UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

 

ROBERT J. MEYER, Individually and On Behalf 

of All Others Similarly Situated, 

Plaintiff, 

 vs. 

THE ST. JOE COMPANY, WILLIAM BRITTON 

GREENE, WILLIAM S. MCCALMONT, PETER 

S. RUMMELL, JANNA L. CONNOLLY, 

MICHAEL L. AINSLIE, HUGH M. DURDEN, 

THOMAS A. FANNING, HARRY H. 

FRAMPTON, III, ADAM W. HERBERT, JR., 

DELORES M. KESLER, JOHN S. LORD, 

WALTER L. REVELL, WILLIAM H. WALTON, 

III, DEUTSCHE BANK SECURITIES INC. and 

KPMG LLP, 

Defendants. 

__________________________________________

STEVEN L. WEISSMAN, Individually and On 

Behalf of All Others Similarly Situated, 

Plaintiff, 

vs. 

THE ST. JOE COMPANY, WILLIAM BRITTON 

GREENE, WILLIAM S. MCCALMONT, PETER 

S. RUMMELL and JANNA L. CONNOLLY, 

Defendants. 

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CASE NO. 3:10-cv-00452/RS-EMT 

CASE NO. 3:10-cv-00504/MCR-MD 

MOTION OF GERALD L. HESS AND RICHARD L. KNEISEL 

FOR CONSOLIDATION OF ALL RELATED ACTIONS, 

APPOINTMENT AS LEAD PLAINTIFF, AND APPROVAL OF THEIR 

SELECTION OF CO-LEAD AND CO-LIAISON COUNSEL AND 

MEMORANDUM OF LAW IN SUPPORT THEREOF

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Gerald L. Hess (“Hess”) and Richard L. Kneisel (“Kneisel”) (collectively, “Hess and 

Kneisel” or “Movants”) respectfully move this Court pursuant to the Private Securities 

Litigation Reform Act of 1995 (“PSLRA” or the “Act”), 15 U.S.C. § 78u-4(a)(3)(B) and 15 

U.S.C. § 77z-1(a)(3)(B),1

 for an Order: (i) consolidating all Related Actions; (ii) appointing 

Hess and Kneisel as Lead Plaintiff; (iii) approving their selection of the law firms of 

Barroway Topaz Kessler Meltzer & Check, LLP (“Barroway Topaz”) and Pomerantz 

Haudek Grossman & Gross LLP (“Pomerantz”) to serve as Co-Lead Counsel; (iv) approving 

their selection of Kurkin Forehand Brandes LLP (“Kurkin Forehand Brandes”) and Shepherd 

Finkelman Miller & Shah LLP (“Shepherd Finkelman”) as Co-Liaison Counsel; and 

(v) granting such other and further relief as the Court may deem just and proper. 

I. PRELIMINARY STATEMENT 

Currently pending in this district are two securities class actions brought on behalf of 

all persons who purchased the common stock of The St. Joe Company (“St. Joe” or the 

“Company”) between February 19, 2008 and October 12, 2010 (the “Class Period”). The 

actions allege violations under §§ 10(b) and 20(a) of the Exchange Act (15 U.S.C. §§ 78j(b) 

and 78t(a)), and Securities and Exchange Commission (“SEC”) Rule 10b-5 (17 C.F.R. § 

240.10b-5). The first filed action, Meyer v. The St. Joe Co., et al.,

2

 also alleges violations of 

§§ 11, 12(a)(2), and 15 of the Securities Act (15 U.S.C. §§ 77k, 77l(a)(2), and 77o) on behalf 

 

1 The lead plaintiff provisions of the Securities Act of 1933 (the “Securities Act”) and 

Securities Exchange Act of 1934 (the “Exchange Act”), as amended by the PSLRA, are 

identical. See 15 U.S.C. §77z-1; 15 U.S.C. §78u-4. To avoid duplicative citation, only the 

lead plaintiff provisions of the Exchange Act are cited herein.

2

 Case No. 3:10-cv-00452/RS-EMT, (N.D. Fla. Filed Nov. 3, 2010). 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 2 of 16
2 

of all persons who purchased or otherwise acquired St. Joe common stock pursuant to or 

traceable to the Company’s February 27, 2008 common stock offering. Both actions are 

based on common misrepresentations and involve common issues of law and fact. As such, 

the actions are ideally suited to be consolidated. See Fed. R. Civ. P. 42(a) (“Rule 42(a)”); 

Section III.A., infra. 

