EXHIBIT W 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE: TIKTOK, INC., 

CONSUMER PRIVACY 

LITIGATION 

This Document Relates to All Cases 

MDL No. 2948 

Master Docket No. 20-cv-4699 

Judge John Z. Lee 

Magistrate Judge Sunil R. Harjani 

DECLARATION OF LESLEY E. WEAVER IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AN AWARD OF ATTORNEYS’ FEES AND EXPENSES FILED ON BEHALF OF 

BLEICHMAR FONTI & AULD LLP 

 I, Lesley E. Weaver, declare and state as follows: 

1. I am the Partner-in-Charge of the Oakland, California office of Bleichmar Fonti & 

Auld LLP (“BFA”) and the head of its Consumer and Antitrust Practice Group. I have practiced 

in this field for more than 25 years and have significant experience in the litigation of complex, 

significant matters, including through trial. My firm’s resume is attached hereto as Exhibit 1. I 

submit this Declaration in support of Plaintiffs’ petition for an award of attorneys’ fees and 

reimbursement of costs and expenses in connection with services rendered and expenses incurred 

by my firm in connection with this litigation. 

2. I have acted as counsel to named plaintiffs R.S. and J.S., by their guardian, and 

Aparna Iyer, Brandy Johnson, Katherine Czajka, and Karina Quinteiro in this litigation. During 

the period from case inception through October 31, 2020 (the first reporting period pursuant to the 

Court’s Case Management Order No. 4: Common Benefit Fee and Expense Protocol [Dkt. 105]), 

my firm conducted the following activities for the common benefit of Plaintiffs: working with cocounsel Amy Keller at DiCello Levitt & Gutzler LLC, I pioneered the work necessary to bring a 

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claim under the Video Privacy Protection Act (“VPPA”), a statutory claim with significant 

statutory penalties. At the time we filed our complaint, no other litigant had pursued that claim. 

To develop a foundation for those claims, BFA consulted with five independent experts who 

specialize in the fields of deceptive user experience, dark patterns web privacy and biometric data 

collection. Through the work of these experts, we established that there was a strong factual 

foundation for alleging claims under the VPPA as well as BIPA. We then pled multiple theories 

of liability, including the VPPA, 18 U.S.C. §§ 2710, et seq., but also claims under California law 

on behalf of Plaintiffs Brandy Johnson and Aparna Iyer, an Illinois resident and California resident, 

respectively, in the Northern District of California (the “Iyer Action”). Iyer, et al. v. TikTok Inc., 

et al., No. 20-cv-03795 (N.D. Cal.), transferred No. 20-cv-05217 (N.D. Ill.). 

3. During and following the extensive lead counsel appointment process, we worked 

cooperatively with counsel in the Hong action, providing them with research and work product to 

augment their work, and assist them in bringing their own VPPA claim. During this time, BFA 

uncovered additional facts, including that TikTok collected users’ 12-digit “media access control” 

or MAC addresses, and engaging experts to develop factual support for these expanded allegations. 

The Amended Complaint also alleged new facts critical to the BIPA claim, augmented the VPPA 

claim, and addressed security issues concerning TikTok’s collection of MAC addresses. See First 

Am. Class Action Complaint, No. 20-cv-04728 (N.D. Ill.). 

4. The total number of hours expended on this litigation by my firm from case 

inception through October 31, 2020, is 425.9 hours, but we seek only reimbursement for 408.1 of 

these hours, having cut the work of some employees to present a more reasonable lodestar. The 

total lodestar for my firm in this time period is $321,697.50. 

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5. For the time period November 1, 2020 through February 28, 2022, and at the 

request of Plaintiffs’ Co-Lead Counsel, my firm assisted with litigation strategy and settlement 

related tasks. The total number of hours expended on this litigation by my firm from for the time 

period November 1, 2020 through February 28, 2022, is 31.9 hours, but we seek only 

reimbursement for 21.7 hours. The total lodestar for my firm in this time period is $20,265. 

6. The total number of hours expended on this litigation by my firm from case 

inception through February 28, 2022, is 429.8 hours. The total lodestar for my firm is $341,962.50. 

My firm’s lodestar figures are based on the firm’s current hourly billing rates. The hourly rates for 

the partners, attorneys, and professional support staff in my firm are the same as the usual and 

customary hourly rates charged for their services in contingent billable matters. The total number 

of hours was determined by the examination of contemporaneous, daily time records regularly 

prepared and maintained by my firm and which have been provided to Co-Lead Counsel for their 

review. 

7. Attached hereto as Exhibit 2 is a detailed summary indicating the amount of time 

spent by the partners, attorneys, and other professional support staff of my firm who have been 

involved in this litigation, and the lodestar calculation is based on my firm’s current hourly billing 

rates from case inception through February 28, 2022. 

8. As detailed in Exhibit 3, my firm has incurred a total of $4,523.92 in unreimbursed 

expenses during the period from case inception through February 28, 2022. These expenses do not 

include my firm’s assessment payments to the common cost litigation fund maintained by CoLead Counsel. 

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9. The expenses incurred in this action are reflected on the books and records of my 

firm. These books and records are prepared from expense vouchers, check records, and other 

source materials, and represent an accurate recordation of the expenses incurred. 

 I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

 Executed on this 25th day of March, 2022 at Oakland, California. 

 

 _/s/ Lesley E. Weaver___________ 

 Lesley E. Weaver 

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Exhibit 

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In Re: TikTok, Inc., Consumer Privacy Litigation

Case No. 1:20ͲcvͲ04699ͲJZL

Honorable John Z. Lee

 

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OVERVIEW

Bleichmar Fonti & Auld LLP (“BFA” or the “Firm”) is a law firm based in New York City with offices in

Oakland, California; Toronto, Ontario; and White Plains, New York. The Firm has recovered more than

$18 billion for its clients since its founding in 2014. The Firm focuses solely on affirmative litigation in

highly significant matters, including consumer, securities and antitrust actions both in the United States

and abroad. We represent a wide range of domestic and foreign clients, including some of the largest

institutional investors and asset managers in the world as well as small businesses and individual

consumers.

Three unique aspects of our firm distinguish BFA from others: (1) our selectivity in choosing cases; (2)

the high quality lawyering our diverse team provides; and (3) a commitment to our clients’ needs

ahead of our own. Because of this, BFA enjoys a reputation as a highly ethical, discerning, and

sophisticated boutique firm.

First, we are extremely selective in the cases we choose to litigate, and the strength of our litigation

skills is second to none. Our clients’ reputations are at stake in every case they pursue, and we guard

their reputations zealously. As a result, we are often asked by our clients to serve as the dissenting

voice when our peers are recommending a case we do not like. We only recommend cases that fit

within our clients’ objectives and do so very seldomly.

We strive for quality and not quantity in every aspect of our practice. This allows us to dedicate a

significant amount of resources to each individual case. Complex litigation requires a substantial

investment of money, time, and resources. It is only with dedicated resources that a wellͲthoughtͲout

litigation strategy can be executed forcefully and effectively. We don’t spread ourselves too thin and

instead strive to take cases deep into litigation. Our results, discussed below, show that we obtain

outsized settlements and reflect the high quality of our work product.

Second, we strive to provide our clients with objective, comprehensive counsel, including about

whether or not participation in specific litigation serves the best interests of the client. We have a

strong commitment to candid and unvarnished advice, made possible through our independence from

litigation funding. In addition, BFA provides advice on multiple other aspects such as the development

of the law and the risk of feeͲshifting provisions, as well as the reputational risk, if any, of participating

in any particular litigation.

Third, BFA’s attorneys have decades of experience litigating complex, high profile cases of import. We

launched BFA in large measure to break away from many of the standard practices of the more

established and larger plaintiffs’ firms. We do not hold an “inventory” of cases (which effectively

includes weak ones) to ensure a steady cashͲflow stream over the years. The high quality of our lawyers

and successful case resolutions allows us to carry out that strategy.

In sum, we are distinguished by our candid counsel, deep experience, and proven results.

CONSUMER LITIGATION HIGHLIGHTS

Lesley Weaver specializes in consumer and antitrust work in significant matters.  She has been

appointed to leadership positions in some of the most significant consumer actions of recent years,

including: In re Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation,

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which resulted in settlements totaling greater than $15 billion; and In re ChryslerͲDodgeͲJeep EcoDiesel

Marketing, Sales Practices and Products Liability, which resulted in a settlement of $307.5 million. She

currently serves as CoͲLead Counsel for Plaintiffs in In re Facebook, Inc. Consumer Privacy User Profile

Litigation, as well as acting coͲlead counsel in Calhoun, et al. v. Google LLC and In re Google RTB

Consumer Privacy Litigation, all of which are currently pending. These, and additional matters, are

described below.

In re Volkswagen “Clean Diesel” Marketing, Sales Practices, and

Products Liability Litigation

x MDL No. 2672

x Northern District of California, No. 3:15ͲmdͲ02672

Total Settlements:

$15 Billion

Background: This landmark case resolved claims against Volkswagen, Audi and Porsche in connection

with the widelyͲreported news that the companies had installed emission systems created to avoid

regulator detection and defraud customers who believed they were buying Volkswagen and Audi

vehicles with “clean diesel” engines. VW admitted that it installed these “defeat devices,” which

eliminated the emissions reduction during normal driving, and only allowed for reduced fuel emissions

when the automobiles were being tested. More than 500 federal lawsuits were filed and consolidated

into one complaint against the automaker for its “dirty diesel” vehicles.

BFA’s Role: Judge Charles R. Breyer appointed Ms. Weaver to the Plaintiffs’ Steering Committee, which,

along with lead counsel, has been described as the “dream team” prosecuting this highͲprofile

emissions scandal. Judge Breyer selected Ms. Weaver from a field of 150 of the nation’s finest

attorneys. Ms. Weaver’s leadership position in the case included spearheading the investigation that

ultimately uncovered German auto supplier Robert Bosch GmbH’s significant role in multiple schemes

to place software in vehicles purposefully designed to evade emissions laws. She also led the

investigation into additional claims relating to defeat devices in certain gas vehicles, resulting in an

additional $96.5 million settlement for the Class.

Status: Lead Counsel and the Plaintiffs’ Steering Committee have achieved settlements for Plaintiffs

worth approximately $15 billion, the largest automotive class action recovery in history. This includes a

$14.7 billion settlement on behalf of eligible owners of Volkswagen and Audi 2.0Ͳliter TDI cars, who

were offered a buyback of their cars. In accordance with the consent decree, $2.7 billion of the

settlement will be allocated to projects to reduce nitrogen oxides emissions, with a focus on improving

air quality in areas that “bear a disproportionate share of the air pollution burden within their

jurisdiction.” As the Justice Department's top environmental attorney John Cruden has highlighted, this

focus on remediation in low income and minority communities is “unique,” and a significant response

to the disproportionate pollution burden felt by these communities.

On March 2, 2020, Judge Breyer granted final approval of a $96.5 million settlement for more than

100,000 consumers who purchased or leased certain gasolineͲpowered Audi, Volkswagen, Porsche,

and Bentley vehicles that were initially labeled and marketed with overstated fuel economy and

understated carbon dioxide emissions.

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Lead Counsel and the Plaintiffs’ Steering Committee continue to pursue claims against Defendants

related to PorscheͲbranded gasoline vehicles.

In re ChryslerͲDodgeͲJeep EcoDiesel Marketing, Sales Practices and

Products Liability Litigation

x MDL No. 2777

x Northern District of California, No. 3:17ͲmdͲ02777

Total Settlements:

$307.5 Million

Background: The class alleges that Fiat Chrysler Automobiles deliberately cheated on emission testing

of 2014Ͳ2016 model Dodge and Jeep trucks marketed and sold as environmentally friendly “ecoͲdiesel”

vehicles.

BFA’s Role: Judge Edward Chen of the U.S. District Court for the Northern District of California

appointed Ms. Weaver as one of nine members of the Plaintiffs’ Steering Committee. Ms. Weaver

played a key role in litigating the action, including taking depositions and coordinating with experts.

Result: The case has settled for $307 million in cash in addition to extended warranties worth more

than $120 million.

In re Facebook, Inc. Consumer Privacy User Profile Litigation

x MDL No. 2843

x Northern District of California, No. 3:18ͲmdͲ02843

Case Status:

Pending

Background: This highͲprofile case seeks redress for Facebook users in the U.S whose private content

was unlawfully shared with thousands of third parties. The detailed complaint documents Facebook’s

violations of consumer fraud and privacy laws in allowing third party apps, including Cambridge

Analytica, to bundle and sell Facebook users’ private information without their knowledge or consent.

BFA’s Role: In a contested and highly competitive field, Judge Chhabria of the Northern District of

California appointed Ms. Weaver as CoͲLead Counsel for Plaintiffs.

