MILBERG WEISS BERSHAD
HYNES & LERACH LLP
WILLIAM S. LERACH (68581)
AMBER L. ECK (177882)
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/231-1058
- and -
REED R. KATHREIN (139304)
JOHN K. GRANT (169813)
222 Kearny Street, 10th Floor
San Francisco, CA 94108
Telephone: 415/288-4545
BERGER & MONTAGUE, P.C.
JACOB A. GOLDBERG
TODD S. COLLINS
1622 Locust Street
Philadelphia, PA 19103
Telephone: 215/875-3000
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
WILLIAM ARNOUVILLE, On Behalf of Himself and
All Others Similarly Situated,
Plaintiff,
vs.
VERSANT OBJECT TECHNOLOGY CORP, et al.,
Defendants.
___________________________________
No. C-98-1079-FMS
CLASS ACTION
DATE: May 15, 1998
TIME: 10:00 a.m.
CTRM: The Honorable
Claudia Wilken
DECLARATION OF JOHN K. GRANT IN SUPPORT OF
GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE
APPOINTED LEAD PLAINTIFFS PURSUANT TO §21D(a)(3)(B)
OF THE SECURITIES EXCHANGE ACT OF 1934 AND FOR APPOINTMENT
OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL
I, JOHN K. GRANT, declare:
1. I am an attorney duly licensed to practice law in the State of California and am admitted to practice before this Court. I am associated with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, one of the counsel of record for plaintiffs in Geffen, et al. v. Versant Object Technology, Inc., et al., C-98-0440-MMC, Luu v. Versant Object Technology Corp., et al., C-98-0969-SBA and Arnouville v. Versant Object Technology, Inc., et al., C-98-1079-FMS. I make this declaration in support of Geffen Group's motion to be appointed lead plaintiffs pursuant to §21D(a)(3)(B) of the Securities Exchange Act of 1934 and for appointment of lead plaintiffs' selection of co-lead counsel. I have personal knowledge of the facts set forth below and if called as a witness could and would testify accurately thereto.
2. Attached hereto are true and correct copies of the following documents:
Exhibit 1: Sworn Certifications of the Geffen Group;
Exhibit 2: Chart of the Geffen Group's Purchases, Sales and Losses During Class Period;
Exhibit 3: Notice of Pendency of Action, published on January 29, 1998;
Exhibit 4: Firm Résumé of Milberg Weiss Bershad Hynes & Lerach LLP;
Exhibit 5: Firm Résumé of Barrack, Rodos & Bacine; and
Exhibit 6: H.R. Conf. Rep. No. 104-369, at 31 (1995), reprinted in 1995 U.S.C.C.A.N. 679, 730.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. If called as a witness, I could and would competently testify thereto. Executed this 30th day of March, 1998, at San Francisco, California.
___________________________________
JOHN K. GRANT
VERSANT\DRD01779.DEC
DECLARATION OF SERVICE BY MAIL
PURSUANT TO NORTHERN DISTRICT LOCAL RULE 23-2(c)(2)
I, the undersigned, declare:
1. That declarant is and was, at all times herein mentioned, a citizen of the United States and a resident of the County of San Francisco, over the age of 18 years, and not a party to or interested in the within action; that declarant's business address is 222 Kearny Street, 10th Floor, San Francisco, California 94108.
2. That on March 30, 1998, declarant served the DECLARATION OF JOHN K. GRANT IN SUPPORT OF GEFFEN GROUP'S NOTICE OF MOTION, MOTION, AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO §21D(a)(3)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND FOR APPOINTMENT OF LEAD PLAINTIFFS' SELECTION OF CO-LEAD COUNSEL by depositing a true copy thereof in a United States mailbox at San Francisco, California in a sealed envelope with postage thereon fully prepaid and addressed to the parties listed on the attached Service List and that this document was forwarded to the following designated Internet site at:
http://securities.milberg.com
3. That there is a regular communication by mail between the place of mailing and the places so addressed.
I declare under penalty of perjury that the foregoing is true and correct. Executed this 30th day of March, 1998, at San Francisco, California.
______________________________
DEBORAH R. DASH