Case 1:04-cv-00665-RPM
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00665-RPM DAVID HELLER, On Behalf of Himself and All Others Similarly Situated, Plaintiff, v. QUOVADX, INC., LORINE R. SWEENEY and GARY T. SCHERPING, Defendants. DECLARATION OF JOY ANN BULL IN SUPPORT OF LEAD COUNSEL'S MOTION FOR AWARD OF ATTORNEYS' FEES AND REIMBURSEMENT OF EXPENSES
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I, JOY ANN BULL, declare as follows: 1. I am a member of the firm of Lerach Coughlin Stoia Geller Rudman & Robbins LLP.
I am submitting this declaration in support of Lead Plaintiff's Motion for Award of Attorneys' Fees and Reimbursement of Expenses. 2. Attached are true and correct relevant portions of the following documents: Elaine Buckberg, Todd Foster, and Stephanie Plancich, Recent Trends in Securities Class Action Litigation: 2003 Early Update (NERA Feb. 2004); In re Northwestern Corp. Sec. Litig., No. 03-4049 (D.S.D. Jan. 14, 2005); Denise N. Martin, Vinita M. Juneja, Todd S. Foster, Frederick C. Dunbar, Recent Trends IV: What Explains Filings and Settlements in Shareholder Class Actions? (NERA Nov. 1996); Thomas E. Willging, Laural L. Hooper & Robert J. Niemic, Empirical Study of Class Actions in Four Federal District Courts: Final Report to the Advisory Committee on Civil Rules (Federal Judicial Center 1996); Rasner v. FirstWorld Commc'ns, Inc., No. 00-K-1376 (D. Colo. Jan. 19, 2005); Angres v. Smallworldwide PLC, No. 99-K-1254 (D. Colo. June 7, 2003); Schwartz v. Celestial Seasonings, Inc., No. 95-K-1045 (D. Colo. Apr. 25, 2000); In re Intelcom Group, Inc. Sec. Litig., No. 95-D-1166 (D. Colo. Mar. 21, 1997); Schaffer v. Evolving Systems, Inc., No. 98-WY-1338-CB (D. Colo. Oct. 4, 1999); Queen Uno Ltd. P'ship. v. Coeur D'Alene Mines Corp., No. 97-WY-1431CB (D. Colo. Aug. 11, 1999); In re Einstein Noah Bagel Corp. Sec. Litig., No. 97-N-1614 (D. Colo. June 4, 1999); In re Coram Healthcare Corp. Sec. Litig., No. 95-N-2074 (D. Colo. Jan. 24, 1997); -1-
Exhibit 1: Exhibit 2: Exhibit 3:
Exhibit 4:
Exhibit 5: Exhibit 6: Exhibit 7: Exhibit 8: Exhibit 9: Exhibit 10: Exhibit 11: Exhibit 12:
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Exhibit 13: Exhibit 14:
In re Resort Income Investors, Inc. Sec. Litig., No. 97-B-1665 (D. Colo. Mar. 13, 1998); and Wolf v. E.A. Breitenbach, No. 95-D-2572 (D. Colo. May 29, 1997).
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 16th day of February, 2007, at San Diego, California.
s/ Joy Ann Bull JOY ANN BULL
S:\Settlement\Quovadx.set\DEC SUPPORT FEE BRF 00039155.doc
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CERTIFICATE OF SERVICE I hereby certify that on February 16, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the attached Manual Notice List.
s/ Joy Ann Bull JOY ANN BULL LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP 655 West Broadway, Suite 1900 San Diego, CA 92101-3301 Telephone: 619/231-1058 619/231-7423 (fax) E-mail:[email protected]
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