Status: In September 2019, Judge Chhabria of the Northern District of California largely denied

Facebook’s motion to dismiss, finding Facebook’s argument that plaintiffs have no right to allege a

breach of privacy based upon Facebook’s sharing of their information with third parties “could not be

more wrong.” On March 10, 2020, the matter was assigned to Magistrate Judge Corley for the

management of discovery. On October 29, 2020, Plaintiffs received a favorable ruling concerning the

scope of discovery at issue in the MDL litigation. The order ruled that discoverable user data includes:

1) Data collected from a user’s onͲplatform activity; 2) Data obtained from third parties regarding a

user’s offͲplatform activities; and 3) Data inferred from a user’s on or offͲplatform activity. Discovery is

ongoing.

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Calhoun et al. v. Google LLC

x Northern District of California, No. 4:20ͲcvͲ05146ͲYGR

Case Status:

Pending

Background: This nationwide data privacy class action is brought on behalf of Google Chrome users

alleging that Google violated its express promise not to take users’ personal data when using the

Chrome browser outside of synched mode.

BFA’s Role: BFA is acting as coͲlead counsel representing the class of Chrome users in this litigation.

Status: In March 2021, this Court issued an order denying in part Google’s motion to dismiss. The order

upheld Plaintiffs’ contract, privacy, and other claims. The order, found that that Chrome users’ data—

including browsing history, cookies, and other site data—is their property and that Plaintiffs had

alleged Google’s unlawful collection of such data constitutes theft. Further, the order upheld claims

that Google acted in bad faith when it collected users’ data in circumvention of cookie blockers.

In re Google RTB Consumer Privacy Litigation

x Northern District of California, No. 4: 21ͲcvͲ02155ͲYGR

Case Status:

Pending

Background: The case is the first in the country to demand transparency about what information

Google reveals about its users when it auctions ad placements to Google users through Google’s “RealͲ

Time Bidding” system.

BFA’s Role: Ms. Weaver is a member of the Plaintiffs’ Executive Committee.

Status: The parties have briefed a motion to dismiss briefing.

In re: ZFͲTRW Airbag Control Units Products Liability Litigation

x Central District of California, No. 2:19ͲMDͲ02905

Case Status:

Pending

Background: The class action complaint alleges the ZFͲTRW airbag and seat belt control units in over 15

million cars sold are defective and may prevent airbags from inflating in the event of crash. This defect

has been linked to at least eight deaths and several serious injuries. The complaint names as

defendants ZFͲTRW, STMicro, and vehicle manufacturers, Kia, Hyundai, Hyundai MOBIS, Fiat Chrysler,

Toyota, Honda, and Mitsubishi.

BFA’s Role: Judge John A. Kronstadt of the U.S. District Court for the Central District of California

appointed Lesley Weaver to the Plaintiffs’ Steering Committee for the multidistrict litigation.

Status: The parties have briefed motions to dismiss, to stay discovery, and to compel arbitration.

*  *  *

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U.S. ANTITRUST LITIGATION HIGHLIGHTS

Lesley Weaver has been appointed to leadership positions in significant antitrust actions. In addition,

Lesley and her team play key roles in many additional matters, as described below.

In re Domestic Airlines Travel Antitrust Litigation

x District of Columbia, No. 1:15ͲmcͲ01404

Case Status:

$60 million in partial

settlements;

Remaining litigation pending

Background: Plaintiffs allege a conspiracy by the four largest commercial air passenger carriers in the

United States—American Airlines, Inc., Delta Airlines, Inc., Southwest Airlines Co., and United Airlines,

Inc.—to fix prices for domestic air passenger transportation services in violation of the Sherman Act by

colluding to limit capacity on their respective airlines.

BFA’s Role: BFA is a key part of Plaintiffs’ nonparty discovery committee and has led meet and confer

negotiations with dozens of nonparties, resulting in the production of some of Plaintiffs’ best evidence.

Status: Plaintiffs have settled for $15 million with Defendant Southwest Airlines and $45 million with

Defendant American Airlines. The parties are briefing motions for summary judgment brought by the

remaining Defendants.

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In re Local TV Advertising Antitrust Litigation

x MDL No. 2867

x Northern District of Illinois, No. 1:18ͲcvͲ0678

Case Status:

Pending

Background: Plaintiffs allege a price fixing cartel facilitated by an anticompetitive information exchange

between and among certain major television station owners and operators to artificially inflate the

prices of broadcast television spot advertisements.

BFA’s Role: BFA acts as counsel for One Source Heating & Cooling, LLC and is an integral member of the

litigation team.

Status: On November 6, 2020, Judge Virginia Kendall of the Eastern District of Illinois denied

Defendants’ motion to dismiss. Discovery in this matter is ongoing.

In re Disposable Contact Lens Antitrust Litigation

x MDL No. 2626

x Middle District of Florida, No. 3:15ͲmdͲ02626

Case Status:

$40 million in settlements;

Remaining litigation currently

at trial

Background: Plaintiffs allege claims for horizontal and vertical conspiracies in violation of state and

federal antitrust laws due to unilateral pricing policies of four leading contact lens manufacturers.

BFA’s Role: BFA is leading discovery efforts against the largest manufacturer, Johnson & Johnson.

Status: Plaintiffs have settled with Defendant CooperVision, Inc. for $3 million and with Defendant

Bausch & Lomb for $10 million. Plaintiffs have also sought final approval of a proposed $30.2 million

settlement with ABB Optical Group LLC. The parties are currently in trial for claims against the

remaining Defendants.

In re Mexican Government Bonds Antitrust

x S.D.N.Y., No. 1:18ͲcvͲ02830

Case Status:

$21 million in settlements;

Remaining litigation pending

Background: Plaintiffs allege that Defendant brokerͲdealers have fixed auctions for securities issued by

the Mexican government and manipulated the bidͲask spread in transactions to U.S.Ͳbased investors,

causing U.S.Ͳbased investors to pay artificially inflated prices for their Mexican government bonds.

BFA’s Role: BFA represents Southeastern Pennsylvania Transit Authority and is assisting the team

litigating the case in the Southern District of New York.

Status: Plaintiffs have negotiated iceͲbreaker settlements with JPMorgan for $15 million and Barclays

PLC for $5.7 million, totaling $20.7 million in addition to cooperation in litigating against the remaining

defendants, and filed a highly detailed complaint based in part on highly incriminating documents

received from the cooperating defendants. The remaining Defendants’ motion to dismiss is pending.

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In re FarmͲRaised Salmon and Salmon Products Litigation

x Southern District of Florida, No. 19ͲCVͲ21551

Case Status:

Pending

Background: Plaintiffs seek redress from Atlantic salmon producers who fixed prices of farmͲraised

Atlantic salmon sold in the United States, including Norwegian producers. Alleged conduct includes

coordinating sales prices and exchanging commercially sensitive information, agreeing to purchase

production from other competitors when those other competitors were selling at lower prices, and

applying a coordinated strategy to increase spot prices in order to secure higher price levels for long

term contracts. As a result, since 2015 farmͲraised Atlantic salmon prices have been artificially inflated.

Role: BFA is working closely with the executive team facilitating jurisdictional discovery.

Status: On March 23, 2021, the Court denied Defendants’ motion to dismiss, finding Plaintiffs have

alleged a plausible conspiracy existed through circumstantial facts.

In re Packaged Seafood Products Antitrust Litigation

x MDL No. 2670

x Southern District of California, No. 3:15ͲmdͲ02670

Case Status:

Pending

Background: Plaintiffs allege defendants entered into a conspiracy involving packaged seafood product

in violation of the Sherman Act and state antitrust law.

BFA’s Role: BFA is part of a critical discovery effort against a key defendant.

Status: On July 30, 2019, the Honorable District Judge Janis L. Sammartino of the Southern District of

California granted class certification to a class of direct purchasers. In January 2021, Direct Purchaser

Plaintiffs and Defendant TriͲUnion Seafoods d/b/a Chicken of the Sea International and Thai Union

Group PCL announced a settlement agreement in principle. The remaining parties have briefed motions

for summary judgment.

In re Blood Plasma Antitrust Litigation

x MDL No. 2109

x Northern District of Illinois, No. 1:09ͲcvͲ07666

Total Settlements:

$128 Million

Background: Plaintiffs allege that Defendants participated in a multiͲyear conspiracy to restrict output

and fix prices of Ig and Albumin in the United States.

BFA’s Role: Ms. Weaver played a significant role, including deposing the Chief Operating Officer and

Chief Marketing Officer of one of the main defendants.

Result: In 2014, the Court granted final approval of the settlements between plaintiffs Defendants

Baxter International, Inc., Baxter Healthcare, CSL Limited, CSL Behring LLC, CSL Plasma Inc., and the

Plasma Protein Therapeutics Association, for a total settlement worth $128 million.

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In re Lithium Ion Batteries Antitrust Litigation

x MDL No. 2420

x Northern District of California, No. 4:13ͲmdͲ02420

Total Settlements:

$64.5 Million

Background: Plaintiffs allege that defendants and their coͲconspirators engaged in an unlawful

conspiracy to fix the prices of lithium ion battery cells, affecting the prices indirect purchasers paid for

lithium ion batteries and lithium ion products. Indirect Purchaser Plaintiffs have settled their claims for

$19.5 million from Sony Corp., $39 million from LG Chem Ltd., $3.45 million from Hitachi Maxwell Ltd.,

and $2.5 million from NEX Corp.

BFA’s Role: BFA represents the cities of Palo Alto and Richmond, California.

Result: On October 27, 2017, the Court gave final approval to the settlement between the IPPs and

Hitachi Maxell, NEC Corporation, and LG Chem. The settlement was worth $45 million, bringing the

total settlements with IPPs to $64.5 million.

*  *  *

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U.S. SECURITIES LITIGATION HIGHLIGHTS

BFA partners have represented lead plaintiffs in more than a dozen securities class actions in the last

decade, including seven since the Firm was founded, as described below. Lesley Weaver has also played

leading roles in significant securities settlements, including Marsh & McLennan ($400 million), and In re

Twitter Inc. Securities Litigation ($810 million), where she served as liaison counsel.

The Police Retirement System of St. Louis v. Granite Construction

Incorporated, et al.

x Northern District of California, No. 19ͲcvͲ04744

x Client: The Police Retirement System of St. Louis

x Lead Attorneys: Javier Bleichmar

Total Settlement:

$129 Million

Background: Plaintiffs allege that Granite and its senior management fraudulently misrepresented the

impact of several of the company’s largest joint venture construction projects on Granite’s business.

Specifically, plaintiffs assert that Granite and its senior management understated the significant cost

overruns and schedule delays that the Company was experiencing as well as their impact on Granite’s

financial statements.

BFA’s Role: BFA is sole Lead Counsel for CourtͲappointed Lead Plaintiff the Police Retirement System of

St. Louis.

Status: On March 17, 2022, the Court granted final approval of a $129 million settlement.

Ontario Teachers’ Pension Plan Board, et al v. Teva Pharmaceutical

Industries Ltd. et al.

x District of Connecticut, No. 17ͲcvͲ00558

x Clients: Ontario Teachers’ Pension Plan Board and Anchorage

Police and Fire Retirement System

x Lead Attorney: Joseph A. Fonti

Case Status:

Proposed $420 Million

Settlement Pending Court

Approval

Background: Plaintiffs allege that the company and its senior management made materially false and

misleading statements that concealed that Teva had engaged in a multiͲyear scheme to exponentially

increase generic drug prices across its portfolio, in some instances by more than 1000%. Often, these

increases were in lockͲstep with soͲcalled competitors.

BFA’s Role: BFA is sole Lead Counsel for CourtͲappointed Lead Plaintiff Ontario Teachers’ and named

plaintiff Anchorage Police and Fire Retirement System.

Status: The Court appointed Ontario Teachers’ as Lead Plaintiff and approved its choice of BFA as Lead

Counsel on July 11, 2017. BFA filed an amended complaint on June 22, 2018. In September 2019, the

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Court denied defendants’ motion to dismiss and in December 2019, BFA filed a further amended

complaint. In March 2020, the Court granted BFA's motion for consolidation. On March 9, 2021, Judge

Underhill granted BFA’s motion to certify a class of Teva investors. Judge Underhill also granted BFA’s

motion to appoint the Ontario Teachers' Pension Plan Board and Anchorage Police and Fire Retirement

System as Class Representatives, and BFA as Class Counsel. On January 18, 2022, BFA secured a $420

million settlement for the class. The Court granted preliminary approval of the settlement on January

27, 2022.

In re Citigroup Securities Litigation

x Southern District of New York, No. 20ͲCVͲ9132

x Client: Public Sector Pension Investment Board ("PSP")

x Lead Attorneys: Javier Bleichmar, Joseph A. Fonti, Erin H.

Woods

Case Status:

Pending

Background: Plaintiffs allege that Citigroup and its senior management misrepresented and

concealed that the company's internal controls and risk management systems suffered from

serious and longstanding deficiencies that exposed the Company to massive regulatory penalties

that will cost significantly more than $1 billion to remediate.

