Law Reporter.
Before joining Pomerantz, Brian was a litigation associate at Shearman & Sterling LLP. Brian graduated
from Rutgers School of Law-Newark in 2009, cum laude, Order of the Coif. While at Rutgers, Brian was co-
editor-in-chief of the Women’s Rights Law Reporter and received the Justice Henry E. Ackerson Prize for
Distinction in Legal Skills and the Carol Russ Memorial Prize for Distinction in Promoting Women’s Rights.
Brian is admitted to practice in New York; the United States District Courts for the Northern, Southern and
Eastern Districts of New York; the District of New Jersey, and the Eastern District of Wisconsin; the United
States Courts of Appeals for the First, Second, Third, Fifth and Tenth Circuits; and the United States
Supreme Court.
Justin D. D’Aloia
Justin D. D’Aloia is a leading class action attorney who specializes in securities fraud litigation. He has
extensive experience litigating high-profile securities cases in federal and state courts across the country.
Justin has represented issuers, underwriters, and senior executives in matters involving a range of
industries, including the financial services, life sciences, real estate, technology, and consumer retail
sectors. His practice covers the full spectrum of proceedings from pre-suit demand through settlement.
Justin was named to Lawdragon’s 2026 Leading 500 Plaintiff Financial Lawyers.
Justin joined Pomerantz as a Partner in October 2022. Before joining Pomerantz, Justin was counsel at a
large international law firm where he focused on securities litigation and other complex shareholder class
action litigation. He previously served as a law clerk to Judge Mark Falk of the United States District Court
for the District of New Jersey.
Justin received his J.D. from Fordham University School of Law, where he was Editor-in-Chief of the
Fordham International Law Journal. Before entering private practice, he served as a law clerk to Judge
Mark Falk of the United States District Court for the District of New Jersey.
Justin is admitted to practice in New York; United States District Courts for the Southern and Eastern
Districts of New York and the District of Colorado; United States Courts of Appeals for the First, Second,
Third, Fifth, and Tenth Circuits.
Emma Gilmore
Emma Gilmore is a Partner at Pomerantz and is regularly involved in high-profile class-action litigation. In
2024, Benchmark Litigation selected her as “Plaintiff Litigator of the Year.” In 2023, the National Law
www.pomlaw.com 22
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 25 of 62
Journal named her a Plaintiffs’ Attorney Trailblazer and Benchmark Litigation shortlisted her for Plaintiff
Litigator of the Year.
Emma was honored by Law360 in 2023 and in 2018 as an MVP in Securities Litigation, part of an “elite
slate of attorneys [who] have distinguished themselves from their peers by securing hard-earned
successes in high-stakes litigation, complex global matters and record-breaking deals.” Only up to six
attorneys nationwide are selected each year as MVPs in Securities Litigation. In 2018, Emma was the first
woman plaintiff attorney to receive this outstanding award since it was initiated in 2011. In 2021, Emma
was awarded a spot on National Law Journal’s prestigious Elite Women of the Plaintiffs Bar list. In 2021
and 2020, she was named by Benchmark Litigation as one of the Top 250 Women in Litigation—an honor
bestowed on only seven plaintiffs’ lawyers in the U.S. those years. The National Law Journal and the New
York Law Journal honored her as a “Plaintiffs’ Lawyer Trailblazer.” Emma has been honored since 2018 as
a Super Lawyer®. She has been recognized by Lawdragon as one of the top 500 Leading Plaintiff Financial
Lawyers in 2024 and 2026.
Emma is regularly invited to speak about recent trends and developments in securities litigation. She
serves on the New York City Bar Association’s Securities Litigation Committee. Emma regularly counsels
clients around the world on how to maximize recoveries on their investments.
Emma leads the Firm’s high-profile litigation against Koninklijke Philips N.V., arising from the company’s
alleged misrepresentations about its compliance with FDA regulations and about Philips’ business and
specific products, including devices used to treat breathing conditions in millions of people worldwide.
The complaint alleges that, unbeknownst to the market and the device users, but known to Defendants,
the foam in the devices was degrading, allowing foam particles to enter the devices’ air pathway and be
ingested or inhaled. The degrading foam could also off-gas chemicals with carcinogenic effects. As of
September 30, 2023, according to the latest death-related updates from the FDA, there have been 561
reported deaths connected to the devices.
Emma co-leads the Firm’s litigation against Alphabet and Google over alleged misrepresentations
Alphabet’s CEO made in testimony to Congress when it described the workings of Google’s advertising
technology. The complaint alleges that, unbeknownst to investors and contrary to its public
representations, Google enjoyed special advantages over other bidding participants. Google has also been
sued by the U.S. Department of Justice and the Attorneys General of dozens of states for related antitrust
violations.
Emma played a leading role in the Firm’s class action case in the Southern District of New York against
Brazil’s largest oil company, Petrobras, arising from a multi-billion-dollar kickback and bribery scheme, in
which the Firm was sole Lead Counsel. In a significant victory for investors, Pomerantz achieved a historic
$3 billion settlement with Petrobras. This is not only the largest securities class action settlement in a
www.pomlaw.com 23
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 26 of 62
decade but is the largest settlement ever in a class action involving a foreign issuer, the fifth-largest class
action settlement ever achieved in the United States, and the largest settlement achieved by a foreign
lead plaintiff. The biggest instance of corruption in the history of Brazil had ensnared not only Petrobras'
former executives but also Brazilian politicians, including former president Lula da Silva and one-third of
the Brazilian Congress. Emma traveled to Brazil to uncover evidence of fraud and drafted the complaint.
She deposed and defended numerous fact and expert witnesses, including deposing the former CEO of
Petrobras, the whistleblower, and the chief accountant. She drafted the appellate brief, playing an
instrumental role in securing a significant victory for investors in this case at the Second Circuit Court of
Appeals, when the Court rejected the heightened ascertainability requirement for obtaining class
certification that had been imposed by other circuit courts. She opposed defendants' petition for a writ
of certiorari to the Supreme Court. Emma successfully obtained sanctions against a professional objector
challenging the integrity of the settlement, both in the District Court and in the Court of Appeals for the
Second Circuit.
Emma organized a group of twenty-seven of the foremost U.S. scholars in the field of evidence and
spearheaded the effort to submit an amicus brief to the U.S. Supreme Court on their behalf in a critical
issue for investors. One of the two issues before the High Court in Goldman Sachs Group, Inc. et al v.
Arkansas Teachers Retirement System, et al. (No. 20-222) squarely affected investors’ ability to pursue
claims collectively as a class: whether, in order to rebut the presumption of reliance originated by the
Court in the landmark Basic v. Levinson decision, defendants bear the burden of persuasion, or whether
they bear only the much lower burden of production. The scholars argued that defendants carry the higher
burden of persuasion. In a 6-3 decision, the Supreme Court sided with Pomerantz and the scholars.