Once the actions are consolidated, Hess and Kneisel believe that they should be 

selected as lead plaintiff. The PSLRA sets forth the criteria for selecting a lead plaintiff in 

securities class action lawsuits like the matter at bar. Pursuant to the PSLRA, the Court is to 

“appoint as lead plaintiff the member or members of the purported plaintiff class that the 

court determines to be most capable of adequately representing the interests of class 

members.” 15 U.S.C. §78u-4(a)(3)(B)(i). 

As detailed in the Certifications submitted herewith, during the Class Period, 

Movants suffered losses exceeding $23,598 from their Class Period purchases of St. Joe’s 

securities. See Declaration of John W. Forehand in Support of Motion of Gerald L. Hess and 

Richard L. Kneisel for Consolidation of All Related Actions, Appointment as Lead Plaintiff, 

and Approval of Their Selection of Co-Lead and Co-Liaison Counsel (“Forehand Decl.”), 

Ex. B, C & D. In addition to evidencing Movants’ significant stake in the outcome of this 

litigation, Movants’ Certifications demonstrate their desire to serve as lead plaintiff in this 

action, as well as their understanding of the attendant duties and obligations of serving in 

that role. See Forehand Decl., Ex. B & C. 

 

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Movants believe that their financial interest in this action is the largest of any 

qualified class member seeking appointment as lead plaintiff in this action. Movants are not 

aware of any other class members filing a complaint or an application for appointment as 

lead plaintiff asserting greater losses due to Defendants’ fraud. In addition, Movants satisfy 

the applicable requirements of Rule 23 of the Federal Rules of Civil Procedure (“Rule 23”). 

Thus, pursuant to the PSLRA’s lead plaintiff provision, Movants are presumptively the most 

adequate plaintiffs and should be appointed Lead Plaintiff for the class. 

II. FACTUAL BACKGROUND 

Defendant St. Joe is a real estate development company that is engaged in town, 

resort, commercial, and industrial development, rural land sales, and timber and forestry 

services. As of December 31, 2009, the Company owned approximately 577,000 acres of 

land, primarily in Northwest Florida. St. Joe is incorporated in Florida and recently 

relocated its headquarters to WaterSound, Florida. The Company was founded in 1936 and 

originally operated as St. Joe Paper Company. As explained below, throughout the Class 

Period, St. Joe and its officers misled investors about the value of the Company’s assets. 

The Class Period begins on February 19, 2008 to coincide with St. Joe announcing its 

fourth quarter and full year 2007 financial results. In this release, the Company announced 

that St. Joe had $943.5 million in real estate investments as of December 31, 2007. St. Joe’s 

2007 Annual Report—filed with the SEC on February 25, 2008—included a detailed 

schedule which provided investors with capitalization and carrying costs for the Company’s 

real estate holdings. The 2007 Annual Report also assured investors that St. Joe’s valuations 

properly reflected actual values. According to the Company, if “homes held in inventory 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 4 of 16
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and other project land were to fall below the book value of these assets,” St. Joe would take 

“write-downs of the book value of these assets” and that any “such write-downs would 

decrease the value of these assets on our balance sheet and would reduce our net income.” 

Despite the Company’s assurances, throughout the Class Period, while the Florida housing 

market was eroding, St. Joe failed to take adequate impairments on its troubled development 

projects. 

Investors finally began to learn about the Company’s true financial condition on 

October 13, 2010, when David Einhorn, of Greenlight Capital, gave a presentation entitled 

“Field of Schemes: If You Build It, They Won’t Come.” Einhorn’s presentation, which was 

based on his team’s investigation of St. Joe’s properties and market conditions in Florida, 

detailed “substantial impairments” that St. Joe has failed to take on the Company’s 

RiverTown, SummerCamp Beach, and WindMark Beach development projects. Einhorn’s 

conclusion was simple: the carrying values that St. Joe continues to report are not warranted 

in light of significantly diminished property values, the absence of meaningful new sales, 

and the significant and continued erosion of the Florida real estate market. 