BFA’s Role: BFA is sole Lead Counsel for CourtͲappointed Lead Plaintiff PSP.

Status: The Court appointed PSP as Lead Plaintiff and approved its choice of BFA as Lead Counsel on

February 4, 2021. BFA filed an Amended Complaint on April 20, 2021.

In re Align Technology, Inc. Securities Litigation

x Northern District of California, No. 17ͲcvͲ5114

x Client: Macomb County Employee’s Retirement System

x Lead Attorneys: Javier Bleichmar, Nancy Kulesa

Case Status:

Pending

Background: Plaintiffs allege Align and its senior management materially overstated the Company’s

performance in China and misrepresented and concealed significant declines in Chinese demand for

Align’s products and the deteriorating sentiment of Chinese consumers towards the Company’s

products.

BFA’s Role: BFA is sole Lead Counsel for CourtͲappointed Lead Plaintiff Macomb County Employee’s

Retirement System.

Status: The Court appointed Macomb County Employee’s Retirement System as Lead Plaintiff and

approved its choice of BFA as Lead Counsel on May 20, 2020. After BFA filed an Amended Complaint,

the Court dismissed the case on March 9, 2021 with the opportunity to replead. Lead Plaintiff filed an

appeal on May 6, 2021. The appeal is pending.

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MTA v. Allianz Global Investors U.S., L.L.C.

x Southern District of New York, No. 20ͲCVͲ7842

x Client: Metropolitan Transportation Authority

x Lead Attorneys: Javier Bleichmar, George Bauer

Case Status:

Pending

Background: Since 2008, the Metropolitan Transportation Authority (“MTA”) invested nearly $200

million in Allianz Global Investor’s (“AllianzGI”) Structured Alpha funds. Due to AllianzGI’s negligent and

imprudent trading strategies and its failure to implement adequate risk management procedures,

despite its commitment to do so, the MTA lost over 90% of its investment. AllianzGI’s failure cost the

MTA and similar institutional investors hundreds of millions of dollars.

BFA’s Role: BFA represents the MTA in their suit against AllianzGI.

Status: BFA filed a complaint against AllianzGI on behalf of the MTA in September 2020. On September

30, 2021, the Court denied defendants’ motion to dismiss.

In re MF Global Holdings Ltd. Securities Litigation

x Southern District of New York, No. 11ͲcvͲ07866

x Client: Alberta Investment Management Corp. (AIMCo)

x Lead Attorneys: Javier Bleichmar, Dominic Auld

Total Settlements:

$234.3 Million

Background: This litigation arose from MF Global’s dramatic bankruptcy in October 2011.  Plaintiffs

alleged that Defendants misrepresented the company’s risk controls, liquidity position, and exposure

to European sovereign debt, and failed to properly account for its deferred tax assets.

BFA’s Role: BFA represented CourtͲappointed CoͲLead Plaintiff AIMCo. Partners Javier Bleichmar and

Dominic Auld represented AIMCo in this case since its inception in November 2011, and served as

CourtͲappointed CoͲLead Counsel for the putative class since January 2012. When BFA launched in

August 2014, the Court approved AIMCo’s selection of BFA to serve as CoͲLead Counsel for the putative

class, continuing the core litigation team’s representation.

Status: Lead Counsel achieved five partial settlements worth a total of just over $234 million on behalf

of investors: (1) a $74 million settlement with Goldman Sachs and certain other underwriters of the

company’s securities; (2) a $64.5 million settlement with former officers and directors, including MF

Global’s former CEO Jon Corzine; (3) a $65 million settlement with auditor PricewaterhouseCoopers;

(4) a $29.825 million settlement with Jefferies and other underwriters of the final bond offering issued

during the Class Period; and (5) a separate $932,828 settlement with another underwriter defendant

associated with that last offering.These settlements represent a recovery of approximately 35% of the

alleged damages – an excellent result, particularly in light of the issuer’s bankruptcy.

These settlements were achieved after years of hard fought litigation. Following the Court’s ruling

sustaining the Complaint and denying Defendants’ six motions to dismiss in their entirety, CoͲLead

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Counsel reviewed millions of documents produced by Defendants and thirdͲparties, and conducted

more than 50 depositions of former employees of MF Global and other key witnesses, including four

days of testimony from former CEO Jon Corzine. The Court granted Plaintiffs’ motion for class

certification on October 14, 2015, which assisted in achieving the settlements.

In re Genworth Financial Inc. Securities Litigation

x Eastern District of Virginia, No. 14ͲcvͲ00682

x Client: Alberta Investment Management Corp.

x Lead Attorney: Joseph A. Fonti

Total Settlement:

$219 Million

Background: Plaintiffs alleged that Defendants misrepresented the profitability of the company’s core

business and reported false financial results by grossly understating longͲterm care insurance reserves.

When Genworth announced a $531 million charge to its reserves, the company’s stock price fell more

than 55% – wiping out billions in market capitalization – and credit rating agencies downgraded the

company and its corresponding debt to “junk” status.

BFA’s Role: BFA represented CourtͲappointed CoͲLead Plaintiff AIMCo. In November 2014, the Court

approved AIMCo’s selection of BFA to serve as CoͲLead Counsel for the putative class.

Notably, BFA secured one of the most thoroughlyͲreasoned, investorͲoriented decisions after the thenͲ

recent decision in Omnicare v. Laborers District Council Construction Industry Pension Fund, 135 S. Ct.

1318 (2015).1 The District Court ruled that Lead Plaintiffs had sufficiently pled that Defendants’

statements were intended to mislead investors and to provide false assurances regarding the

company’s reserves. The District Court also largely sustained allegations that Defendants falsely

certified that the company’s internal controls were adequate.

Status: On March 10, 2016, Genworth announced a proposed settlement of $219 million, the largest

ever securities class action recovery achieved in Virginia, and as much as 44% of recoverable damages

available at trial. BFA and AIMCo sought and achieved a significant contribution from the company

beyond available insurance; despite significant liquidity issues, the company paid $69 million, and the

remaining $150 million was funded by insurance.

The settlement was reached after 15 months of intense and complex litigation.The Eastern District of

Virginia is known as the “rocket docket” for its rapid disposition of cases and strict adherence to

scheduled deadlines. In December 2014, Lead Plaintiffs filed a consolidated complaint and, in February

2015, Defendants filed a motion to dismiss.  Partner Joseph Fonti successfully argued against the

1 The decision in Omnicare clarified the legal standard about pleading statements by defendants that are deemed

to be opinions, rather statements of fact.  The Supreme Court sought to limit liability for opinion statements,

making it more difficult for plaintiffs to sustain their allegations.The decision secured in Genworth, on behalf of

BFA’s client AIMCo, ruled that certain categories of statements around accounting reserves were not opinions,

and therefore actionable.

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motion on April 28, 2015, and the securities fraud claims were sustained on May 1, 2015. Lead

Plaintiffs filed their motion for class certification on December 3, 2015; fact discovery closed on

January 15, 2016; and expert discovery closed on February 11, 2016. In effect, BFA conducted two to

four years of litigation in just 15 months. This effort included more than 20 depositions, extensive trial

preparation, and full briefing on motions for class certification and summary judgment.At the time of

settlement, BFA attorneys were preparing for trial, which was scheduled to begin on May 9, 2016.

In re Weatherford International Securities Litigation

x Southern District of New York, No. 12ͲcvͲ02121

x Client: Anchorage Police and Fire Retirement System

x Lead Attorney: Javier Bleichmar

Total Settlement:

$120 Million

Background: Plaintiffs alleged that Weatherford, one of the world’s largest oil and gas servicing

companies, issued false financial statements that misled investors about its tax structure and internal

controls. The company allegedly overstated its earnings by more than $900 million and was forced to

issue three restatements due to its failure to comply with Generally Accepted Accounting Principles.

BFA’s Role: BFA represented CourtͲappointed CoͲLead Plaintiff Anchorage Police and Fire Retirement

System in this case, and BFA partner Javier Bleichmar represented Anchorage continuously since the

case was filed in March 2012.

Status: In June 2015, the company agreed to settle all claims for $120 million of outͲofͲpocket cash,

with no available insurance, or approximately 30% of recoverable damages. Achieving this settlement

required more than three years of intense litigation, including defeating Defendants’ motion to dismiss

in its entirety; obtaining class certification; completing fact discovery, after more than 20 depositions

and the review of more than eight million pages of documents; filing four expert reports; and preparing

for expert discovery and summary judgment.

In re Computer Sciences Corp. Securities Litigation

x Eastern District of Virginia, No. 11ͲcvͲ00610

x Client: Ontario Teachers’ Pension Plan Board

x Lead Attorney: Joseph A. Fonti

Total Settlement:

$97.5 Million

Background: Plaintiffs alleged that the company and two of its executive officers misrepresented (i) a

multiͲbillionͲdollar contract with the United Kingdom’s National Health Service, and (ii) that the

company’s internal controls were adequate.

BFA Role: BFA partners Javier Bleichmar, Joseph A. Fonti, and Dominic Auld represented CourtͲ

appointed Lead Plaintiff Ontario Teachers’ at all stages of this case. Upon the founding of the Firm, the

Court approved Ontario Teachers’ Pension Plan Board’s selection of BFA as counsel, continuing the

team’s representation.

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Status: On September 2013, the Court granted final approval to the $97.5 million settlement.At that

time, the settlement was the second largest all cash recovery ever achieved in the Eastern District of

Virginia, and represented as much as 38% of recoverable damages at trial.

In re Celestica Inc. Securities Litigation

x Southern District of New York, No. 07ͲcvͲ00312

x Client: New Orleans Employees’ Retirement System

x Lead Attorney: Joseph A. Fonti

Total Settlement:

$30 Million

Background: Plaintiffs alleged false and misleading statements relating to a significant corporate

restructuring plan, earnings, profitability, and financial outlook. When Celestica ultimately disclosed

the truth, its stock price dropped 50%, reducing market capitalization by $1.3 billion.

BFA’s Role: BFA partners Joseph Fonti and Erin Woods represented Lead Plaintiffs in this litigation.

Notably, Joseph was successful in arguing before the Court of Appeals for the Second Circuit, securing

an investorͲoriented interpretation of the pleading standard for scienter. Joseph also successfully

argued in favor of Plaintiffs’ class certification and summary judgment motions before the District

Court, securing the first lower court decision after Halliburton Co. v. Erica P. John Fund, Inc., 134 S. Ct.

2398 (2014) in favor of investors on the issue of classͲwide reliance.

Status: In April 2015, Plaintiffs filed a motion for preliminary approval of a proposed $30 million

settlement resolving all claims against the company and officer defendants. The final approval hearing

was held on July 28, 2015 and, later that day, the Court approved the $30 million settlement.

*  *  *

BFA attorneys have also played key roles in some of the most significant investor protection litigation in

recent history, helping shareholders recover significant losses caused by financial misconduct in various

industries across the marketplace.Select cases include:

In re Broadcom Corp. Class Action Litigation, Civ. No. 06ͲcvͲ5036 (C.D. Cal.).

This class action against Broadcom was based on allegations that the company inflated its stock price

by intentionally backdating its stock option grants for over five years. Ultimately, the company was

forced to issue a $2.2 billion restatement of its financial statements for the period spanning from 1998

through 2005, which became the largest restatement ever due to options backdating.

The company acknowledged the “substantial evidence” of backdating, and lead plaintiffs secured a

$173.5 million settlement, which, at the time, was the second largest cash settlement ever involving a

company accused of options backdating.This was also the only such case in which claims against the

auditors were sustained.

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In re HealthSouth Corp. Securities Litigation, Civ. No. 03ͲcvͲ1501ͲS (N.D. Ala.).

This case involved the largest securities fraud ever arising out of the healthcare industry, and ultimately

resulted in a total settlement amount of $804.5 million for the class.The class action involved claims

against HealthSouth for falsifying its revenues and conducting a series of acquisition transactions in

order to effectuate a massive fraud against the Medicare system.

False statements by the company and its officers led to the inflation of HealthSouth’s stock price, while

at the same time company executives were amassing significant personal wealth by selling their own

shares of HealthSouth stock.

Significantly, the litigation also resulted in the recovery of $109 million from HealthSouth’s outside

auditor Ernst & Young LLP, one of the largest recoveries to date against an auditing firm.

In re ScheringͲPlough Corp. / ENHANCE Securities Litigation, Civ. No. 08Ͳ397 (D.N.J.).

Lead Plaintiffs brought litigation in the District of New Jersey against ScheringͲPlough Corporation and

Merck/ScheringͲPlough Pharmaceuticals, and certain company officers, in In re ScheringͲPlough Corp. /

ENHANCE Securities Litigation, alleging that they failed to disclose material information about the

prospects of cholesterolͲlowering drugs.