Emma led the Firm’s class action litigation against Deutsche Bank and its executives, arising from the
Bank’s improper anti-money-laundering and know-your-customer procedures. Plaintiffs alleged that,
despite the Bank’s representations that it implemented a “robust and strict” Know Your Customer
program with “special safeguards” for politically exposed persons (PEPs), defendants repeatedly
exempted high-net-worth individuals and PEPs from any meaningful due diligence, enabling their criminal
activities through the Bank’s facilities. For example, Deutsche Bank continued “business as usual” with
Jeffrey Epstein even after learning that 40 underage girls had come forward with testimony that he had
sexually assaulted them. Deutsche Bank’s former CEOs also onboarded, retained, and serviced Russian
oligarchs and other clients reportedly engaged in criminal activities, with little or no due diligence. On
October 20, 2022, Emma secured for investors nearly 50% of recoverable damages, which reflects a
premium for the palpable misconduct and is exceptionally high for securities class action settlements. The
Deutsche Bank litigation and settlement serve as important legal precedents aimed to deter financial
institutions from enabling the wealthy and powerful to commit crimes in return for financial benefits to
the institutions.
www.pomlaw.com 24
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 27 of 62
Emma played a leading role in Strougo v. Barclays PLC, a high-profile securities class action that alleged
Barclays PLC misled institutional investor clients about the extent of the banking giant’s use of so-called
“dark pool” trading systems. She secured an important precedent-setting opinion from the Second Circuit.
Emma organized a group of leading evidence experts who filed amicus briefs supporting plaintiffs’ position
in the Second Circuit.
Emma secured a unanimous decision by a panel of the Ninth Circuit Court of Appeals, benefiting
defrauded investors in Costa Brava Partnership III LP v. ChinaCast Education Corp. In an issue of first
impression, the Ninth Circuit held that imputation of the CEO's scienter to the company was warranted
vis-a-vis innocent third parties, despite the fact that the executive acted for his own benefit and to the
company's detriment.
She was Lead Counsel in the Firm's class action litigation against Arconic, in which she secured a $74
million settlement for the class. Arconic is the U.S. company that manufactured the highly flammable
aluminum cladding allegedly responsible for the 2017 Grenfell Tower fire in London that eradicated a
public housing block, killing 72 people and injuring 70 other tenants. Arconic repeatedly misrepresented
to the market its safety protocols and the safety classification of its cladding products. When the truth
about Arconic’s unsafe practices emerged, investors lost over $1 billion in damages.
Before joining Pomerantz, Emma was a litigation associate with the firms of Skadden, Arps, Slate, Meagher
and Flom, LLP, and Sullivan & Cromwell, LLP. She worked on the WorldCom Securities Litigation, which
settled for $2 billion.
She also served as a law clerk to the Honorable Thomas C. Platt, former U.S. Chief Judge for the Eastern
District of New York.
Emma graduated cum laude from Brooklyn Law School, where she served as a staff editor for the Brooklyn
Law Review. She was the recipient of two CALI Excellence for the Future Awards, in the subjects of
evidence and discovery. She graduated summa cum laude from Arizona State University, with a BA in
French and a minor in Business.
She serves on the Firm's Anti-Harassment and Discrimination Committee.
Michael Grunfeld
Michael Grunfeld is a Partner at Pomerantz LLP. He has extensive experience in securities, derivative,
complex commercial, and white-collar matters in both federal and state courts nationwide.
He has played a leading role in some of the Firm’s significant class action litigation, including its case
against Yahoo!, Inc. arising out of the biggest data breaches in U.S. history, in which the Firm, as Lead
www.pomlaw.com 25
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 28 of 62
Counsel, achieved an $80 million settlement on behalf of the Class. This settlement made history as the
first substantial shareholder recovery in a securities fraud class action related to a cybersecurity breach.
Michael also plays a leading role in many of the Firm’s other ongoing class actions.
In 2020 and 2022, Michael was included on Benchmark Litigation's 40 & Under Hot List, an honor granted
to a few of the “best and brightest law firm partners [under 40 years old] who stand out in their practices.”
In 2019, Law360 named him a Rising Star. Michael has been ranked by Super Lawyers® as a Top-Rated
Securities Litigation Attorney from 2020 - 2024, and as a New York Metro Rising Star in 2018 and 2019.
He was also named to Lawdragon’s 2026 Leading 500 Plaintiff Financial Lawyers.
Michael also leads Pomerantz’s litigation on behalf of the Colorado Public Employees’ Retirement System
as an intervenor in The Doris Behr 2012 Irrevocable Trust v. Johnson & Johnson. At issue is an activist
investor’s attempt to have Johnson & Johnson (“J&J”) shareholders vote on a proxy proposal instituting a
corporate bylaw that would require all securities fraud claims against the company to be pursued through
mandatory arbitration, and that would waive shareholder’s rights to bring securities
class actions. In March 2022, the district court handed down an important victory for shareholders when
it granted J&J’s and the Intervenors’ Motion to Dismiss the Third Amended Complaint.
Michael co-authored a chapter on damages in securities class actions for the LexisNexis treatise, Litigating
Securities Class Actions.
His earlier career highlights include serving as a clerk for Judge Ronald Gilman of the Sixth Circuit Court of
Appeals and as a foreign law clerk for Justice Asher Grunis of the Israeli Supreme Court. Before joining
Pomerantz, he worked as a litigation associate at Shearman & Sterling LLP and Paul, Weiss, Rifkind,
Wharton & Garrison LLP.
Michael graduated from Columbia Law School in 2008, where he was a Harlan Fiske Stone Scholar. He
graduated from Harvard University with an A.B. in Government, magna cum laude, in 2004.
Michael is admitted to practice in New York; the United States District Courts for the Southern and Eastern
Districts of New York, Eastern District of Michigan, and the District of Colorado; and the United States
Courts of Appeal for the First, Second, Third, Fourth, Sixth, Ninth, and Tenth Circuits.
J. Alexander Hood II
J. Alexander Hood II joined Pomerantz in June 2015 and was elevated to Of Counsel to the Firm in 2019.
He was elevated to Partner in 2022. Alex leads the Firm’s case origination team, identifying and
investigating potential violations of the federal securities laws. In 2023, Alex was selected as a Rising Star
in the National Law Journal’s Elite Trial Lawyers awards competition. This award honors lawyers under 40
who represent the next generation of legal leaders. He has been named a Super Lawyers® Rising Star each
year since 2019 and was named to Lawdragon’s 2026 Leading Financial Plaintiff Lawyers.
Alex played a key role in securing Pomerantz’s appointment as Lead Counsel in actions against Meta
Platforms, Inc., AT&T, Inc., Adobe, Inc., Hawaiian Electric Industries, Inc., Rite Aid Corporation, Yahoo!,
Inc., Fiat Chrysler Automobiles N.V., Wynn Resorts Limited, Perrigo Company plc, among others.
www.pomlaw.com 26
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 29 of 62
Alex also oversees the firm’s involvement on behalf of institutional investors in non-U.S. litigations,
assisting Pomerantz clients with respect to evaluating and pursuing recovery in foreign jurisdictions,
including matters in the Netherlands, Germany, the UK, Australia, Brazil, Denmark, and elsewhere.
Prior to joining Pomerantz, Alex practiced at nationally recognized law firms, where he was involved in
commercial, financial services, corporate governance, and securities matters.
