Case 5:15-md LHK Document Filed 01/26/18 Page 1 of 23 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

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1 Case :-md-0-lhk Document - Filed 0// Page of 0 LIEFF CABRASER HEIMANN & BERNSTEIN LLP MICHAEL W. SOBOL (SBN ) msobol@lchb.com DAVID T. RUDOLPH (SBN ) drudolph@lchb.com MELISSA GARDNER (SBN 0) mgardner@lchb.com Battery Street, th Floor San Francisco, California Telephone: () -00 Facsimile: () -0 JASON L. LICHTMAN (pro hac vice) jlichtman@lchb.com 0 Hudson Street New York, NY 0 () -00 Plaintiffs Steering Committee In Re Anthem, Inc. Data Breach Litigation I, Michael W. Sobol, declare as follows: UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION Case No. -MD-0-LHK REPLY DECLARATION OF MICHAEL W. SOBOL IN SUPPORT OF PLAINTIFFS MOTION FOR ATTORNEYS FEES, LITIGATION EXPENSES, AND SERVICE AWARDS TO CLASS REPRESENTATIVES Date: February, 0 Time: :0 p.m. Judge: Hon. Lucy H. Koh Crtrm:, th Floor. I am a member in good standing of the State Bar of California, a partner in Lieff, Cabraser, Heimann & Bernstein, LLP ( LCHB ), and one of the two attorneys appointed by the Court to serve on Plaintiff s Steering Committee. I make this Declaration of my own personal knowledge. If called upon to testify, I could and would testify competently to the truth of the matters stated herein. Reply Declaration of Michael W. Sobol in Support of Plaintiffs Motion for Attorneys Fees, Litigation Expenses, and Service Awards to Class Representatives; CASE NO. -md-0-lhk (NC)

2 Case :-md-0-lhk Document - Filed 0// Page of 0. I submit this declaration in support of Class Counsel s reply brief in support of their motion for an award of attorneys fees and expenses. I have previously submitted a declaration in support of Class Counsel s motion (Dkt. -).. As I noted in my previous declaration in support of this motion (Dkt. -, ), LCHB s customary rates, which were used for purposes of calculating lodestar here, are based on prevailing market rates, including within this District. LCHB s rates have been approved by this Court, other courts in the Northern District of California, and other courts throughout the country. LCHB sets its hourly rates according to prevailing market rates, bills its hourly paying clients according to those rates, and is routinely awarded fees according to those rates. Certain of LCHB s staff and contract attorneys that worked on this case have been practicing law for over years. The following LCHB staff and contract attorneys contributed significant amounts of time and effort to this case and all graduated from law school or more years ago: a. Tanya Ashur graduated from Chicago-Kent College of Law, Chicago in 000. She is a staff attorney in the San Francisco office of LCHB. b. James Gilyard graduated from University of San Francisco School of Law in 00. He was a contract attorney at the San Francisco office of Lieff Cabraser until December 0. c. Eva Guo graduated from University of California, Hastings College of the Law in. She was a contract attorney at the San Francisco office of Lieff Cabraser until June 0. d. Donna Solen graduated from University of Florida College of Law in. She was a contract attorney at the San Francisco office of Lieff Cabraser until May 0.. A true and correct copy of the Transcript of the September, 0 hearing, In re Bank of New York Mellon Corp. Forex Transactions Litigation, No. -MD- (LAK), S.D.N.Y., is attached hereto as Exhibit A. Reply Declaration of Michael W. Sobol in Support of Plaintiffs Motion for Attorneys Fees, Litigation Expenses, and Service Awards to Class Representatives; CASE NO. -md-0-lhk (NC)

3 Case :-md-0-lhk Document - Filed 0// Page of I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, and that this Declaration was signed in San Francisco, California, on January, 0. /s/ Michael W. Sobol Michael W. Sobol 0 Reply Declaration of Michael W. Sobol in Support of Plaintiffs Motion for Attorneys Fees, Litigation Expenses, and Service Awards to Class Representatives; CASE NO. -md-0-lhk (NC)