After nearly six years of litigation, Defendants agreed to pay $473 million to settle the matter on the

eve of trial.  This marked the largest securities class action recovery in history obtained from a

pharmaceutical company.Together with a related securities class action against Merck, the ENHANCE

litigation settled for $688 million.

NONͲU.S. LITIGATION HIGHLIGHTS

In the past five years, we have acted and advised clients in a liaison capacity for their participation in

over thirty shareholder claims in Australia, England, Germany, the Netherlands, Denmark, France,

Spain, Italy, Japan, Brazil, and other jurisdictions. The list below is representative but not exhaustive.

We have assisted, and continue to assist, our clients in connection with matters that remain

confidential, including efforts to secure private settlements without formal action.

CIMIC Group Ltd. (formerly Leighton Holdings Ltd.) (Australia) – advised public pension funds on

registering claims

Fortis SA/NV (now known as Ageas) (Belgium / Netherlands) – liaison counsel to public pension funds

QBE Insurance Group Ltd. (Australia) – advised public pension funds

Treasury Wine Estates Ltd. (Australia) – advised public pension funds

Olympus Corp. (Japan) – liaison counsel to public pension funds

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OZ Minerals Ltd. (Australia) – advised public pension funds

Credit Suisse Group AG (Switzerland) – liaison counsel to public pension fund

Wirecard AG (Germany) – liaison counsel to public pension funds

Vale S.A. (Brazil) – liaison counsel to public pension funds

BRF S.A. (Brazil) – liaison counsel to public pension funds

Novo Nordisk AS (Denmark) – liaison counsel to public pension funds

Kobe Steel, Ltd. (Japan) – liaison counsel to public pension fund

Danske Bank AS (Denmark) – liaison counsel to public pension funds

Steinhoff International Holdings NV (Netherlands / Germany / South Africa) – liaison counsel to public

pension funds

Volkswagen AG (Germany) – liaison counsel to public pension funds

Porsche Automobil Holding SE (Germany) – liaison counsel to public pension funds

Mitsubishi Motors Corp. (Japan) – liaison counsel to public pension funds

Toshiba Corp. (Japan) – liaison counsel to public pension funds

Saipem SpA (Italy) – liaison counsel to public pension fund

Vivendi Universal SA (France) – liaison counsel to public pension funds

Daimler AG (Germany) – advising public pension funds

Petroleo Brasileiro SA (Brazil / Netherlands) – advising public pension funds

Tesco PLC (England) – advising public pension funds

BFA also evaluates clients’ eligibility to participate in Australian class actions that do not require a

litigation funding agreement based on an analysis of the client’s trading history. In the past five years,

we have identified and advised clients in regard to over 25 recovery opportunities in Australia,

including the following actions: Allco Finance Group Ltd.; AMP Ltd.; Ashley Services Group Ltd.;

Bellamy's Australia Ltd.; Crown Resorts Ltd.; Discovery Metals Ltd.; Downer EDI Ltd.; DSHE Holdings Ltd.

(f.k.a. Dick Smith Holdings Ltd.); Estia Health Ltd.; GetSwift Ltd.; Iluka Resources Ltd.; Macmahon

Holdings Ltd.; Murray Goulburn / MG Unit Trust; Myer Holdings Ltd.; QRxPharma Ltd.; Quintis Ltd.;

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Sims Ltd. (f.k.a. Sims Metal Management Ltd.); Sirtex Medical Ltd.; Slater & Gordon Ltd.; Spotless Group

Holdings Ltd.; Surfstitch Group Ltd.; Treasury Wine Estates Ltd. ; UGL Ltd.; Vocation Ltd.; Vocus Group

Ltd.; Woolworths Group Ltd. (f.k.a. Woolworths Ltd.); and WorleyParsons Ltd.

TEAM PROFILES

LESLEY WEAVER

Partner Oakland

x Email: lweaver@bfalaw.com

x Tel: +1 415 455 4004

x www.bfalaw.com/professionals/ lesleyͲ

weaver

Lesley Weaver leads the Firm’s Antitrust and Consumer Litigation Practice. Lesley joined BFA as a

partner in 2016, opening the Firm’s California office. In her twentyͲyear career, Lesley has focused

primarily on cases that protect the public interest, consumers, and public entities. She has substantial

leadership experience litigating complex antitrust and consumerͲoriented class litigation, and has been

appointed to leadership positions in some of the largest class actions in the country. In 2021, Lesley

was named to The National Trial Lawyers list of the Top 100 Civil Plaintiff Trial Lawyers in California for

her superior skills and qualifications. In 2018, Lesley was honored as a “California Lawyer of the Year”

(“CLAY”) for her work in In re Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products

Liability Litigation and was recognized as a “Plaintiff Trailblazer” by the National Law Journal (2018). In

2017 and 2018, she was named a “Super Lawyer” in the field of Class Action & Mass Torts Attorneys.

In July 2018, Judge Chhabria of the Northern District of California appointed Lesley as coͲlead counsel

for plaintiffs in In re Facebook, Inc. Consumer Privacy User Profile Litigation. This high profile case seeks

redress for Facebook users in the U.S and U.K. whose content specifically marked private was shared

with thousands of third parties with no oversight and for the purpose of creating revenue for Facebook

only. The more than four hundred page complaint documents how Facebook violated consumer fraud

and privacy laws in allowing hundreds of third party apps, including Cambridge Analytica, to bundle and

sell Facebook users’ private information without their knowledge or consent.

In June 2017, Judge Edward M. Chen appointed Lesley to the Plaintiffs’ Steering Committee in In re

ChryslerͲDodgeͲJeep EcoDiesel Marketing, Sales Practices, and Products Liability Litigation. Lesley

worked closely with technical experts in that matter to determine if proposed fixes to the subject

vehicles inflict additional damages upon class members. In May 2019, Plaintiffs secured final approval

of a settlement of $307.5 million in cash as well as extended warranties.

In December 2017, Judge Charles R. Breyer appointed Lesley to the Plaintiffs’ Steering Committee in In

re German Automotive Manufacturers Antitrust Litigation. Consumers and suppliers allege that German

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automakers engaged in a 20Ͳyear cartel—the single largest known automobile cartel in U.S. and

European history—to suppress the development of technology in their automobiles.

In 2015, Judge Charles R. Breyer appointed Lesley to the Plaintiffs’ Steering Committee in In re

Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation. Lesley’s

leadership position in this litigation included spearheading the investigation that ultimately uncovered

German auto supplier Robert Bosch GmbH’s significant role in multiple schemes to place software in

vehicles purposely designed to evade emissions laws. Plaintiffs in the Volkswagen litigation have

recovered approximately $15 billion for class members and the environment, the largest automotive

class action recovery ever.

She represents the Cities of Palo Alto and Richmond, California in a municipal subclass in In re Lithium

Ion Batteries Antitrust Litigation. In In re Automotive Parts Antitrust Litigation, Lesley represented

Oakland County, Michigan; Traverse City, Michigan; the Village of Northport, New York; Mecklenburg

County, North Carolina; and Richmond, California in the case against manufacturers of wire harnesses

that settled on a nonͲclass basis far in excess of the entities’ actual damages.

Lesley recently represented the National Black Farmers’ Association (“NBFA”), pro bono, in challenging

the terms of the proposed merger between BB&T and SunTrust Bank. In 2019, she testified on behalf of

the NBFA at the joint public hearing held by the Federal Reserve Board and the Federal Deposit

Insurance Corporation advocating for terms that will better serve small farmers. As a condition of

securing merger approval from the Department of Justice, the banks have since agreed to sell off 28

branches in regions that BFA identified.

In addition, Lesley has extensive experience representing sophisticated institutional investors in

landmark securities actions. Some of those cases include In re Marsh & McLennan Cos., Inc. Securities

Litigation ($400 million settlement); In re Cavanaugh Securities Litigation (including an appeal to the

Ninth Circuit concerning the method of selecting lead plaintiff and lead counsel after the enactment of

the Private Securities Litigation Reform Act (“PSLRA”)); In re Cardinal Health Inc. Securities

Litigation ($600 million settlement); and In re Cisco Systems, Inc. Securities Litigation ($99 million

settlement).

Lesley’s extensive trial experience has spanned her career. In October 2014, Lesley tried an internet

privacy case against a ChineseͲowned, CaliforniaͲbased internet site, recovering 100 percent of

economic damages and a $15 million punitive damages jury verdict, as well as significant injunctive

relief. Her first trial was in 1998 before the Honorable Vaughn Walker on behalf of Amanda Buritica, a

U.S. citizen born in Colombia who was unlawfully detained by U.S. Customs at San Francisco

International Airport; that case resulted in the largest verdict at the time under the Federal Tort Claims

Act.

Lesley is committed to public service through volunteer efforts, and currently serves on the Advisory

Council of the East Bay Community Law Center, as well as the Executive Committee of the Securities

Section for the Bar Association of San Francisco. She is a past CoͲChair of the San Francisco LGBT

Community Center, a past CoͲChair of Bay Area Lawyers for Individual Freedom, a past National Chair

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- 20 - 

of the National Center for Lesbian Rights, and a past Vice President and Director of the Board of the

Frameline Film Festival. She has previously served on the boards of Women Lawyers of Alameda

County, Equality California, the International Gay and Lesbian Human Rights Commission, and the Alice

B. Toklas Democratic Club. She also is a member of the National Association of Public Pension

Attorneys (NAPPA).

Lesley serves on the drafting committee for the Sedona Conference Data Privacy Primer on Biometrics

and is a frequent speaker on privacyͲrelated topics.She is a recurring participant in the “Masters of

Litigation” conference taught at West Virginia Law School, and has spoken at the Northern District of

California Judicial Conference. She is an acting Lawyer Representative for the Northern District of

California and an active member of the Executive Committees of the CyberSecurity, Privacy, and

Securities committees for the Bar Association of San Francisco. She is also a coͲauthor of the George

Washington Law School’s Inclusivity and Excellence: Guidelines and Best Practices for Judges

Appointing Lawyers to Leadership Positions in MDL and Class Action Litigation.

Lesley holds degrees from the University of Bonn (Germany) and Harvard College, and received a J.D.

from the University of Virginia Law School (1997). She attended high school at Haderslev

Katedraleskole in Denmark. She speaks German and Danish, and is proficient in French.

Lesley is admitted to practice in California (1997), the U.S. Court of Appeals for the Ninth Circuit (1998),

and the U.S. District Courts for the Northern District (1997) and the Eastern, Central, and Southern

Districts of California (1998) and the Eastern District of Michigan (2019).

JAVIER BLEICHMAR

Partner New York

x Email: jbleichmar@bfalaw.com

x Tel: +1 212 789 1341

x www.bfalaw.com/ professionals/javierͲ

bleichmar

Javier Bleichmar leads BFA’s U.S. Case Evaluation and U.S. Securities Litigation teams. He brings a long

career of litigation success to his prosecution of largeͲscale fraud class actions on behalf of investors.

Javier has nearly two decades of experience and has been “recommended” in the field of securities

litigation by The Legal 500.

Javier currently leads the BFA teams prosecuting class actions led by our clients against Teva

Pharmaceutical Industries, Ltd., Citigroup, Inc., Granite Construction Incorporated, and Align

Technology, Inc. Javier is also leading a securities action against Allianz Global Investors U.S., L.L.C. on

behalf of the Metropolitan Transportation Authority.

Javier previously led the team litigating In re MF Global Holdings Limited Securities Litigation on behalf

of Her Majesty the Queen in Right of Alberta and MF Global investors, in connection with the

company’s dramatic collapse on October 31, 2011. Judge Marrero in the Southern District of New York

sustained the complaint in its entirety, and plaintiffs secured settlements totaling over $234 million,

resolving claims against MF Global’s former officers and directors, several underwriter defendants, and

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MF Global’s outside auditor.

Javier also led the team that prosecuted Freedman v. Weatherford International Ltd., et al., on behalf

of the Anchorage Police & Fire Retirement System.The case alleged that Weatherford, which made

three restatements of audited financials totaling approximately $1 billion, misled investors about the

Company’s tax accounting.After more than three years of intense litigation, including 22 depositions

and complex expert testimony, the parties announced a proposed $120 million settlement on June 30,

2015.

Javier is also a successful appellate advocate, prevailing before the Eighth Circuit in Public Pension Fund

Group v. KV Pharmaceutical, Co. The Eighth Circuit reversed an earlier dismissal and clarified the

standard governing pharmaceutical companies’ disclosures relating to FDA notifications.

Javier is active in educating international institutional investors on developing trends in the law,

particularly the ability of international investors to participate in securities class actions outside the

United States. Through these efforts, many of Javier’s international clients were able to join the

organization representing investors (i.e., the Foundation) in the first securities class action settlement

under the thenͲrecently enacted Dutch statute against Royal Dutch Shell.He has coͲauthored articles

concerning the developments in the class action landscape in Australia, and also provides thought

leadership as a regular contributor on securities issues in the New York Law Journal.  He has coͲ

authored “IndyMac Leaves Uncertain Landscape for OptͲOut Litigation” and “The Evolving Legacy of

Fait v. Regions Financial.” Javier is an active member of the National Association of Public Pension Plan

Attorneys (NAPPA).

