UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) )

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1 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 Christopher Kim, Esq. (Bar No. 000 Lisa J. Yang, Esq. (Bar No. 0 LIM RUGER & KIM, LLP 0 West Seventh Street, Suite 00 Los Angeles, California 00 Telephone: ( christopher.kim@limruger.com lisa.yang@limruger.com David Kessler, Esq. Gregory M. Castaldo, Esq. Andrew L. Zivitz, Esq. BARROWAY TOPAZ KESSLER MELTZER & CHECK, LLP 0 King of Prussia Road Radnor, Pennsylvania 0 Telephone: (0-0 Counsel for Plaintiffs Allyn Z. Lite, Esq. Joseph J. DePalma, Esq. LITE DEPALMA GREENBERG & RIVAS, LLC Two Gateway Center, th Floor Newark, New Jersey 00 Telephone: ( -000 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA In re: TENET HEALTHCARE CORP. SECURITIES LITIGATION This Document Relates to ALL ACTIONS. WESTERN DIVISION No. CV-0--RSWL (Rzx [PROPOSED] ORDER AUTHORIZING DISTRIBUTION OF NET SETTLEMENT FUND Date: July, 00 Time: :00 A.M. Judge: The Hon. Ronald Lew Courtroom:

2 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 WHEREAS, by its Final Judgment and Order Approving Partial Settlement dated May, 00, this Court approved the first of two partial settlements in the above-captioned action (the Action embodied in the Stipulation and Agreement of Partial Settlement dated as of January, 00 between Lead Plaintiff, the State of New Jersey and its Division of Investment ( Lead Plaintiff, and defendants Tenet Healthcare Corporation, Jeffrey C. Barbakow, David L. Dennis, Thomas B. Mackey, Raymond L. Mathiasen, Barry P. Schochet and Christi R. Sulbach (the Tenet Settlement, and a plan for allocating the settlement proceeds among the members of the Tenet Class; and WHEREAS, this Court had directed the parties to consummate the terms of the Tenet Settlement; and WHEREAS, the $,00,000 cash settlement proceeds obtained in the Tenet Settlement (the Tenet Settlement Fund have been deposited into an interest-bearing escrow account established by Lead Plaintiff s Counsel, on behalf of the Tenet Class; and WHEREAS, as set forth in the Notice of Pendency and Proposed Partial Settlement of Class Action (the Tenet Notice disseminated to potential members of the Tenet Class, the deadline for submission of Proof of Claim and Release forms ( Proofs of Claim in order to participate in the Tenet Settlement was July, 00; and WHEREAS, by its Final Judgment and Order dated December, 00, this Court approved the second partial settlement in this Action embodied in the Stipulation and Agreement of Settlement dated as of June 0, 00 between Lead Capitalized terms not defined herein shall have the meanings contained in the Declaration of Gregory M. Castaldo in Support of Lead Plaintiff s Motion for Distribution of Net Settlement Fund (the Joint Declaration submitted herewith.

3 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 Plaintiff and defendant KPMG LLP (the KPMG Settlement, and a plan for allocating the settlement proceeds among the members of the KPMG Class; and WHEREAS, this Court had directed the parties to consummate the terms of the KPMG Settlement; and WHEREAS, the $,000,000 cash settlement proceeds obtained in the KPMG Settlement (the KPMG Settlement Fund have been deposited into an interest-bearing escrow account established by Lead Plaintiff s Counsel, on behalf of the KPMG Class; and WHEREAS, as set forth in the Notice of Proposed Settlement of Tenet Securities Litigation with KPMG LLP, Motion for Attorneys Fees and Reimbursement of Expenses and Settlement Fairness Hearing (the KPMG Notice disseminated to potential members of the KPMG Class, the deadline for members of the KPMG Class, who did not previously submit a Proof of Claim in connection with the Tenet Settlement, to submit Proofs of Claim in order to participate in the KPMG Settlement was October 0, 00; and WHEREAS, in satisfaction of due process requirements, all members of the Tenet Class and KPMG Class (collectively, the Class who filed claims that were in any way ineligible or deficient were: ( informed that their claims were ineligible or deficient; and ( given opportunities to correct any deficiency prior to their claims being finally rejected, or to contest the determination as to the deficiency, by requesting a hearing before the Court; and WHEREAS, the process of reviewing all Proofs of Claim received by members of the Class has been completed; and WHEREAS, Lead Plaintiff s Counsel now seek authorization to make a distribution of the Tenet and KPMG Settlement Funds (together, the Settlement Fund to Authorized Claimants, less any taxes due on the income earned on the Settlement Fund, less any fees and expenses previously awarded by the Court, and after deduction of any fees and expenses approved by this Order; and