The market reacted swiftly to Einhorn’s analysis and by the close of trading on 

October 13, 2010, St. Joe’s stock declined $2.38 per share, or 9.7 percent, from its close the 

previous day to close at $22.16 per share. As Einhorn’s presentation continued to be 

digested, the Company’s shares declined an additional $2.42 per share, or 10.9 percent, to 

close on October 14, 2010 at $19.74 per share. The losses are directly related to the market 

correcting the price of St. Joe’s stock based on the information in Einhorn’s presentation. 

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III. ARGUMENT 

The PSLRA provides the framework for organizing securities class action lawsuits. 

First, the PSLRA requires consideration of motions seeking to consolidate related actions. 

Second, with respect to selecting a lead plaintiff, the PSLRA provides a presumption 

favoring the plaintiff with the largest financial interest who also meet the typicality and 

adequacy requirements under Rule 23. For the reasons set forth below, Hess and Kneisel 

respectfully believe that the two related actions filed to date (indentified below) should be 

consolidated and that Hess and Kneisel should be appointed Lead Plaintiff and their 

selection of Co-Lead and Co-Liaison counsel approved. 

A. The Related Actions Should Be Consolidated 

The PSLRA provides that “[i]f more than one action on behalf of a class asserting 

substantially the same claim or claims arising under this title [] has been filed,” courts shall 

not appoint a lead plaintiff until “after the decision on the motion to consolidate is rendered.” 

 15 U.S.C. §78u-4(a)(3)(B)(ii); see also Grand Lodge of Pa. v. Peters, 2007 U.S. Dist. 

LEXIS 48191, at *4 (M.D. Fla. June 22, 2007) (“The PSLRA requires that the Court 

consolidate the actions, if warranted, before determining lead plaintiff.”). 3 Consolidation is 

appropriate under Rule 42(a) where the actions involve common questions of law or fact. 

See Newman v. Eagle Bldg. Techs., 209 F.R.D. 499, 501 (S.D. Fla. 2002). 

 

3 Unless otherwise noted, all citations are omitted and emphasis is added.

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 6 of 16
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Here, there are at least two related securities class actions pending in this District on 

behalf of investors who purchased St. Joe securities during the Class Period (the “Related 

Actions”): 

Abbreviated Case Name Case Number Date Filed

Meyer v. The St. Joe Co., et al. 10-cv-00452-RS 11/03/2010 

Weissman v. The St. Joe Co., et al. 10-cv-00504-MCR 12/07/2010 

The Related Actions present virtually identical factual and legal issues and arise out of the 

same alleged course of misconduct and seek to assert claims on behalf of similar classes of 

investors. Accordingly, consolidation is appropriate. See Newman, 209 F.R.D. at 501-02 

(“Consolidation of shareholder class actions is recognized as benefitting the court and the 

parties by expediting pretrial proceedings, reducing case duplication, and minimizing the 

expenditure of time and money by all persons concerned”). 

B. The PSLRA’s Lead Plaintiff Provisions 

The PSLRA establishes the procedure for the appointment of a lead plaintiff in “each 

private action arising under [the Exchange Act] that is brought as a plaintiff class action 

pursuant to the Federal Rules of Civil Procedure.” 15 U.S.C. § 78u-4(a)(1). First, the 

plaintiff who files the initial action must publish a notice to the class within twenty days, 

informing class members of their right to file a motion for appointment as lead plaintiff. See

15 U.S.C. § 78u-4(a)(3)(A)(i). Here, notice of the first filed action was published on PR 

Newswire on November 3, 2010. See Forehand Decl., Ex. A. Second, within sixty days of 

the publication of notice, any member of the proposed class may apply to be appointed as 

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lead plaintiff, whether or not they have previously filed a complaint in this action. See 15 

U.S.C. § 78u-4(a)(3)(A)(i)(II). 

Third, within ninety days after publication of notice, courts shall consider any motion 

made by a class member and shall appoint as lead plaintiff the member or members of the 

class that the court determines to be most capable of adequately representing the interests of 

class members. See 15 U.S.C. § 78u-4(a)(3)(B)(i). In determining the “most adequate 

plaintiff,” the PSLRA provides that: 

[T]he court shall adopt a presumption that the most adequate plaintiff in any private 

action arising under this [Act] is the person or group of persons that – 

(aa) has either filed the complaint or made a motion in response to a notice...; 

(bb) in the determination of the court, has the largest financial interest in the relief 

sought by the class; and 

(cc) otherwise satisfies the requirements of Rule 23. 