Prior to founding the firm, Javier was a Partner of Labaton Sucharow LLP.  He also practiced at

Bernstein Litowitz Berger & Grossmann LLP, where he was actively involved in the In re Williams

Securities Litigation, which resulted in a $311 million settlement, as well as significant securities

matters involving Lucent Technologies, Inc., Conseco, Inc. and Biovail Corp.He began his legal career at

Kirkland & Ellis LLP.

Javier earned a B.A. from the University of Pennsylvania and a J.D. from Columbia University School of

Law (1998), where he was a Harlan Fiske Stone Scholar. During law school, he served as a law clerk to

the Honorable Denny Chin, U.S. District Court Judge for the Southern District of New York. Javier is a

native Spanish speaker and fluent in French.

Javier is admitted to practice in New York (1998), the U.S. Supreme Court (2010), and the U.S. Courts of

Appeals for the Second Circuit (2010), Eight Circuit (2010), Ninth Circuit (2010), Tenth Circuit (2013),

and Eleventh Circuit (2011). He is also admitted in the U.S. District Courts for the Southern and Eastern

Districts of New York (1999). 

JOSEPH A. FONTI

Partner New York

x Email: : jfonti@bfalaw.com

x Tel: +1 212 789 1342

x www.bfalaw.com/ professionals/josephͲfonti

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Joseph A. Fonti leads the Firm’s U.S. Securities Litigation team. He has nearly twenty years of

experience in prosecuting complex litigations on behalf of institutional investors. His commitment to

clients, advocacy skills, and litigation results have resulted in Joseph being “recommended” in the field

of securities litigation by the Legal 500.

Joseph currently leads the BFA teams prosecuting class actions led by our clients against Teva

Pharmaceutical Industries, Ltd. and Citigroup, Inc.

Joseph previously served as coͲlead counsel in In re Genworth Financial Inc. Securities Litigation in the

Eastern District of Virginia – widely known as the “rocket docket.” Joseph led the litigation to a

remarkable recovery for the class in the amount of $219 million, the largest securities class action

recovery ever achieved in that jurisdiction.In defeating defendants’ motion to dismiss, Joseph secured

one of the first proͲinvestor opinions after the Supreme Court’s recent decision in the Omnicare

matter.Joseph already had notable success in the highͲpressure environment of the E.D.Va. In 2013, as

lead trial lawyer on behalf of shareholders of Computer Science Corp., after prevailing at class

certification and only four weeks before trial in the CSC matter, Joseph and his team secured a $97.5

million settlement – the secondͲlargest cash securities settlement in the court’s history.

Joseph also contributed to the prosecution and ultimate resolution of the Weatherford securities

litigation (Freedman v. Weatherford International Ltd., et al.).  Joseph’s contribution to this very

intense litigation centered on complex accounting and expert matters, and he took trial testimony of

several thirdͲparty accountants and consultants who were not expected to appear for trial.Joseph, as

part of the team led by partner Javier Bleichmar, contributed to an outstanding recovery of $120

million for Weatherford shareholders.

With over a dozen years of experience in investor litigation, Joseph’s career is also marked by

significant successes in the area of auditor liability and stock options backdating. For example, he

represented shareholders in the $671 million recovery in In re HealthSouth Securities Litigation.

Particularly, Joseph played a significant role in recovering $109 million from HealthSouth’s outside

auditor Ernst & Young LLP, one of the largest recoveries to date against an auditing firm. He also

contributed to securing a $173.5 million settlement in In re Broadcom Corp. Securities Litigation, which,

at the time, was the secondͲlargest cash settlement involving a company accused of options

backdating. This was the only such case in which claims against the auditors were sustained.

In addition to representing several of the most significant U.S. institutional investors, Joseph has

represented a number of Canada’s most significant pension systems and asset managers.  He also

provides thought leadership on issues of particular relevance to these clients.  For example, he coͲ

authored "CrossͲListed Securities Cases Present Challenges,” for the National Law Journal, (May 30,

2016), which addresses recent Morrison interpretations in light of modern financial markets.He also

led the prosecution of In re NovaGold Resources Inc. Securities Litigation, which resulted in the largest

settlement under Canada’s securities class action laws.

Additionally, Joseph has achieved notable success as an appellate advocate. He successfully argued

before the Second Circuit Court of Appeals in In re Celestica Inc. Securities Litigation. The Second Circuit

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- 23 - 

reversed an earlier dismissal and turned the tide of recent decisions by realigning pleading standards in

favor of investors. Joseph was also instrumental in the advocacy before the Ninth Circuit Court of

Appeals in the In re Broadcom Corp. Securities Litigation. This appellate victory marked the first

occasion a court sustained allegations against an outside auditor related to options backdating.

Prior to founding the firm, Joseph was a Partner of Labaton Sucharow LLP. He also practiced securities

litigation at Bernstein Litowitz Berger & Grossmann LLP, and began his legal career at Sullivan &

Cromwell LLP, where he represented Fortune 100 corporations and financial institutions in complex

securities litigation, in multifaceted SEC investigations, and at trial.

Joseph is a member of the ABA, the NY State Bar Association, the Bar of the City of New York, and the

National Association of Public Pension Attorneys (NAPPA).

Joseph earned a B.A., cum laude, from New York University and a J.D. from New York University School

of Law (1999), where he was a member of the Marden Moot Court. He is admitted to practice in New

York (2000), the U.S. Supreme Court (2007), and the U.S. Courts of Appeals for the Second Circuit

(2010), Ninth Circuit (2007), and Tenth Circuit (2013). He also is admitted in the U.S. District Courts for

the Southern and Eastern Districts of New York (2001).

DOMINIC J. AULD

Partner Toronto

x Email: dauld@bfalaw.com

x Tel: +1 212 789 1344

x www.bfalaw.com /professionals/dominicͲ

auld

Dominic J. Auld leads BFA’s NonͲU.S. Litigation team. He has more than a decade of experience in

representing and advising institutional clients in largeͲscale securities and investmentͲrelated lawsuits.

Dominic has been named a “Super Lawyer” in the field of securities litigation by Super Lawyer awards

and has been “recommended” in the field of securities litigation by The Legal 500.

Dominic is responsible for BFA’s outreach to pension systems, asset managers, and sovereign wealth

funds outside the United States – regularly advising clients in Europe, Australia, Asia, and across his

home country of Canada.

Dominic and his team have served as liaison counsel to global investors in many shareholder and

investor litigations outside the United States, including class and collective actions against Olympus

Corp. (Japan); OZ Minerals Ltd. (Australia); Fortis (Belgium and the Netherlands); Vivendi Universal

(France); and Volkswagen AG (Germany), and many other companies.

Dominic is sought after as a commentator on topics such as corporate governance, shareholder

activism, fiduciary duty, corporate misconduct, and international class and collective litigation. He has

been a regular speaker and panelist at law and investment conferences, including past events such as

the Canadian Foundation for Advancement of Investor Rights (FAIR Canada) and Osgoode Hall Law

School conference on public and private securities enforcement and investor recovery in Toronto, the

IMF Bentham shareholder class action conference in Sydney, and the Annual International Bar

Association meeting in Dubai.

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Dominic is the author of various articles of interest to the Firm’s client base, including an analysis of

shareholder remedies in Japan in Law360, and a piece regarding custodian bank fees and their impact

on pension funds globally in Nordic Regions Pensions and Investment News magazine. He is quoted in

publications including The Economist, The Financial Times, The New York Times, USA Today, The Times

of London, The Evening Standard, The Guardian, and The Daily Mail, and trade publications such as

Global Pensions, OP Risk and Regulation, The Lawyer, Investments and Pensions Europe, Professional

Pensions, and Benefits Canada. He also was interviewed by Corporate Counsel for a feature article on

rogue trading.

Prior to founding the Firm, Dominic was a Partner of Labaton Sucharow LLP. He also practiced securities

litigation at Bernstein Litowitz Berger & Grossmann LLP, where he began his career as a member of the

team responsible for prosecuting the landmark action In re WorldCom Inc. Securities Litigation, which

resulted in a settlement of more than $6 billion.

Dominic has years of experience working directly with institutional clients affected by securities fraud.

For example, he worked extensively with the Ontario Teachers’ Pension Plan Board as it led securities

actions In re Nortel Networks Corp. Securities Litigation, In re Williams Securities Litigation, and In re

Biovail Corp. Securities Litigation – cases that recovered a total of more than $1.7 billion for investors.

Dominic earned a B.A. from Queen’s University in Canada and a J.D. from Lewis and Clark Law School

(1998). He is admitted to practice in New York (1998), and in the U.S. District Courts for the Southern

and Eastern Districts of New York (2011).

Nancy A. Kulesa

Partner New York

x Email: nkulesa@bfalaw.com

x Tel: +1 212 789 1343

x www.bfalaw.com/nancyͲkulesa

Nancy Kulesa has extensive experience in complex litigation in federal and state courts, including

securities litigation, Employee Retirement Income Security Act of 1974 (ERISA) litigation, consumer

fraud litigation, mergers and acquisitions cases, and antitrust litigation.

Nancy represents public pension funds, TaftͲHartley funds, and other institutional investors in

securities class actions and derivative litigation. She has nearly two decades of experience assisting

clients in identifying material losses in their securities portfolios caused by corporate wrongdoing.

Nancy consults with institutional investors to help them monitor litigation and to evaluate

opportunities for recovery.

Nancy is currently litigating the class action against Align Technology Inc. on behalf of CourtͲappointed

Lead Plaintiff Macomb County Employee’s Retirement System. Nancy is also litigating an action against

certain members of the current and former board of directors of Tesla on behalf of the Police & Fire

Retirement System of City of Detroit, and is pursing confidential derivative actions on behalf of

additional institutional clients. Nancy has previously been counsel in numerous highͲprofile securities

fraud litigations that have recovered hundreds of millions of dollars for shareholders including:

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- 25 - 

x In re CIT Group Securities Litigation, 1:08Ͳ06613 (S.D.N.Y.) ($75 million)

x Klugmann v. American Capital Ltd., 09ͲcvͲ0005 (D. Md.) ($18 million)

x In re Nuvelo, Inc. Securities Litigation, 07ͲcvͲ4056 (N.D. Cal.) ($8.9 million)

x Bauer v. Prudential, Inc., 09ͲcvͲ1120 (JLL) (D. NJ) ($16.5 million)

x Carlson v. Xerox Corporation, 3:00CV01621 (ATW) (D Conn) ($750 million)

x Fragala v. 500.com Ltd., 2:15ͲcvͲ01463ͲMMM (C.D. Cal.) ($2.5 million)

Nancy represented a TaftͲHartley Fund in the historic settlement with TwentyͲFirst Century Fox, Inc.

regarding allegations surrounding workplace harassment incidents at Fox News, which resulted in a $90

million derivative settlement and wideͲranging corporate governance reforms at the company.

Nancy has also represented consumers in complex, class action litigation involving false advertising and

defective product claims, including serving as courtͲappointed Lead Counsel in Logan Landes, et al, v.

Sony Mobile Communications, et al, 17ͲcvͲ02264ͲJFBͲSIL (EDNY), which resulted in settlement relief to

consumers valued at over $6 million. In that litigation, the Honorable Joseph F. Bianco recognized the

high quality of her work, “The quality of the representation, as I noted, has been extremely high, not

just in terms of the favorable outcome in terms of the substance of the settlement, but in terms of the

diligence and the hard work that has gone into producing that outcome.”

Prior to joining BFA, Nancy was a partner at a wellͲestablished national securities litigation firm where

she represented investors in securities class actions and created and directed the firm’s Portfolio

Monitoring Services practice. Nancy has experience in representing corporations seeking antitrust

clearance of mergers and acquisitions and has also handled commercial litigation matters and

contractual disputes.

Nancy frequently speaks on topics related to securities litigation and investor rights at educational

forums for public pension funds and TaftͲHartley funds.

She is a member of the National Conference on Public Employee Retirement Systems (“NCPERS”),

International Foundation of Employee Benefit Plans (IFEBP), Texas Association of Public Employee

Retirement Systems (TEXPERS), Florida Public Pensions Trustees Association (FPPTA), Michigan

Association of Public Employee Retirement Systems (MAPERS) and Illinois Public Pension Fund

Association (IPFFA).Nancy serves as an Officer to the National Association of Shareholder & Consumer

Attorneys (NASCAT) as Treasurer.

Nancy was recognized by Lawdragon as a Leading Plaintiff Financial Lawyer.

Nancy earned a B.A. in International Politics from Fordham University in 1998 and a J.D. from the

University of Connecticut School of Law in 2001.

