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Robert S . Green (State Bar No . 136183) (rsg@classcounsel .com)GREEN WELLING LLP235 Pine Street, 15`h FloorSan Francisco, CA 94104Telephone : (415) 477-6700Facsimile: (415) 477-6710

[Proposed] Liaison Counse l

Stuart L. Berman (sberman@sbclasslaw .com)Sean M. Handler (shandler@sbclasslaw.com)Robin Winchester (rwinchester@sbclasslaw .com)SCHIFFRIN & BARROWAY, LLP280 King of Prussia RoadRadnor, PA 19087Telephone : (610) 667-7706Facsimile : (610) 667-705 6

[Proposed] Lead Counsel

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

In re LEADIS TECHNOLOGY, INC .SECURITIES LITIGATION

This Document Relates To : All Actions

Master File No. C-5-0882-CRB

CLASS ACTION

DECLARATION OF ROBINWINCHESTER IN SUPPORT OFMOTION TO APPOINT THE LEGROUP AS LEAD PLAINTIFFPURSUANT TO SECTION 27 OF THESECURITIES ACT OF 1933 AND TOAPPROVE PLAINTIFF'S CHOICE OFCOUNSEL

Date : June 10, 2005Time: 10:00 a.m .Dept: Courtroom 8, 19' FloorJudge: Hon. Charles R. Breyer

28 1

1 I, Robin Winchester, declare under penalty of perjury, this 2nd day of May 2005, a s

2 ollows:

3 1. I am an attorney at Schiffrin & Barroway, LLP. I submit this declaration in

4 support of the motion of Ngoan Van Le, Richard Beedenbender and Scott Strouse (the "L e

5 Group" or "Movant") for the appointment of lead plaintiff and for approval of lead plaintiff s

6 election of lead counsel and liaison counsel .

7 2. Attached hereto as Exhibit A are true and correct copies of the signe d

8 certifications of members of the Le Group pursuant to the requirements of the Private Securities

9 itigation Reform Act of 1995 ("PSLRA") . See 15 U.S.C. § 77z-1(a)(2) .

10 3. Attached hereto as Exhibit B is a true and correct copy of the notice to class

11 embers concerning the first-filed of the above-captioned action that was published on March 2,

12 005 on Business Wire advising the public of the pendency of a class action filed on behalf of

13 shareholders of Leadis Technology, Inc . ("Leadis") .

14 4. Attached hereto as Exhibit C is a true and correct copy of a chart of Movant's

15 ansactions in Leadis securities and approximate losses .

16 5. Attached hereto as Exhibit I] is a true and correct copy of the firm biography for

17 chiffrin & Barroway, LLP, the law firm seeking the Court's approval as Lead Counsel .

18 6. Attached hereto as Exhibit E is a true and correct copy of the firm biography for

19 reen Welling LLP, the law firm seeking the Court's approval as Liaison Counsel .

20 I hereby declare under penalty of perjury that the foregoing is true and correct under the

21 Jaws of the State of California.

22

23

24

25

26

27

28

OBIN WINCHESTE

EXHIBIT A

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CERTIFICATION OF NAMED PLAINTIFFPURSUANT TO FEDERAL SECtJR1TIES LAW S

1 . (print narncR&L 'e je" u Lt Ptaintifl") declaic , a s to the claims asserted under the l' deral

securities laws, that :

1 . Plaintitfhas reviewed the Complaint and authorizes its filing -

2 . Plaintiff did not purchase the security that is the subject of this action at the direction of Plaintiffs counsel or in order to

participate in any private action-

Plaintiff is willing to serve as a representative party on behalf of the class . including providing testimony at deposition and

trial tt necessary.

4. Ptaintiffs transaction(s) in the Leaciis Technology, Inc- (Nasdaq : LDIS) security that is the subject of this action during

the Class Period is/are as follows' :

No. of Shares Buy/Sel Date Price Per Share

PLEASE SEE ATTACHE D

'List additional transactions on a separate sheet of paper , if necessary.

