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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE: TIKTOK, INC., ) 

CONSUMER PRIVACY ) MDL No. 2948 

LITIGATION, ) 

 ) Master Docket No. 20 C 4699 

 ) 

 ) Judge John Z. Lee 

 ) 

 ) Magistrate Judge Sunil R. Harjani 

This Document Relates to All Cases ) 

DECLARATION OF KARA M. WOLKE

I, Kara M. Wolke, declare as follows: 

1. I am a senior Partner at Glancy Prongay & Murray LLP (“GPM” or “Glancy 

Prongay”). My firm is co-counsel for plaintiffs Misty Hong, minor A.S., through her mother and 

legal guardian Laurel Slothower, and minor A.R., through her mother and legal guardian Gilda Avila 

(“Plaintiffs”). 

2. I submit this Declaration in support of my Application for Plaintiffs’ Steering 

Committee, Nomination of Ekwan Rhow and Megan Jones as co-lead counsel, and David Given 

and Amanda Klevorn to the Plaintiff’s Steering Committee Motion for Appointment of Interim 

Lead Counsel. I have personal knowledge of the facts set forth herein and if called to testify 

regarding the statements herein, I could and would competently do so. 

MY CLASS ACTION AND CHINA-RELATED EXPERIENCE 

3. For my entire legal career, I have primarily represented consumers and investors in 

class action cases. Some of the cases in which I served as Lead or Co-Lead Counsel and where I 

was in charge of the litigation for GPM, and other cases where I was not appointed lead but had 

significant leadership responsibility include: Shah v. Zimmer Biomet Holdings, Inc., Case No. 3:16-cv00815 (N.D. Ind.) (lead class counsel, $50 million settlement); Christine Asia Co. Ltd. v. Jack Ma et al.

(Alibaba), Case No. 1:15-md-02631 (S.D.N.Y.) (additional counsel with significant leadership 

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responsibility, including for Chinese discovery, $250 million settlement); Zacharia v. Straight Path 

Communications, Inc., Case No. 2:15-cv-08051 (D.N.J.) (lead class counsel, $9.45 million settlement); In 

re K12 Inc. Securities Litig., Case No. 4:16-cv-04069 (N.D. Cal.) (lead class counsel, $3.5 million 

settlement); Farmington Hills Employees’ Retirement System v. Wells Fargo Bank, Case No. 10-4372 (D. 

Minn.) (class counsel, $62.5 million settlement); In Re: Mannkind Corporation Securities Litigation, Case 

No. 11-929 (C.D. Cal) (class counsel, $22 million settlement); Schleicher, et al. v. Wendt, et al.

(Conseco), Case No. 02-cv-1332 (S.D. Ind.) (class counsel, $41.5 million settlement); and many 

other multimillion dollar recoveries. 

4. My experience in Alibaba will be especially useful in this case. Throughout that 

litigation, I helped coordinate, implement, and manage all aspects of e-discovery and depositions of 

China-based defendant Alibaba, which litigation settled for $250 million. Among other things, I 

oversaw our team’s review and analysis of more than 1.1 million pages of documents produced by 

Defendants and third parties, a substantial number of which were produced in Mandarin Chinese 

and thus required review by Mandarin Chinese-speaking attorneys, as well as translation and 

preparation of the documents for use in U.S. litigation. I also coordinated and took numerous 

Mandarin-language depositions in Hong Kong, which depositions involved the use of interpreters 

and check interpreters. As a result of this work, I have established relationships with China-based 

court reporters, videographers, and interpreters, as well as project attorneys fluent in Mandarin and 

document translation firms. I am confident that I can efficiently and effectively manage all aspects 

of affirmative discovery in this action, including any China-based discovery. 

5. Given my experience in the Alibaba case, I have volunteered to oversee and direct, 

in assistance of the appointed Co-Lead Counsel, the extensive discovery that will take place in the 

United States and China. This will also include navigating the complex e-discovery issues relating to 

relevant source code information, foreign language document translation and managing an efficient 

document review process. 

THE GPM TEAM MANAGING THE HONG LITIGATION 

6. In addition to myself, the GPM team on this case consists of Marc Godino, who has 

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decades of consumer protection experience, including consumer privacy matters, and who manages 

GPM’s consumer class action department. Mr. Godino has been appointed class counsel in a variety 

of class actions, including MDL litigation. Mr. Godino was recently appointed to an executive 

committee in an MDL case involving a large consumer medical data breach in In Re: American Medical 

Collection Agency, Inc. Customer Data Security Breach Litigation, Case No, 19-md-2904 (D. N.J.) 

7. Mr. Godino has successfully litigated a variety of class actions with GPM including: 

Castillo, et al., v. Seagate Technology, LLC, Case No. 16-cv-01958-RS (N.D. Cal.) (data breach case in 

which the class benefits were valued at $42 million and also included injunctive relief); In re 

Zappos.com, Inc. Customer Data Security Breach Litigation, Case No. 12-cv-00325 (D. Nev.) (after 

defeating a motion to compel arbitration as well as obtaining a reversal in the Ninth Circuit of the 

lower court’s dismissal of this data breach case, a favorable class settlement was achieved); Gann, et 

al., v. Nissan North America, Inc., Case No. 18-00966 (M.D. Tenn.) (extended warranty for class 

vehicles alleged to have defective transmissions as well as a reimbursement program valued at over 

$400 million); Feist, et al, v. Petco Animal Supplies, Inc., Case No. 16-cv-1359 (S.D. Cal.) ($1.2 million 

FCRA class settlement); Story v. Mammoth Mountain Ski Area, LLC, No. 2:14-cv-02422 (E.D. Cal.) 

($3.75 Million TCPA class settlement); Peterson v. CJ America, Inc., Case No. 14-02570 (S.D. Cal.) 

($1.5 Million class settlement in food mislabeling case); Pappas v. Naked Juice Co. of Glendora, Inc., Case 

No. 11-08276 (C.D. Cal.) ($9 million settlement plus injunctive relief in this food mislabeling case); 

In re Magma Design Automation, Inc. Securities Litigation, Case No. 05-2394 (N.D. Cal.) ($13.5 million 

securities settlement); Kelly v. Phiten USA, Inc., Case No. 11-67 (S.D. Iowa) ($3.2 million settlement 

plus injunctive relief in false advertising case); Payday Advance Plus, Inc. v. MIVA, Inc., Case No. 06-

1923 (S.D.N.Y.) ($3.9 million settlement in this “click fraud” case); Sciortino v. Pepsico, Inc., Case No. 

14-478 (N.D. Cal.) (obtained nationwide injunctive relief requiring certain Pepsico products to 

comply with California’s Proposition 65); In Re: Bank of America Credit Protection Marketing and Sales 

Practices Litigation, Case No. 11-md-02269 (N.D. Cal.) ($20 million settlement involving the bank’s 

payment protection plan). 

8. I will also have the support of Jonathan Rotter, who has been instrumental in the 

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investigation and prosecution of this case, and who has extensive experience in technical and patent 

related matters as well as class actions including in the fields of data privacy, digital content, 

securities, consumer protection, and antitrust. Since joining the firm, he has played a key role in 

cases recovering over $100 million. Before joining the firm, Mr. Rotter served for three years as the 

first Patent Pilot Program Law Clerk at the United States District Court for the Central District of 

California. There, he assisted the Honorable S. James Otero, Andrew J. Guilford, George H. Wu, 

John A. Kronstadt, and Beverly Reid O’Connell with hundreds of patent cases in every major field 

of technology, from complaint to post-trial motions, advised on case management strategy, and 

organized and provided judicial education. Mr. Rotter also served as a law clerk for the Honorable 

Milan D. Smith, Jr. on the United States Court of Appeals for the Ninth Circuit, working on the full 

range of matters handled by the Circuit. 

9. Also assisting me in this case is Pavithra Rajesh, who has been a key attorney in 

drafting the pleadings and motions to date. She specializes in fact discovery, including pre-litigation 

investigation, and develops legal theories in securities, derivative, and privacy-related matters. Ms. 

Rajesh unique writing experience derived from her judicial externship for the Patent Pilot Program 

in the United States District Court for the Central District of California, where she worked closely 

with the Clerk and judges in the program on patent cases. Drawing from this experience, Ms. Rajesh 

regularly engages with experts to understand a wide range of complex technology, including network 

security and videogame electronics. 

GPM’s SIGNIFICANT WORK ON THE HONG CLASS ACTION 

10. Since early 2019, GPM along with co-counsel Bird, Marella, Boxer, Wolpert, Nessim, 

Drooks, Lincenberg & Rhow, P.C. (“Bird Marella”) have devoted significant time and resources 

investigating the facts underlying this case, resulting in the most detailed complaint filed against 

defendants alleging defendants’ misappropriation of personal consumer data. Our investigation of a 

constellation of smartphone app data privacy issues leading to the development of the specific 

allegations in this case stretches back even further. 

11. GPM researched numerous legal issues in the data privacy field as they relate to this 

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case – such as (1) jurisdiction and venue; (2) potential causes of action; (3) standing; (4) damages; (5) 

injunctive relief; (6) notice and consent, and (7) arbitration and class action waivers to craft the initial 

November 27, 2019 46-page complaint, an even more detailed May 11, 2020 89-page amended 

complaint, and a 112-page consolidated complaint in this Court on August 14, 2020, which included 

a VPPA claim potentially worth billions of dollar, based on the illicit transfer of private and 

personally identifiable video viewing histories to Facebook and Google. 

12. In addition, my firm worked closely with highly trained source code experts in 

analyzing multiple versions of the Musical.ly and TikTok apps to uncover (1) the various types of 

private and personally-identifiable data stolen by defendants and third-party entities whose software 

development kits and analytic libraries are secretly embedded within the apps, and (2) the domestic 

and foreign destinations of such misappropriated data. 

13. Bird Marella and GPM teamed up with Phillips, Erlewine, Given & Carlin LLP 

(“Phillips Erlewine”) in early 2020, and the three firms invested additional time and resources to 

build upon earlier work and further develop the factual and legal foundation for an Illinois Biometric 

Information Privacy Act, 740 ILCS 14/1 et seq. (“BIPA”) claim and provide further support for the 

other claims, including by hiring another highly trained source code expert who teaches at a 

prominent university and a biometrics expert with experience in BIPA litigation, both of whom 

helped to develop the unlawful face geometry scanning allegations. 

14. GPM has also been consulting with well-credentialed experts who have conducted 

original research into the intersection of data privacy, artificial intelligence, Chinese corporations and 

the Chinese government, including Chinese laws requiring corporations to share data with the 

government. 

15. In early 2020, Bird Marella, Glancy Prongay, and Phillips Erlewine invested 

substantial time and resources to further develop the factual and legal foundation for a BIPA claim, 

including hiring another highly trained source code expert who teaches at a prominent university and 

a biometrics expert with notable experience in BIPA litigation, both of whom helped to develop the 

unlawful face geometry scanning allegations. The 89-page amended Hong complaint contains the 

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most thorough BIPA allegations among the competing lawsuits, focusing not just on the app’s 

conspicuous Augmented Reality (“AR”) features that are the cornerstone of other lawsuits, but also 

on considerably stronger evidence of BIPA violations (and violations of other statutes and common 

law), such as: 

 the functionality and code of the TikTok app, including (1) content recommendations based on 

TikTok users’ race/ethnicity and age; (2) scans of face geometry to determine TikTok users’ age; 

(3) censoring video content to remove people defendants consider “ugly”; (4) code for deepfake 

videos; and (5) code for age, race/ethnicity and emotion recognition; 

 ongoing work in China, including (1) the application of facial recognition technology to TikTok 

users’ videos by highly-trained engineers skilled in computer vision, convolutional neural 

network and machine learning; (2) patent applications for face, voice, age, race/ethnicity and 

emotion recognition technologies; and (3) the publicly-known functionality of the Chinese 

version of TikTok (Douyin) that allows its users to perform facial recognition on faces selected 

by such users from other users’ videos; and 

 the defendants’ legal and political obligations to accumulate and share vast troves of data, 

including biometrics, in order to assist the Chinese government in achieving world dominance in 

artificial intelligence, and population surveillance and control. 

16. GPM has been collecting and analyzing numerous iterations of the TikTok terms of 

use and privacy policies upon which defendants will rely for their arbitration and consent defenses 

and developing the arguments and evidence necessary to defeat those defenses. 

17. My firm is also thoroughly researching the defendant corporations – with the aid of 

two teams of investigators in California and in China and an ESI expert – to better understand 

defendants’ corporate structure, document and data collection and retention systems, internal 

reporting systems, business and advertising models, artificial intelligence and patent development 

programs, and other relevant foreign and domestic activities, all of which is critically important to 

establishing the statutory and common law violations, the class’s damages, defendants’ unjust 

enrichment, and the alter ego defense to the foreign defendant companies’ anticipated personal 

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jurisdiction challenge. 