Alex graduated from Boston University School of Law (J.D.) and from the University of Oregon School of
Law (LL.M.). During law school, he served as a member of the Boston University Review of Banking &
Financial Law and participated in the Thomas Tang Moot Court Competition. In addition, Alex clerked for
the American Civil Liberties Union of Tennessee and, as a legal extern, worked on the Center for Biological
Diversity’s Clean Water Act suit against BP in connection with the Deepwater Horizon oil spill.
Alex is admitted to practice in New York; the United States District Courts for the Southern, Eastern,
Western and Northern Districts of New York; the District of Colorado; the Eastern District of Michigan; the
Eastern District of Wisconsin; the Northern District of Illinois; the Northern District of Indiana; the
Southern District of Texas; and the United States Courts of Appeals for the Second Circuit.
Omar Jafri
Omar Jafri is a Partner at Pomerantz. He represents defrauded investors in individual and class action
securities litigation.
Lawdragon named him one of the country’s 500 Leading Plaintiff Financial Lawyers in 2026, and Super
Lawyers® has repeatedly recognized him as a Top-Rated Securities Litigator. Previously, Omar was
recognized by the National Law Journal as a Rising Star of the Plaintiffs’ Bar. The National Law Journal
selected lawyers who “demonstrated repeated success in cutting-edge work on behalf of plaintiffs over
the last 18 months [and] possess a solid track record of client wins over the past three to five years.” He
was also recognized by Super Lawyers® as a Rising Star in Securities Litigation between 2021 and 2023.
Omar has played an integral role in numerous cases where the Firm achieved significant recoveries for
defrauded shareholders as Lead, Co-Lead or Additional Counsel, including: Roofer’s Pension Fund v. Papa
et al. ($97 million recovery); Glazer Capital Management, L.P. et al. v. Forescout Technologies, Inc. et
al. ($45 million recovery); In re Chicago Bridge & Iron Co. N.V. Securities Litigation ($44 million recovery);
In re Juno Therapeutics, Inc. Securities Litigation ($24 million recovery); In re Aveo Pharmaceuticals, Inc.
Securities Litigation ($18 million recovery, which was more than four times larger than the SEC’s fair fund
recovery in its parallel litigation); Sudunagunta v. NantKwest, Inc. ($12 million settlement); Cooper v.
Thoratec Corporation et al. ($11.9 million settlement following a reversal in the United States Court of
Appeals for the Ninth Circuit after the lower court repeatedly dismissed the case); Felipe v. Playstudios,
Inc. et al. ($6.5 million settlement); Thomas v. MagnaChip Semiconductor Corp. Securities Litigation ($6.2
million settlement with majority shareholder, Avenue Capital); Solomon v. Sprint Corporation et al. ($3.75
million settlement); In re Paysign, Inc. Securities Litigation ($3.75 million settlement); Schaeffer v. Nabriva
Therapeutics plc et al. ($3 million settlement); In re Sequans Communications S.A. Securities Litigation
($2.75 million settlement); Torres et al. v. Berry Corporation et al. ($2.5 million settlement); and Busic v.
Orphazyme A/S et al. ($2.5 million settlement).
www.pomlaw.com 27
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 30 of 62
Through vigorous litigation, Omar has helped shape important precedents for all investors. NantKwest
was the first case in the United States to recognize statistical proof of traceability. In Roofer’s Pension
Fund v. Papa et al., the District Court independently analyzed the market of a security traded on a foreign
exchange and found that it met the standards of market efficiency to allow for class certification for the
first time since the U.S. Supreme Court decided Morrison. Nabriva was the first case in the Second Circuit
to sustain a complaint based on the failure to disclose the FDA’s serious criticisms identified in a Form 483
letter. In Yan v. ReWalk Robotics et al., while the United States Court of Appeals for the First Circuit
disagreed on the merits, the Circuit held that it is erroneous to dismiss a case for lack of standing when a
named plaintiff can be substituted with another class member, shutting the door on such defense tactics
in any future case filed in that Circuit. In re Bed Bath & Beyond Corporation Securities Litigation was one
of the first decisions in the country to conclude that the dissemination of a misleading emoji can be an
actionable misrepresentation under the federal securities laws. And in Glazer Capital Management, L.P.
et al. v. Forescout Technologies, Inc. et al., Omar won a rare reversal in a securities fraud class action in
the United States Court of Appeals for the Ninth Circuit. In a published decision that reversed the dismissal
in Forescout, the Ninth Circuit held that lower courts must not comingle the lower standard for falsity with
the higher standard for scienter in analyzing the sufficiency of a securities fraud complaint, and repudiated
numerous arguments concerning the testimony of Confidential Witnesses that the defense bar had
convinced many lower courts to erroneously endorse over the years.
Omar started his legal career at the height of the financial crisis in 2008 and has litigated major disputes
on behalf of institutional investors arising out of the credit crisis, including disputes related to
Collateralized Debt Obligations, Residential Mortgage-Backed Securities, Credit Default Swaps and other
complex financial investments. Omar also represented the Examiner in the Lehman Brothers bankruptcy,
the largest in history at the time, and helped draft a report that identified colorable claims against
Lehman’s senior executives for violating their fiduciary duties. He also has a robust pro bono criminal
defense practice and has represented indigent defendants charged with crimes that range from simple
battery to arson and murder.
Before joining Pomerantz, Omar was a law clerk to Judge William S. Duffey, Jr. of the United States District
Court for the Northern District of Georgia, and an associate at an international law firm where he
represented clients in a wide variety of matters, including securities litigation, complex commercial
litigation, white collar criminal defense, and internal investigations.
Omar is a 2004 honors graduate of the University of Texas at Austin, and a 2008, magna cum laude,
graduate of the University of Illinois College of Law, where he was inducted into the Order of the Coif and
received the Rickert Award for Excellence in Advocacy. He is a fellow of the American Bar Foundation.
Omar is admitted to practice in Illinois; the United States District Courts for the Northern District of Illinois
(Trial Bar) and the Northern District of Indiana; the United States Courts of Appeals for the First, Second,
Fifth, Ninth and D.C. Circuits; and the United States Supreme Court.
Jordan L. Lurie
Jordan L. Lurie joined Pomerantz as a partner in the Los Angeles office in December 2018. Jordan heads
Pomerantz’s Strategic Consumer Litigation practice. He was named a 2021 Southern California Super
Lawyer®, and named to Lawdragon’s 2026 Leading Financial Plaintiff Lawyers.
www.pomlaw.com 28
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 31 of 62
Jordan has litigated shareholder class and derivative actions, complex corporate securities and consumer
litigation, and a wide range of fraud and misrepresentation cases brought under state and federal
consumer protection statutes involving unfair competition, false advertising, and privacy rights. Among
his notable representations, Jordan served as Lead Counsel in the prosecution and successful resolution
of major nationwide class actions against Nissan, Ford, Volkswagen, BMW, Toyota, Chrysler and General
Motors. He also successfully preserved a multi-million dollar nationwide automotive class action
settlement by convincing the then Chief Judge of the Ninth Circuit and his wife, who were also class
members and had filed objections to the settlement, to withdraw their objections and endorse the
settlement.
