The parties participated in a mediation before the Honorable Daniel Weinstein on December 21, 2005. On that date, the parties reached an agreement to settle all claims among them, without any admission of liability, and executed a memorandum of understanding. The parties will now negotiate and draft a formal stipulation of settlement based on the memorandum of understanding.
Once the stipulation of settlement has been executed by all parties, lead plaintiffs will present the stipulation of settlement to the Court along with a motion for preliminary approval of the settlement. The motion for preliminary approval will request the Court, among other things, to conditionally certify a settlement class; to appoint a claims administrator; to direct the mailing and publication to the settlement class of a notice of settlement and claim form; and to schedule a date for final approval of the settlement after an adequate time for settlement class members to review the settlement and respond. The parties anticipate submission of the stipulation of settlement and motion for preliminary approval to the Court within the next thirty (30) days.
By: /s/Peter A. Binkow Peter A. Binkow Avi N. Wagner 1801 Avenue of the Stars, Suite 311 Los Angeles, California 90067 Telephone: (310) 201-9150 Facsimile: (310) 201-9160 Co-Lead Counsel for Plaintiffs
Dated: December 27, 2005 MORRISON & FOERSTER LLP
By: /s/Dan Marmalefsky Dan Marmalefsky Mark R. McDonald James P. Maniscalco
555 West Fifth Street, Suite 3500
Los Angeles, CA 90013 Telephone: Facsimile:
(213) 892 5200 (213) 892 5454
Counsel for Defendants
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