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Nancy is admitted to practice in Connecticut (2001), the United States District Court for the District of

Connecticut (2004), the United States District Court for the Southern District of New York (2015), and

the United States Court of Appeals for the Ninth Circuit (2016).

ERIN WOODS

Partner New York

x Email: ewoods@bfalaw.com

x Tel: +1 212 789 1353

x www.bfalaw.com /professionals/erinͲwoods

As CoͲDirector of Institutional Investor Relations and the head of BFA’s Claims Filing Team, Erin Wood’s

practice combines her vast experience advising institutional investors on current and potential

securities litigation and advising clients in recovering investment losses through filing settlement

claims.

With more than twelve years in the class action industry, Erin brings a unique blend of seasoned

litigator, a decade of representation of institutional investors, and expertise in the claims

administration process. Erin is currently a member of the team prosecuting the securities class action

against Citigroup, Inc. She also leads institutional investor outreach and advises pension funds and

other entities on lawsuits concerning violations of U.S. and nonͲU.S. securities and investment laws,

antitrust and consumer laws, and securities class action settlements.

Prior to joining BFA, Erin was a Director at an industryͲleading claims administration firm, where she

provided plaintiffs’ and defense counsel comprehensive, accurate, and practical approaches to class

action and mass tort settlement administration.

While working with BFA’s founding partners as an associate at their prior firm, Erin litigated securities

class actions such as In re Celestica Inc. Securities Litigation and In re NovaGold Resources Inc. Securities

Litigation, which resulted in a crossͲborder settlement that was at the time the largest settlement

under Canada’s securities class action laws, and two related cases against OppenheimerFunds Inc. that

resulted in a $100 million settlement.

Erin is a member of the National Association of Public Pension Attorneys (NAPPA), National Conference

of Public Employee Retirement Systems (NCPERS), National Council on Teacher Retirement (NCTR),

National Association of State Retirement Administrators (NASRA), State Association of County

Retirement Systems (SACRS), California Association of Public Retirement Systems (CALAPRS), and a

number of additional organizations.

Erin earned a B.A. from Villanova University in 2004 and a J.D. from Brooklyn Law School in 2008. She is

admitted to practice in New York (2009), the U.S. Courts of Appeals for the Ninth Circuit (2010) and

Second Circuit (2011), and the U.S. District Court for the Southern District of New York (2009).

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ANNE DAVIS

Partner Oakland

x Email: adavis@bfalaw.com

x Tel: +1 415 445 4016

x www.bfalaw.com/professionals/ anneͲdavis

Anne Davis joined BFA in 2018. She has a decade of experience litigating complex matters in both

federal and state courts, including the courts of California, Delaware, and Kansas. She focuses her

practice on complex investigations and litigation of antitrust, consumer, and securities matters.

Anne plays a key role in litigating In re: Facebook, Inc. Consumer Privacy User Profile Litigation; she is

also a member of the BFA teams litigating In re German Automotive Manufacturers Antitrust Litigation

and In re Domestic Airlines Travel Antitrust Litigation. She recently coͲauthored That’s The Ticket –

Game On For Plaintiffs Challenging Suppression of the Market For Football Broadcasts for the

September edition of the Antitrust, UCL and Privacy Section EͲBrief for California Lawyer’s Association,

and The Interplay of the European Union’s General Data Protection Regulation and U.S. EͲDiscovery—

One Year Later, the View Remains the Same, which was published in the Spring 2019 edition of

Competition.

Prior to joining BFA, Anne served as a Principal Counsel for Sales Practice Enforcement at the Financial

Industry Regulatory (FINRA), where she, as appropriate, brought charges and negotiated resolutions or

litigated formal actions pertaining to violations of FINRA, U.S. Securities and Exchange Commission

(SEC), and Municipal Securities Rulemaking Board (MSRB) rules, and the federal securities laws by

registered individuals and FINRA member firms.

Before FINRA, she was a senior associate at Morrison & Foerster, LLP, where she specialized in

securities litigation and enforcement, complex civil litigation, and internal investigations. She also

maintained a pro bono practice involving Title IX compliance in California public schools, litigation on

behalf of prisoners asserting Section 1983 excessive force claims, and asylum claims.

Anne earned a B.A. with honors from DePaul University (2002), a M.A. (Political Science) from the

University of Michigan (2006), and a J.D. from the University of Michigan Law School (2008). She is

admitted to practice in California (2009), and the U.S. District Courts for the Northern (2010), Central

(2011) and Eastern (2014) Districts of California and the Eastern District of Michigan (2019).

EVAN KUBOTA

Partner New York

x Email: ekubota@bfalaw.com

x Tel: +1 212 789 1347

x www.bfalaw.com /professionals/evanͲ

kubota

Evan Kubota brings substantial experience in all stages of litigation, from preͲsuit investigation and

strategic advice through motion practice, discovery, trial, and appeal. His experience includes complex

securities and derivative actions, bankruptcy confirmation and adversary proceedings, and regulatory

investigations. He has taken and defended numerous depositions, worked closely with damages and

industry experts, and participated in several trials.

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Evan is currently a member of the team prosecuting the cases against Teva Pharmaceutical Industries,

Ltd. and Granite Construction Incorporated.

Prior to joining BFA in 2019, Evan was an associate at Paul, Weiss, Rifkind, Wharton & Garrison LLP for

nine years, where he litigated highͲprofile matters on behalf of financial institutions and issuers in a

variety of industries.Representative matters include plaintiff's counsel in breach of contract, fraud and

civil RICO litigations against a distressed insurance company; debtor's counsel in a leading media

company's Chapter 11 bankruptcy, which eliminated over $1 billion in debt; and the defense of

numerous RMBSͲrelated litigations, arbitrations, and investigations in the wake of the financial crisis.

Evan earned a B.A. from the University of Florida, cum laude, in 2007 and a J.D. from Harvard Law

School, cum laude, in 2010.He is admitted to practice in New York (2011), as well as the U.S. District

Courts for the Southern and Eastern Districts of New York (2011).

MATTHEW MELAMED

Partner Oakland

x Email: mmelamed@bfalaw.com

x Tel: +1 415 445 5601

x www.bfalaw.com/ professionals/MatthewͲ

Melamed

Matthew Melamed joined the firm in 2021, focusing on prosecuting complex consumer and antitrust

matters.

Before joining the firm, Matt was a partner at Robbins Geller Rudman & Dowd LLP, where he

represented cities, counties, and states in nationwide litigation concerning the marketing, distribution,

and dispensing of prescription opioids. Among other roles in those cases, he represented the City and

County of San Francisco, whose case was remanded as an MDL bellwether from In re: National Opiate

Litigation. Matt also litigated numerous securities fraud lawsuits, including Jones v. Pfizer Inc., In re St.

Jude Medical, Inc. Securities Litigation, and Villella v. Chemical & Mining Company of Chile, Inc. He was

a member of case teams that recovered more than $1.2 billion.

Matt was previously a law clerk for the Honorable Joseph A. Greenaway, Jr. on both the United States

District Court for the District of New Jersey and the United States Court of Appeals for the Third Circuit.

He was also the KazanͲWallace Attorney at Public Justice PC. During law school, Matt was an extern for

the Honorable Susan Y. Illston, United States District Court for the Northern District of California.

Matt is admitted to practice in California (2008), the United States Courts of Appeals for the Third

(2010) and Tenth (2009) Circuits, and the United States District Courts for the Northern (2010) and

Central (2012) Districts of California.

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ROSS SHIKOWITZ

Partner New York

x Email: rshikowitz@bfalaw.com

x Tel: +1 212 789 1349

x www.bfalaw.com/professionals/rossͲshikowitz

For over a decade, Ross Shikowitz has been advising many of the world’s largest and most sophisticated

institutional investors concerning their rights and potential legal claims arising out of securitiesͲrelated

matters.He is a senior member of the firm’s Client Monitoring and Case Evaluation Group in which he,

together with a team of attorneys and financial analysts, develops and recommends legal strategies to

the firm’s clients.

Ross is also one of the lead attorneys litigating the securities class action against Granite Construction

Incorporated, which the court sustained over defendants’ motion to dismiss and recently certified as a

class action.Ross is also one of the lead attorneys representing investors in the securities class actions

concerning Citigroup Inc. and Align Technology, Inc.For his success representing investors, Ross has

consistently been named by Super Lawyers as a New York “Rising Star” in the area of securities

litigation.

Prior to joining the firm, Ross was an associate at Bernstein Litowitz Berger & Grossmann LLP where he

was a senior member of its New Matter Department.Ross was also an instrumental member of the

litigation teams responsible for recovering hundreds of millions of dollars on behalf of injured investors

that were misled when purchasing residential mortgageͲbacked securities.He also served as a member

of the litigation team prosecuting the securities fraud class action against Volkswagen, which resulted

in a recovery of $48 million for investors in Volkswagen American Depositary Receipts.  Ross also

served as a member of the team litigating the securities class action concerning GT Advanced

Technologies, which has resulted in $36.7 million in recoveries toͲdate.

Ross earned a B.A., cum laude, from Skidmore College, and an M.A. from Indiana UniversityͲ

Bloomington. He earned a J.D., cum laude, from Brooklyn law School (2010) where he worked as a

research assistant to Brooklyn Law School Professor of Law Emeritus Norman Poser, a widely respected

expert in international and domestic securities regulation. He also served as a judicial intern to the

Honorable Brian M. Cogan of the Eastern District of New York, a legal intern for the Major Narcotics

Investigations Bureau of the Kings Country District Attorney’s Office, and a summer associate at a

prominent defense firm.

Ross is admitted to practice in New York (2011), the U.S. District Courts for the Southern District of New

York (2011) and the Eastern District of New York (2011).

KENDRA SCHRAMM

Of Counsel New York

x Email: kschramm@bfalaw.com

x Tel: +1 212 789 1358

x www.bfalaw.com /professionals/kendraͲ

schramm

Kendra Schramm is a highly valued litigator with over ten years of experience prosecuting complex

securities class actions. Kendra is a key member of the Firm’s NonͲU.S. Litigation and Claims Filing

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- 30 - 

teams. She also assists the Client Reporting and Data Analysis team in assessing clients’ loss exposure in

both domestic and international matters.

Kendra acts as liaison counsel to institutional investors in securities and investmentͲrelated actions

across the globe – including in Australia, Europe, and Japan. She provides highly pragmatic advice to

sophisticated clients on the risks of participation in these cases, which often require a formal decision

to pursue a claim. She is instrumental to BFA’s outreach to institutional clients outside the United

States. In addition, Kendra recently coͲauthored "A Look at Shareholder Remedies in Japan” in Law360,

commenting on the evolving Japanese litigation regime.

Prior to joining the Firm, Kendra was an associate at Labaton Sucharow LLP, where she was a member

of the team that recovered more than $1 billion in total settlements in the landmark securities class

action against American International Group and numerous related defendants. She also was

instrumental in prosecuting the complex securities litigation against the Federal National Mortgage

Association (Fannie Mae), which successfully alleged that investors’ losses were caused by the

defendants’ misstatements and misconduct, rather than the recent financial crisis, and recovered $170

million.

Kendra earned a B.A. from New York University and a J.D. from Brooklyn Law School (2011), where she

was an Associate Managing Editor of the Journal of Law & Policy. During law school, she served as a law

clerk to the Honorable Elizabeth S. Stong, U.S. Bankruptcy Court Judge for the Eastern District of New

York. She is admitted to practice in New York (2012), New Jersey (2012), the U.S. Supreme Court

(2014), and the U.S. District Courts for the Southern District of New York (2012) and the District of New

Jersey (2012).

SARA SIMNOWITZ

Special Counsel New York

x Email: ssimnowitz@bfalaw.com

x Tel: +1 212 789 2309

x www.bfalaw.com/saraͲsimnowitz

Sara Pildis Simnowitz is Special Counsel at BFA, prosecuting a variety of complex litigations.

Sara Simnowitz has nearly twenty years of experience in all aspects of litigating complex matters.Sara

is dedicated to prosecuting securities, antitrust, and consumer fraud class actions on behalf of

institutional, municipal, and individual clients. Sara draws on her extensive litigation experience while

playing a key role in prosecuting the Firm’s antitrust and consumer cases, including In re: Facebook, Inc.

Consumer Privacy User Profile Litigation.

Sara is also a central member of the team prosecuting Ontario Teachers' Pension Plan Board, et al. v.

Teva Pharmaceutical Industries Ltd. et al., and prosecuted In re Genworth Financial Securities

Litigation on behalf of Her Majesty the Queen in Right of Alberta in the Eastern District of Virginia.

Before joining BFA, Ms. Simnowitz was a senior associate at Arnold & Porter LLP, where she focused on

complex commercial litigation. She previously practiced at Heller Ehrman LLP in New York and Foley

Hoag LLP in Massachusetts, where she focused on complex commercial and securities litigation.