15 U.S.C. § 78u-4(a)(3)(B)(iii); see also Newman, 209 F.R.D. at 502. 

The time period in which class members may move to be appointed lead plaintiff in 

this case expires January 3, 2011. See 15 U.S.C. § 78u-4(a)(3)(A)-(B). Pursuant to the 

PSLRA, and within the requisite time frame after publication of the required notice, Movants 

have timely moved to be appointed lead plaintiff on behalf of all members of the class and 

otherwise meet all the criteria to be appointed lead plaintiff. 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 8 of 16
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C. Movants Are the “Most Adequate Plaintiff” 

a. Movants have the Largest Financial Interest in the Relief 

Sought by the Class 

According to 15 U.S.C. § 78u-4(a)(3)(B)(iii), the court shall presume that the most 

adequate plaintiff is the “person or group of persons” that represents the largest financial 

interest in the relief sought by the action. See Newman, 209 F.R.D. at 502. Here, Movants 

suffered losses exceeding $23,598 in connection with their Class Period transactions in St. 

Joe stock. See Forehand Decl., Ex. D. To the best of their knowledge, this represents the 

largest financial interest in the relief sought by the class. 

b. Movants Otherwise Satisfy Rule 23 

In addition to possessing the largest financial interest in the outcome of the litigation, 

the lead plaintiff must also “otherwise satisf[y] the requirements of Rule 23 of the Federal 

Rules of Civil Procedure.” 15 U.S.C. § 78u-4(a)(3)(B). Rule 23(a) provides that parties may 

serve as class representatives if the following four requirements are satisfied: (1) the class is 

so numerous that joinder of all members is impracticable, (2) there are questions of law or 

fact common to the class, (3) the claims or defenses of the representative parties are typical 

of the claims or defenses of the class, and (4) the representative parties will fairly and 

adequately protect the interests of the class. Although Rule 23 consists of four requirements, 

at this stage of the litigation, only a preliminary showing of typicality and adequacy is 

required. See Miller v. Dyadic Int'l, Inc., 2008 U.S. Dist. LEXIS 32271, at *18 (S.D. Fla. 

Apr. 18, 2008) (“Of those prerequisites, only two - typicality and adequacy - are relevant in 

deciding a motion for appointment of lead plaintiff.”). 

i. Movants Are Typical 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 9 of 16
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The typicality requirement under Rule 23 is satisfied if the lead plaintiff’s “claims 

share the same ‘essential characteristics as the class at large.’” Id. at *19 (citing PradoSteinman ex rel. Prado v. Bush, 221 F.3d 1266, 1278-79 n.14 (11th Cir. 2000)). The claims 

of the lead plaintiff, however, need not be identical to the claims of the class to satisfy 

typicality. See In re MIVA, Inc., 2008 U.S. Dist. LEXIS 21108, at *10 (M.D. Fla. Mar. 12, 

2008) (“Neither typicality or commonality require that all putative class members share 

identical claims, and both may be satisfied even if some factual differences exist between the 

claims of the named representatives and the claims of the class at large.”). 

Here, Movants are typical because, just like all other class members they: (1) 

purchased or otherwise acquired St. Joe securities during the Class Period; (2) at market 

prices artificially inflated as a result of Defendants’ violations of the securities laws; and (3) 

suffered damages when corrective disclosures removed the inflation created by Defendants’ 

fraud causing the price of St. Joe’s securities to fall. See Dyadic, 2008 U.S. Dist. LEXIS 

32271 at *19. Thus, Movants’ claims are typical of those of other class members because 

their claims and the class’s claims share the same essential characteristics. 

ii. Movants Are Adequate 

Movants also satisfy the adequacy requirement of Rule 23 which requires that the 

representative parties “fairly and adequately protect the interests of the class.” 15 U.S.C. § 

78u-4(a)(3)(B). Specifically, the adequacy requirement is met when plaintiffs demonstrate 

that “(1) class counsel is qualified, experienced, and generally able to conduct the litigation; 

(2) the class members’ interests are not antagonistic to one another; and (3) the class has 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 10 of 16
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sufficient interest in the outcome of the case to ensure vigorous advocacy.” Dyadic, 2008 

U.S. Dist. LEXIS 32271 at *19. 

