UNTED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

MINNEAPOLIS FIREFIGHTERS’ RELIEF 

ASSOCIATION, on behalf of itself and all others 

similarly situated, 

 Plaintiff, 

 vs. 

BRISTOL-MYERS SQUIBB COMPANY, 

PETER R. DOLAN, and ANDREW R.J. 

BONFIELD, 

 Defendants. 

Case No. 07-CV-5867 (PAC) 

ELECTRONICALLY FILED

JEAN LAI, Individually and On behalf of All 

Others Similarly Situated, 

 Plaintiff, 

 vs. 

BRISTOL-MYERS SQUIBB COMPANY, 

PETER R. DOLAN and ANDREW R. J. 

BONFIELD, 

 Defendants.

Case No. 07-CV-6259 (PAC) 

NOTICE OF MOTION OF ONTARIO TEACHERS’ PENSION PLAN BOARD 

FOR (1) APPOINTMENT AS LEAD PLAINTIFF; (2) APPROVAL OF ITS 

SELECTION OF COUNSEL AS LEAD COUNSEL FOR THE CLASS; AND (3) 

CONSOLIDATION OF ALL RELATED ACTIONS 

Case 1:07-cv-05867-PAC Document 10 Filed 08/27/2007 Page 1 of 3
PLEASE TAKE NOTICE that on a date and time as may be set by the Court, 

before the Honorable Paul A. Crotty, at the United States District Court for the Southern 

District of New York, located at the Daniel Patrick Moynihan United States Courthouse, 

500 Pearl Street, Courtroom 20C, New York, New York 10007-1312, the Ontario 

Teachers’ Pension Plan Board (“Ontario Teachers”) will respectfully move this Court, 

pursuant to Section 21D(a)(3)(B) of the Securities Exchange Act of 1934 (the “Exchange 

Act”), 15 U.S.C. § 78u-4(a)(3)(B), as amended by the Private Securities Litigaiton 

Reform Act of 1995 (the “PSLRA”), for entry of an Order appointing Ontario Teachers 

as Lead Plaintiff in the above-captioned actions, approving its selection of Bernstein 

Litowitz Berger & Grossmann LLP as Lead Counsel for the Class, and consolidating all 

related actions herewith under Rule 42(a) of the Federal Rules of Civil Procedure. 

Ontario Teachers believes that it has the largest financial interest in the relief 

sought by the Class and, thus, should be appointed Lead Plaintiff. Ontario Teachers 

purchased 1,350,800 shares of Bristol-Myers Squibb Co. common stock during the period 

from March 22, 2006 through August 8, 2006 (the “Class Period”). Ontario Teachers has 

suffered losses, based on either a FIFO (“first in, first out”) or a LIFO calculation, of 

approximately $1.7 million. 

The appointment of Ontario Teachers as Lead Plaintiff would advance the 

primary goal of the PSLRA’s lead plaintiff provisions to encourage institutional investors 

with large financial stakes in the outcome of the litigation to assume control over 

securities class actions. In addition, Ontario Teachers meets the requirements of Rule 23 

of the Federal Rules of Civil Procedure because its claims are typical of other Class 

Case 1:07-cv-05867-PAC Document 10 Filed 08/27/2007 Page 2 of 3
2

members’ claims and because it will fairly and adequately represent the interests of the 

Class. 

This Motion is supported by the accompanying Memorandum of Law in support 

thereof, the Declaration of Gerald H. Silk filed herewith, the pleadings and other files, 

and such other written or oral argument as may be permitted by the Court. 

For the forgoing reasons, Ontario Teachers respectfully requests that the Court (i) 

appoint Ontario Teachers as Lead Plaintiff pursuant to the PSLRA; (ii) approve Ontario 

Teachers’ selection of Bernstein Litowitz Berger & Grossmann LLP as Lead Counsel for 

the Class; (iii) consolidate all related actions; and (iv) grant such other and further relief 

as the Court may deem just and proper. 

Dated: August 27, 2007 Respectfully submitted, 

BERNSTEIN LITOWITZ BERGER & 

GROSSMANN LLP 

/s/ Gerald H. Silk 

Gerald H. Silk (GS-4565) 

Salvatore J. Graziano (SG-6854) 

Noam Mandel (NM-0203) 

1285 Avenue of the Americas, 38th Floor 

New York, NY 10019 

(212) 554-1400 

Counsel for Ontario Teachers’ Pension Plan 

Board and Proposed Lead Counsel for the 

Class 

Case 1:07-cv-05867-PAC Document 10 Filed 08/27/2007 Page 3 of 3