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5 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE: BANK OF NEW YORK MELLON CORP. FOREX TRANSACTIONS LITIGATION x Before: HON. LEWIS A. KAPLAN, APPEARANCES LIEFF CABRASER HEIMANN & BERNSTEIN LLP Attorneys for Customer Plaintiffs BY: ELIZABETH CABRASER, ESQ. DANIEL P. CHIPLOCK, ESQ. MD (LAK) New York, N.Y. September, 0 : a.m. District Judge KESSLER, TOPAZ, MELTZER, CHECK LLP Attorneys for Plaintiff SEPTA Customer Class BY: SARAN NIRMUL, ESQ. JOSEPH H. MELTZER, ESQ. McTIGUE LAW LLP Attorneys for ERISA Plaintiffs Lead Settlement BY: J. BRIAN McTIGUE, ESQ. REGINA MARKEY, ESQ. KELLER, ROHRBACK, LLP Attorneys for ERISA Plaintiffs - Carter BY: LYNN LINCOLN SARKO, ESQ. MURRAY, MURPHY, MOUL & BASIL, LLP Attorneys for Plaintiff Ohio Pension Fund BY: BRIAN K. MURPHY, ESQ. KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, PLLC Attorneys for Defendant Bank of New York Mellon BY: REID M. FIGEL, ESQ. AND JASON E. FRIEDMAN, Senior Counsel, BNY Mellon () 0-000

6 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 (In open court) (Case called) MR. NIRMUL: Good morning, your Honor. Sharan Nirmul, Kessler, Topaz, Meltzer and Check. MR. MELTZER: Good morning, your Honor. Joseph Meltzer from Kessler, Topaz. MS. CABRASER: Good morning, your Honor. Elizabeth Cabraser from Lieff, Cabraser, Heimann and Bernstein. THE COURT: Good morning. Are you staying in town for the MDL next week? MS. CABRASER: I will be back, your Honor. MR. CHIPLOCK: Good morning, your Honor. Daniel Chiplock from Lieff, Cabraser, Heimann and Bernstein. MR. McTIGUE: Brian McTigue, your Honor, from McTigue Law for the ERISA plaintiffs. MR. SARKO: Lynn Sarko on behalf of Keller, Rohrback, your Honor. MS. MARKEY: Regina Markey with McTigue Law. THE DEPUTY CLERK: Counsel for Ohio Pension Fund. MR. MURPHY: Good morning, your Honor. Murray, Murphy, Moul and Basil, Brian Murphy. THE DEPUTY CLERK: Counsel for Bank of New York Mellon. MR. FIGEL: Good morning, your Honor. Reid Figel for BNY Mellon, and with me is Jason Friedman for BNY Mellon. () 0-000

7 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 THE COURT: Good morning. We'll take up the settlement and the plan of allocations first. There are no objectors? Is there any objector present? No. MS. CABRASER: We did not receive any objections, your Honor. THE COURT: Okay. Well, if plaintiffs want to make a brief statement, I'll certainly hear it. I don't need to, but if you'd like to, I'm happy to hear it. MS. CABRASER: Your Honor, we'll be very brief. We do respectfully submit settlement plan of allocation to your Honor for your approval. We're very pleased and proud of what we've all been able to accomplish for the customer class, and we note that, in this case, the whole is really greater than the sum of its parts because this settlement is a coordinated settlement that includes settlements of the customer class members' own claims, the New York AG's claims, the Department of Justice's claims under FIRREA, and the Department of Labor's claims. The combined value, in dollar terms, of the settlement is $ million. There is also valuable, important, industry changing relief in the DOJ agreement. Of that amount, $0 million is available for class recovery, including the $ million going directly into the customer class settlement, $ million of the New York AG's settlement that goes to fund class recoveries, and $ million from the Department of Labor that goes to the ERISA claims. () 0-000