Jordan has argued cases in the California Court of Appeals and in the Ninth Circuit that resulted in
published opinions establishing class members’ rights to intervene and clarifying the standing
requirements for an objector to appeal. He also established a Ninth Circuit precedent for obtaining
attorneys’ fees in a catalyst fee action. Jordan has tried a federal securities fraud class action to verdict.
He has been a featured speaker at California Mandatory Continuing Legal Education seminars and is a
trained ombudsman and mediator. In 2020, Jordan was recognized as a 2021 Southern California Super
Lawyer.
Outside of his legal practice, Jordan is an active educator and community leader and has held executive
positions in various organizations in the Los Angeles community. Jordan participated in the first Wexner
Heritage Foundation leadership program in Los Angeles and the first national cohort of the Board Member
Institute for Jewish Nonprofits at the Kellogg School of Management.
Prior to joining Pomerantz, Jordan was the Managing Partner of the Los Angeles office of Weiss & Lurie
and Senior Litigator at Capstone Law APC.
Jordan graduated cum laude from Yale University in 1984 with a B.A in Political Science and received his
law degree in 1987 from the University of Southern California Gould School of Law, where he served as
Notes Editor of the University of Southern California Law Review.
Jordan is a member of the State Bar of California and has been admitted to practice before the United
States District Courts for the Northern, Southern, Central and Eastern Districts of California, the Eastern
and Western Districts of Michigan, and the District of Colorado.
Jennifer Pafiti
Jennifer Pafiti became associated with the Firm in April 2014 and was elevated to Partner in December
2015. A dually qualified U.K. solicitor and U.S. attorney, she is the Firm’s Head of Client Services and also
takes an active role in complex securities litigation, representing clients in both class and non-class action
securities litigation.
Jennifer received the Innovative Leader Award in Corporate Counsel’s 2024 Women, Influence, and Power
in Law Awards. She has been recognized with inclusion in the 2024 Lawdragon 500 Global Plaintiff Lawyers
list and the 2024 and 2026 Lawdragon 500 Leading Plaintiff Financial Leaders list. In 2023, Jennifer was
one of only four individuals to be honored with the New York Law Journal’s Innovation Award, which
www.pomlaw.com 29
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 32 of 62
recognizes “creative and inspiring approaches by forward-thinking firms and individuals.” Jennifer was
nominated as a 2023 Lawyer of Distinction. In 2022, The Enterprise World named Jennifer as The Most
Successful Business Leader to Watch. In 2021, Jennifer was selected as one of the “Women, Influence and
Power in Law” honorees by Corporate Counsel, in the Collaborative Leadership—Law Firm category.
Lawdragon has named Jennifer among the Leading 500 Lawyers in the United States every year since
2021. In 2020 she was named a Southern California Rising Star by Super Lawyers® and was recognized by
Benchmark Litigation as a Future Star. Lawdragon has recognized Jennifer as a Leading Plaintiff Financial
Attorney from 2019 through 2021. In 2019, she was also honored by Super Lawyers® as a Southern
California Rising Star in Securities Litigation, named to Benchmark Litigation’s 40 & Under Hot List of the
best young attorneys in the United States, and recognized by Los Angeles Magazine as one of Southern
California’s Top Young Lawyers. In 2018, Jennifer was recognized as a Lawyer of Distinction. She was
honored by Super Lawyers® in 2017 as both a Rising Star and one of the Top Women Attorneys in Southern
California. In 2016, the Daily Journal selected Jennifer for its “Top 40 Under 40” list of the best young
attorneys in California.
Jennifer was an integral member of the Firm’s litigation team for In re Petrobras Securities Litigation, a
case relating to a multi-billion-dollar kickback and bribery scheme at Brazil’s largest oil company, Petróleo
Brasileiro S.A.–Petrobras, in which the Firm was sole Lead Counsel. She helped secure a significant victory
for investors in this case at the Second Circuit Court of Appeals, when the court rejected the heightened
ascertainability requirement for obtaining class certification that had been imposed by other Circuit courts
such as the Third and Sixth Circuit Courts of Appeals. Working closely with Lead Plaintiff, Universities
Superannuation Scheme Limited, she was also instrumental in achieving the historic settlement of $3
billion for Petrobras investors. This is not only the largest securities class action settlement in a decade
but is the largest settlement ever in a securities class action involving a foreign issuer, the fifth-largest
securities class action settlement ever achieved in the United States, the largest securities class action
settlement achieved by a foreign Lead Plaintiff, and the largest securities class action settlement in history
not involving a restatement of financial reports.
Jennifer was involved, among other cases, in the securities class action against rare disease
biopharmaceutical company, KaloBios, and certain of its officers, including CEO Martin Shkreli. In 2018,
Pomerantz achieved a settlement of $3 million plus 300,000 shares for defrauded investors—an excellent
recovery in light of the company’s bankruptcy. Isensee v. KaloBios. Jennifer also helped achieve a $10
million recovery for the class in a securities litigation against the bankrupt Californian energy company,
PG&E, which arose from allegedly false statements made by the company about its rolling power outages
in the wake of the catastrophic wildfire incidents that occurred in California in 2015, 2017, and 2018. Vataj
v. Johnson, et al.
Jennifer earned a Bachelor of Science degree in Psychology at Thames Valley University in England, prior
to studying law. She earned her law degrees at Thames Valley University (G.D.L.) and the Inns of Court
School of Law (L.P.C.) in the U.K.
Before studying law in England, Jennifer was a regulated financial advisor and senior mortgage
underwriter at a major U.K. financial institution. She holds full CeFA and CeMAP qualifications. After
qualifying as a solicitor, Jennifer specialized in private practice civil litigation, which included the
representation of clients in high-profile cases in the Royal Courts of Justice. Prior to joining Pomerantz,
Jennifer was an associate with Robbins Geller Rudman & Dowd LLP in their San Diego office.
www.pomlaw.com 30
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 33 of 62
Jennifer regularly travels throughout the U.S. and Europe to advise clients on how best to evaluate losses
to their investment portfolios attributable to financial fraud or other misconduct, and how best to
maximize their potential recoveries. Jennifer is also a regular speaker at events on securities litigation and
fiduciary duty. In 2022, Thought Leaders 4 Disputes published Jennifer’s article entitled “The Globalisation
of Securities Litigation.”
Jennifer served on the Honorary Steering Committee of Equal Rights Advocates (“ERA”), which focuses on
specific issues that women face in the legal profession. ERA is an organization that protects and expands
economic and educational access and opportunities for women and girls.
Jennifer is a member of the National Association of Pension Fund Attorneys and represents the Firm as a
member of the California Association of Public Retirement Systems, the State Association of County
Retirement Systems, the National Association of State Treasurers, the National Conference of Employee
Retirement Systems, the Texas Association of Public Employee Retirement Systems, and the
U.K.'s National Association of Pension Funds.
Jennifer is admitted to practice in England and Wales; California; the United States District Courts for the
Northern, Central and Southern Districts of California; and the United States Court of Appeals for the Ninth
Circuit.
