UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY. 1. I am a member of the law firm of Lieff Cabraser Heimann & Bernstein, LLP

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1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY In Re: LIQUID ALUMINUM SULFATE ANTITRUST LITIGATION Civil Action No. 16-md-2687 (JLL) (JAD) DECLARATION OF ERIC B. FASTIFF IN SUPPORT OF APPLICATION FOR ATTORNEYS FEES AND EXPENSES I, Eric B. Fastiff, declare as follows: 1. I am a member of the law firm of Lieff Cabraser Heimann & Bernstein, LLP ( Lieff Cabraser ), 275 Battery Street, 29th Floor, San Francisco, California , and a member of the Plaintiffs Steering Committee in the above-captioned action ( Action ). In such capacity, I am fully familiar with the facts contained herein based upon my personal knowledge concerning Lieff Cabraser s involvement in this litigation, and the books and records kept in the ordinary course of Lieff Cabraser s business. I submit this declaration in support of Class Counsel s application for an award of attorneys fees, as well as for reimbursement of expenses incurred by my firm, both in connection with the Action. 2. As a member of the Plaintiffs Steering Committee ( PSC ), I have been involved in all aspects of this Action from its beginning. Under my supervision, Lieff Cabraser was among the firms that first filed a complaint alleging illegal behavior concerning the sale of liquid aluminum sulfate, and researched the factual bases and legal theories set forth in the consolidated complaint. After this case was consolidated as a multi-district litigation in this Court, I was part of the team that drafted and filed an amended consolidated complaint. As the parties prepared for discovery, I was also involved in organizing document review strategy, drafting written discovery, the addition of new defendants, and in the retention of an economic expert and in guiding that expert s work. I have also been involved in efforts at resolution, including written

2 mediation statements. Throughout this case, I have also regularly participated in PSC calls and meetings. 3. In addition, under my supervision, my firm has undertaken a variety of tasks in this Action. Lieff Cabraser attorneys have reviewed a large volume of the defendants document productions, researched and drafted a complaint against an additional defendant (American Securities), drafted an opposition to a motion to dismiss filed by American Securities, drafted written discovery requests, participated in meet-and-confers concerning discovery issues, including related to document production, deposition planning and scheduling, and privilege log issues, attended status conferences, planned for depositions, assisted with mediation statements, and contributed factual and legal research memoranda and information on various topics. 4. The schedule attached hereto as Exhibit 1 is a summary indicating the amount of time spent by each attorney and professional support staff employee of my firm who was involved in the Action from April 11, 2016 (the date of the first time entry after my appointment to the PSC) through March 19, 2019 ( Time Period ), and the lodestar calculation based on my firm s current billing rates. For personnel who are no longer employed by my firm, the lodestar calculation is based upon the billing rate for such personnel in his or her final year of employment by my firm. The schedule was prepared from contemporaneous daily time records regularly prepared and maintained by my firm, which are available at the request of the Court. Time expended in preparing this application for fees and reimbursement of expenses has not been included in this request. 5. The hourly rates for the attorneys and professional support staff in my firm included in Exhibit 1 are the same as the regular rates that would be charged for their services in non-contingent matters and/or which have been accepted in other class action settlements

3 6. The total number of hours expended on this Action by my firm during the Time Period is 3, The total lodestar for my firm for that period is $1,827,264.00, consisting of $1,768, for attorneys time and $59, for professional support staff time. 7. My firm s lodestar figures are based upon the firm s billing rates, which do not include charges for expense items. Expense items are billed separately and such charges are not duplicated in my firm s billing rates. 8. As detailed in the schedule attached hereto as Exhibit 2, my firm has incurred a total of $19, in unreimbursed expenses in connection with the prosecution of this Action. That amount includes Lieff Cabraser s unreimbursed contributions to a litigation cost fund administered by Interim Lead Counsel. 9. The expenses incurred in this Action are reflected on the books and records of my firm. These books and records are prepared from expense vouchers, check records and other source materials and are an accurate record of the expenses incurred. 10. With respect to the standing of my firm, I have previously submitted Lieff Cabraser s firm resume, which includes biographies of attorneys who have been principally involved in this Action. See ECF No (Exhibit 3). I hereby declare under penalty of perjury that the foregoing facts are true and correct. Executed on March 21, 2019 in San Francisco, California. Eric B. Fastiff Lieff Cabraser Heimann & Bernstein, LLP 275 Battery Street, 29th Floor San Francisco, California Telephone: Facsimile: efastiff@lchb.com

4 EXHIBIT 1

5 EXHIBIT 1 In re: Liquid Aluminum Sulfate Antitrust Litigation Case No. 2:16-md-2687 Lieff Cabraser Heimann & Bernstein, LLP Summary of Lodestar TIMEKEEPER RATE HOURS LODESTAR Partner ERIC FASTIFF , KATHERINE LUBIN BENSON , DAVID RUDOLPH , DANIEL SELTZ , Associate KATHERINE LUBIN BENSON , SEAN PETTERSON , Document Review Attorney JAY MCKIBBEN ,052, ALEX WU , Paralegal/Clerk RAMI BATA TAYLOR EVANS NINA GLIOZZO , REBECCA TAYLOR BRIAN TROXEL , Lit. Support/Research SIOBHAN INNES-GAWN , NICOLAS MENARD , TOTAL 3, ,827,

6 EXHIBIT 2

7 EXHIBIT 2 In re: Liquid Aluminum Sulfate Antitrust Litigation Case No. 2:16-md-2687 Lieff Cabraser Heimann & Bernstein, LLP Summary of Expenses In-House Copies $51.90 Postage Print 2, Telephone Computer Research Federal Express/Messenger Travel 8, Cost Funds Assessments 200, Filing, pro hac vice, and admission fees Costs reimbursement received 3, ,600 Total $19,