8 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 THE COURT: Now, just enlighten me, or remind me, about whether and to what extent these other settlements are conditioned on this being approved? MS. CABRASER: The Department of Justice settlement is contingent on this settlement. The Department of Labor settlement is contingent on the settlement. So when we say this is a coordinated settlement, all of the litigation that touches the customer claims, that is really the case. THE COURT: And what about the New York AG? MS. CABRASER: It includes the New York AG settlement. THE COURT: Is the State settlement contingent? MS. CABRASER: It is, and in practical terms, your Honor. THE COURT: What does that mean? MS. CABRASER: It is in real terms. THE COURT: All right. Fine. Thank you. Anything further? MS. CABRASER: We would note, for the record, your Honor, that the notes program in this case -- and I think this is important because this was direct notice plus. We did have publication, but through repeated efforts, the notice administrator and class counsel have contacted all of the,00, approximately,00, class members. They each have their own code. They each have their own account number. They each have their own portal in the settlement, and they've () 0-000

9 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 each gotten a spreadsheet that tells them exactly how much they will get both in gross terms and net of the attorney's fees and costs as requested. So these were class members that had complete information in evaluating whether a settlement was a positive one, from their point of view. These are sophisticated entities. Many of them have over a million dollars at stake in this settlement. None of them has objected. There were originally three opt-outs. One of those opt-outs has requested to come back into the class. The defendants have agreed to that, and we were actually down to one-and-a-half opt-outs because one opt-out was only on behalf of funds that no longer exist; so distribution of a relatively nominal amount would be impossible. So this settlement matters to the class members. One class member will get $ million; of them will get a million dollars or more. This is not a situation in which the class members are or should be indifferent to whether or not this settlement is approved and whether or not this settlement is acceptable to them. THE COURT: It's just a matter of curiosity, but if it's not something that's sensitive in terms of public dissemination, who gets $ million? MS. CABRASER: Who does get million? MR. CHIPLOCK: It's one of the Ohio Pension Funds. () 0-000

10 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of FOPBANC 0 It's not one of the plaintiffs in the case, but it's another Ohio Pension Fund. THE COURT: All right. Thank you. MS. CABRASER: Thank you, your Honor. THE COURT: Anyone else want to be heard? Okay. The settlement and the plan of allocation are approved. I've modified the order slightly to make clear I'm not, by doing this, approving service awards, fees or expenses. I'm signing the orders right now. Okay. Now, attorneys' fees and related application. If you wouldn't mind using the lectern. That microphone is not getting through to me. MS. CABRASER: Certainly, your Honor. Thank you, your Honor. Elizabeth Cabraser and, first, thank you on behalf of the plaintiffs and the customer class for granting final approval to the settlement and the plan of allocation. This means a tremendous amount to the class. Because there are no objections, it means the distribution to class members by check or wire transfer will be able to be made in approximately 0 days' time. This is great news for the class. With respect to the requests for attorneys' fees and reimbursement of costs, as the class notice materials and the class members' individual spreadsheets reflected, class counsel are requesting a fee award in the aggregate of percent of the $ million of the $0 million in the fund. () 0-000

11 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of FOPBANC 0 While the settlement provides that fees are not to be deducted from the $ million coming in through the New York AG's office, the fact of the matter is that the three amounts, actually -- the million, the million on the AG's case and the $ million from the Department of Labor -- are being administered together by part of the city groups. The class members will each get one check or wire transfer, and if the fee request is calculated as a percentage of that overall amount, it is equivalent to. percent of the entire cash class benefit. Your Honor, under the lodestar cross-check system, that reflects a blended multiplier of. to the firms, approximately,000 hours in the case. As your Honor is aware, each of the firms has submitted a declaration attaching the lodestar information and the joint declaration of Sharan Nirmul and Dan Chiplock, which recounts in detail, from beginning to end, every aspect of this litigation, includes that information as well. Your Honor, much of that time was spent of necessity on discovery activities. That same could be said, I suppose, for many class action settlements, but in this case, the discovery activities were essential to the efforts of the plaintiffs to reconstruct out of the past, out of ephemeral documents and information their case. This was not confirmatory discovery. This was the discovery essential to demonstrate the fact of contracts, the practices of the bank's, () 0-000

