MILBERG WEISS BERSHAD
HYNES & LERACH LLP
PATRICK J. COUGHLIN (111070)
RANDI D. BANDMAN (145212)
SPENCER A. BURKHOLZ (147029)
AMBER L. ECK (177882)
600 West Broadway, Suite 1800
San Diego, CA 92101
Telephone: 619/231-1058
BERNSTEIN LIEBHARD & LIFSHITZ
SANDY A. LIEBHARD
MEL E. LIFSHITZ
ABRAHAM I. KATSMAN
274 Madison Avenue
New York, NY 10016
Telephone: 212/779-1414
Attorneys for Plaintiff and the Class
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
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SARA WERCZBERGER, On Behalf of |
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No. C-97-20538-RMW(PVT) CLASS ACTION DECLARATION OF AMBER L. ECK DATE: October 24, 1997 |
I, AMBER L. ECK, declare:
1. I am an attorney duly licensed to practice in the State of California, and am admitted to practice before this Court. I am an attorney with the law firm of Milberg Weiss Bershad Hynes & Lerach LLP, counsel for plaintiffs in the above-referenced action (hereinafter referred to as "Moving Plaintiffs"). I have personal knowledge of the facts set forth below and if called as a witness could and would competently testify thereto.
2. Attached hereto are true and correct copies of the following documents:
Exhibit 1: Moving Plaintiffs' Purchases, Sales and Losses Chart for StorMedia, Inc.;
Exhibit 2: Notice to class members published in the Business Wire on June 20, 1997;
Exhibit 3: Plaintiffs' Certifications;
Exhibit 4: Firm Resumé of Milberg Weiss Bershad Hynes & Lerach LLP;
Exhibit 5: Firm Resumé of Bernstein Liebhard & Lifshitz; and
Exhibit 6: H. R. Conf. Rep. No. 104-369, 104th Cong. 1st Sess., Statement of the Managers (November 28, 1995).
3. Moving Plaintiffs' damages, as set forth in Exhibit 1, attached hereto, are calculated as follows:
(a) For StorMedia shares purchased and sold between November 27, 1995 and August 6, 1996, inclusive (the "Class Period"), damages have been calculated as the difference between the purchase price and the sales price; and
(b) For StorMedia shares purchased during the Class Period and held as of the end of the Class Period, damages have been calculated according to the PSLRA.
I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed this ____ day of August, 1997, at San Diego, California.
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STORMEDIA\BMG06243.DEC
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 Diego, over the age of 18 years, and not a party to or interested in the within action; that declarant's business address is 600 West Broadway, Suite 1800, San Diego, California 92101.
2. That on August 14, 1997, declarant served the DECLARATION OF AMBER L. ECK IN SUPPORT OF MOTION TO BE APPOINTED LEAD PLAINTIFFS AND FOR APPROVAL OF LEAD PLAINTIFFS' CHOICE OF CO-LEAD COUNSEL by depositing a true copy thereof in a United States mailbox at San Diego, 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:
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 14th day of August, 1997, at San Diego, California.
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