Michael D. Braun (CSB #167416)
Steven B. Chroman (CSB #183037)
STULL, STULL & BRODY
10940 Wilshire Boulevard
Suite 2300
Los Angeles, CA 90024
(310) 209-2468
Jules Brody
Aaron L. Brody
STULL STULL & BRODY
6 East 45th Street
New York, NY 10017
(212) 687-7230
Kevin J. Yourman (147159)
WEISS & YOURMAN
10940 Wilshire Boulevard
24th Floor
Los Angeles, CA 90024
(310) 208-2800
Attorneys for Bisson Group
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
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JEFFREY M. BOREN, MICHAEL POWELL Plaintiffs, v. SMART MODULAR TECHNOLOGIES
Defendants. |
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CASE NO. C 98 20692 JW CLASS ACTION DECLARATION OF STEVEN
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I, Steven Chroman, declare:
1. I am an attorney at law duly licensed to practice in the State of California. I am associated with the firm of Stull Stull & Brody, counsel of record for plaintiff George A. Bisson and Jay C. Bisson ("Bisson) along with other class members (hereinafter "The Bisson Group")1 in this action. I make this declaration in support of "The Bisson Group's Motion for Appointment of Lead Plaintiffs and Lead Counsel Pursuant to Section 21D of the Securities Exchange Act of 1934 and for Consolidation of all Related Actions." I have personal knowledge of the matters stated herein and if called as a witness, I could and would competently testify to the following:
2. Attached hereto are true and correct copies of the following documents:
Exhibit A: |
Chart of Smart Media Technologies, Inc. Plaintiff Transactions. |
Exhibit B: |
The notice of pendency of this action as published on Business Wire on July 1, 1998. |
Exhibit C: |
Plaintiffs Notice of Related Cases |
Exhibit D: |
In re Diamond Multimedia Systems, Inc. Sec. Litig., No. C-96-2644-SBA, slip op. at 2-4 (N.D. Cal. Jan. 13, 1997), Order Re Appointment of Lead Plaintiff and Lead Counsel |
Exhibit E: |
In re Read-Rite Corp. Sec. Litig., No. C-97-20059-RMW, slip op. at 4-5 (N.D. Cal. May 23, 1997), Order Granting Plaintiffs' Motion For Appointment of Lead Plaintiff and Lead Counsel |
Exhibit F: |
Malin v. IVAC Corporation, et al., No. 96-1843-CIV-Moreno, slip op. at 4-8 (S.D. Fla. Nov. 1, 1996), Order Granting... Plaintiffs Group's Motion for Appointment as Lead Plaintiffs and Order Approving Lead Plaintiffs' Choice of Counsel. |
Exhibit G: |
Zuckerman v. Foxmeyer Health Corp., No. 3:96-CV-2258-T, slip op. at 5 (N.D. Tex. Mar. 28, 1997), Order Granting Motion... For Appointment of Lead Plaintiffs and Lead Counsel. |
Exhibit H: |
Chan v. Orthologic Corp., No. Civ. 96-1514 PHX RCB, slip op. at 13 (D. Ariz. Dec. 19, 1996), Order. |
Exhibit I: |
Powers v. Eichen, Civ. No. 96-1431-B(AJB), Order at 1 (S.D. Cal. Nov. 15, 1996), Order Granting Plaintiffs' Motion to Be Appointed Lead Plaintiffs And For Appointment of Lead Plaintiffs' Counsel. |
Exhibit J: |
Sworn Certifications of plaintiffs. |
Exhibit K: |
Firm biography of Stull Stull & Brody |
Exhibit L: |
Firm biography of Weiss & Yourman |
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 28th day of August, 1998 at Los Angeles, California.
Dated: __________
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1 The "Bisson Group" consists of George A. Bisson, Jay C. Bisson, and additional purchasers of Smart Media Technologies, Inc. common stock which are listed in Exhibit A to the "Declaration of Steven Chroman in Support of the Bisson Group's Motion for Appointment of Lead Plaintiffs and Lead Counsel and for Consolidation of All Related Actions" (the "Chroman Decl.").