18. Bird Marella, GPM, and Phillips Erlewine also participated in an April 6, 2020 

mediation of the eight original claims in the Hong complaint as well as the BIPA claim before 

former United States District Judge Layn Phillips. Plaintiffs and defendants exchanged two rounds 

of extensive briefing on many of the critical issues in the case, further preparing the Bird Marella, 

GPM and Phillips Erlewine firms for defendants’ anticipated motions. Also, Bird Marella and GPM 

served eight sets of discovery on defendants prior to mediation, and defendants responded to each. 

The two firms also negotiated and agreed to a protective order with defendants to facilitate 

discovery. 

19. Although, along with the rest of the executive committee appointed by Judge Koh in 

In re: TikTok, Inc. Privacy Litigation, we did not believe that another mediation was appropriate before 

the determination of venue, once the J.P.M.L. centralized the cases in this Court, we attempted to 

attend the second mediation, but were excluded by Defendants based on their unfounded “feeling” 

that we, together with the Bird Marella firm, had “secret clients” in the case. That is, and has always 

been, untrue. We also agreed to attend a third mediation with Defendants, see Status Report, Doc. 

No. 7, but that mediation was scuttled by the Settling Plaintiffs, see Status Report, Doc No. 8. 

GPM IS ONE OF THE PREMIER CLASS ACTION FIRMS IN THE COUNTRY 

20. GPM has been protecting consumers for more than 25 years and has significant 

knowledge and experience handling class actions, complex litigation and the types of claims involved 

in this case. GPM’s practice exclusively focuses on class actions and other complex litigation in state 

and federal courts all around the country. GPM is one of the premier plaintiffs’ class action firms in 

the country. Attached hereto as Exhibit A is a true and correct copy of GPM’s current firm resume, 

reflecting the firm’s experience in class action litigation. 

21. As reflected in Exhibit A, GPM has recovered billions of dollars on behalf of 

consumers and investors nationwide. As with all class actions GPM has prosecuted, GPM will 

commit all necessary resources to this action. Class actions can be litigated for many years, and 

GPM has the resources to fund such long-term litigation, as reflected by the firm’s resume. For 

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example, GPM was Class Counsel in Schleicher v. Wendt, Case No. 021332 (S.D. Ind.), for nine years 

of litigation before reaching a $41 Million settlement. GPM is fully prepared to invest the financial 

resources necessary in this case as well. 

22. GPM has a reputation for working cooperatively with other firms. Indeed, GPM’s 

track record in serving as Lead or Co-Lead in some cases, while serving on executive committees in 

others, proves this point. 

23. Additionally, GPM knows how to effectively manage cases to ensure that high 

quality work is being performed while at the same time ensuring that cases are not overstaffed and 

that duplicated efforts are avoided. 

I declare under penalty of perjury under the laws of the State of California and the United 

States that the foregoing is true and correct, and that I executed this declaration on September 8, 

2020, at Los Angeles, California.

 /s/ Kara M. Wolke

Kara M. Wolke 

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EXHIBIT A 

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FIRM RESUME

Glancy Prongay & Murray LLP (the “Firm”) has represented investors, consumers and 

employees for over 25 years. Based in Los Angeles, with offices in New York City and 

Berkeley, the Firm has successfully prosecuted class action cases and complex 

litigation in federal and state courts throughout the country. As Lead Counsel, Co-Lead 

Counsel, or as a member of Plaintiffs’ Counsel Executive Committees, the Firm’s 

attorneys have recovered billions of dollars for parties wronged by corporate fraud, 

antitrust violations and malfeasance. Indeed, the Institutional Shareholder Services unit 

of RiskMetrics Group has recognized the Firm as one of the top plaintiffs’ law firms in 

the United States in its Securities Class Action Services report for every year since the 

inception of the report in 2003. The Firm’s efforts have been publicized in major 

newspapers such as the Wall Street Journal, the New York Times, and the Los Angeles 

Times.

Glancy Prongay & Murray’s commitment to high quality and excellent personalized 

services has boosted its national reputation, and we are now recognized as one of the 

premier plaintiffs’ firms in the country. The Firm works tenaciously on behalf of clients to 

produce significant results and generate lasting corporate reform.

The Firm’s integrity and success originate from our attorneys, who are among the 

brightest and most experienced in the field. Our distinguished litigators have an 

unparalleled track record of investigating and prosecuting corporate wrongdoing. The 

Firm is respected for both the zealous advocacy with which we represent our clients’

interests as well as the highly-professional and ethical manner by which we achieve 

results. We are ideally positioned to pursue securities, antitrust, consumer, and 

derivative litigation on behalf of our clients. The Firm’s outstanding accomplishments 

are the direct result of the exceptional talents of our attorneys and employees.

SECURITIES CLASS ACTION SETTLEMENTS

Appointed as Lead or Co-Lead Counsel by judges throughout the United States, Glancy 

Prongay & Murray has achieved significant recoveries for class members in numerous 

securities class actions, including:

In re Mercury Interactive Corporation Securities Litigation, USDC Northern District of 

California, Case No. 05-3395-JF, in which the Firm served as Co-Lead Counsel and 

achieved a settlement valued at over $117 million.

In re Real Estate Associates Limited Partnership Litigation, USDC Central District of 

California, Case No. 98-7035-DDP, in which the Firm served as local counsel and 

1925 Century Park East, Suite 2100

Los Angeles, CA 90067

T: 310.201.9150

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plaintiffs achieved a $184 million jury verdict after a complex six week trial in Los 

Angeles, California and later settled the case for $83 million.

In Re Yahoo! Inc. Securities Litigation, USDC Northern District of California, Case No. 

5:17-cv-00373-LHK, in which the Firm served as Co-Lead Counsel and achieved an 

$80 million settlement.

The City of Farmington Hills Employees Retirement System v. Wells Fargo Bank, N.A., 

USDC District of Minnesota, Case No. 10-cv-04372-DWF/JJG, in which the Firm served 

as Co-Lead Counsel and achieved a settlement valued at $62.5 million.

Schleicher v. Wendt, (Conseco Securities Litigation), USDC Southern District of 

Indiana, Case No. 02-1332-SEB, a securities fraud class action in which the Firm 

served as Lead Counsel for the Class and achieved a settlement of over $41 million.

Robb v. Fitbit, Inc., USDC Northern District of California, Case No. 3:16-cv-00151, a 

securities fraud class action in which the Firm served as Lead Counsel for the Class 

and achieved a settlement of $33 million.

Yaldo v. Airtouch Communications, State of Michigan, Wayne County, Case No. 99-

909694-CP, in which the Firm served as Co-Lead Counsel and achieved a settlement 

valued at over $32 million for defrauded consumers.

Lapin v. Goldman Sachs, USDC Southern District of New York, Case No. 03-0850-KJD, 

a securities fraud class action in which the Firm served as Co-Lead Counsel for the 

Class and achieved a settlement of $29 million.

In re Heritage Bond Litigation, USDC Central District of California, Case No. 02-ML1475-DT, where as Co-Lead Counsel, the Firm recovered in excess of $28 million for 

defrauded investors and continues to pursue additional defendants.

In re Livent, Inc. Noteholders Litigation, USDC Southern District of New York, Case No. 

99 Civ 9425-VM, a securities fraud class action in which the Firm served as Co-Lead 

Counsel for the Class and achieved a settlement of over $27 million.

In re ECI Telecom Ltd. Securities Litigation, USDC Eastern District of Virginia, Case No. 

01-913-A, in which the Firm served as sole Lead Counsel and recovered almost $22 

million for defrauded ECI investors. 

Senn v. Sealed Air Corporation, USDC New Jersey, Case No. 03-cv-4372-DMC, a 

securities fraud class action, in which the Firm acted as co-lead counsel for the Class 

and achieved a settlement of $20 million.

In re Gilat Satellite Networks, Ltd. Securities Litigation, USDC Eastern District of New 

York, Case No. 02-1510-CPS, a securities fraud class action in which the Firm served 

as Co-Lead Counsel for the Class and achieved a settlement of $20 million.

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In re Lumenis, Ltd. Securities Litigation, USDC Southern District of New York, Case 

No.02-CV-1989-DAB, in which the Firm served as Co-Lead Counsel and achieved a 

settlement valued at over $20 million.

In re Infonet Services Corporation Securities Litigation, USDC Central District of 

California, Case No. CV 01-10456-NM, in which as Co-Lead Counsel, the Firm

achieved a settlement of $18 million.

In re ESC Medical Systems, Ltd. Securities Litigation, USDC Southern District of New 

York, Case No. 98 Civ. 7530-NRB, a securities fraud class action in which the Firm 

served as sole Lead Counsel for the Class and achieved a settlement valued in excess 

of $17 million.

In re Musicmaker.com Securities Litigation, USDC Central District of California, Case 

No. 00-02018-CAS, a securities fraud class action in which the Firm was sole Lead 

Counsel for the Class and recovered in excess of $13 million. 

In re Lason, Inc. Securities Litigation, USDC Eastern District of Michigan, Case No. 99 

76079-AJT, in which the Firm was Co-Lead Counsel and recovered almost $13 million 

for defrauded Lason stockholders.

In re Inso Corp. Securities Litigation, USDC District of Massachusetts, Case No. 99 

10193-WGY, a securities fraud class action in which the Firm served as Co-Lead 

Counsel for the Class and achieved a settlement valued in excess of $12 million.

In re National TechTeam Securities Litigation, USDC Eastern District of Michigan, Case 

No. 97-74587-AC, a securities fraud class action in which the Firm served as Co-Lead 

Counsel for the Class and achieved a settlement valued in excess of $11 million.

Taft v. Ackermans (KPNQwest Securities Litigation), USDC Southern District of New 

York, Case No. 02-CV-07951-PKL, a securities fraud class action in which the Firm 

served as Co-Lead Counsel for the Class and achieved a settlement worth $11 million.

Jenson v. First Trust Corporation, USDC Central District of California, Case No. 05-cv3124-ABC, in which the Firm was appointed sole lead counsel and achieved an $8.5 

million settlement in a very difficult case involving a trustee’s potential liability for losses 

incurred by investors in a Ponzi scheme. Kevin Ruf of the Firm also successfully 

defended in the 9th Circuit Court of Appeals the trial court’s granting of class 

certification in this case.

In re Ramp Networks, Inc. Securities Litigation, USDC Northern District of California, 

Case No. C-00-3645-JCS, a securities fraud class action in which the Firm served as 

Co-Lead Counsel for the Class and achieved a settlement of nearly $7 million.

Capri v. Comerica, Inc., USDC Eastern District of Michigan, Case No. 02-CV-60211-

MOB, a securities fraud class action in which the Firm served as Co-Lead Counsel for 

the Class and achieved a settlement of $6.0 million.

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Plumbing Solutions Inc. v. Plug Power, Inc., USDC Eastern District of New York, Case 

No. CV 00 5553-ERK, a securities fraud class action in which the Firm served as CoLead Counsel for the Class and achieved a settlement of over $5 million.

Ree v. Procom Technologies, Inc., USDC Southern District of New York, Case No. 02-

CV-7613-JGK, a securities fraud class action in which the Firm served as Co-Lead 

Counsel for the Class and achieved a settlement of $2.7 million.

Tatz v. Nanophase Technologies Corp., USDC Northern District of Illinois, Case No. 01-

C-8440-MCA, a securities fraud class action in which the Firm served as Co-Lead 

Counsel for the Class and achieved a settlement of $2.5 million.

In re F & M Distributors Securities Litigation, USDC Eastern District of Michigan, Case 

No. 95 CV 71778-DT, a securities fraud class action in which the Firm served on the 

Executive Committee and helped secure a $20.25 million settlement.

ANTITRUST PRACTICE GROUP AND ACHIEVEMENTS

Glancy Prongay & Murray’s Antitrust Practice Group focuses on representing individuals 

and entities that have been victimized by unlawful monopolization, price-fixing, market 

allocation, and other anti-competitive conduct. The Firm has prosecuted significant 

antitrust cases and has helped individuals and businesses recover billions of dollars. 

Prosecuting civil antitrust cases under federal and state laws throughout the country, 

the Firm’s Antitrust Practice Group represents consumers, businesses, and Health and 

Welfare Funds and seeks injunctive relief and damages for violations of antitrust and 

commodities laws. The Firm has served, or is currently serving, as Lead Counsel, CoLead Counsel or Class Counsel in a substantial number of antitrust class actions, 

including:

In re Nasdaq Market-Makers Antitrust Litigation, USDC Southern District of New York, 

Case No. 94 C 3996-RWS, MDL Docket No. 1023, a landmark antitrust lawsuit in which 

the Firm filed the first complaint against all of the major NASDAQ market makers and 

served on Plaintiffs’ Counsel’s Executive Committee in a case that recovered $900 

million for investors.