Hess and Kneisel satisfy the necessary elements and, therefore, meet the adequacy 

requirement of Rule 23. First, as explained below, Movants have selected highly qualified 

firms with significant experience prosecuting class action lawsuits under the federal 

securities laws to serve as co-lead and co-liaison counsel for the class. See Section III. D., 

infra. Second, there is no conflict between Movants and the class. Both Movants and the 

class seek to recover losses caused by Defendants’ fraud. Third, Movants, with losses over 

$23,598 from their Class Period transactions in St. Joe common stock, have a substantial 

financial interest in this action and are committed to vigorously advocating the class’s 

claims, as evidenced by their sworn Certifications. See Forehand Decl., Ex. B, C & D. As 

such, Movants have demonstrated that they will fairly and adequately represent the interests 

of the class. 

In sum, Movants, in addition to having the largest financial interest, have made a 

prima facie showing of typicality and adequacy and, therefore, satisfy all elements for 

appointment as Lead Plaintiff in this action. See 15 U.S.C. § 78u-4(a)(3)(B)(iii).

D. The Court Should Approve Movants’ Selection of Counsel 

The parties selected to serve as lead plaintiff “shall, subject to the approval of the 

court, select and retain counsel to represent the class.” See 15 U.S.C. § 78u-4(a)(3)(B)(v). 

Courts should not disturb the lead plaintiff’s choice of counsel unless it is necessary to 

“protect the interests of the class.” 15 U.S.C. §78u-4(a)(3)(B)(iii)(II)(aa). Here, Movants 

have selected and retained Barroway Topaz and Pomerantz to serve as Co-Lead Counsel for 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 11 of 16
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the Class and Kurkin Forehand Brandes and Shepherd Finkelman to serve as Co-Liaison 

Counsel for the Class. These firms have extensive experience in prosecuting complex class 

actions and are well qualified to represent the Class. See Forehand Decl., Exs. E-H. 

Barroway Topaz has specialized in prosecuting securities class action litigation for 

over twenty years and has emerged as one of the preeminent law firms in its field and is 

currently serving as lead or co-lead counsel in several high profile securities class actions

including, In re Bank of America Corporation Securities Litigation, No. 09-md-2058 

(S.D.N.Y.) and Security Police & Fire Professionals of America Retirement Fund v. Pfizer, 

Incorporated, No. 10-3105 (D.N.J.). Barroway Topaz has represented defrauded investors in 

numerous class actions resulting in the recovery of billions of dollars for injured class 

members. Noteworthy achievements include serving as lead (or co-lead) counsel in complex 

securities fraud cases such as In re Tyco International, Limited Securities Litigation, No. 02-

266-PB (D.N.H.), In re Tenet Healthcare Corporation Securities Litigation, No. 02-8462 

(C.D. Cal.), and In re AremisSoft Corporation Sec. Litig., No. 01-2486 (D.N.J.). See

Forehand Decl., Ex. E. The firm recently also obtained a favorable jury verdict for a class 

of investors in In re BankAtlantic Bancorp, Incorporated Securities Litigation, No. 07-6154, 

Trial Tr. at 4350:8-4364:10 (S.D. Fla. Nov. 18, 2010). The verdict in BankAtlantic is just the 

tenth securities class action lawsuit verdict based on post-PSLRA conduct. 

Similarly, Pomerantz is highly experienced in the area of securities litigation and 

class actions, and has successfully prosecuted numerous securities litigations and securities 

fraud class actions and obtained excellent recoveries on behalf of defrauded investors. The 

firm’s approach has led courts to repeatedly commend the firm for its ability to vigorously 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 12 of 16
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pursue and successfully litigate actions on behalf of investors in securities fraud. For 

example, in appointing Pomerantz as Lead Counsel in a securities fraud class action, a court 

noted that the firm “has significant experience (and has been extremely effective) litigating 

securities class actions, employs several highly qualified attorneys, and possesses ample 

resources to effectively manage the class litigation and protect the class’s interests.” In re 

Am. Italian Pasta Co. Secs. Litig., 2006 U.S. Dist. LEXIS 43816 (W.D. Mo., Dec. 19, 2005). 

 Similarly, in approving a $146.25 million settlement in which Pomerantz served as Lead 

Counsel, a court praised the firm’s efforts, noting the “vigor” with which the firm prosecuted 

the claims and the “excellent results” the firm obtained. In re Charter Communications Sec. 