4 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 NOW, THEREFORE, upon reading and filing: (i the Affidavit of Stephen J. Cirami in Support of Lead Plaintiff s Motion for Distribution of Net Settlement Fund (the Cirami Affidavit, submitted on behalf of The Garden City Group, Inc. ( GCG ; (ii the Declaration of Gregory M. Castaldo of Barroway Topaz Kessler Meltzer & Check, LLP, submitted on behalf of counsel for Lead Plaintiff and the Class; and upon all prior proceedings heretofore had herein, and after due deliberation, it is hereby ORDERED, that the administrative determinations of GCG accepting the claims as indicated on the computer printout of accepted claims submitted and described in the Cirami Affidavit, calculated pursuant to the Court-approved Plans of Allocation, including claims submitted (i after the July, 00 submission deadline for the Tenet Settlement but before the initial mailing of the KPMG Notice on July, 00 and (ii after the October 0, 00 submission deadline for the KPMG Settlement, be and the same hereby are approved, and said claims are hereby accepted; and it is further ORDERED, that the administrative determinations of GCG rejecting the claims as indicated on the computer printout of rejected claims submitted with and described in the Cirami Affidavit, calculated pursuant to the Court-approved Plans of Allocation, be and the same hereby are approved, and said claims are hereby rejected; and it is further ORDERED, that payment be made from the Settlement Fund to the Internal Revenue Service for the proper amount of taxes due and owing on the interest earned on the Settlement Fund while in escrow, if any; and it is further ORDERED, that GCG be paid the sum of $,. from the Settlement Fund as payment for the balance of its fees and expenses incurred and to be incurred in connection with giving notice to the Class, processing the Proofs of Claim, preparing the tax returns for the Settlement Fund and distributing the Net Settlement Fund to the Authorized Claimants; and it is further

5 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 ORDERED, that the balance of the Settlement Fund after deducting payments previously allowed and set forth herein (the Net Settlement Fund shall be distributed to the Authorized Claimants listed on the computer printout submitted with the Cirami Affidavit under the proposed Plans of Allocation in proportion to each Authorized Claimant s Recognized Loss as compared to the total Recognized Losses of all accepted claimants as shown on such printout; and it is further ORDERED, that the checks for distribution to the Authorized Claimants shall bear the notation CASH PROMPTLY, VOID AND SUBJECT TO RE- DISTRIBUTION 0 DAYS AFTER DISTRIBUTION DATE. Lead Plaintiff s Counsel and GCG are authorized to take appropriate action to locate and/or contact any Authorized Claimant who has not cashed his, her or its check within said time; and it is further ORDERED, that if one ( year following the initial distribution of the Net Settlement Fund to Authorized Claimants and after GCG has made reasonable and diligent efforts to have Class Members who are entitled to participate in the distribution of the Net Settlement Fund cash their distributions, any monies remain in the Net Settlement Fund, the Claims Administrator shall redistribute any balance remaining in the Net Settlement Fund to Class Members who have cashed their initial distributions and who would receive at least $0.00 from such redistribution, after payment of any unpaid costs or fees incurred in administering the Net Settlement Fund for such redistribution, if such a redistribution is economically feasible. If after six ( months, after such redistribution, any funds remain in the Net Settlement Fund, such remaining balance shall be contributed to non-sectarian, not-for-profit, 0(c( organization(s designated by the Court after twenty (0 days prior notice to the Lead Plaintiff and Lead Plaintiff s Counsel, each of which may suggest to the Court one or more such organizations for the Court s selection; and it is further

6 Case :0-cv-0-RSWL-RZ Document Filed 0/0/00 Page of 0 0 ORDERED, that the Court finds that the administration of the Tenet and KPMG Settlements and the proposed distribution of the Net Settlement Fund comply with the terms of the settlement agreement entered in each settlement and the Plans of Allocation and that all persons involved in the review, verification, calculation, tabulation, or any other aspect of the processing of the claims submitted herein, or otherwise involved in the administration or taxation of the Settlement Fund or the Net Settlement Fund are released and discharged from any and all claims arising out of such involvement, and all Class Members, whether or not they are to receive payment from the Net Settlement Fund are barred from making any further claims against the Net Settlement Fund or the Released Persons beyond the amount allocated to them pursuant to this Order; and it is further ORDERED, that GCG is hereby authorized to discard paper or hard copies of Proofs of Claim and supporting documents not less than one ( year after the final distribution of the Net Settlement Fund to the eligible claimants and electronic copies of the same not less than three ( years after the final distribution of the Net Settlement Fund to the eligible claimants; and it is further ORDERED, that this Court retain jurisdiction over any further application or matter which may arise in connection with this Action; and it is further ORDERED, that claims submitted after June 0, 00 may be accepted only for excusable neglect on the part of the claimant, as determined by Lead Plaintiff s Counsel. IT IS SO ORDERED, this th day of July, 00: / S / Honorable Ronald S. W. Lew Senior, U.S. DISTRICT COURT JUDGE