12 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of FOPBANC 0 and the impact, in economic terms, on the class members. As your Honor remarked early in this case, this is an unusual, perhaps unique case in that there's no single document that constitutes the contract. The contract had to be reconstructed. It had to be theorized. The case began back in 00 with an FX trader turned whistleblower. That trader had a trader's eye view of the practices and had some documents but they were fragments. They were enough for a few of us to go on, but they needed to be completed through the remainder of discovery, of all of the transactions and all the records. As your Honor is aware, the contracts changed over time, sometimes for each class member, and the contracts differed for each class member. And our task was to create, from all of these scattered fragments, much like a jigsaw puzzle thrown on the floor or a mosaic that's been disbursed, a picture, a picture that would convince, first, your Honor on summary judgment and class certification, and ultimately a jury that the practice that trader saw had, in fact, occurred with respect to the class members; that it caused them damage; that that damage was actionable under our theories of breach of contract, breach of fiduciary duty and state statutes; that that damage could be quantified; that it took an expert reconstruction; and that it could be awarded to class members, in fact, on appeal. That's a shorthand way of talking both about the Grinnell factors and the final approval of settlement () 0-000

13 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of FOPBANC 0 and the Goldberger factors for fee awards. This case was not within the familiar template of securities class actions or antitrust cases that, as your Honor has observed, are merely bound to settle. We weren't bound for settlement. THE COURT: I couldn't hear what you said. MS. CABRASER: I said, this is not a case within the template of the securities case or antitrust case, the type of cases, as your Honor has observed, that usually settle. We weren't bound for settlement in 00 or 0. THE COURT: I may have a lot more to say on that than what's been attributed to me along those lines later in the month or next month, but this is not the time. MS. CABRASER: Yes. And I think it's worth noting too that, at least in terms of statistical trends, that those who serve the field of securities cases, settlements are becoming less frequent, more difficult. Dismissals are becoming more frequent. No one's case is easy these days. No one's case is cheap to litigate, and no one's case is certain. This case was a unique case that included difficulties and proof, choice of law, class certification issues that most securities cases and antitrust cases don't share. This is not within the mind-run of litigation. This is not one of those FX trading cases. There aren't other FX trading cases. There is one that Judge Cote dismissed, as you know from the papers, and () 0-000

14 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 there's another one in Boston. It's in mediation. We survived motion to dismiss there, but this is really a unique instance of a case that's survived motions to dismiss, ruled on both by Judge Alsup and your Honor. It has survived a rigorous period of discovery, including depositions, far more, over ten times more, for example, than in the IndyMack case or other cases. And, uniquely, it's a case in which the bank, represented by brilliant counsel, decided early on that the best defense was an aggressive offense, and attempted to turn the tables on the class by pursuing counterclaims and third-party claims. Those claims, at least as to the named plaintiffs, survived motions to dismiss, as well. And so we had the type of litigation that, in some respects, resembled more the business-versus-business litigation, an Apple v. Google, which are hard fought, expensive. In those cases, of course, each side pays their lawyers. In this case, the funds could not pay lawyers; so class counsel represented them in all respects of the litigation on a contingent basis, subject to court-awarded fees by your Honor. Your Honor, we are more than happy to answer any questions that you have about our lodestar, about the different task categories, about how that lodestar compares to other cases. What we can tell you is the ways in which this case does not compare to other cases, even cases involving () 0-000

15 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 recoveries of the same magnitude. This is not an antitrust case in which the private actions followed government investigations or indictments. We didn't follow here. We led. We're very proud to say that the private actions led, and the governmental actions were able to take advantage of our discovery, to take advantage of our resources, and to take advantage of our daily coordination in order, in the case of the Department of Justice, to prosecute claims on behalf of the United States and recover $ million for the U.S. Attorney, and with respect to the New York AG, to prosecute claims under the Martin act, which have benefited both the customer class members themselves and the State of New York. The whole is greater than the sum of its parts. The customer class counsel brought these cases. They played a leading role both in terms of sequence and chronology and in terms of dedication of resources and in terms of creatively constructing the theories and legal claims. But, your Honor, it was also the opportunity presented by the transfer and centralization of the customer actions into this court, as an MDL, where the Department of Justice case was pending and where the New York AG's case was pending in a neighboring New York State court, that enabled another unique attribute of this litigation to occur. And that is real, active coordination on a daily basis and collaboration in terms of sharing work () 0-000