Litig., 2005 U.S. Dist. LEXIS 14772 (E.D. Mo., June 30, 2005). See Forehand Decl., Ex. F. 

 Indeed, both Barroway Topaz and Pomerantz have shown their commitment to 

protecting the class as they are the only firms to have filed complaints against St. Joe. 

Additionally, Kurkin Forehand Brandes and Shepherd Finkelman are experienced in 

litigating complex actions and are more than capable of serving as Co-Liaison Counsel. See

Forehand Decl., Exs. G & H. 

Thus, the Court can be assured that by granting this motion, the proposed class will 

receive the highest caliber of legal representation. 

IV. CONCLUSION 

For the foregoing reasons, Movants respectfully request that the Court: (i) 

consolidate the Related Actions; (ii) appoint Hess and Kneisel as Lead Plaintiff for the Class; 

(iii) approve their selection of Barroway Topaz and Pomerantz to serve as Co-Lead Counsel 

for the Class; (iv) approve their selection of Kurkin Forehand Brandes and Shepherd 

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Finkelman as Co-Liaison Counsel for the Class; and (v) grant such other and further relief as 

the Court may deem just and proper. 

Dated: January 3, 2010 

By: 

Respectfully submitted, 

s/ John W. Forehand 

John W. Forehand (Fla. Bar No. 0979813) 

KURKIN FOREHAND BRANDES LLP 

800 North Calhoun Street, Suite 1-B 

Tallahassee, FL 32303 

Tel: (850) 391-5060 

Fax: (850) 391-2645 

Proposed Co-Liaison Counsel 

Scott R. Shepherd (Fla. Bar No. 069655) 

Nathan C. Zipperian (Fla. Bar No. 065125) 

Jayne A. Goldstein (Fla. Bar No. 0144088) 

SHEPHERD, FINKELMAN, MILLER & 

SHAH, LLP 

1640 Town Center Circle 

Suite 216 

Weston, FL 33326 

Tel: (954) 515-0123 

Fax: (954) 515-0124 

Proposed Co-Liaison Counsel 

Sean M. Handler 

Darren J. Check 

Naumon A. Amjed 

BARROWAY TOPAZ KESSLER 

MELTZER & CHECK, LLP 

280 King of Prussia Road 

Radnor, PA 19087 

Tel: (610) 667-7706 

Fax: (610) 667-7056 

Proposed Co-Lead Counsel 

Patrick V. Dahlstrom 

Marc I. Gross 

POMERANTZ HAUDEK GROSSMAN 

& GROSS LLP 

100 Park Avenue 

Case 3:10-cv-00452-RS -EMT Document 20 Filed 01/03/11 Page 14 of 16
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New York, NY 10017 

Tel: (212) 661-1100 

Fax: (212) 661-8665 

Proposed Co-Lead Counsel 

 

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CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that the foregoing was filed in the United States District Court, 

Northern District of Florida, CM/ECF system on this 3rd day of January, 2011, and was served 

electronically via the CM/ECF system on the following: 

Amy Desmond Lamberti 

Charles Alan Gilman 

David G. Januszewski 

CAHILL GORDON & REINDELL LLP 

80 Pine Street 

New York, NY 

Telephone: (212) 701-3000 

Facsimile: (212) 269-5420 

Attorneys for Defendant Deutsche Bank 

Securities, Inc. 

Dennis K. Larry 

CLARK, PARTINGTON, HART, LARRY, BOND &

STACKHOUSE

125 West Romana Street, Suite 800 

Pensacola, Florida 32502 

Telephone: (850) 434-9200 

Facsimile: (850) 432-7340 

Attorneys for Defendants Deutsche Bank 

Securities, Inc., The St. Joe Company, William 

Britton Greene, William S. McClamont, Peter S. 

Rummell, Janna L. Connolly, Michael L. Ainslie, 

Hugh Durden, Thomas Fanning, Harry H. 

Frampton, III, Adam W. Herbert, Jr., Delores M. 

Kesler, John S. Lord, Walter L. Revell, and 

William H. Walton, III 

Clifford C. Higby 

BRYANT AND HIGBY, CHARTERED

P.O. Box 860 

Panama City, Florida 32402 

Telephone: (850) 763-1787 

Facsimile: (850) 785-1533 

Attorney for KPMG LLP 

s/ John W. Forehand 

 

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