Sullivan v. DB Investments, USDC District of New Jersey, Case No. No. 04-cv-2819, 

where the Firm served as Co-Lead Settlement Counsel in an antitrust case against 

DeBeers relate to the pricing of diamonds that settled for $295 million.

In re Korean Air Lines Antitrust Litig., USDC Central District of California, Master File 

No. CV 07-05107 SJO(AGRx), MDL No. 07-0189, where the Firm served as Co-Lead 

Counsel in a case related to fixing of prices for airline tickets to Korea that settled for 

$86 million.

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In re Urethane Chemical Antitrust Litig., USDC District of Kansas, Case No. MDL 1616, 

where the Firm served as Co-Lead counsel in an antitrust price fixing case that settled 

$33 million.

In re Western States Wholesale Natural Gas Litig., USDC District of Nevada, Case No.

MDL 1566, where the Firm served as Class Counsel in an antitrust price fixing case that 

settled $25 million.

In re Aggrenox Antitrust Litig., USDC District of Connecticut, Case No. 14-cv-2516, 

where the Firm played a major role in achieving a settlement of $54,000,000.

In re Solodyn Antitrust Litig., USDC District of Massachusetts, Case No. MDL 2503, 

where the Firm played a major role in achieving a settlement of $43,000,000.

In re Generic Pharmaceuticals Pricing Antitrust Litig., USDC Eastern District of 

Pennsylvania, Case No. 16-md-2427, where the Firm is representing a major Health 

and Welfare Fund in a case against a number of generic drug manufacturers for price 

fixing generic drugs.

In re Actos End Payor Antitrust Litig., USDC Southern District of New York, Case No.

13-cv-9244, where the Firm is serving on Plaintiffs’ Executive Committee.

In re Heating Control Panel Direct Purchaser Action, USDC Eastern District of Michigan, 

Case No. 12-md-02311, representing a recreational vehicle manufacturer in a pricefixing class action involving direct purchasers of heating control panels.

In re Instrument Panel Clusters Direct Purchaser Action, USDC Eastern District of 

Michigan, Case No. 12-md-02311, representing a recreational vehicle manufacturer in a 

price-fixing class action involving direct purchasers of instrument panel clusters.

In addition, the Firm is currently involved in the prosecution of many market 

manipulation cases relating to violations of antitrust and commodities laws, including 

Sullivan v. Barclays PLC (manipulation of Euribor rate), In re Foreign Exchange 

Benchmark Rates Antitrust Litig., In re LIBOR-Based Financial Instruments Antitrust 

Litig., In re Gold Futures & Options Trading Litig., In re Platinum & Palladium Antitrust 

Litig., Sonterra Cap. Master Fund v. Credit Suisse Group AG (Swiss Libor rate 

manipulation), Twin City Iron Pension Fund v. Bank of Nova Scotia (manipulation of 

treasury securities), and Ploss v. Kraft Foods Group (manipulation of wheat prices). 

Glancy Prongay & Murray has been responsible for obtaining favorable appellate 

opinions which have broken new ground in the class action or securities fields, or which 

have promoted shareholder rights in prosecuting these actions. The Firm successfully 

argued the appeals in a number of cases:

In Smith v. L’Oreal, 39 Cal.4th 77 (2006), Firm partner Kevin Ruf established groundbreaking law when the California Supreme Court agreed with the Firm’s position that 

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waiting penalties under the California Labor Code are available to any employee after 

termination of employment, regardless of the reason for that termination. 

OTHER NOTABLE ACHIEVEMENTS

Other notable Firm cases are: Silber v. Mabon I, 957 F.2d 697 (9th Cir. 1992) and Silber 

v. Mabon II, 18 F.3d 1449 (9th Cir. 1994), which are the leading decisions in the Ninth 

Circuit regarding the rights of opt-outs in class action settlements. In Rothman v. 

Gregor, 220 F.3d 81 (2d Cir. 2000), the Firm won a seminal victory for investors before 

the Second Circuit Court of Appeals, which adopted a more favorable pleading standard 

for investors in reversing the District Court’s dismissal of the investors’ complaint. After 

this successful appeal, the Firm then recovered millions of dollars for defrauded 

investors of the GT Interactive Corporation. The Firm also argued Falkowski v. Imation 

Corp., 309 F.3d 1123 (9th Cir. 2002), as amended, 320 F.3d 905 (9th Cir. 2003), and 

favorably obtained the substantial reversal of a lower court’s dismissal of a cutting edge, 

complex class action initiated to seek redress for a group of employees whose stock 

options were improperly forfeited by a giant corporation in the course of its sale of the 

subsidiary at which they worked. 

The Firm is also involved in the representation of individual investors in court 

proceedings throughout the United States and in arbitrations before the American 

Arbitration Association, National Association of Securities Dealers, New York Stock 

Exchange, and Pacific Stock Exchange. Mr. Glancy has successfully represented 

litigants in proceedings against such major securities firms and insurance companies as 

A.G. Edwards & Sons, Bear Stearns, Merrill Lynch & Co., Morgan Stanley, 

PaineWebber, Prudential, and Shearson Lehman Brothers.

One of the Firm’s unique skills is the use of “group litigation” - the representation of 

groups of individuals who have been collectively victimized or defrauded by large 

institutions. This type of litigation brought on behalf of individuals who have been 

similarly damaged often provides an efficient and effective economic remedy that 

frequently has advantages over the class action or individual action devices. The Firm 

has successfully achieved results for groups of individuals in cases against major 

corporations such as Metropolitan Life Insurance Company, and Occidental Petroleum 

Corporation.

Glancy Prongay & Murray LLP currently consists of the following attorneys:

PARTNERS

LEE ALBERT, a partner, was admitted to the bars of the Commonwealth of 

Pennsylvania, the State of New Jersey, and the United States District Courts for the 

Eastern District of Pennsylvania and the District of New Jersey in 1986. He received his 

B.S. and M.S. degrees from Temple University and Arcadia University in 1975 and 

1980, respectively, and received his J.D. degree from Widener University School of Law 

in 1986. Upon graduation from law school, Mr. Albert spent several years working as a 

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civil litigator in Philadelphia, PA. Mr. Albert has extensive litigation and appellate 

practice experience having argued before the Supreme and Superior Courts of 

Pennsylvania and has over fifteen years of trial experience in both jury and non-jury 

cases and arbitrations. Mr. Albert has represented a national health care provider at 

trial obtaining injunctive relief in federal court to enforce a five-year contract not to 

compete on behalf of a national health care provider and injunctive relief on behalf of an 

undergraduate university.

Currently, Mr. Albert represents clients in all types of complex litigation including matters 

concerning violations of federal and state antitrust and securities laws, mass 

tort/product liability and unfair and deceptive trade practices. Some of Mr. Albert’s 

current major cases include In Re Automotive Wire Harness Systems Antitrust Litigation 

(E.D. Mich.); In Re Heater Control Panels Antitrust Litigation (E.D. Mich.); Kleen 

Products, et al. v. Packaging Corp. of America (N.D. Ill.); and In re Class 8 

Transmission Indirect Purchaser Antitrust Litigation (D. Del.). Previously, Mr. Albert had 

a significant role in Marine Products Antitrust Litigation (C.D. Cal.); Baby Products 

Antitrust Litigation (E.D. Pa.); In re ATM Fee Litigation (N.D. Cal.); In re Canadian Car 

Antitrust Litigation (D. Me.); In re Broadcom Securities Litigation (C.D. Cal.); and has 

worked on In re Avandia Marketing, Sales Practices and Products Liability Litigation

(E.D. Pa.); In re Ortho Evra Birth Control Patch Litigation (N.J. Super. Ct., Middlesex 

County); In re AOL Time Warner, Inc. Securities Litigation (S.D.N.Y.); In re WorldCom, 

Inc. Securities Litigation (S.D.N.Y.); and In re Microsoft Corporation Massachusetts 

Consumer Protection Litigation (Mass. Super. Ct.).

PETER A. BINKOW has prosecuted lawsuits on behalf of consumers and investors in 

state and federal courts throughout the United States. He served as Lead or Co-Lead 

Counsel in many class action cases, including: In re Mercury Interactive Securities 

Litigation ($117.5 million recovery); The City of Farmington Hills Retirement System v 

Wells Fargo ($62.5 million recovery); Schleicher v Wendt (Conseco Securities litigation -

$41.5 million recovery); Lapin v Goldman Sachs ($29 million recovery); In re Heritage 

Bond Litigation ($28 million recovery); In re National Techteam Securities Litigation ($11 

million recovery for investors); In re Lason Inc. Securities Litigation ($12.68 million 

recovery), In re ESC Medical Systems, Ltd. Securities Litigation ($17 million recovery); 

and many others. In Schleicher v Wendt, Mr. Binkow successfully argued the seminal 

Seventh Circuit case on class certification, in an opinion authored by Chief Judge Frank 

Easterbrook. He has argued and/or prepared appeals before the Ninth Circuit, Seventh 

Circuit, Sixth Circuit and Second Circuit Courts of Appeals.

Mr. Binkow joined the Firm in 1994. He was born on August 16, 1965 in Detroit, 

Michigan. Mr. Binkow obtained a Bachelor of Arts degree from the University of 

Michigan in 1988 and a Juris Doctor degree from the University of Southern California in 

1994.

JOSEPH D. COHEN has extensive complex civil litigation experience, and currently 

oversees the firm’s settlement department, negotiating, documenting and obtaining 

court approval of the firm’s securities, merger and derivative settlements.

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Prior to joining the firm, Mr. Cohen successfully prosecuted numerous securities fraud, 

consumer fraud, antitrust and constitutional law cases in federal and state courts 

throughout the country. Cases in which Mr. Cohen took a lead role include: Jordan v. 

California Dep’t of Motor Vehicles, 100 Cal. App. 4th 431 (2002) (complex action in 

which the California Court of Appeal held that California’s Non-Resident Vehicle $300 

Smog Impact Fee violated the Commerce Clause of the United States Constitution, 

paving the way for the creation of a $665 million fund and full refunds, with interest, to 

1.7 million motorists); In re Geodyne Res., Inc. Sec. Litig. (Harris Cty. Tex.) (settlement 

of securities fraud class action, including related litigation, totaling over $200 million); In 

re Cmty. Psychiatric Centers Sec. Litig. (C.D. Cal.) (settlement of $55.5 million was 

obtained from the company and its auditors, Ernst & Young, LLP); In re McLeodUSA 

Inc., Sec. Litig. (N.D. Iowa) ($30 million settlement); In re Arakis Energy Corp. Sec. Litig.

(E.D.N.Y.) ($24 million settlement); In re Metris Cos., Inc., Sec. Litig. (D. Minn.) ($7.5 

million settlement); In re Landry’s Seafood Rest., Inc. Sec. Litig. (S.D. Tex.) ($6 million 

settlement); and Freedman v. Maspeth Fed. Loan and Savings Ass’n, (E.D.N.Y) 

(favorable resolution of issue of first impression under RESPA resulting in full recovery 

of improperly assessed late fees).

Mr. Cohen was also a member of the teams that obtained substantial recoveries in the 

following cases: In re: Foreign Exchange Benchmark Rates Antitrust Litig. (S.D.N.Y.) 

(partial settlements of approximately $2 billion); In re Washington Mutual MortgageBacked Sec. Litig. (W.D. Wash.) (settlement of $26 million); Mylan Pharm., Inc. v. 

Warner Chilcott Public Ltd. Co. (E.D. Pa.) ($8 million recovery in antitrust action on 

behalf of class of indirect purchasers of the prescription drug Doryx); City of Omaha 

Police and Fire Ret. Sys. v. LHC Group, Inc. (W.D. La.) (securities class action 

settlement of $7.85 million); and In re Pacific Biosciences of Cal., Inc. Sec. Litig. (Cal. 

Super. Ct.) ($7.6 million recovery).

In addition, Mr. Cohen was previously the head of the settlement department at 

Bernstein Litowitz Berger & Grossmann LLP. While at BLB&G, Mr. Cohen had primary 

responsibility for overseeing the team working on the following settlements, among 

others: In Re Merck & Co., Inc. Sec., Deriv. & “ERISA” Litig. (D.N.J.) ($1.062 billion 

securities class action settlement); New York State Teachers’ Ret. Sys. v. General 

Motors Co. (E.D. Mich.) ($300 million securities class action settlement); In re 

JPMorgan Chase & Co. Sec. Litig. (S.D.N.Y.) ($150 million settlement); Dep’t of the 

Treasury of the State of New Jersey and its Division of Inv. v. Cliffs Natural Res. Inc., et 

al. (N.D. Ohio) ($84 million securities class action settlement); In re Penn West 

Petroleum Ltd. Sec. Litig. (S.D.N.Y.) ($19.76 million settlement); and In re BioScrip, Inc. 