Joshua B. Silverman
Joshua B. Silverman is a partner in Pomerantz’s Chicago office. He specializes in individual and class action
securities litigation. He was named to the 2026 Lawdragon 500 Leading Financial Plaintiff Lawyers list.
Josh was Lead Counsel in In re Groupon, Inc. Securities Litigation, achieving a $45 million settlement, one
of the highest percentage recoveries in the Seventh Circuit. He was also Lead or Co-Lead Counsel in In re
MannKind Corp. Securities Litigation ($23 million settlement); In re AVEO Pharmaceuticals, Inc. Securities
Litigation ($18 million settlement, more than four times larger than the SEC’s fair fund recovery in parallel
litigation); New Mexico State Investment Council v. Countrywide Financial Corp. (very favorable
confidential settlement); New Mexico State Investment Council v. Cheslock Bakker & Associates (summary
judgment award in excess of $30 million); Sudunagunta v. NantKwest, Inc. ($12 million settlement); Bruce
v. Suntech Power Holdings Corp. ($5 million settlement); In re AgFeed, Inc. Securities Litigation ($7 million
settlement); and In re Hemispherx BioPharma Securities Litigation ($2.75 million settlement). Josh also
played a key role in the Firm's representation of investors before the United States Supreme Court
in StoneRidge, and prosecuted many of the Firm's other class cases, including In re Sealed Air Corp.
Securities Litigation ($20 million settlement).
Josh, together with Managing Partner Jeremy Lieberman, achieved a critical victory for investors in the
securities fraud class action against Perrigo Co. plc when Judge Arleo of the United States District Court
for the District of New Jersey certified classes of investors that purchased Perrigo securities on both the
New York Stock Exchange and the Tel Aviv Stock Exchange. Pomerantz represents a number of
institutional investors that purchased Perrigo securities on both exchanges after an offer by Mylan N.V.
to tender Perrigo shares. This is the first time since Morrison that a U.S. court has independently analyzed
www.pomlaw.com 31
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 34 of 62
the market of a security traded on a non-U.S. exchange and found that it met the standards of market
efficiency necessary allow for class certification.
Several of Josh’s cases have set important precedent. For example, In re MannKind established that
investors may support complaints with expert information. New Mexico v. Countrywide recognized that
investors may show Section 11 damages for asset-backed securities even if there has been no interruption
in payment or threat of default. More recently, NantKwest was the first Section 11 case in the nation to
recognize statistical proof of traceability.
In addition to prosecuting cases, Josh regularly speaks at investor conferences and continuing legal
education programs.
Before joining Pomerantz, Josh practiced at McGuireWoods LLP and its Chicago predecessor, Ross &
Hardies, where he represented one of the largest independent futures commission merchants in
commodities fraud and civil RICO cases. He also spent two years as a securities trader, and continues to
actively trade stocks, futures, and options for his own account.
Josh is a 1993 graduate of the University of Michigan, where he received Phi Beta Kappa honors, and a
1996 graduate of the University of Michigan Law School.
Josh is admitted to practice in Illinois; the United States District Court for the Northern District of Illinois;
the United States Courts of Appeals for the First, Second, Third, Seventh, Eighth and Ninth Circuits; and
the United States Supreme Court.
Brenda Szydlo
Brenda Szydlo joined Pomerantz in January 2016 as Of Counsel and was elevated to Partner in 2022. She
brings to the Firm extensive experience in complex civil litigation in federal and state court on behalf of
plaintiffs and defendants, with a particular focus on securities and financial fraud litigation, litigation
against pharmaceutical corporations, accountants’ liability, and commercial litigation. In 2020-2024,
Brenda was recognized by Super Lawyers® as a “Top-Rated Securities Litigation Attorney.” She was
included on the Lawdragon 500 Leading Plaintiff Financial Lawyers list in 2022–2026 and was named New
York Metro Top Women 2024 for Securities Litigation.
Brenda played a leading role in the Firm’s securities class action case in the Southern District of New York
against Brazil’s largest oil company, Petrobras, arising from a multi-billion-dollar kickback and bribery
scheme, in which the Firm, as sole Lead Counsel, achieved a precedent-setting legal ruling and a historic
$3 billion settlement for the Class. This is not only the largest securities class action settlement in a decade
but is the largest settlement ever in a securities class action involving a foreign issuer, the fifth-largest
securities class action settlement ever achieved in the United States, the largest securities class action
settlement achieved by a foreign Lead Plaintiff, and the largest securities class action settlement in history
not involving a restatement of financial reports.
Brenda has represented investors in additional class and private actions that have resulted in significant
recoveries, such as In re Pfizer, Inc. Securities Litigation, where the recovery was $486 million, and In re
Refco, Inc. Securities Litigation, where the recovery was in excess of $407 million. She has also represented
www.pomlaw.com 32
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 35 of 62
investors in opt-out securities actions, such as investors opting out of In re Bank of America Corp.
Securities, Derivative & ERISA Litigation in order to pursue their own securities action.
Prior to joining Pomerantz, Brenda served as Senior Counsel in a prominent plaintiff advocacy firm, where
she represented clients in securities and financial fraud litigation, and litigation against pharmaceutical
corporations and accounting firms. Brenda also served as Counsel in the litigation department of one of
the largest premier law firms in the world, where her practice focused on defending individuals and
corporations in securities litigation and enforcement, accountants’ liability actions, and commercial
litigation.
Brenda is a graduate of St. John’s University School of Law, where she was a St. Thomas More Scholar and
member of the Law Review. She received a B.A. in economics from Binghamton University.
Brenda is admitted to practice in New York; the United States District Courts for the Southern and Eastern
Districts of New York; the U.S. Courts of Appeals for the Second, Third, and Ninth Circuits; the United
States District Court for the District of Colorado; and the United States Supreme Court.
Matthew L. Tuccillo
A Partner since 2013, Matthew L. Tuccillo joined Pomerantz in 2011. With 26+ years of experience, he is
recognized as a top national securities litigator.
Matt serves as the Firm’s lead litigator on high-stakes securities class action litigation in courts nationwide.
He closely advises institutional clients, which are regularly appointed to serve as lead plaintiffs overseeing
such lawsuits, which often have class-wide damages of $500 million - $1 billion+. Matt’s representative
cases include:
• In In re Emergent Biosolutions, Inc. Securities Litigation, No. 8:21-cv-00955-PWG (D. Md.), arising
from a company’s COVID-19 vaccine manufacturing failures, Matt investigated and prepared a robust
amended complaint, then succeeded in overcoming Defendants’ motion to dismiss in September 2023,
in securing class certification in June 2024, and in leading the case is through discovery. Matt secured a
$40 million class-wide settlement following a mediation and months of ensuring negotiations. The court
granted final approval in February 2025 and distributed in August 2025.
• In Edwards v. McDermott Int’l, Inc., No. 4:18-cv-4330-AB (S.D. Tex.), Matt successfully opposed a
motion to dismiss a class action lawsuit alleging a years-long, multi-prong fraud by an engineering and
construction company that did a risky merger, delayed massive write-downs, and declared bankruptcy.