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Sara earned a B.A., summa cum laude, from Brandeis University, a J.D. from the University of Chicago

Law School (2001), and an M.A. from the London School of Economics and Political Science (2002). She

is admitted to practice in Massachusetts (2002), New York (2006), the U.S. Supreme Court (2008), the

U.S. Court of Appeals for the First Circuit (2003), and the U.S. District Courts for the District of

Massachusetts (2002), the Southern and Eastern Districts of New York (2006), and the Western District

of New York (2008).

GEORGE BAUER

Associate New York

x Email: gbauer@bfalaw.com

x www.bfalaw.com /professionals/georgeͲ

bauer

For almost nine years, George Bauer has taken a lead role in all stages of complex civil litigation, from

preͲsuit investigation through motion practice, discovery, summary judgment, and trial.

George is currently a member of the teams prosecuting cases against Granite Construction

Incorporated and Allianz Global Investors U.S., L.L.C.

While an associate and later junior partner at the international law firm of Kirkland & Ellis LLP, George

gained experience taking and defending depositions, working with expert consultants and witnesses,

and appearing in court. In addition, George has handled numerous internal investigations and

investigations by both the U.S. Department of Justice and the U.S. Securities and Exchange

Commission. George has represented clients in connection with complex regulatory enforcement

matters dealing with, among other things, securities fraud, commodities fraud, and foreign bribery

issues.He has also advised transactional teams on litigation and compliance related risks.

Prior to Kirkland, George attended Brooklyn Law School where he served as a student prosecutor in the

Kings County District Attorney’s office and led the prosecution of misdemeanor domestic violence

cases.He also interned at the New York City Police Department, the U.S. Attorney’s Office for the

Eastern District of New York, the Federal Trade Commission, and the New York Attorney General’s

Office.

George earned a B.A. from the University of Massachusetts at Amherst, cum laude, in 2008 and a J.D.

from Brooklyn Law School, magna cum laude, in 2011.He is admitted to practice in New York (2012),

the Eastern District of New York (2013), and the Southern District of New York (2014).

ANGELICA ORNELAS

Associate Oakland

x Email: aornelas@bfalaw.com

x Tel: +1 415 445 4011

x www.bfalaw.com/ professionals/angelicaͲ

ornelas

Angelica Ornelas has substantial experience litigating class actions and other complex matters in

federal courts across the country. Prior to joining BFA, Angelica was an associate at Girard Sharp, where

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- 32 - 

she specialized in consumer protection and financial products litigation. While at Girard Sharp, Angelica

served as coͲclass counsel in Prather v. Wells Fargo Bank, N.A., representing individuals who received

illegal automated calls or text messages from the bank. Angelica was also a member of the litigation

team in Daccache v. Raymond James Financial, Inc., brought on behalf of victims of the Jay Peak

investment fraud—the largest in the history of the EBͲ5 visa program—and Larson v. John Hancock Life

Insurance Company (U.S.A), a certified class action alleging that John Hancock improperly inflated cost

of insurance charges deducted from its customers’ life insurance policies.

Before Girard Sharp, Angelica was a Fellow at the California Monitor Program, a program of the

California Attorney General, where she worked closely with Congresswoman Katie Porter to ensure

that the nation’s five largest mortgage servicers delivered the relief Vice President Kamala Harris

negotiated for Californians as part of the landmark $25 billion National Mortgage Settlement.

Angelica earned an undergraduate degree from UC Los Angeles and completed a master’s program at

San José State University before receiving her law degree from UC Berkeley. After law school, she

clerked for the United States District Court for the Northern District of California and the United States

Bankruptcy Court for the District of Nevada.

Angelica is an active member of the Sedona Conference, Working Group 1 on Electronic Document

Retention and Production. A frequent speaker on electronic discovery issues, she recently participated

in a panel hosted by eͲdiscovery service provider Driven, Inc. entitled “Safeguarding the AttorneyͲClient

Privilege in Discovery.” Last November, she presented at Georgetown Law’s Advanced Electronic

Discovery Institute on topics involving collection, review, and production of electronically stored

information during the COVDͲ19 pandemic. She was also featured as a panelist at the 2019 California

Employment Lawyers Association’s Electronic Discovery Seminar.

Angelica is also a member of the Federal Bar Association, was selected as "Top 40 Under 40 Civil

Plaintiff Trial Lawyers in California" by The National Trial Lawyers for 2021, and has been selected as a

Northern California Rising Star every year since 2017.

BENJAMIN F. BURRY

Associate New York

x Email: bburry@bfalaw.com

x Tel: +1 212 789 1345

x www.bfalaw.com /professionals/benjaminͲ

burry

Benjamin Burry has substantial experience representing clients in a broad range of complex commercial

and statutory litigation matters, including in contract and investment disputes, intellectual property

disputes, actions involving a wide array of business torts, fraud, breach of fiduciary duty, securities class

actions, shareholder derivative litigation, and bankruptcy litigation, as well as cases involving the

Federal Arbitration Act.He has represented clients in federal and state courts throughout the United

States, including bankruptcy court, as well as arbitration forums, private mediation, and in enforcement

proceedings.

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At BFA, Benjamin is a member of the teams prosecuting cases against Teva Pharmaceutical Industries,

Ltd. and Granite Construction, Inc.

Benjamin also maintains an active pro bono practice, including representing New York City parks and

community gardens in civil litigation as well as in corporate governance issues, land rights, local law and

regulations, licensing and leases.

Prior to joining BFA, Benjamin was a senior associate at Sidley Austin LLP, where he was a member of

the firm’s securities and shareholder litigation, commercial litigation and disputes, and Supreme Court

and appellate practices.

Benjamin earned a B.A., magna cum laude, from Illinois Wesleyan University in 2007 and a J.D. from

the University of Chicago Law School in 2010. Benjamin is admitted to practice in the U.S. Court of

Appeals for the Second Circuit (2014) and the U.S District Courts for the Southern and Eastern Districts

of New York (2013). After earning his law degree, Benjamin served as law clerk to the Honorable Susan

P. Read of the New York Court of Appeals.

THAYNE STODDARD

Associate New York

x Email: tstoddard@bfalaw.com

x Tel: +1 212 789 1355

x www.bfalaw.com /professionals/thayneͲ

stoddard

Thayne Stoddard is a capable litigator with experience in all aspects of litigation, including investigating

and drafting claims, briefing dispositive and other motions, coordinating discovery efforts, and

preparing for and attending trial.

At BFA, Thayne primarily prosecutes complex securities fraud cases on behalf of institutional investors,

and is a member of the teams prosecuting cases against Teva Pharmaceutical Industries, Ltd. and

Citigroup, Inc.

Prior to joining BFA, Thayne was an associate at Kirkland & Ellis LLP for over three years and

represented clients in numerous securities class action, complex commercial, shareholder, and

bankruptcy cases.

Thayne earned a B.A. from Yale University in 2011, a J.D. from Duke University School of Law in 2014,

and a M.A. from Duke University in 2014.Thayne is admitted to practice in New York (2015) and the

U.S. District Court for the Southern District of New York (2016).

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NICHOLAS DENNANY

Associate New York

x Email: ndennany@bfalaw.com

x Tel: +1 212 789 1354

x www.bfalaw.com/nicholasͲdennany

Nicholas Dennany focuses his practice on investigating and analyzing pending and potential securities

fraud and derivative claims and assists the Firm advise and recommend strategies to its clients to

ensure that their rights are protected.Nick is also a member of the Firm’s litigation team and has more

than a decade of litigation experience, with specific expertise in discovery matters and managing largeͲ

scale electronic document reviews.

Nick was a member of the team that prosecuted Genworth Financial in the notoriously fastͲpaced

jurisdiction of the Eastern District of Virginia. The case alleged that the defendants misled investors

about the true state of the company’s deteriorating longͲterm care business. BFA recovered $219

million for investors – the largest ever class action settlement in Virginia.

Nick was also a key contributor to the Firm’s recent success in MF Global, in connection with the

company’s dramatic collapse on October 31, 2011. The plaintiffs secured several settlements totaling

more than $234 million, resolving claims against MF Global’s former officers and directors, several

underwriter defendants, and MF Global’s outside auditor.

Prior to joining the Firm, Nick worked with many of the attorneys now at BFA while at Labaton

Sucharow LLP, where he was a member of the team that successfully prosecuted securities claims In re

Broadcom Corp. Securities Litigation ($173.5 million settlement) and In re NovaGold Resources Inc.

Securities Litigation ($26.6 million settlement).

Nick earned a B.A., cum laude, from the University of Florida and a J.D. from the University of Florida,

Levin College of Law (2004). He is admitted to practice in New York (2006).

JOSHUA SAMRA

Associate Oakland

x Email: jsamra@bfalaw.com

x Tel: +1 415 445 4017

x www.bfalaw.com/professionals /joshuaͲ

samra

Joshua Samra is an associate in the Firm’s Antitrust and Consumer practice group. Josh currently plays a

significant role in the In re: Facebook, Inc. Consumer Privacy User Profile Litigation.

Prior to joining BFA, Josh was a Deputy District Attorney in Contra Costa County. As a Deputy District

Attorney, Josh oversaw all parts of criminal prosecutions, including filing complaints, preparing and

arguing motions, interviewing witnesses, trying cases before a jury, and litigating postͲtrial appeals.

During his time in the District Attorney’s office, Josh prosecuted ten jury trials to verdict.

Josh earned his B.A. from the University of California Berkeley (2013) and his J.D. from the University of

California Los Angeles (2016), where he served as an Associate Editor for the UCLA Law Review. Josh is

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 40 of 50 PageID #:4340
- 35 - 

admitted to practice in California (2016) and the U.S. District Courts for the Northern (2019) and

Central (2019) Districts of California and for the Eastern District of Michigan (2019).

MATHEW HOUGH

Associate New York

x Email: mhough@bfalaw.com

x www.bfalaw.com /professionals/mathewͲ

hough

Mathew Hough’s practice focuses on securities litigation, corporate governance, and shareholder rights

litigation.Mathew is skilled in all aspects of litigation, including investigating potential securities fraud

claims, briefing dispositive motions, and coordinating discovery efforts.

Matt is currently a member of the team prosecuting the securities class action against Teva

Pharmaceutical Industries, Ltd.

Prior to joining the Firm, Mathew was an associate at a prominent plaintiffs’ securities class action law

firm, where he counseled institutional investors on potential legal claims as part of a team of attorneys,

financial analysts, and investigators.Mathew was also previously an associate at Sullivan & Cromwell

LLP where he worked extensively on complex commercial litigation, securities litigation, enforcement,

and internal investigations.

Mathew earned a B.A. from Washington State University in 2012, and a J.D., magna cum laude, from

Boston University School of Law in 2017.Mathew is admitted to practice in New York (2018).

FREDERICK WILLIAM GREEN

Associate New York

x Email: wgreen@bfalaw.com

x Tel: +1 212 789 1348

x www.bfalaw.com /professionals/frederickͲ

green

Frederick William Green (“Will”) joined the firm in 2014 and is currently a Senior Projects Associate

who assists with a number of the firm’s securities litigation cases.

Will previously contributed to the Firm’s discovery efforts in In re Genworth Financial Inc. Securities

Litigation, managing the staff attorney discovery team from inception to settlement. The case alleged

that Genworth, the largest seller of longͲterm care insurance in the U.S., misled investors about the

true state of its deteriorating longͲterm care business. On May 1, 2015, U.S. District Judge James R.

Spencer denied defendants’ motion to dismiss. The parties reached a settlement of $219 million,

establishing a record for securities litigations in the Eastern District of Virginia.

Previously, Will contributed to the Firm’s discovery efforts in the securities litigation against

Weatherford International Ltd. on behalf of the Anchorage Police & Fire Retirement System (Freedman

v. Weatherford International Ltd., et al.). The case alleged that Weatherford, which made three

restatements of audited financials totaling approximately $1 billion, misled investors about the

Company’s tax accounting.After more than three years of intense litigation, including 22 depositions

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- 36 - 

and complex expert testimony, plaintiffs reached an outstanding recovery of $120 million on behalf of

shareholders.

Will received a B.A. from Union College (2009) and a J.D. from Washington University in St. Louis

(2013).Will is admitted to practice in New York (2015) and in Massachusetts (2013).

FRANKLYN WILLIAMS

Senior Projects Attorney New York

x Email: fwilliams@bfalaw.com

x Tel: +1 212 789 1357

x www.bfalaw.com /professionals/franklynͲ

williams

Franklyn Williams brings nearly a decade of legal experience to his role as a Senior Projects Attorney.

As a Senior Projects Attorney, Franklyn is an integral part of the team currently litigating Ontario

Teachers' Pension Plan Board, et al v. Teva Pharmaceutical Industries Ltd. et al, which alleges that Teva

fraudulently misled investors about its U.S. generics business, its financial performance, and its

participation in a widespread generic drugs antitrust conspiracy.