Sec. Litig. ($10.9 million settlement).

JOSHUA L. CROWELL, a partner in the firm’s Los Angeles office, concentrates his 

practice on prosecuting complex securities cases on behalf of investors.

Recently, he was co-lead counsel in In re Yahoo! Inc. Securities Litigation, No. 17-CV00373-LHK (N.D. Cal.), which resulted in an $80 million settlement for the class. He 

also led the prosecution of In re Akorn, Inc. Securities Litigation, No. 1:15-cv-01944 

(N.D. Ill.), achieving a $24 million class settlement.

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Prior to joining Glancy Prongay & Murray LLP, Joshua was an Associate at Labaton 

Sucharow LLP in New York, where he substantially contributed to some of the firm’s 

biggest successes. There he helped secure several large federal securities class 

settlements, including:

 In re Countrywide Financial Corp. Securities Litigation, No. CV 07-05295 MRP 

(MANx) (C.D. Cal.) – $624 million

 In re Schering-Plough Corp. / ENHANCE Securities Litigation, No. 08-397 (DMC) 

(JAD) (D.N.J.) – $473 million

 In re Broadcom Corp. Class Action Litigation, No. CV-06-5036-R (CWx) (C.D. Cal.) –

$173.5 million

 In re Fannie Mae 2008 Securities Litigation, No. 08-civ-7831-PAC (S.D.N.Y.) – $170 

million

 Oppenheimer Champion Fund and Core Bond Fund actions, Nos. 09-cv-525-JLKKMT and 09-cv-1186-JLK-KMT (D. Colo.) – $100 million combined

He began his legal career as an Associate at Paul, Hastings, Janofsky & Walker LLP in 

New York, primarily representing financial services clients in commercial litigation.

Super Lawyers has selected Joshua as a Rising Star in the area of Securities Litigation 

from 2015 through 2017.

Prior to attending law school, Mr. Joshua was a Senior Economics Consultant at Ernst 

& Young LLP, where he priced intercompany transactions and calculated the value of 

intellectual property. Joshua received a J.D., cum laude, from The George Washington 

University Law School. During law school, he was a member of The George 

Washington Law Review and the Mock Trial Board. He was also a law intern for Chief 

Judge Edward J. Damich of the United States Court of Federal Claims. Joshua earned 

a B.A. in International Relations from Carleton College.

LIONEL Z. GLANCY, a graduate of University of Michigan Law School, is the founding 

partner of the Firm. After serving as a law clerk for United States District Judge Howard 

McKibben, he began his career as an associate at a New York law firm concentrating in 

securities litigation. Thereafter, he started a boutique law firm specializing in securities 

litigation, and other complex litigation, from the Plaintiff’s perspective. Mr. Glancy has 

established a distinguished career in the field of securities litigation over the last thirty 

years, having appeared and been appointed lead counsel on behalf of aggrieved 

investors in securities class action cases throughout the country. He has appeared and 

argued before dozens of district courts and a number of appellate courts. His efforts 

have resulted in the recovery of hundreds of millions of dollars in settlement proceeds 

for huge classes of shareholders. Well known in securities law, he has lectured on its 

developments and practice, including having lectured before Continuing Legal 

Education seminars and law schools.

Mr. Glancy was born in Windsor, Canada, on April 4, 1962. Mr. Glancy earned his 

undergraduate degree in political science in 1984 and his Juris Doctor degree in 1986, 

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both from the University of Michigan. He was admitted to practice in California in 1988, 

and in Nevada and before the U.S. Court of Appeals, Ninth Circuit, in 1989.

MARC L. GODINO has extensive experience successfully litigating complex, class 

action lawsuits as a plaintiffs’ lawyer. Since joining the firm in 2005, Mr. Godino has 

played a primary role in cases resulting in settlements of more than $100 million. He 

has prosecuted securities, derivative, merger & acquisition, and consumer cases 

throughout the country in both state and federal court, as well as represented defrauded 

investors at FINRA arbitrations. Mr. Godino manages the Firm’s consumer class action 

department. 

While a senior associate with Stull Stull & Brody, Mr. Godino was one of the two primary 

attorneys involved in Small v. Fritz Co., 30 Cal. 4th 167 (April 7, 2003), in which the 

California Supreme Court created new law in the State of California for shareholders 

that held shares in detrimental reliance on false statements made by corporate 

officers. The decision was widely covered by national media including The National

Law Journal, the Los Angeles Times, the New York Times, and the New York Law

Journal, among others, and was heralded as a significant victory for shareholders.

Mr. Godino’s successes with Glancy Prongay & Murray LLP include: Good Morning To

You Productions Corp., et al., v. Warner/Chappell Music, Inc., et al., Case No. 13-04460 

(C.D. Cal.) (In this highly publicized case that attracted world-wide attention, Plaintiffs

prevailed on their claim that the song “Happy Birthday” should be in the public domain

and achieved a $14,000,000 settlement to class members who paid a licensing fee for

the song); Ord v. First National Bank of Pennsylvania, Case No. 12-766 (W. D. Pa.)

($3,000,000 settlement plus injunctive relief); Pappas v. Naked Juice Co. of Glendora,

Inc., Case No. 11-08276 (C.D. Cal.) ($9,000,000 settlement plus injunctive

relief);Astiana v. Kashi Company, Case No. 11-1967 (S.D. Cal.) ($5,000,000

settlement); In re Magma Design Automation, Inc. Securities Litigation, Case No. 05-

2394 (N.D. Cal.) ($13,500,000 settlement); In re Hovnanian Enterprises, Inc. Securities

Litigation, Case No. 08-cv-0099 (D.N.J.) ($4,000,000 settlement); In re Skilled

Healthcare Group, Inc. Securities Litigation, Case No. 09-5416 (C.D. Cal.) ($3,000,000

settlement); Kelly v. Phiten USA, Inc., Case No. 11-67 (S.D. Iowa) ($3,200,000

settlement plus injunctive relief); (Shin et al., v. BMW of North America, 2009 WL

2163509 (C.D. Cal. July 16, 2009) (after defeating a motion to dismiss, the case settled

on very favorable terms for class members including free replacement of cracked

wheels); Payday Advance Plus, Inc. v. MIVA, Inc., Case No. 06-1923 (S.D.N.Y.)

($3,936,812 settlement); Esslinger, et al. v. HSBC Bank Nevada, N.A., Case No. 10-

03213 (E.D. Pa.) ($23,500,000 settlement); In re Discover Payment Protection Plan

Marketing and Sales Practices Litigation, Case No. 10-06994 ($10,500,000 settlement

); In Re: Bank of America Credit Protection Marketing and Sales Practices

Litigation, Case No. 11-md-02269 (N.D. Cal.) ($20,000,000 settlement).

Mr. Godino was also the principal attorney in the following published decisions: In re

Zappos.com, Inc., Customer Data Sec. Breach Litigation, 714 Fed Appx. 761 (9th Cir. 

2018) (reversing order dismissing class action complaint); Small et al., v. University

Medical Center of Southern Nevada, et al., 2017 WL 3461364 (D. Nev. Aug. 10, 2017) 

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(denying motion to dismiss); Sciortino v. Pepsico, Inc., 108 F.Supp. 3d 780 (N.D. Cal.. 

June 5, 2015) (motion to dismiss denied); Peterson v. CJ America, Inc., 2015 WL 

11582832 (S.D. Cal. May 15, 2015) (motion to dismiss denied); Lilly v. Jamba Juice

Company, 2014 WL 4652283 (N. D. Cal. Sep 18, 2014) (class certification granted in 

part); Kramer v. Toyota Motor Corp., 705 F. 3d 1122 (9th Cir. 2013) (affirming denial of 

Defendant’s motion to compel arbitration); Sateriale, et al. v. R.J. Reynolds Tobacco

Co., 697 F. 3d 777 (9th Cir. 2012) (reversing order dismissing class action 

complaint); Shin v. BMW of North America, 2009 WL 2163509 (C.D. Cal. July 16, 2009) 

(motion to dismiss denied); In re 2TheMart.com Securities Litigation, 114 F. Supp. 2d 

955 (C.D. Cal. 2002) (motion to dismiss denied); In re Irvine Sensors Securities

Litigation, 2003 U.S. Dist. LEXIS 18397 (C.D. Cal. 2003) (motion to dismiss denied).

The following represent just a few of the cases Mr. Godino is currently litigating in a 

leadership position: Small v. University Medical Center of Southern Nevada, Case No. 

13-00298 (D. Nev.); Courtright, et al., v. O’Reilly Automotive Stores, Inc., et al., Case 

No. 14-334 (W.D. Mo); Keskinen v. Edgewell Personal Care Co., et al., Case No. 17-

07721 (C.D. CA); Ryan v. Rodan & Fields, LLC, Case No. 18-02505 (N.D. Cal)

MATTHEW M. HOUSTON, a partner in the firm’s New York office, graduated from 

Boston University School of Law in 1988. Mr. Houston is an active member of the Bar 

of the State of New York and an inactive member of the bar for the Commonwealth of 

Massachusetts. Mr. Houston is also admitted to the United States District Courts for the 

Southern and Eastern Districts of New York and the District of Massachusetts, and the 

Second, Seventh, Ninth, and Eleventh Circuit Court of Appeals of the United States. 

Mr. Houston repeatedly has been selected as a New York Metro Super Lawyer.

Mr. Houston has substantial courtroom experience involving complex actions in federal 

and state courts throughout the country. Mr. Houston was co-lead trial counsel in one 

the few ERISA class action cases taken to trial asserting breach of fiduciary duty claims 

against plan fiduciaries, Brieger et al. v. Tellabs, Inc., No. 06-CV-01882 (N.D. Ill.), and 

has successfully prosecuted many ERISA actions, including In re Royal Ahold N.V. 

Securities and ERISA Litigation, Civil Action No. 1:03-md-01539. Mr. Houston has been 

one of the principal attorneys litigating claims in multi-district litigation concerning 

employment classification of pickup and delivery drivers and primarily responsible for 

prosecuting ERISA class claims resulting in a $242,000,000 settlement; In re FedEx 

Ground Package Inc. Employment Practices Litigation, No. 3:05-MD-527 (MDL 1700). 

Mr. Houston recently presented argument before the Eleventh Circuit Court of Appeals 

on behalf of a class of Florida pickup and delivery drivers obtaining a reversal of the 

lower court’s grant of summary judgment. Mr. Houston represented the interests of 

Nevada and Arkansas drivers employed by FedEx Ground obtaining significant 

recoveries on their behalf. Mr. Houston also served as lead counsel in multi-district 

class litigation seeking to modify insurance claims handling practices; In re 

UnumProvident Corp. ERISA Benefits Denial Actions, No. 1:03-cv-1000 (MDL 1552).

Mr. Houston has played a principal role in numerous derivative and class actions 

wherein substantial benefits were conferred upon plaintiffs: In re: Groupon Derivative 

Litigation, No. 12-cv-5300 (N.D. Ill. 2012) (settlement of consolidated derivative action 

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resulting in sweeping corporate governance reform estimated at $159 million) Bangari 

v. Lesnik, et al., No. 11 CH 41973 (Illinois Circuit Court, County of Cook) (settlement of 

claim resulting in payment of $20 million to Career Education Corporation and 

implementation of extensive corporate governance reform); In re Diamond Foods, Inc. 

Shareholder Litigation, No. CGC-11-515895 (California Superior Court, County of San 

Francisco) ($10.4 million in monetary relief including a $5.4 million clawback of 

executive compensation and significant corporate governance reform); Pace American

Shareholder Litigation, 94-92 TUC-RMB (securities fraud class action settlement 

resulting in a recovery of $3.75 million); In re Bay Financial Securities Litigation, Master 

File No. 89-2377-DPW, (D. Mass.) (J. Woodlock) (settlement of action based upon 

federal securities law claims resulting in class recovery in excess of $3.9 million); 

Goldsmith v. Technology Solutions Company, 92 C 4374 (N.D. Ill. 1992) (J. Manning) 

(recovery of $4.6 million as a result of action alleging false and misleading statements 

regarding revenue recognition).

In addition to numerous employment and derivative cases, Mr. Houston has litigated 

actions asserting breach of fiduciary duty in the context of mergers and acquisitions. 