Matt led the case through discovery. He secured court orders that required defendants to review for
production 1.25 million+ documents identified via plaintiff-authored search terms on plaintiff-selected
custodians. He oversaw review of 450,000+ defense and third party documents and 40 party and non-
party fact depositions. Matt secured an order partially certifying the class in June 2024, which he
successfully defended on Rule 23(f) appeal to the Fifth Circuit, which issued its order in December 2025.
The litigation is ongoing.
www.pomlaw.com 33
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 36 of 62
• In In re Miniso Group Holding Limited Securities Litigation, No. CV-22-5815 (MR Wx) (S.D.N.Y.),
securities class action claims arose from a China-based retail company’s U.S. IPO. A motion to dismiss
the third amended complaint has been fully briefed and is awaiting decision.
• In Chun v. Fluor Corp., et al., No. 3:18-cv-01338-S (N.D. Tex.), Matt served as co-lead counsel in
hard-fought litigation concerning underperforming, large-scale, fixed-bid projects through two motions
to dismiss. A months-long mediation and negotiation process resulted in a court-approved $33 million
settlement, which was a 37.5% recovery of the upheld claim value.
• In Kendall v. Odonate Therapeutics, Inc., et al., No. 3:20-01828-H-LL (S.D. Cal.), Matt successfully
opposed a motion to dismiss a securities lawsuit arising from a pharmaceuticals company’s failure to
advance its lead drug candidate to FDA approval. Notably, the court held that the individual defendants’
scienter (intent) was sufficiently pled, even though they bought, rather than sold, company stock during
the period of alleged fraud. A successful mediation resulted in a court-approved $12.75 million
settlement.
• In In re BP p.l.c. Securities Litigation, No. 4:10-md-2185 (S.D. Tex.), where the court praised the
“uniformly excellent” “quality of lawyering,” Matt spearheaded lawsuits over BP’s Gulf of Mexico oil spill
by 125+ global institutional investors. Over 9 years, he successfully opposed three motions to dismiss,
oversaw e-discovery of 1.75 million documents, led the Plaintiffs Steering Committee, was the sole
interface with BP and the Court, and secured some of the Firm’s most ground-breaking rulings. In a
ruling of first impression, he successfully argued that investors asserted viable English law “holder
claims” for losses due to retention of already-owned shares in reliance on a fraud, a theory barred under
U.S. law since Blue Chip Stamps v. Manor Drug Stores, 421 U.S. 723 (1975). He successfully argued
against forum non conveniens (wrong forum) dismissal of 80+ global institutions’ lawsuits - the first
ruling after Morrison v. Nat’l Australia Bank Ltd., 130 S. Ct. 2869 (2010), to permit foreign investors to
pursue in U.S. court their foreign law claims for losses in a foreign company’s securities traded on a
foreign exchange. He successfully argued that the U.S. Securities Litigation Uniform Standards Act of
1998 (SLUSA), which extinguishes U.S. state law claims in deference to the U.S. federal law, should not
extend to the foreign law claims of U.S. and foreign investors, a ruling that saved those claims from
dismissal where U.S. federal law afforded no remedy after Morrison. In 2021, Matt achieved mediator-
assisted, confidential, favorable monetary settlement for all 35 Firm clients including public and private
pension funds, money management firms, partnerships, and trusts from the U.S., Canada, the U.K.,
France, the Netherlands, and Australia. Notably, seven of these plaintiffs were Matt’s institutional
clients from the U.S., U.K., and Canada.
• In In re Toronto-Dominion Bank Securities Litigation, No. 1:17-cv-01735 (D.N.J.), Matt pled a
multi-year fraud arising at one of Canada’s largest banks, based on extensive statements by former
employees detailing underlying retail banking misconduct. Matt persuaded the court to reject a motion
to dismiss in an order noteworthy because it validated the scienter (intent) pleading despite no witness
speaking directly to the individual defendants’ state of mind. The court approved a $13.25 million class-
wide settlement achieved after mediation.
• In Perez v. Higher One Holdings, Inc., et al., No. 14-cv-00755-AWT (D. Conn.), Matt persuaded
the court, after an initial dismissal, to uphold a second amended complaint asserting five threads of
fraud by an education funding company and its founders and to approve a $7.5 million class-wide
www.pomlaw.com 34
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 37 of 62
settlement. Notably, the court held that the company’s reported financial results violated SEC
Regulation S-K, Item 303, for failure to disclose known trends and impacts from underlying misconduct –
a rare ruling absent an accounting restatement.
• In In re KaloBios Pharmaceuticals, Inc. Securities Litigation, No. 15-cv-05841 (N.D. Cal.), a lawsuit
against a bankrupt drug company and its jailed ex-CEO, Matt negotiated two class-wide settlements
totaling $3.25+ million, including cash payments and stock from the company, that were approved by
the bankruptcy and district courts.
• In In re Silvercorp Metals, Inc. Securities Litigation, No. 1:12-cv-09456 (S.D.N.Y.), Matt worked
with mining, accounting, damages, and market efficiency experts to survive a motion to dismiss by a
Canadian company with mining operations in China and NYSE-traded stock. In approving the $14 million
settlement achieved after two mediations, Judge Rakoff called the case “unusually complex,” given the
technical nature of mining metrics, the need to compare mining standards in Canada, China, and the
U.S., and the volume of Chinese-language evidence.
Matt was also on the multi-firm team that represented commercial real estate investors against the
Empire State Building’s long-term lessees/operators regarding a consolidation, REIT formation, and IPO in
In re Empire State Realty Trust, Inc. Investor Litig., No. 650607/2012 (N.Y. Sup. Ct.), which was resolve for
a $55 million cash/securities settlement fund, a $100 million tax benefit from restructured terms, remedial
disclosures, and deal protections.
Matt regularly counsels institutional investors, foreign and domestic, regarding pending or potential
complex litigation in the U.S. He is skilled at identifying potential securities frauds early, regularly
providing clients with the first opportunity to evaluate and pursue their claims, and he has worked
extensively with outside investment management firms retained by clients to identify a winning set of
supporting evidence. When litigation is filed, he fully oversees its conduct and resolution, counseling
clients throughout every step of the process, while handling all significant motions and courtroom
arguments. These skills have enabled him to sign numerous institutional clients for litigation and portfolio
monitoring services, including public and private pension plans, investment management firms and
sponsored investment vehicles, from both the U.S. and abroad. These clients have spearheaded the Firm’s
litigation efforts in the BP, Fluor, McDermott, Emergent, and Miniso litigations discussed above.
Matt takes great pride in representing union clients. He got his own union card as a teenager (United
Food & Commercial Workers International Union, Local 371), following in the footsteps of his grandfather
(International Brotherhood of Teamsters, Local 560).
Before joining Pomerantz, Matt worked at a large full-service firm then plaintiff-side boutique firms in
Boston and Connecticut, litigating complex business disputes and securities, consumer, and employment
class actions. His pro bono work included securing Social Security benefits for a veteran with non-service-
related disabilities.
