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Stanford University Law School
- Securities Class Action Clearinghouse
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MILBERG WEISS BERSHAD
HYNES & LERACH LLP
WILLIAM S. LERACH (68581)
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/231-1058
- and -
REED R. KATHREIN (139304)
JEFFREY W. LAWRENCE (166806)
DAVID R. STICKNEY (188574)
222 Kearny Street, 10th Floor
San Francisco, CA 94108
Telephone: 415/288-4545
[Proposed] Lead Counsel for Plaintiffs
KAUFMAN, MALCHMAN, KIRBY
& SQUIRE, LLP
JEFFREY H. SQUIRE
IRA M. PRESS
919 Third Avenue, 11th Floor
New York, NY 10022
Telephone: 212/371-6600
KAPLAN, KILSHEIMER & FOX, LLP
ROBERT N. KAPLAN
685 Third Avenue, 26th Floor
New York, NY 10017
Telephone: 212/687-1980
WOLF POPPER LLP
LESTER L. LEVY
845 Third Avenue
New York, NY 10022
Telephone: 212/759-4600
[Proposed] Executive Committee for Plaintiffs
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
MARK MOORE, et al., On Behalf of Themselves and
All Others Similarly Situated,
Plaintiffs,
vs.
RASTER GRAPHICS, INC., et al.
Defendants.
___________________________________
No. C-98-1489-SBA
CLASS ACTION
DECLARATION OF JEFFREY W. LAWRENCE IN SUPPORT OF MOVANTS' MOTION
TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO SECTION 21D(a)(3)(B) OF
THE SECURITIES EXCHANGE ACT OF 1934 AND APPROVAL OF LEAD PLAINTIFFS'
CHOICE OF COUNSEL
DATE: June 9, 1998
TIME: 2:00 p.m.
CTRM: 3 (Hon. Saundra Brown Armstrong)
I, JEFFREY W. LAWRENCE, hereby depose and state as follows:
1. I am an attorney with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, counsel for Movants in this action. I am duly admitted to practice in the State of California and before this Court. I make this Declaration in support of Movants' Notice of Motion to Be Appointed Lead Plaintiffs Pursuant to Section 21D(a)(3)(B) of the Securities Exchange Act of 1934 and Approval of Lead Plaintiffs' Choice of Counsel, and I have personal knowledge of the facts asserted herein.
2. Attached hereto are true and correct copies of the following:
Exhibit A: Ginter, et al. v. Raster Graphics, et al., Case No. CV772401, Complaint (Santa Clara County Sup. Ct., Mar. 14, 1998);
Exhibit B: Movants' and Shareholders' Signed Certifications for their purchases of Raster Graphics, Inc. stock;
Exhibit C: Movants' and Shareholders' Purchases, Sales and Losses in Raster Graphics stock 4/24/97-10/19/97;
Exhibit D: Movants' Purchases, Sales and Losses in Raster Graphics stock 10/20/97-4/3/98;
Exhibit E: Firm résumé of Milberg Weiss Bershad Hynes & Lerach LLP;
Exhibit F: Firm résumé of Kaufman, Malchman, Kirby & Squire, LLP;
Exhibit G: Firm résumé of Kaplan, Kilsheimer & Fox, LLP;
Exhibit H: Firm résumé of Wolf Popper LLP;
Exhibit I: March 3, 1998 Business Wire;
Exhibit J: In re Read-Rite Corp. Sec. Litig., No. C-97-20059 RMW, Order Granting Plaintiffs' Motion for Appointment of Lead Plaintiff and Lead Counsel (N.D. Cal. May 28, 1997);
Exhibit K: In re Diamond Multimedia Sys., Inc. Sec. Litig., No. C 96-2644 SBA, Order Re Appointment of Lead Plaintiff and Lead Counsel (N.D. Cal. Jan. 13, 1997);
Exhibit L: Malin v. Ivax Corp., No. 96-1843-CIV-Moreno, Order Granting Malin/Ferretti/Pennsylvania Pension Fund Plaintiffs Group's Motion for Appointment as Lead Plaintiffs and Order Approving Lead Plaintiffs' Choice of Counsel (S.D. Fla. Nov. 1, 1996);
Exhibit M: Zuckerman v. Foxmeyer Health Corp., No. 3:96-CV-2258-T, Order Granting Motion to Withdraw Motion and Granting Joint Motion for Appointment of Lead Plaintiffs and Lead Counsel (N.D. Tex. Mar. 28, 1997);
Exhibit N: Chan v. Orthologic Corp., No. Civ. 96-1514-PHX(RCB), Order (D. Ariz. Dec. 19, 1996); and
Exhibit O: Powers v. Eichen, Civ. No. 96-1431-B(AJB), Order Granting Plaintiffs' 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' Lead Counsel (S.D. Cal. Nov. 15, 1996).
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 4th day of May, 1998, at San Francisco, California.
___________________________________
JEFFREY W. LAWRENCE
RASTER-G\DRD01839.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 May 4, 1998, declarant served the DECLARATION OF JEFFREY W. LAWRENCE IN SUPPORT OF MOVANTS' MOTION TO BE APPOINTED LEAD PLAINTIFFS PURSUANT TO SECTION 21D(a)(3)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND APPROVAL OF LEAD PLAINTIFFS' CHOICE OF 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 4th day of May, 1998, at San Francisco, California.
______________________________
DEBORAH R. DASH