Mr. Houston has been responsible for securing millions of dollars in additional 

compensation and structural benefits for shareholders of target companies: In re Instinet 

Group, Inc. Shareholders Litigation, C.A. No. 1289 (Delaware Court of Chancery); 

Jasinover v. The Rouse Company, Case No. 13-C-04-59594 (Maryland Circuit Court); 

McLaughlin v. Household International, Inc., Case No. 02 CH 20683 (Illinois Circuit 

Court); Sebesta v. The Quizno’s Corporation, Case No. 2001 CV 6281 (Colorado 

District Court); Crandon Capital Partners v. Sanford M. Kimmel, C.A. No. 14998 (Del. 

Ch.); and Crandon Capital Partners v. Kimmel, C.A. No. 14998 (Del. Ch. 1996) (J. 

Chandler) (settlement of an action on behalf of shareholders of Transnational 

Reinsurance Co. whereby acquiring company provided an additional $10.4 million in 

merger consideration).

JASON L. KRAJCER is a partner in the firm’s Los Angeles office. He specializes in 

complex securities cases and has extensive experience in all phases of litigation (fact 

investigation, pre-trial motion practice, discovery, trial, appeal).

Prior to joining Glancy Prongay & Murray LLP, Mr. Krajcer was an Associate at 

Goodwin Procter LLP where he represented issuers, officers and directors in multihundred million and billion dollar securities cases. He began his legal career at Orrick, 

Herrington & Sutcliffe LLP, where he represented issuers, officers and directors in 

securities class actions, shareholder derivative actions, and matters before the U.S. 

Securities & Exchange Commission.

Mr. Krajcer is admitted to the State Bar of California, the Bar of the District of Columbia, 

the United States Supreme Court, the Ninth Circuit Court of Appeals, and the United 

States District Courts for the Central and Southern Districts of California. 

SUSAN G. KUPFER is the founding partner of the Firm’s Berkeley office. Ms Kupfer 

joined the Firm in 2003. She is a native of New York City, and received her A.B. degree 

from Mount Holyoke College in 1969 and her Juris Doctor degree from Boston 

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University School of Law in 1973. She did graduate work at Harvard Law School and, 

in 1977, was named Assistant Dean and Director of Clinical Programs at Harvard, 

supervising and teaching in that program of legal practice and related academic 

components.

For much of her legal career, Ms. Kupfer has been a professor of law. Her areas of 

academic expertise are Civil Procedure, Federal Courts, Conflict of Laws, Constitutional 

Law, Legal Ethics, and Jurisprudence. She has taught at Harvard Law School, Hastings 

College of the Law, Boston University School of Law, Golden Gate University School of 

Law, and Northeastern University School of Law. From 1991 through 2002, she was a 

lecturer on law at the University of California, Berkeley, Boalt Hall, teaching Civil 

Procedure and Conflict of Laws. Her publications include articles on federal civil rights 

litigation, legal ethics, and jurisprudence. She has also taught various aspects of 

practical legal and ethical training, including trial advocacy, negotiation and legal ethics, 

to both law students and practicing attorneys.

Ms. Kupfer previously served as corporate counsel to The Architects Collaborative in 

Cambridge and San Francisco, and was the Executive Director of the Massachusetts 

Commission on Judicial Conduct. She returned to the practice of law in San Francisco 

with Morgenstein & Jubelirer and Berman DeValerio LLP before joining the Firm.

Ms. Kupfer’s practice is concentrated in complex antitrust litigation. She currently 

serves, or has served, as Co-Lead Counsel in several multidistrict antitrust cases: In re 

Photochromic Lens Antitrust Litig. (MDL 2173, M.D. Fla. 2010); In re Fresh and Process 

Potatoes Antitrust Litig. (D. ID. 2011); In re Korean Air Lines Antitrust Litig. (MDL No. 

1891, C.D. Cal. 2007); In re Urethane Antitrust Litigation (MDL 1616, D. Kan. 2004); In 

re Western States Wholesale Natural Gas Litigation (MDL 1566, D. Nev. 2005); and 

Sullivan et al v. DB Investments et al (D. N.J. 2004). She has been a member of the 

lead counsel teams that achieved significant settlements in: In re Sorbates Antitrust 

Litigation ($96.5 million settlement); In re Pillar Point Partners Antitrust Litigation ($50 

million settlement); and In re Critical Path Securities Litigation ($17.5 million settlement).

Ms. Kupfer is a member of the bar of Massachusetts and California, and is admitted to 

practice before the United States District Courts for the Northern, Central, Eastern and 

Southern Districts of California, the District of Massachusetts, the Courts of Appeals for 

the First and Ninth Circuits, and the U.S. Supreme Court.

GREGORY B. LINKH works out of the New York office, where he litigates antitrust, 

securities, shareholder derivative, and consumer cases. Greg graduated from the State 

University of New York at Binghamton in 1996 and from the University of Michigan Law 

School in 1999. While in law school, Greg externed with United States District Judge 

Gerald E. Rosen of the Eastern District of Michigan. Greg was previously associated 

with the law firms Dewey Ballantine LLP, Pomerantz Haudek Block Grossman & Gross 

LLP, and Murray Frank LLP.

Previously, Greg had significant roles in In re Merrill Lynch & Co., Inc. Research

Reports Securities Litigation (settled for $125 million); In re Crompton Corp. Securities

Litigation (settled $11 million); Lowry v. Andrx Corp. (settled for $8 million); In re

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Xybernaut Corp. Securities MDL Litigation (settled for $6.3 million); and In re EIS Int’l

Inc. Securities Litigation (settled for $3.8 million). Greg also represented the West 

Virginia Investment Management Board (“WVIMB”) in WVIMB v. Residential Accredited

Loans, Inc., et al., relating to the WVIMB's investment in residential mortgage-backed 

securities.

Currently, Greg is litigating various antitrust and securities cases, including In re Korean

Ramen Antitrust Litigation, In re Automotive Parts Antitrust Litigation, and In re

Horsehead Holding Corp. Securities Litigation.

Greg is the co-author of Inherent Risk In Securities Cases In The Second Circuit, NEW 

YORK LAW JOURNAL (Aug. 26, 2004); and Staying Derivative Action Pursuant to 

PSLRA and SLUSA, NEW YORK LAW JOURNAL, P. 4, COL. 4 (Oct. 21, 2005).

BRIAN MURRAY is the managing partner of the Firm's New York Park Avenue office 

and the head of the Firm's Antitrust Practice Group. He received Bachelor of Arts and 

Master of Arts degrees from the University of Notre Dame in 1983 and 1986, 

respectively. He received a Juris Doctor degree, cum laude, from St. John’s University 

School of Law in 1990. At St. John’s, he was the Articles Editor of the ST. JOHN’S 

LAW REVIEW. Mr. Murray co-wrote: Jurisdição Estrangeira Tem Papel Relevante Na 

De Fiesa De Investidores Brasileiros, ESPAÇA JURÍDICO BOVESPA (August 2008); 

The Proportionate Trading Model: Real Science or Junk Science?, 52 CLEVELAND ST. 

L. REV. 391 (2004-05); The Accident of Efficiency: Foreign Exchanges, American 

Depository Receipts, and Space Arbitrage, 51 BUFFALO L. REV. 383 (2003); You 

Shouldn’t Be Required To Plead More Than You Have To Prove, 53 BAYLOR L. REV. 

783 (2001); He Lies, You Die: Criminal Trials, Truth, Perjury, and Fairness, 27 NEW 

ENGLAND J. ON CIVIL AND CRIMINAL CONFINEMENT 1 (2001); Subject Matter 

Jurisdiction Under the Federal Securities Laws: The State of Affairs After Itoba, 20 

MARYLAND J. OF INT’L L. AND TRADE 235 (1996); Determining Excessive Trading in 

Option Accounts: A Synthetic Valuation Approach, 23 U. DAYTON L. REV. 316 (1997); 

Loss Causation Pleading Standard, NEW YORK LAW JOURNAL (Feb. 25, 2005); The 

PSLRA ‘Automatic Stay’ of Discovery, NEW YORK LAW JOURNAL (March 3, 2003); 

and Inherent Risk In Securities Cases In The Second Circuit, NEW YORK LAW 

JOURNAL (Aug. 26, 2004). He also authored Protecting The Rights of International 

Clients in U.S. Securities Class Action Litigation, INTERNATIONAL LITIGATION NEWS 

(Sept. 2007); Lifting the PSLRA “Automatic Stay” of Discovery, 80 N. DAK. L. REV. 405 

(2004); Aftermarket Purchaser Standing Under § 11 of the Securities Act of 1933, 73 

ST. JOHN’S L. REV.633 (1999); Recent Rulings Allow Section 11 Suits By Aftermarket 

Securities Purchasers, NEW YORK LAW JOURNAL (Sept. 24, 1998); and Comment, 

Weissmann v. Freeman: The Second Circuit Errs in its Analysis of Derivative Copyrights by Joint Authors, 63 ST. JOHN’S L. REV. 771 (1989).

Mr. Murray was on the trial team that prosecuted a securities fraud case under Section 

10(b) of the Securities Exchange Act of 1934 against Microdyne Corporation in the 

Eastern District of Virginia and he was also on the trial team that presented a claim 

under Section 14 of the Securities Exchange Act of 1934 against Artek Systems 

Corporation and Dynatach Group which settled midway through the trial.

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Mr. Murray’s major cases include In re Horsehead Holding Corp. Sec. Litig., No. 16-cv292, 2018 WL 4838234 (D. Del. Oct. 4, 2018) (recommending denial of motion to 

dismiss securities fraud claims where company’s generic cautionary statements failed to 

adequately warn of known problems); In re Deutsche Bank Sec. Litig., --- F.R.D. ---, 

2018 WL 4771525 (S.D.N.Y. Oct. 2, 2018) (granting class certification for Securities Act 

claims and rejecting defendants’ argument that class representatives’ trading profits 

made them atypical class members); Robb v. Fitbit Inc., 216 F. Supp. 3d 1017 (N.D. 

Cal. 2016) (denying motion to dismiss securities fraud claims where confidential witness 

statements sufficiently established scienter); In re Eagle Bldg. Tech. Sec. Litig., 221 

F.R.D. 582 (S.D. Fla. 2004), 319 F. Supp. 2d 1318 (S.D. Fla. 2004) (complaint against 

auditor sustained due to magnitude and nature of fraud; no allegations of a “tip-off” were 

necessary); In re Turkcell Iletisim A.S. Sec. Litig., 209 F.R.D. 353 (S.D.N.Y. 2002) 

(defining standards by which investment advisors have standing to sue); In re Turkcell 

Iletisim A.S. Sec. Litig., 202 F. Supp. 2d 8 (S.D.N.Y. 2001) (liability found for false 

statements in prospectus concerning churn rates); Feiner v. SS&C Tech., Inc., 11 F.

Supp. 2d 204 (D. Conn. 1998) (qualified independent underwriters held liable for pricing 

of offering); Malone v. Microdyne Corp., 26 F.3d 471 (4th Cir. 1994) (reversal of directed 

verdict for defendants); and Adair v. Bristol Tech. Systems, Inc., 179 F.R.D. 126 

(S.D.N.Y. 1998) (aftermarket purchasers have standing under section 11 of the 

Securities Act of 1933). Mr. Murray also prevailed on an issue of first impression in the 

Superior Court of Massachusetts, in Cambridge Biotech Corp. v. Deloitte and Touche 

LLP, in which the court applied the doctrine of continuous representation for statute of 

limitations purposes to accountants for the first time in Massachusetts. 6 Mass. L. Rptr. 

367 (Mass. Super. Jan. 28, 1997). In addition, in Adair v. Microfield Graphics, Inc. (D. 

Or.), Mr. Murray settled the case for 47% of estimated damages. In the Qiao Xing 

Universal Telephone case, claimants received 120% of their recognized losses.

Among his current cases, Mr. Murray represents a class of investors in a securities 

litigation involving preferred shares of Deutsche Bank and is lead counsel in a securities 

class action against Horsehead Holdings, Inc. in the District of Delaware.

Mr. Murray served as a Trustee of the Incorporated Village of Garden City (2000-2002); 

Commissioner of Police for Garden City (2000-2001); Co-Chairman, Derivative Suits 

Subcommittee, American Bar Association Class Action and Derivative Suits Committee, 

(2007-2010); Member, Sports Law Committee, Association of the Bar for the City of 

New York, 1994-1997; Member, Litigation Committee, Association of the Bar for the City 

of New York, 2003-2007; Member, New York State Bar Association Committee on 

Federal Constitution and Legislation, 2005-2008; Member, Federal Bar Council, Second 

Circuit Committee, 2007-present.

Mr. Murray has been a panelist at CLEs sponsored by the Federal Bar Council and the 

Institute for Law and Economic Policy, at the German-American Lawyers Association 

Annual Meeting in Frankfurt, Germany, and is a frequent lecturer before institutional 

investors in Europe and South America on the topic of class actions.