Matt graduated from the Georgetown University Law Center in 1999, where he made the Dean’s List. He
graduated from Wesleyan University in 1995, and among his various volunteer activities, he served as
President of the Wesleyan Lawyers Association from 2017-2020.
www.pomlaw.com 35
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 38 of 62
His has been named a Super Lawyers® “Top-Rated Securities Litigation Attorney” (2016-present),
Lawdragon 500 Leading Plaintiff Financial Lawyer (2019-present), Benchmark Litigation Star (2021-2023,
2026), Legal 500 Recommended Securities Litigator (2016, 2021), American Lawyer Top Rated Litigator
(2023) and Northeast Trailblazer (2021), and a Martindale-Hubbell AV® Preeminent™ peer-rated attorney
(2014-present). His advocacy has been covered by Bloomberg, Law360, the Houston Chronicle, the
Hartford Business Journal, and other outlets.
He is a member of the Bars the Supreme Court of the United States; the State of New York; the State of
Connecticut; the Commonwealth of Massachusetts; the Second and Ninth Circuit Courts of Appeals; and
the United States District Courts for the Southern and Eastern District of New York, Connecticut,
Massachusetts, the Northern District of Illinois, the Eastern District of Wisconsin, and the Southern District
of Texas. He is regularly admitted pro hac vice in state and federal courts nationwide.
Austin P. Van
Austin focuses his practice on securities class actions and other high-profile litigations. Austin has
repeatedly been recognized by Lawdragon as one of the top 500 Leading Plaintiff Financial Lawyers, and
has been named as a Recommended Lawyer by The Legal 500. From 2018–2024, Austin has been honored
as a Super Lawyers® Rising Star. In 2020, Austin was named an MVP in Securities Litigation by Law360, as
part of an “elite slate of attorneys [who] have distinguished themselves from their peers by securing hard-
earned successes in high-stakes litigation, complex global matters and record-breaking deals.” Only up to
six attorneys nationwide are selected each year as MVPs in Securities Litigation. Austin was named to
Benchmark Litigation’s “40 and Under Hotlist” in 2020 and 2021.
Austin represents clients in some of the largest class actions in the country:
x Currently represents institutional investor lead plaintiffs in a shareholder securities class action
against social media and technology behemoth Meta Platforms, Inc. The complaint alleges that Meta
misrepresented the impact of privacy changes in Apple’s iOS operating system on Meta’s core
advertising business. Seeks to recover damages amounting to hundreds of billions of dollars on behalf
of global investors resulting from the 26% drop in Meta’s share price following the revelation of the
true impact of these privacy changes—in absolute terms, the largest one-day drop of a publicly traded
company in U.S. history. (N.D. Cal. 2024)
x Currently represents plaintiffs in a putative nationwide consumer class action against Apple, Inc.,
maker of the iPhone and other technology products. The complaint alleges that Apple violated federal
and state computer intrusion statutes and state consumer protection laws by tricking iPhone users to
install updates to their older iPhone devices that effectively crippled them. Successfully argued and
defeated defendants ’motion to dismiss before District Judge Casey Pitts. (N.D. Cal. 2024)
x Currently represents lead plaintiffs in a securities class action against Hawaiian Electric Company
and its officers. The complaint alleges that Hawaiian Electric misrepresented the actions it was taking
to mitigate wildfire risk, and so concealed the extent of the unmitigated risk of wildfire from investors,
who suffered billions of dollars in losses when this risk materialized in the 2023 Maui wildfire disaster
in Lahaina. (N.D. Cal. 2023)
x Currently represents lead plaintiffs in a securities class action against GSX Techedu, n/k/a Gaotu
Techedu, a Chinese online education company. Complaint alleges that GSX falsified half of its student
www.pomlaw.com 36
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 39 of 62
enrollment and revenues and caused investors billions of dollars in losses when the truth became
known. Successfully defeated defendants ’motion to dismiss. (D.N.J. 2023)
x Represented institutional investor as lead plaintiff in a securities class action against ATI Physical
Therapy and its SPAC acquirer. The complaint alleged that ATI misrepresented that its attrition rate
was low, when in fact the rate was twice the industry average. Successfully defeated defendants ’
motion to dismiss and proceeded to discovery on all claims under Section 10(b), Section 14 and
Section 20(a) of the Exchange Act to proceed. Settled for $24.9 million. (N.D. Ill. 2023)
x Represented lead plaintiffs in a securities class action against Citrix Systems, Inc. The complaint
alleged that defendants violated Section 14 of the Exchange Act by soliciting votes to approve the sale
of Citrix based on a proxy that concealed from shareholders accelerating SaaS ARR, a key business
trend, so Citrix paid shareholders less for their shares than was fair. Successfully argued and defeated
defendants ’motion to dismiss before District Judge Rodolfo Ruiz. Settled case on favorable terms for
$17.5 million. (S.D. Fl. 2024)
x Represented certified class in a securities class action against TechnipFMC, a Fortune 500 oil and gas
services company. Plaintiffs alleged TechnipFMC overstated its net income in its initial registration
statement due to its use of incorrect foreign exchange rates. Successfully argued and defeated
defendants ’motion to dismiss, argued and won lead plaintiffs’ motion for class certification, and
argued and defeated defendants ’motion for summary judgment, all before District Judge Alfred
Bennett. Led the class through complete preparations for trial. The case settled for approximately
$20 million. (S.D. Tex. 2020)
x Represented lead plaintiffs in a securities class action against electric vehicle manufacturer Faraday
Future Intelligent Electric, Inc. and its SPAC acquirer, Property Solutions Acquisition Corp. The
complaint alleged that defendants violated Sections 10(b) and 14(a) of the Exchange Act and Section
11 of the Securities Act by misrepresenting the level of committed reservations Faraday had for its
flagship car in SEC filings, including in a proxy statement for the de-SPAC acquisition of Faraday.
Successfully argued and defeated defendants ’motion to dismiss before District Judge Christina Snyder
and defeated defendants’ motion for reconsideration. Settled case on favorable terms for $7.5
million. (C.D. Cal. 2021)
x Represented lead plaintiffs in a securities class action against Rockwell Medical, Inc. Based on the
strength of the complaint, at a pre-motion conference for defendants ’motion to dismiss, District
Senior Judge Allyn R. Ross stated that“ based on what I have reviewed, it is virtually inconceivable to
me that the consolidated amended complaint could possibly be dismissed on a Rule 12(b)(6) motion
or a Rule 9(b) motion” and that any proposed motion to dismiss “would be a complete waste of time
and resources of counsel, of the clients ’money, and my time.” Defendants declined even to move to
dismiss the complaint and settled the case $3.7 million—a highly favorable settlement for the class.
(E.D.N.Y. 2019)
x Represented lead plaintiffs in a securities class action against Franklin Wireless Inc., a maker of
wireless routers and communications devices. Based on the strength of the complaint, defendants
declined to move to dismiss. Successfully obtained class certification and settled the matter on terms
highly favorable for the class for $2.4 million. (S.D. Cal. 2021)
Austin received a J.D. from Yale Law School, where he was an editor of the Yale Law Journal and the Yale
Journal of International Law. He has a B.A. from Yale University and an M.Sc. from the London School of
Economics. Prior to joining Pomerantz, Austin worked as an associate at Cravath, Swaine & Moore LLP.
www.pomlaw.com 37
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 40 of 62
Austin is admitted to practice law in New York and New Jersey, the United States District Courts for the
Southern and Eastern Districts of New York, the District of New Jersey, the Northern District of Illinois, the
Southern District of Texas, the United States Courts of Appeals for the First, Second, Seventh and Ninth
Circuits, and the United States Supreme Court.