16 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 product, sharing deposition and discovery duties with the U.S. Attorney's Office and with the State AG's office. The lawyers at the plaintiff's table, collectively, have many, many years of experience in complex financial cases of every sort, the usual and the unusual, but I think it's fair to say that none of us has ever experienced the real coordination that occurred in this case as a result of transferring coordination here, as a result of your Honor's case management and directives and the good faith and good efforts of lawyers who recognized that together they were far more formidable, they were far more powerful than any could be alone. We were able to take the laboring ore, and that's the settlement class counsel, with respect to most of the depositions. We took over 0, leading role; the Department of Justice took 0; the State of New York took one. We weren't awaiting government litigation or prosecution, and we weren't litigating in parallel. We had the best of both worlds. We had joinder. That joinder was made possible by the investment of thousands of hours and millions of dollars on behalf of settlement class counsel on a contingent basis. Your Honor, you are the boss of fees and costs, and you have seen many fees and costs applications, and you have written much about those applications under the circumstances of each particular case. We're here to answer any of your () 0-000

17 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 questions, and we would respectfully request that you consider our application with its modest multiplier, with its time well spent, without objection from the very informed and sophisticated class, under the unique circumstances of this case, and issue an order that recognizes the work that has been done in this case, the quality of the efforts, the formidable nature of the challenges, which were unprecedented, and the outcome. And in doing so, incentivizes and encourages other counsel to do likewise, to bring the difficult case, to not be daunted by the daunting task of reconstruction of a case, to do real discovery, to stand up to cross claims, to enter into what, by all accounts, was an intense war with very able, very creative, very sophisticated counsel on the other side of the V, and not to do that in just the usual case, but to do that in the cases that present the most challenges, the cases that might not be brought, the cases where the losses to class members are large enough to hurt, but not large enough to justify individual litigation by the class members through paid counsel. We have persevered in this case. We are proud of the result, and we appreciate everything that this Court has done both to create a forum that encouraged and directed coordination, to give us the schedule that resulted in the intense work that we all had to accomplish. As your Honor () 0-000

18 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 knows, over 0 depositions taken in just a year with the very peak of activity and deadlines looming and a settlement reached at literally the th hour of the last day. I think the chronology set forth in the joint declaration speaks for itself. We hope our work speaks for itself, and as I say, we're here to answer your Honor's questions about that work. THE COURT: Thank you. The first question in my mind is to put the private litigation, the customer litigation, your litigation, in a temporal context with the securities case which is on for another day. But which came first? MS. CABRASER: The customer litigation came first, your Honor. THE COURT: That's what I thought. MS. CABRASER: Customer litigation started informally in federal courts in 0 in Philadelphia and San Francisco, with local cases, the SEPTA cases that were then transferred to your Honor as part of the MDL litigation. THE COURT: At what point in the process did the first securities complaint get filed? MS. CABRASER: Your Honor, I don't have that date in mind, but Mr. Chiplock does. MR. CHIPLOCK: December 0, your Honor. THE COURT: December 0. Okay. Thank you. MS. CABRASER: So about a year and a half difference. THE COURT: And that's after Judge Alsup had ruled, () 0-000

19 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 right, on the motion to dismiss in California, and was it before or after my first ruling on a dispositive motion? MS. CABRASER: It was after Judge Alsup. He ruled while the cases were actually in transit to your Honor, and then -- MR. CHIPLOCK: Judge Alsup ruled on the motion to dismiss in the local cases on February th, 0. We then proceeded to brief class certification, and we had actually finaled our opening brief on class certification four days before the case was transferred per the MDL order. THE COURT: And remind me whether the class actions securities cases started before or after I ruled on the motions to dismiss here. MR. CHIPLOCK: Actually, I apologize, your Honor. The securities classing action was filed in December 0, not 0. I believe that filing was actually what precipitated the MDL petition being filed by the bank. THE COURT: Okay. And Judge Alsup's ruling is before that? MR. CHIPLOCK: No. Judge Alsup ruled on our motion to dismiss while that motion was pending. THE COURT: The MDL motion? MR. CHIPLOCK: Yes, the MDL motion had been filed. It had not been fully -- it may have been briefed in January, February of 0, but he ruled on the motion to dismiss and () 0-000