Prior to joining BFA, Franklyn served as a Team Leader on a variety of complex litigation.He was also

contracted to serve as part of the team at Robbins Geller Rudman & Dowd that litigated Beaver County

Emps’ Ret. Fund v. Tile Shop Holdings, Inc., resulting in a $9.5 million recovery.

Franklyn received his J.D. in 2006 from Boston University School of Law where he served as the Editor

in Chief of the Boston University International Law Journal and participated in the Civil Litigation Clinic.

Franklyn earned his BA in 2003 from Cornell University with a minor in Law & Society and majors in

both government and philosophy.While attending Cornell, Franklyn externed with Judge Patricia Anne

Williams of the Bronx County Supreme Court and summer interned with both NYC HRA Bureau of Fraud

Investigation and NYC ACS Legal Division.

Franklyn is admitted to practice in New York (2008) and New Jersey (2007).

JANELLE MOODY

Projects Associate Oakland

x Email: jmoody@bfalaw.com

x Tel: +1 415 445 4006

x www.bfalaw.com/janelleͲmoody

Janelle Moody joined the Firm in 2016 and is currently a Projects Associate in BFA’s Oakland office.

Janelle brings extensive experience in all phases of litigation to the Firm. She currently plays a

significant role in managing discovery in In re Facebook, Inc. Consumer Privacy User Profile Litigation.

Her role of providing strategic discovery advice was integral in the negotiation of electronic discovery

issues in the In re ChryslerͲDodgeͲJeep EcoDiesel Marketing, Sales Practices, and Products Litigation.

Janelle earned her J.D. from Northwestern School of Law at Lewis and Clark College (1997) and is

admitted to practice in California (2003) and Oregon (1998).

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KATHERINE SULLIVAN

Projects Associate Oakland

x Email: ksullivan@bfalaw.com

x Tel: +1 415 445 4014

x www.bfalaw.com/katherineͲsullivan

Katherine Sullivan (‘Kasey”) joined the Firm in 2016 and is currently a Projects Associate in BFA’s

Oakland office. Kasey brings nearly two decades of experience to BFA. She currently plays a significant

role in managing third party discovery in the In re Domestic Airlines Travel Antitrust Litigation and In re

Facebook, Inc. Consumer Privacy User Profile Litigation.

Kasey earned her J.D. from Northwestern University School of Law (1999), and is admitted to practice

in California (2000).

DAVID WAX

Staff Associate New York x Email: dwax@bfalaw.com

x www.bfalaw.com /professionals/davidͲwax

David Wax has significant experience litigating complex matters in New York Federal and State Courts.

David focuses his practice on the discovery phase of complex commercial litigations and has played a

meaningful role supporting the litigation teams in the Firm’s securities, antitrust and consumer class

action practice groups.

Prior to joining BFA Mr. Wax was an associate at a large New York law firm where he focused his

practice on class actions, insurance and contractual disputes, and complex judicial foreclosures.

David earned his J.D. from Fordham University School of Law (2008) and is admitted to practice in New

York (2009) and the Southern and Eastern District of New York (2009).

SYLVIA SUM

Staff Associate Oakland

x Email: ssum@bfalaw.com

x Tel: +1 415 445 4003

Sylvia Sum joined the firm in 2016, and is a staff associate at BFA’s Oakland office where she focuses on

prosecuting consumer and antiͲtrust class actions. Sylvia brings over twenty years of experience to BFA.

She has played a meaningful role in litigating several matters including In re Volkswagen “Clean Diesel”

Marketing, Sales Practices, and Products Liability Litigation and In re ChryslerͲDodgeͲJeep EcoDiesel

Marketing, Sales Practices, and Products Liability Litigation. In each of these litigations Sylvia’s German

language skills have been critical in analyzing the evidence underlying plaintiffs’ claims.

Sylvia earned her J.D. from the UCLA School of Law (1997), and is admitted to practice in California

(2000) and Oregon (1997).

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- 38 - 

GLEN TSURUDOME

Staff Associate Oakland

x Email: gtsurudome@bfalaw.com

x Tel: +1 415 789 1348

Glen Tsurudome joined BFA’s Oakland office in 2019 where he is currently a Staff Associate. Glen brings

over a decade of experience to his role as staff associate at BFA’s Oakland office where he focuses on

prosecuting consumer and antitrust class actions.

Glen received a B.A. (2005) from the University of California, San Diego and a J.D. from the University of

San Francisco School of Law (2005). Glen has also completed the Yamasa Institute Academic Intensive

Japanese Program (2012). Glen is admitted to practice in California (2005).

CHRISTOHER CAPUOZZO

Associate Director, Client Data and

Claims

New York

x Email: ccapuozzo@bfalaw.com

x Tel: +1 212 789 2307

x www.bfalaw.com /professionals/christopherͲ

capuozzo

Christopher Capuozzo is a Senior Data Analyst who joined BFA in January 2017 with more than twelve

years of experience in the securities class action and claims filing fields. Chris is a member of the Firm’s

Data Analysis team, contributing to BFA’s Global Investment Monitoring Program and analyzing clients’

loss exposure to financial fraud across the global marketplace. He also is a member of the Firm’s Claims

Filing team and is instrumental in the preparation of claim documents on behalf of eligible clients. His

financial analysis assists in the identification and evaluation of potential opportunities for the Firm’s

clients to serve as lead plaintiff, participate in direct actions, join actions outside the United States, and

recover from settled matters.

Prior to joining BFA, Chris was a Data Analytics Manager at a securities litigation firm, where he

managed a team of analysts providing portfolio monitoring services to the Firm’s client base, and also a

Research Analyst at the Goal Group of Companies, a global leader in class action recovery

services. Chris began his career at a prominent claims administrator. During his time there, he

processed electronically filed claims from leading financial institutions, and advised the company’s

software developers about what fields to include and how to structure their secure claim filing website

for institutional investors.

VICTORIA TSE

Senior Data Analyst New York

x Email: vtse@bfalaw.com

x Tel: +1 212 789 3601

x www.bfalaw.com /professionals/victoriaͲtse

Victoria Tse joined BFA in 2020 as a Senior Data Analyst. Victoria monitors client portfolios to identify

and evaluate investment losses, exposure to financial fraud, and potential opportunities for BFA clients

to serve as lead plaintiff, participate in direct actions, join class action litigation in nonͲU.S. jurisdictions,

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- 39 - 

and recover from class action settlements. In assessing client exposure, she evaluates recovery

opportunities for clients based on courtͲapproved loss methodologies for a wide variety of securities

fraud allegations. Victoria also helps oversee the acquisition of client investment data from custodians

on a monthly basis, as well as maintains clients’ accounts by performing annual reviews.

Prior to joining the Firm, Victoria was a senior data analyst at a securities litigation firm.

Elaine Rivera

Data Analyst New York

x Email: erivera@bfalaw.com

x Tel: +1 212 789 3604

x www.bfalaw.com /professionals/elaineͲ

rivera

Elaine Rivera monitors and analyzes client exposure to financial fraud and evaluates investment losses

and potential opportunities for clients to serve as lead plaintiff. In assessing client exposure, she

evaluates recovery opportunities for clients based on courtͲapproved loss methodologies for a wide

variety of securities fraud allegations. Elaine also assists with determining client eligibility to participate

in class action settlements and submitting the necessary claim documents on behalf of eligible clients.

Prior to joining BFA, Elaine was a Data Analyst at a securities litigation firm.

Jeffrey Esperance

Data Analyst New York

x Email: jesperance@bfalaw.com

x Tel: +1 212 789 2306

x www.bfalaw.com /professionals/jeffreyͲ

esperance

Jeffrey Esperance monitors and analyzes client exposure to financial fraud and evaluates investment

losses and potential opportunities for clients to serve as lead plaintiff. In assessing client exposure, he

evaluates recovery opportunities for clients based on courtͲapproved loss methodologies for a wide

variety of securities fraud allegations.

Jeffrey also assists with determining client eligibility to participate in international securities cases and

in class action settlements.

Prior to joining BFA, Jeffrey was a Data Analyst at a securities litigation firm.

Jeffrey received a Bachelor of Arts from Baruch College.

Umang Narayan Suhalka

Data Analyst New York

x Email: usuhalka@bfalaw.com

x Tel: +1 212 789 3605

x www.bfalaw.com /professionals/jeffreyͲ

esperance

Umang Narayan Suhalka is a Data Analyst at BFA, where he maintains BFA’s proprietary database,

monitors and analyzes client exposure to financial fraud, and evaluates investment losses and potential

opportunities for clients to serve as lead plaintiff. In assessing client exposure, he evaluates recovery

opportunities for clients based on courtͲapproved loss methodologies for a wide variety of securities

fraud allegations.

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- 40 - 

Umang also assists with determining client eligibility to participate in international securities cases and

in class action settlements.

Prior to joining BFA, Umang interned at a financial services firm.

Umang received a Bachelor of Engineering in Computer Science from the University of Pune and a

Masters of Science in Information Technology from New York University.

TRACEY SHEAK

Marketing Director New York

x Email: tsheak@bfalaw.com

x Tel: +1 860 810 9177

x www.bfalaw.com /professionals/traceyͲ

sheak

Tracey Sheak leads BFA’s marketing efforts, with responsibility for client outreach and initiatives with

institutional investors throughout the United States.

Tracey is actively involved in the firm’s plans and presentations at industry events, conferences, and

organizations including the National Conference on Public Employee Retirement Systems (NCPERS),

International Foundation of Employee Benefit Plans (IFEBP), as well as many state pension associations,

including Texas, Massachusetts, Michigan, Florida, Georgia and Illinois.

A seasoned marketing professional, Tracey has nearly two decades of experience working closely with

attorneys and assisting them to expand and enhance the firm’s outreach. She also works with firm

leadership on a variety of strategic initiatives to further the firm’s leading brand and market position.

Outside the firm, Tracey is a successful entrepreneur and founder and president of a highͲquality

cosmetic and medicinal herbal product line.She has been involved in her communities for many years,

volunteering time with organizations including Massachusetts Special Olympics, Hole in the Wall Gang

Camp SCUBA Experience, and St. Vincent De Paul warming shelters along with many local and global

environmental and humanitarian initiatives.Tracey resides in Connecticut where she raised her family

and still enjoys many outdoor sports and activities along the shore.

For more information, please visit:

www.bfalaw.com

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 46 of 50 PageID #:4346
Exhibit 

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 47 of 50 PageID #:4347
Firm Name:

Categories: TITLE:

ATTORNEYS(P, A)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS HOURS CURRENT 

HOURS

CUMULATIVE 

HOURS

Angelica Ornelas (A) 3.20 73.30 5.50 0.50 1.40 0.00 83.90 83.90 Kelsey Robertson (A) 30.20 0.00 30.20 30.20 Joshua Samra (A) 16.00 114.30 0.00 130.30 130.30 

Lesley Weaver (P) 7.90 135.80 7.30 13.40 21.00 0.00 185.40 185.40 SUB-TOTAL 0.00 0.00 27.10 0.00 353.60 0.00 0.00 0.00 12.80 13.90 22.40 0.00 0.00 0.00 0.00 0.00 429.80 429.80 

NON-ATTORNEYS(LC, SPL, PL)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS HOURS CURRENT 

HOURS

CUMULATIVE 

HOURS

0.00 0.00 0.00 

SUB-TOTAL 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 GRAND TOTAL: 0.00 0.00 27.10 0.00 353.60 0.00 0.00 0.00 12.80 13.90 22.40 0.00 0.00 0.00 0.00 0.00 429.80 429.80 

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2

TIME REPORT SUMMARY AT CURRENT RATES

Bleichmar Fonti & Auld LLP Reporting Period: Inception through February 28, 2022

1) Legal Research2) Investigation / Factual Research3) Discovery  (Written / Deposition Taking &  Defending / Meet & Confer / etc. )4) Document Review (Including for depo prep, class cert, experts, liability issues,  jurisdictional issues, and meetings  re doc review)

5) Pleadings, Briefs & Motions (Drafting, Research, Serving & Filing)6) Class Certification7) Summary Judgment8) Appeals9) Court Appearance and Prep10) Experts 

11) Settlements & Mediation12) Case Management13) Class Notice 14) Trial Prep  (Exhibit & Witness List/Jury Instruction/  Vior Dire/Opening Statements/Closing  Arguments/Demonstratives/etc.)15) Trial

(P(A(L(S(P

 556281 

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 48 of 50 PageID #:43
Exhibit 

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 49 of 50 PageID #:4349
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees $800.00

Experts/consultants $3,000.00

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw $318.92

Photocopies - in House

Photocopies - Outside $405.00

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous

TOTAL EXPENSES $4,523.92

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 3 

EXPENSE REPORT SUMMARY

FIRM NAME: Bleichmar Fonti & Auld LLP

REPORTING PERIOD: Inception through February 28, 2022

 556281 Ex 3 Expense Summary

Case: 1:20-cv-04699 Document #: 197-40 Filed: 03/31/22 Page 50 of 50 PageID #:4350