ROBERT V. PRONGAY is a partner in the Firm’s Los Angeles office where he focuses 

on the investigation, initiation, and prosecution of complex securities cases on behalf of 

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institutional and individual investors. Mr. Prongay’s practice concentrates on actions to 

recover investment losses resulting from violations of the federal securities laws and 

various actions to vindicate shareholder rights in response to corporate and fiduciary 

misconduct. 

Mr. Prongay has extensive experience litigating complex cases in state and federal 

courts nationwide. Since joining the Firm, Mr. Prongay has successfully recovered 

millions of dollars for investors victimized by securities fraud and has negotiated the 

implementation of significant corporate governance reforms aimed at preventing the 

recurrence of corporate wrongdoing.

Mr. Prongay was recently recognized as one of thirty lawyers included in the Daily 

Journal’s list of Top Plaintiffs Lawyers in California for 2017. Several of Mr. Prongay’s 

cases have received national and regional press coverage. Mr. Prongay has been 

interviewed by journalists and writers for national and industry publications, ranging 

from The Wall Street Journal to the Los Angeles Daily Journal. Mr. Prongay has 

appeared as a guest on Bloomberg Television where he was interviewed about the 

securities litigation stemming from the high-profile initial public offering of Facebook, Inc.

Mr. Prongay received his Bachelor of Arts degree in Economics from the University of 

Southern California and his Juris Doctor degree from Seton Hall University School of 

Law. Mr. Prongay is also an alumnus of the Lawrenceville School.

DANIELLA QUITT, a partner in the firm’s New York office, graduated from Fordham 

University School of Law in 1988, is a member of the Bar of the State of New York, and 

is also admitted to the United States District Courts for the Southern and Eastern 

Districts of New York, the United States Court of Appeals for the Second, Fifth, and 

Ninth Circuits, and the United States Supreme Court.

Ms. Quitt has extensive experience in successfully litigating complex class actions from 

inception to trial and has played a significant role in numerous actions wherein 

substantial benefits were conferred upon plaintiff shareholders, such as In re SafetyKleen Corp. Stockholders Litigation, (D.S.C.) (settlement fund of $44.5 million); In re 

Laidlaw Stockholders Litigation, (D.S.C.) (settlement fund of $24 million); In re 

UNUMProvident Corp. Securities Litigation, (D. Me.) (settlement fund of $45 million); In 

re Harnischfeger Industries (E.D. Wisc.) (settlement fund of $10.1 million); In re Oxford 

Health Plans, Inc. Derivative Litigation, (S.D.N.Y.) (settlement benefit of $13.7 million 

and corporate therapeutics); In re JWP Inc. Securities Litigation, (S.D.N.Y.) (settlement 

fund of $37 million); In re Home Shopping Network, Inc., Derivative Litigation, (S.D. Fla.) 

(settlement benefit in excess of $20 million); In re Graham-Field Health Products, Inc. 

Securities Litigation, (S.D.N.Y.) (settlement fund of $5.65 million); Benjamin v. 

Carusona, (E.D.N.Y.) (prosecuted action on behalf of minority shareholders which 

resulted in a change of control from majority-controlled management at Gurney’s Inn 

Resort & Spa Ltd.); In re Rexel Shareholder Litigation, (Sup. Ct. N.Y. County) 

(settlement benefit in excess of $38 million); and Croyden Assoc. v. Tesoro Petroleum 

Corp., et al., (Del. Ch.) (settlement benefit of $19.2 million).

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In connection with the settlement of Alessi v. Beracha, (Del. Ch.), a class action brought 

on behalf of the former minority shareholders of Earthgrains, Chancellor Chandler 

commented: “I give credit where credit is due, Ms. Quitt. You did a good job and got a 

good result, and you should be proud of it.”

Ms. Quitt has focused her practice on shareholder rights and ERISA class actions but 

also handles general commercial and consumer litigation. Ms. Quitt serves as a 

member of the S.D.N.Y. ADR Panel and has been consistently selected as a New York 

Metro Super Lawyer.

JONATHAN M. ROTTER leads the Firm’s intellectual property litigation practice and 

has extensive experience in class action litigation, including in the fields of data privacy, 

digital content, securities, consumer protection, and antitrust. His cases often involve 

technical and scientific issues, and he excels at the critical skill of understanding and 

organizing complex subject matter in a way helpful to judges, juries, and ultimately, the 

firm’s clients. Since joining the firm, he has played a key role in cases recovering over 

$100 million. He handles cases on contingency, partial contingency, and hourly bases, 

and works collaboratively with other lawyers and law firms across the country.

Before joining the firm, Mr. Rotter served for three years as the first Patent Pilot 

Program Law Clerk at the United States District Court for the Central District of 

California, both in Los Angeles and Orange County. There, he assisted the Honorable 

S. James Otero, Andrew J. Guilford, George H. Wu, John A. Kronstadt, and Beverly 

Reid O’Connell with hundreds of patent cases in every major field of technology, from 

complaint to post-trial motions, advised on case management strategy, and organized 

and provided judicial education. Mr. Rotter also served as a law clerk for the Honorable 

Milan D. Smith, Jr. on the United States Court of Appeals for the Ninth Circuit, working 

on the full range of matters handled by the Circuit.

Before his service to the courts, Mr. Rotter practiced at an international law firm, where 

he argued appeals at the Federal Circuit, Ninth Circuit, and California Court of Appeal,

tried cases, argued motions, and managed all aspects of complex litigation. He also 

served as a volunteer criminal prosecutor for the Los Angeles City Attorney’s Office.

Mr. Rotter graduated with honors from Harvard Law School in 2004. He served as an

editor of the Harvard Journal of Law & Technology, was a Fellow in Law and Economics 

at the John M. Olin Center for Law, Economics, and Business at Harvard Law School, 

and a Fellow in Justice, Welfare, and Economics at the Harvard University 

Weatherhead Center For International Affairs. He graduated with honors from the 

University of California, San Diego in 2000 with a B.S. in molecular biology and a B.A. in 

music.

Mr. Rotter serves on the Merit Selection Panel for Magistrate Judges in the Central 

District of California, and served on the Model Patent Jury Instructions and Model 

Patent Local Rules subcommittees of the American Intellectual Property Law 

Association. He has written extensively on intellectual property issues, and has been 

honored for his work with legal service organizations. He is admitted to practice in 

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California and before the United States Courts of Appeals for the First, Second, Ninth 

and Federal Circuits, the United States District Courts for the Northern, Central, and 

Southern Districts of California, and the United States Patent & Trademark Office.

KEVIN F. RUF graduated from the University of California at Berkeley with a Bachelor 

of Arts in Economics and earned his Juris Doctor degree from the University of 

Michigan. He was an associate at the Los Angeles firm Manatt Phelps and Phillips from 

1988 until 1992, where he specialized in commercial litigation. In 1993, he joined the 

firm Corbin & Fitzgerald (with future federal district court Judge Michael Fitzgerald) 

specializing in white collar criminal defense work. Kevin joined the Glancy firm in 2001 

and is the head of the firm’s Labor practice.

Kevin has successfully argued a number of important appeals, including in the 9th 

Circuit Court of Appeals. He has twice argued cases before the California Supreme 

Court – winning both. In Smith v. L'Oreal (2006), the California Supreme Court 

established a fundamental right of all California workers to immediate payment of all 

earnings at the conclusion of their employment. The second California Supreme Court 

case, Lee v. Dynamex (2018), has been called a “blockbuster” and “bombshell” as it 

altered 30 years of California law and established a new definition of employment that 

brings more workers within the protections of California’s Labor Code. 

Kevin has been named one of California’s “Top 75 Employment Lawyers” by the Daily 

Journal. He has consistently been named a “Super Lawyer.”

Since 2014, Kevin has been an elected member of the Ojai Unified School District 

Board of Trustees. Kevin was also a Main Company Member of the world-famous 

Groundlings improv and sketch comedy troupe – “where everyone else got famous.”

BENJAMIN I. SACHS-MICHAELS, a partner in the firm’s New York office, graduated 

from Benjamin N. Cardozo School of Law in 2011. His practice focuses on shareholder 

derivative litigation and class actions on behalf of shareholders and consumers.

While in law school, Mr. Sachs-Michaels served as a judicial intern to Senior United 

States District Judge Thomas J. McAvoy in the United States District Court for the 

Northern District of New York and was a member of the Cardozo Journal of Conflict 

Resolution.

Mr. Sachs-Michaels is a member of the Bar of the State of New York. He is also 

admitted to the United States District Courts for the Southern and Eastern Districts of 

New York and the United States Court of Appeals for the Second Circuit.

CASEY E. SADLER is a native of New York, New York. After graduating from the 

University of Southern California, Gould School of Law, Mr. Sadler joined the Firm in 

2010. While attending law school, Mr. Sadler externed for the Enforcement Division of 

the Securities and Exchange Commission, spent a summer working for P.H. Parekh & 

Co. – one of the leading appellate law firms in New Delhi, India – and was a member of 

USC's Hale Moot Court Honors Program.

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Mr. Sadler’s practice focuses on securities and consumer litigation. A partner in the 

Firm’s Los Angeles office, Mr. Sadler is admitted to the State Bar of California and the 

United States District Courts for the Northern, Southern, and Central Districts of 

California.

EX KANO S. SAMS II EX KANO S. SAMS II earned his Bachelor of Arts degree in 

Political Science from the University of California Los Angeles. Mr. Sams earned his 

Juris Doctor degree from the University of California Los Angeles School of Law, where 

he served as a member of the UCLA Law Review. After law school, Mr. Sams practiced 

class action civil rights litigation on behalf of plaintiffs. Subsequently, Mr. Sams was a 

partner at Coughlin Stoia Geller Rudman & Robbins LLP (currently Robbins Geller 

Rudman & Dowd LLP), where his practice focused on securities and consumer class 

actions on behalf of investors and consumers.

During his career, Mr. Sams has served as lead counsel in dozens of securities class 

actions and complex-litigation cases, and has worked on cases at all levels of the state 

and federal court systems throughout the United States. Mr. Sams was one of the 

counsel for respondents in Cyan, Inc. v. Beaver Cty. Employees Ret. Fund, 138 S. Ct. 

1061 (2018), in which the United States Supreme Court ruled unanimously in favor of 

respondents, holding that: (1) the Securities Litigation Uniform Standards Act of 1998 

(“SLUSA”) does not strip state courts of jurisdiction over class actions alleging violations 

of only the Securities Act of 1933; and (2) SLUSA does not empower defendants to 

remove such actions from state to federal court. Mr. Sams also participated in a 

successful appeal before a Fifth Circuit panel that included former United States 

Supreme Court Justice Sandra Day O’Connor sitting by designation, in which the court 

unanimously vacated the lower court’s denial of class certification, reversed the lower 

court’s grant of summary judgment, and issued an important decision on the issue of 

loss causation in securities litigation: Alaska Electrical Pension Fund v. Flowserve 

Corp., 572 F.3d 221 (5th Cir. 2009). The case settled for $55 million.

Mr. Sams has also obtained other significant results. Notable examples include: 

Beezley v. Fenix Parts, Inc., No. 1:17-CV-7896, 2018 WL 3454490 (N.D. Ill. July 13, 

2018) (denying motion to dismiss); In re Flowers Foods, Inc. Sec. Litig., No. 7:16-CV222 (WLS), 2018 WL 1558558 (M.D. Ga. Mar. 23, 2018) (largely denying motion to 

dismiss; case settled for $21 million); In re King Digital Entm’t plc S’holder Litig., No. 

CGC-15-544770 (San Francisco Superior Court) (case settled for $18.5 million); In re 

Castlight Health, Inc. S’holder Litig., Lead Case No. CIV533203 (California Superior 

Court, County of San Mateo) (case settled for $9.5 million); Wiley v. Envivio, Inc., 

Master File No. CIV517185 (California Superior Court, County of San Mateo) (case 

settled for $8.5 million); In re CafePress Inc. S’holder Litig., Master File No. CIV522744 

(California Superior Court, County of San Mateo) (case settled for $8 million); Estate of 

Gardner v. Continental Casualty Co., No. 3:13-cv-1918 (JBA), 2016 WL 806823 (D. 