Murielle Steven Walsh
Murielle Steven Walsh joined the Firm in 1998 and was elevated to Partner in 2007. In 2024 Murielle was
named a Titan of the Plaintiffs Bar by Law360, and in 2022 she was selected to participate on the
publication’s Securities Editorial Board. She was named a 2020 Plaintiffs’ Lawyer Trailblazer by the
National Law Journal, an award created to “honor a handful of individuals from each practice area that
are truly agents of change” and was also honored as a 2020 Plaintiffs’ Trailblazer by the New York Law
Journal. Murielle was honored in 2019, 2020 and 2021 as a Super Lawyers® “Top-Rated Securities
Litigation Attorney,” a recognition bestowed on 5% of eligible attorneys in the New York Metro
area. Lawdragon has recognized Murielle among the 500 Leading Financial Plaintiff Lawyers every year
since 2019.
During her career at Pomerantz, Murielle has prosecuted highly successful securities class action and
corporate governance cases. She was one of the lead attorneys litigating In re Livent Noteholders’
Securities Litigation, a securities class action in which she obtained a $36 million judgment against the
company’s top officers, a ruling which was upheld by the Second Circuit on appeal. Murielle was also part
of the team litigating EBC I v. Goldman Sachs, where the Firm obtained a landmark ruling from the New
York Court of Appeals, that underwriters may owe fiduciary duties to their issuer clients in the context of
a firm-commitment underwriting of an initial public offering.
Murielle led Firm's high-profile securities class action against Wynn Resorts Ltd., where the Firm served
as lead counsel. The litigation stemmed from the company’s alleged cover-up of a prolonged pattern of
sexual misconduct by its founder and former CEO, billionaire casino mogul Stephen Wynn. In January
2025, Murielle secured final approval of a $70 million settlement on behalf of defrauded investors. Wynn
is widely regarded as the first high-profile executive whose misconduct was exposed by the #MeToo
movement. Ferris v. Wynn Resorts Ltd., No. 18-cv-479 (D. Nev.)
In a securities class action against Ormat Technologies, Inc., Murielle achieved a $3.75 million settlement
on behalf of defrauded investors in January 2021. Ormat’s securities are dual-listed on the NYSE and the
Tel Aviv Stock Exchange. Murielle persuaded the district court in exercise supplemental jurisdiction in
order to apply U.S. securities law to the claims in the case, regardless of where investors purchased their
securities.
Murielle led the Firm’s ground-breaking litigation that arose from the popular Pokémon Go game, in which
Pomerantz was lead counsel. Pokémon Go is an “augmented reality” game in which players use their
smart phones to “catch” Pokémon in real-world surroundings. GPS coordinates provided by defendants
to gamers included directing the public to private property without the owners’ permission, amounting
to an alleged mass nuisance. In re Pokémon Go Nuisance, No. 3:16-cv-04300 (N.D. Cal.)
Murielle was co-lead counsel in Thorpe v. Walter Investment Management Corp., No. 14-cv-20880 (S.D.
Fla.), a securities fraud class action challenging the defendants’ representations that their lending
www.pomlaw.com 38
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 41 of 62
activities were regulatory-compliant, when in fact the company’s key subsidiary engaged in rampant
violations of federal consumer financial protection laws, subjecting it to various government
investigations and enforcement action by the CFPB and FTC. In 2016, the Firm obtained a $24 million
settlement on behalf of the class. She was also co-lead counsel in Robb v. Fitbit, Inc., No. 16-cv-00151
(N.D. Cal.), a securities class action alleging that the defendants misrepresented that their key product
delivered “highly accurate” heart rate readings when in fact their technology did not consistently deliver
accurate readings during exercise and its inaccuracy posed serious health risks to users of Fitbit’s products.
The Firm obtained a $33 million settlement on behalf of the investor class in this action.
In 2018 Murielle, along with then-Senior Partner Jeremy Lieberman, achieved a $3.3 million settlement
for the Class in the Firm’s case against Corinthian Colleges, one of the largest for-profit college systems in
the country, for alleged misrepresentations about its job placement rates, compliance with applicable
regulations, and enrollment statistics. Pomerantz prevailed in the motion to dismiss the proceedings, a
particularly noteworthy victory because Chief Judge George King of the Central District of California had
dismissed two prior lawsuits against Corinthian with similar allegations. Erickson v. Corinthian Colleges,
Inc., No. 2:13-cv-07466 (C.D. Cal.).
Murielle serves as a member and on the Executive Committee of the Board of Trustees of the non-profit
organization Court Appointed Special Advocates for Children (“CASA”) of Monmouth County. She also
served on the Honorary Steering Committee of Equal Rights Advocates (“ERA”), which focuses on and
discusses specific issues that women face in the legal profession. ERA is an organization that protects and
expands economic and educational access and opportunities for women and girls. In the past, Murielle
served as a member of the editorial board for Class Action Reports, a Solicitor for the Legal Aid Associates
Campaign, and has been involved in political asylum work with the Association of the Bar of the City of
New York.
Murielle serves on the Firm's Anti-Harassment and Discrimination Committee.
Murielle graduated cum laude from New York Law School in 1996, where she was the recipient of the
Irving Mariash Scholarship. During law school, Murielle interned with the Kings County District Attorney
and worked within the mergers and acquisitions group of Sullivan & Cromwell.
Murielle is admitted to practice in New York; United States District Court for the Southern District of New
York; United States Courts of Appeals for the Second, Sixth, and Ninth Circuits
Tamar A. Weinrib
Tamar A. Weinrib joined Pomerantz in 2008. She was Of Counsel to the Firm from 2014 through 2018 and
was elevated to Partner in 2019. In 2020, The Legal 500 honored her as a Next Generation Partner. Tamar
was named a 2018 Rising Star under 40 years of age by Law360, a prestigious honor awarded to a select
few “top litigators and dealmakers practicing at a level usually seen from veteran attorneys.” Tamar has
been recognized by Super Lawyers® as a 2021 “Top-Rated Securities Litigation Attorney;” she was honored
as a New York Metro Rising Star every year from 2014 to 2019. She was also named to the 2026 Lawdragon
500 Leading Financial Plaintiff Lawyers list.
www.pomlaw.com 39
Case 1:26-cv-24485-RKA Document 39-6 Entered on FLSD Docket 08/28/2026 Page 42 of 62
In 2019, Tamar and Managing Partner Jeremy Lieberman achieved a $27 million settlement for the Class
in Strougo v. Barclays PLC, a high-profile securities class action in which Pomerantz was Lead Counsel.
Plaintiffs alleged that Barclays PLC misled institutional investor clients about the extent of the banking
giant’s use ofShowing the first 150,000 of 221,350 characters. Full text.