20 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page 0 of of FOPBANC 0 denied defendant's motion in its entirety on February th, 0. We then had roughly three months to complete class certification discovery, as well as submit our opening class expert report by early to mid-april of 0, which we did. And then, as I said earlier, four days later the order came down from the MDL panel transferring the case from Judge Alsup's courtroom to this courtroom. THE COURT: Okay. Thank you. MS. CABRASER: Right. And then late 0 for the securities filing. THE COURT: Sorry. MS. CABRASER: That would have been, as Mr. Chiplock noted, late 0 for the securities case filing, not 0. THE COURT: Thank you. I have no other questions. Anyone else wish to be heard? All right. Well, I've decided to grant the attorney's fee and reimbursement in full. $. million, in the aggregate and fees, roughly $00 in expenses. I am denying the service report request. This really was an extraordinary case in which plaintiff's counsel performed, at no small risk, an extraordinary service, and they ought to be compensated for it for all the reasons that Ms. Cabraser has said. They did a wonderful jobs in this case, and I've seen a lot of wonderful lawyers over the years. This was a great performance. They () 0-000

21 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 were fought tooth and nail at every step of the road. It undoubtedly vastly expanded the costs of the case, but it's an adversary system, and sometimes you meet adversaries who are heavily armed and well financed, and if you're going to win, you have to fight them and it costs money. It's no secret that, on occasion, I -- indeed, on all occasions -- look somewhat skeptically on fee awards in class action cases, but that doesn't mean that I start with the presumption against them or anything remotely like that. I've written and spoken on class actions, especially in the securities context, a lot. I think I've made clear that my personal view is they perform often a valuable function. That doesn't mean each and every one does, but they do, in general, as a feature of our legal system. But this is above and beyond all of that. This was an outrageous wrong committed by the Bank of New York Mellon, and plaintiffs' counsel deserve a world of credit for taking it on, for running the risk, for financing it and doing a great job. I accept the lodestar. I accept as fair, reasonable and accurate everything that went into it. I think the multiplier of., I think, is, given the circumstances, perfectly appropriate in this case. I really, ultimately, don't have any problem with granting this in all respects. So I'll sign that order probably later in the day. I couldn't find it here in the () 0-000

22 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC 0 bench. There is a little bit of paper in this case. It's not so easy to keeping track of, and my law clerks have been here, between them, for a total of three weeks, cumulatively. And it's no disrespect to them to say that we don't yet have every piece of paper someplace we can put our hands on. The former law clerks, who knew where it all was, are now somewhere else. MS. CABRASER: We do have paper copies for your Honor. THE COURT: Of the order? MS. CABRASER: Of the orders. THE COURT: Well, I've signed two of them; so if you hand up the ones for the fees. MS. CABRASER: We have the fees. It's all blank. THE COURT: Yes, I'll manage to put something in there. MS. CABRASER: Thank you. THE COURT: Okay. I thank everybody involved in this case. It was a terrific challenge, for you far more than the Court, but a lot of efforts on the Courts' parts. And I want to extend my appreciate also to Justice Marcy Friedman in the State court, who coordinated with me where that was necessary and appropriate, and was a distinguished partner in trying to bring this all to the conclusion. I have had a number of MDLs, and this is the one that stands out as the model for federal, state cooperation, in my experience. So I appreciate her efforts in this matter as () 0-000

23 Case :-md-0-lak-jlc :-md-0-lhk Document - Filed 0// /0/ Page of of FOPBANC well. Okay. Thank you, folks. MS. CABRASER: Thank you, your Honor. (Adjourned) 0 () 0-000