Conn. Mar. 1, 2016) (granting class certification); Forbush v. Goodale, No. 33538/2011, 

2013 WL 582255 (N.Y. Sup. Feb. 4, 2013) (denying motions to dismiss); Curry v. 

Hansen Med., Inc., No. C 09-5094 CW, 2012 WL 3242447 (N.D. Cal. Aug. 10, 2012) 

(upholding complaint; case settled for $8.5 million); Wilkof v. Caraco Pharm. Labs., Ltd., 

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280 F.R.D. 332 (E.D. Mich. 2012) (granting class certification); Puskala v. Koss Corp., 

799 F. Supp. 2d 941 (E.D. Wis. 2011) (upholding complaint); Mishkin v. Zynex Inc., Civil 

Action No. 09-cv-00780-REB-KLM, 2011 WL 1158715 (D. Colo. Mar. 30, 2011) 

(denying motion to dismiss); and Tsirekidze v. Syntax-Brillian Corp., No. CV-07-02204-

PHX-FJM, 2009 WL 2151838 (D. Ariz. July 17, 2009) (granting class certification; case 

settled for $10 million).

Additionally, Mr. Sams has successfully represented consumers in class action 

litigation. Mr. Sams worked on nationwide litigation and a trial against major tobacco 

companies, and in statewide tobacco litigation that resulted in a $12.5 billion recovery 

for California cities and counties in a landmark settlement. He also was a principal 

attorney in a consumer class action against one of the largest banks in the country that 

resulted in a substantial recovery and a change in the company’s business practices. 

Mr. Sams also participated in settlement negotiations on behalf of environmental 

organizations along with the United States Department of Justice and the Ohio Attorney 

General’s Office that resulted in a consent decree requiring a company to perform 

remediation measures to address the effects of air and water pollution. Additionally, Mr. 

Sams has been an author or co-author of several articles in major legal publications, 

including “9th Circuit Decision Clarifies Securities Fraud Loss Causation Rule” 

published in the February 8, 2018 issue of the Daily Journal, and “Market Efficiency in 

the World of High-Frequency Trading” published in the December 26, 2017 issue of the 

Daily Journal.

LEANNE HEINE SOLISH is a partner in GPM’s Los Angeles office. Her practice 

focuses on complex securities litigation.

Ms. Solish has extensive experience litigating complex cases in federal courts 

nationwide. Since joining GPM in 2012, Ms. Solish has helped secure several large 

class action settlements for injured investors, including: The City of Farmington Hills 

Employees Retirement System v. Wells Fargo Bank, Case No. 10-4372--DWF/JJG (D. 

Minn.) ($62.5 million settlement on behalf of participants in Wells Fargo’s securities 

lending program. The settlement was reached on the eve of trial and ranked among the 

largest recoveries achieved in a securities lending class action stemming from the 2008 

financial crisis.); Mild v. PPG Industries, Inc. et al., Case No. 2:18-cv-04231 (C.D. Cal.) 

($25 million settlement); In re Penn West Petroleum Ltd. Securities Litigation, Case No. 

1:14-cv-06046-JGK (S.D.N.Y.) ($19 million settlement for the U.S. shareholder class as 

part of a $39 million global settlement); In re ITT Educational Services, Inc. Securities 

Litigation (Indiana), Case No. 1:14-cv-01599-TWP-DML ($12.5375 million settlement); 

In re Doral Financial Corporation Securities Litigation, Case No. 3:14-cv-01393-GAG 

(D.P.R.) ($7 million settlement); Larson v. Insys Therapeutics Incorporated, et al., Lead 

Case No. 14-cv-01043-PHX-GMS (D. Ariz.) ($6.125 million settlement); In re Unilife 

Corporation Securities Litigation, Case No. 1:16-cv-03976-RA ($4.4 million settlement); 

and In re K12 Inc. Securities Litigation, Case No. 4:16-cv-04069-PJH (N.D. Cal.) ($3.5 

million settlement).

Super Lawyers Magazine has selected Ms. Solish as a “Rising Star” in the area of 

Securities Litigation for the past four consecutive years, 2016 through 2019.

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Ms. Solish graduated summa cum laude with a B.S.M. in Accounting and Finance from 

Tulane University, where she was a member of the Beta Alpha Psi honors accounting 

organization and was inducted into the Beta Gamma Sigma Business Honors Society. 

Ms. Solish subsequently earned her J.D. from the University of Texas School of Law. 

Ms. Solish is admitted to the State Bar of California, the Ninth Circuit Court of Appeals, 

and the United States District Courts for the Central, Northern, and Southern Districts of 

California. Ms. Solish is also a Registered Certified Public Accountant in Illinois.

KARA M. WOLKE is a partner in the firm’s Los Angeles office. Ms. Wolke specializes in 

complex litigation, including the prosecution of securities fraud, derivative, consumer, 

and wage and hour class actions. She has extensive experience in written appellate 

advocacy in both State and Federal Circuit Courts of Appeals, and has successfully 

argued before the Court of Appeals for the State of California.

With over a decade of experience in financial class action litigation, Ms. Wolke has 

helped to recover hundreds of millions of dollars for injured investors, consumers, and 

employees. Notable cases include: Farmington Hills Employees’ Retirement System v. 

Wells Fargo Bank, Case No. 10-4372 (D. Minn.) ($62.5 million settlement on behalf of 

participants in Wells Fargo’s securities lending program. The settlement was reached 

on the eve of trial and ranked among the largest recoveries achieved in a securities 

lending class action stemming from the 2008 financial crisis.); Schleicher, et al. v. 

Wendt, et al. (Conseco), Case No. 02-cv-1332 (S.D. Ind.) ($41.5 million securities class 

action settlement); Lapin v. Goldman Sachs, Case No. 03-850 (S.D.N.Y.) ($29 million 

securities class action settlement); In Re: Mannkind Corporation Securities Litigation, 

Case No. 11-929 (C.D. Cal) (approximately $22 million settlement - $16 million in cash 

plus stock); Jenson v. First Trust Corp., Case No. 05-3124 (C.D. Cal.) ($8.5 million 

settlement of action alleging breach of fiduciary duty and breach of contract against trust 

company on behalf of a class of elderly investors); and Pappas v. Naked Juice Co., 

Case No. 11-08276 (C.D. Cal.) ($9 million settlement in consumer class action alleging 

misleading labeling of juice products as “All Natural”). 

With a background in intellectual property, Ms. Wolke was a part of the team of lawyers 

who successfully challenged the claim of copyright ownership to the song “Happy 

Birthday to You” on behalf of artists and filmmakers who had been forced to pay hefty 

licensing fees to publicly sing the world’s most famous song. In the resolution of that 

action, the defendant music publishing company funded a settlement of $14 million and, 

significantly, agreed to relinquish the song to the public domain. Previously, Ms. Wolke 

penned an article regarding the failure of U.S. Copyright Law to provide an important 

public performance right in sound recordings, 7 Vand. J. Ent. L. & Prac. 411, which was 

nationally recognized and received an award by the American Bar Association and the 

Grammy® Foundation. 

Committed to the provision of legal services to the poor, disadvantaged, and other 

vulnerable or disenfranchised individuals and groups, Ms. Wolke also oversees the 

Firm’s pro bono practice. Ms. Wolke currently serves as a volunteer attorney for KIND 

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(Kids In Need of Defense), representing unaccompanied immigrant and refugee 

children in custody and deportation proceedings, and helping them to secure legal 

permanent residency status in the U.S.

Ms. Wolke graduated summa cum laude with a Bachelor of Science in Economics from 

The Ohio State University in 2001. She subsequently earned her J.D. (with honors) from 

Ohio State, where she was active in Moot Court and received the Dean’s Award for 

Excellence during each of her three years. 

Ms. Wolke is admitted to the State Bar of California, the Ninth Circuit Court of Appeals, 

as well as the United States District Courts for the Northern, Southern, and Central 

Districts of California. She lives with her husband and two sons in Los Angeles.

OF COUNSEL

BRIAN D. BROOKS joined the New York office of Glancy Prongay & Murray LLP in 

2019, specializing in antitrust, consumer, and securities litigation. His current cases 

include In re Zetia Antitrust Litigation, No. 18-md-2836 (E.D. Va.); Staley, et al. v. Gilead 

Sciences, Inc., et al., No. 3:19-cv-02573-EMC (N.D. Cal.); and In re: Seroquel XR 

(Extended Release Quetiapine Fumarate) Litigation, No. 1:19-cv-08296-CM (S.D.N.Y.).

Prior to joining the firm, Mr. Brooks was an associate at Murray, Frank & Sailer, LLP in 

New York, where his practice was focused on antitrust, consumer, and securities 

matters, and later a partner at Smith, Segura & Raphael, LLP, in New York and 

Louisiana. During his tenure at Smith Segura & Raphael, LLP, Mr. Brooks represented 

direct purchasers in numerous antitrust matters, including In re: Suboxone 

(Buprenorphine Hydrochloride and Naloxone) Antitrust Litigation, No. 2:13-md-02445 

(E.D. Pa.), In re: Niaspan Antitrust Litigation, No. 2:13-md-02460 (E.D. Pa.), and In re: 

Novartis & Par Antitrust Litigation (Exforge), No. 18-cv-4361 (S.D.N.Y.), and was an 

active member of the trial team for the class in In re: Nexium (Esomeprazole) Antitrust 

Litigation, No. 12-md-2409 (D. Mass.), the first post-Actavis reverse-payment case to be 

tried to verdict. He was also an active member of the litigation teams in the King Drug 

Company of Florence, Inc. et al. v. Cephalon, Inc., et al. (Provigil), No. 2:06-cv-1797 

(E.D. Pa.); In re: Prograf Antitrust Litigation, No. 1:11-md-2242 (D. Mass.) and In re: 

Miralax antitrust matters, which collectively settled for more than $600 million, and a 

member of the litigation teams in In re: Relafen Antitrust Litigation, No. 01-cv-12239 (D. 

Mass.); In re: Buspirone Antitrust Litigaiton, MDL Dkt. No. 1410 (S.D.N.Y.); In re: 

Remeron Antitrust Litigation, No. 02-2007 (D.N.J.); In re: Terazosin Hydrochloride 

Antitrust Litigation, No. 99-MDL-1317 (S.D. Fla.); and In re K-Dur Antitrust Litigation, 

No. 10-cv-1652 (D.N.J.).

Mr. Brooks received his B.A. from Northwestern State University of Louisiana in 1998 

and his J.D. from Washington and Lee School of Law in 2002, where he was a staff 

writer for the Environmental Law Digest and clerked for the Alderson Legal Assistance 

Program, handling legal matters for inmates of the Federal Detention Center in 

Alderson, West Virginia. He is admitted to practice in all state courts in New York and 

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Louisiana, as well as the United States District Courts for the Southern and Eastern 

Districts of New York and the Eastern and Western Districts of Louisiana.

MARK S. GREENSTONE specializes in consumer, financial fraud and employmentrelated class actions. Possessing significant law and motion and trial experience, Mr. 

Greenstone has represented clients in multi-million dollar disputes in California state 

and federal courts, as well as the Court of Federal Claims in Washington, D.C.

Mr. Greenstone received his training as an associate at Sheppard, Mullin, Richter & 

Hampton LLP where he specialized in complex business litigation relating to investment 

management, government contracts and real estate. Upon leaving Sheppard Mullin, Mr. 

Greenstone founded an internet-based company offering retail items on multiple 

platforms nationwide. He thereafter returned to law bringing a combination of business 

and legal skills to his practice. 

Mr. Greenstone graduated Order of the Coif from the UCLA School of Law. He also 

received his undergraduate degree in Political Science from UCLA, where he graduated 

Magna Cum Laude and was inducted into the Phi Beta Kappa honor society.

Mr. Greenstone is a member of the Consumer Attorneys Association of Los Angeles, 

the Santa Monica Bar Association and the Beverly Hills Bar Association. He is admitted 

to practice in state and federal courts throughout California.

ROBERT I. HARWOOD, Of Counsel to the firm, graduated from William and Mary Law 

School in 1971, and has specialized in securities law and securities litigation since 

beginning his career in 1972 at the Enforcement Division of the New York Stock 

Exchange. Mr. Harwood was a founding member of Harwood Feffer LLP. He has 

prosecuted numerous securities, class, derivative, and ERISA actions. He is a member 

of the Trial Lawyers’ Section of the New York State Bar Association and has served as 

a guest lecturer at trial advocacy programs sponsored by the Practicing Law Institute. 

In a statewide survey of his legal peers published by Super Lawyers Magazine, Mr. 

Harwood has been consistently selected as a “New York Metro Super Lawyer.” Super 

Lawyers are the top five percent of attorneys in New York, as chosen by their peers and 

through the independent research. He is also a Member of the Board of Directors of the 

MFY Legal Services Inc., which provides free legal representation in civil matters to the 

poor and the mentally ill in New York City. Since 1999, Mr. Harwood has also served as 

a Village Justice for the Village of Dobbs Ferry, New York.

Commenting on Mr. Harwood’s abilities, in In re Royal Dutch/Shell Transport ERISA

Litigation, (D.N.J.), Judge Bissell stated:

the Court knows the attorneys in the firms involved in this matter and they 

are highly experienced and highly skilled in matters of this kind. 

Moreover, in this case it showed. Those efforts were vigorous, 

imaginative and prompt in reaching the settlement of this matter with a 

minimal amount of discovery . . . . So both skill and efficiency were 

brought to the table here by counsel, no doubt about that.

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Likewise, Judge Hurley stated in connection with In re Olsten Corporation Securities 

Litigation, No. 97 CV-5056 (E.D.N.Y. Aug. 31, 2001), wherein a settlement fund of $24.1 

million was created: “The quality of representation here I think has been excellent.” Mr. 

Harwood was lead attorney in Meritt v. Eckerd, No. 86 Civ. 1222 (E.D.N.Y. May 30, 

1986), where then Chief Judge Weinstein observed that counsel conducted the litigation 

with “speed and skill” resulting in a settlement having a value “in the order of $20 Million 

Dollars.” Mr. Harwood prosecuted the Hoeniger v. Aylsworth class action litigation in 

the United States District Court for the Western District of Texas (No. SA-86-CA-939), 

which resulted in a settlement fund of $18 million and received favorable comment in 

the August 14, 1989 edition of The Wall Street Journal (“Prospector Fund Finds Golden 

Touch in Class Action Suit” p. 18, col. 1). Mr. Harwood served as co-lead counsel in In 

Re Interco Incorporated Shareholders Litigation, Consolidated C.A. No. 10111 

(Delaware Chancery Court) (May 25, 1990), resulting in a settlement of $18.5 million, 

where V.C. Berger found, “This is a case that has an extensive record that establishes it 

was very hard fought. There were intense efforts made by plaintiffs’ attorneys and 

those efforts bore very significant fruit in the face of serious questions as to ultimate 

success on the merits.”

Mr. Harwood served as lead counsel in Morse v. McWhorter (Columbia/HCA Healthcare 

Securities Litigation), (M.D. Tenn.), in which a settlement fund of $49.5 million was 

created for the benefit of the Class, as well as In re Bank One Securities Litigation, 

(N.D. Ill.), which resulted in the creation of a $45 million settlement fund. Mr. Harwood 

also served as co-lead counsel in In re Safety-Kleen Corp. Stockholders Litigation, 

(D.S.C.), which resulted in a settlement fund of $44.5 million; In re Laidlaw Stockholders 

Litigation, (D.S.C.), which resulted in a settlement fund of $24 million; In re AIG ERISA 

Litigation, (S.D.N.Y.), which resulted in a settlement fund of $24.2 million; In re JWP Inc. 

Securities Litigation, (S.D.N.Y.), which resulted in a $37 million settlement fund; In re 

Oxford Health Plans, Inc. Derivative Litigation, (S.D.N.Y.), which resulted in a settlement 

benefit of $13.7 million and corporate therapeutics; and In re UNUMProvident Corp. 

Securities Litigation, (D. Me.), which resulted in the creation of settlement fund of $45 

million. Mr. Harwood has also been one of the lead attorneys in litigating claims in In re 

FedEx Ground Package Inc. Employment Practices Litigation, No. 3:05-MD-527 (MDL 

1700), a multi-district litigation concerning employment classification of pickup and 

delivery drivers which resulted in a $242,000,000 settlement.

ASSOCIATES

CHRISTOPHER FALLON focuses on securities, consumer, and anti-trust litigation. 

Prior to joining the firm, Mr. Fallon was a contract attorney with O'Melveny & Myers LLP 

working on anti-trust and business litigation disputes. He is a Certified E-Discovery 

Specialist through the Association of Certified E-Discovery Specialists (ACEDS).

Mr. Fallon earned his J.D. and a Certificate in Dispute Resolution from Pepperdine Law 

School in 2004. While attending law school, Christopher worked at the Pepperdine 

Special Education Advocacy Clinic and interned with the Rhode Island Office of the 

Attorney General. Prior to attending law school, he graduated from Boston College with 

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a Bachelor of Arts in Economics and a minor in Irish Studies, then served as Deputy 

Campaign Finance Director on a U.S. Senate campaign.

THOMAS J. KENNEDY works out of the New York office, where he focuses on 

securities, antitrust, mass torts, and consumer litigation. He received a Juris Doctor 

degree from St. John’s University School of Law in 1995. At St. John’s, he was a 

member of the ST. JOHN’S JOURNAL OF LEGAL COMMENTARY. Mr. Kennedy

graduated from Miami University in 1992 with a Bachelor of Science degree in 

Accounting and has passed the CPA exam. Mr. Kennedy was previously associated 

with the law firm Murray Frank LLP.

JENNIFER M. LEINBACH served for nearly five years as a judicial law clerk for a 

number of judges in the Central District of California. As a judicial law clerk, Ms. 

Leinbach was responsible for assisting these judges with case management, preparing 

for hearings and trial, and drafting rulings. Ms. Leinbach worked on a variety of different 

cases, including cases involving financial fraud, insolvency and complex civil litigation. 

Ms. Leinbach was also responsible for assisting those judges, sitting by designation, on 

appellate cases.

Ms. Leinbach graduated magna cum laude from Vermont Law School and was a 

member of Vermont Law Review, where she focused on environmental law issues. 

During law school, Ms. Leinbach served as a judicial extern in the District of Vermont. 

She obtained her undergraduate degree cum laude from Pepperdine University.

CHARLES H. LINEHAN graduated summa cum laude from the University of California, 

Los Angeles with a Bachelor of Arts degree in Philosophy and a minor in Mathematics. 

Mr. Linehan received his Juris Doctor degree from the UCLA School of Law, where he 

was a member of the UCLA Moot Court Honors Board. While attending law school, Mr. 

Linehan participated in the school’s First Amendment Amicus Brief Clinic (now the Scott 

& Cyan Banister First Amendment Clinic) where he worked with nationally recognized 

scholars and civil rights organizations to draft amicus briefs on various Free Speech 

issues.

DANIELLE L. MANNING is a litigation associate in the firm’s Los Angeles office. Ms. 

Manning specializes in prosecuting complex class action lawsuits in state and federal 

courts nationwide, including consumer and securities fraud class actions. She has 

particular experience litigating automobile defect and Telephone Consumer Protection 

Act (“TCPA”) cases and excels at managing multiple significant matters at once. Ms. 

Manning has experience in all phases of pre-trial litigation, including conducting fact 

investigation, drafting pleadings, researching and drafting briefs in the context of law 

and motion practice, drafting and responding to discovery requests, assisting with 

deposition preparation, and preparing for and negotiating settlements. Ms. Manning is 

admitted to the State Bar of California, the Ninth Circuit Court of Appeals, United States 

District Courts for the Central and Northern Districts of California, and the Eastern 

District of Michigan.

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A few of the matters Ms. Manning is currently taking an active role in are: Gann et. al. v. 

Nissan North America, Case No. 3:18-cv-00966 (M.D. Tenn.) (preliminary approval 

granted July 16, 2019); Salcedo v. Häagen-Dazs Shoppe Company Inc., Case No. 

5:17-cv-03504 (N.D. Cal.); Andre Damico et. al. v. Hyundai Motor America Inc., Case 

No. 30-2018-01008552-CU-BC-CXC (Cal. Super. Ct.) (demurrer overruled); Elaine Hall 

et al. v. General Motors LLC, Case No. 4:19-cv-10186 (E.D. Mich.) (motion to dismiss 

pending); Mark Mina v. Red Robin International Inc., et al., Case No. 2:18-cv-09472 

(C.D. Cal.)(motion to dismiss pending) and Kohna et al. v. Subaru of America Inc., Case 

No. 1:19-cv-09323 (D.N.J).

Ms. Manning received her Juris Doctor degree from the University of California Los 

Angeles School of Law, where she served as Chief Managing Editor of the Journal of

Environmental Law and Policy. While attending law school, Ms. Manning externed for 

the Honorable Laurie D. Zelon in the California Court of Appeal and interned for the 

California Department of Justice, Office of the Attorney General. Ms. Manning received 

her Bachelor of Arts degree with honors in Environmental Analysis from Claremont 

McKenna College.

NATALIE S. PANG is an associate in the firm's Los Angeles office. Ms. Pang has 

advocated on behalf of thousands of consumers during her career. Ms. Pang has 

extensive experience in case management and all facets of litigation: from a case’s 

inception through the discovery process--including taking and defending depositions 

and preparing witnesses for depositions and trial--mediation and settlement 

negotiations, pretrial motion work, trial and post-trial motion work. 

Prior to joining the firm, Ms. Pang lead the mass torts department of her last firm, where 

she managed the cases of over two thousand individual clients. There, Ms. Pang 

worked on a wide variety of complex state and federal matters which included cases 

involving pharmaceutical drugs, medical devices, auto defects, toxic torts, false 

advertising, and uninhabitable conditions. Ms. Pang was also trial counsel in the notable 

case, Celestino Acosta et al. v. City of Long Beach et al. (BC591412) which was 

brought on behalf of residents of a mobile home park built on a former trash dump and 

resulted in a $39.5 million verdict after an eleven-week jury trial in Los Angeles Superior 

Court. 

Ms. Pang received her J.D. from Loyola Law School. While in law school, Ms. Pang 

received a Top 10 Brief Award as a Scott Moot Court competitor, was chosen to be a 

member of the Scott Moot Court Honor's Board, and competed as a member of the 

National Moot Court Team. Ms. Pang was also a Staffer and subsequently an Editor for 

Loyola's Entertainment Law Review as well as a Loyola Writing Tutor. During law 

school, Ms. Pang served as an extern for: the Hon. Rolf Treu (Los Angeles Superior 

Court), the Los Angeles City Attorney's Office, and the Federal Public Defender's Office. 

Ms. Pang obtained her undergraduate degree from the University of Southern California 

and worked in the healthcare industry prior to pursuing her career in law.

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JARED F. PITT focuses on securities, consumer, and anti-trust litigation. Prior to joining 

the firm, Mr. Pitt was an associate at Willoughby Doyle LLP and was a senior financial 

statement auditor for KMPG LLP where he earned his CPA license. 

Mr. Pitt earned his J.D. from Loyola Law School in 2010. Prior to attending law school 

he graduated with honors from both the University of Michigan’s Ross School of 

Business and USC’s Marshall School of Business where he received a Masters of 

Accounting.

PAVITHRA RAJESH is a litigation associate in the firm’s Los Angeles office. She 

specializes in fact discovery, including pre-litigation investigation, and develops legal 

theories in securities, derivative, and privacy-related matters.

Ms. Rajesh has unique writing experience from her judicial externship for the Patent 

Pilot Program in the United States District Court for the Central District of California, 

where she worked closely with the Clerk and judges in the program on patent cases. 

Drawing from this experience, Ms. Rajesh is passionate about expanding the firm's 

Intellectual Property practice, and she engages with experts to understand complex 

technology in a wide range of patents, including network security and videogame 

electronics.

Ms. Rajesh graduated from University of California, Santa Barbara with a Bachelor of 

Science degree in Mathematics and a Bachelor of Arts degree in Psychology. She 

received her Juris Doctor degree from UCLA School of Law. While in law school, Ms. 

Rajesh was an Associate Editor for the UCLA Law Review.

GARTH A. SPENCER is based in the New York office. His work includes securities, 

antitrust, and consumer litigation. Mr. Spencer also works on whistleblower matters.

Mr. Spencer received his B.A. in Mathematics from Grinnell College in 2006. He 

received his J.D. in 2011 from Duke University School of Law, where he was a staff 

editor on the Duke Law Journal. From 2011 until 2014 he worked in the tax group of a 

large, international law firm. Since 2014 he has worked on tax whistleblower matters. 

Mr. Spencer received his LL.M. in Taxation from New York University in 2016 

immediately prior to joining the firm.

MELISSA WRIGHT is a litigation associate in the firm’s Los Angeles office. Ms. Wright 

specializes in complex litigation, including the prosecution of securities fraud and 

consumer class actions. She has particular expertise in all aspects of the discovery 

phase of litigation, including drafting and responding to discovery requests, negotiating 

protocols for the production of Electronically Stored Information (ESI) and all facets of 

ESI discovery, and assisting in deposition preparation. She has managed multiple 

document production and review projects, including the development of ESI search 

terms, overseeing numerous attorneys reviewing large document productions, drafting 

meet and confer correspondence and motions to compel where necessary, and 

coordinating the analysis of information procured during the discovery phase for 

utilization in substantive motions or settlement negotiations.

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Ms. Wright received her J.D. from the UC Davis School of Law in 2012, where she was 

a board member of Tax Law Society and externed for the California Board of 

Equalization’s Tax Appeals Assistance Program focusing on consumer use tax issues. 

Ms. Wright also graduated from NYU School of Law, where she received her LL.M. in 

Taxation in 2013.

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