5 . Plaintiff has corupiete authority to bring a suit to recover for investment losses .

6. During the three years prior to the date of this Certification , Plaintiff has sought to serve or served as a representative party

or a class in the following actions Wed under the federal securities laws (if none, so i ndicate); Q?~

7. Plaintiff will not accept any payment for serving as a representative party on behalf of the class beyond the Plaintiffs pro

rata share of any recovery, except such reasonable costs and ex ses (including lost wages) directly relating to the representation of the class

as ordered or approved by the Court .

I declare under penal of perjury that the foregoing is true a nd cwrreeL

Executed th is day of jet /

-<e d' iC," de 6-,

Richard Beedenbender

Purchase or Number ofDate Sale Securities

10/13/2004 Purchase 1,000

Type ofSecurities

Com Stk

Price ofSecurities

15.7000

C RTIP1CATION OF NAMED PL.AINMFPURSUANT TO MERALSECURITIES LAWS

(print name)( €[aiotrf ") dealare, as to the clahm asserted under the federal

aeowbics laws that

L PtaintW s reviewed the Complaint and authorhea its Sling .

2. PlaintUdtd not purchase the security that is the subject of this action at the direction of Plaintiffs counsel or is order to

pe a Hinay prsvarin aka

3. Plaintiff is witting to serve as a representative party on behalf of the class, including providing rrstiur]ny at deposition and

friar, if necom cry.

4. PlsintifFs hen on(s) in die Leadis Techuology, Inc . (Nasdaq: LDJS) security that is the subject of this ac6on dutigg

the Cbss Pe iod is/are as faUowsx :

Nat of Sb €at'es iAMM-1 Date rdst Per Share

5 . Plaintiff has complete authority to bring a suit to recover foi investment losses .

6 Dui ng the three years prior to the date of this Certification, Plaintiff has sought to serve or served as a repta"atatift party

or a class in the follow actions filed under the federal securities laws (ifttone, FO indicate) :

Z P tiff will not accept any payment for serv ing as a representative party on behalf r f the class beyond th e Plaintiffs pro

rata share ninny recovery, except such reasonable costs and expenses (including lost wages) directly relating to the representation of t e class

as ordered or approved by the Court.

I declare under penalty of perjury that the foregoing its true and correct.

Perorated tl~i~s day of 41 c t tJ , 2OQj

~OsePrint Name

'List additional transactions on a separate sheet of paper, if necessary.

EXHIBIT B

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Press Release Source : Lerach Coughlin Stoia Geller Rudman & Robbins LL P

Lerach Coughlin Stoia Geller Rudman & Robbins LLP Files ClassAction Suit against Leadis Technology, Inc .Wednesday March 2, 6 :53 pm E T

SAN DIEGO-(BUSINESS WIRE)-March 2, 2005-Lerach Coughlin Stoia Geller Rudman & Robbins LLP ("LerachCoughlin") (http :1/www.Ierachlaw.comlcaseslieadis/) today announced that a class action has been commenced inthe United States District Court for the Northern District of California on behalf of those who acquired Leadi sTechnology, Inc . ("Leadis") (NASDAQ : - DIS - News) common stock pursuant to the Company's false and misleadingRegistration Statement and Prospectus for its initial public offering ("IPO") on June 16, 2004 .

If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from today . If you wish to discussthis action or have any questions concerning this notice or your rights or interests, please contact plaintiffs counsel,William Lerach or Darren Robbins of Lerach Coughlin at 800-449-4900 or 619-231-1058, or via e-mail a twsl c lerachlaw .com. If you are a member of this class, you can view a copy of the complaint as filed or join this classaction online at http :llwww.lerachlaw.com/cases/leadis/ . Any member of the purported class may move the Court toserve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent classmember .

The complaint charges Leadis and certain of its officers and directors with violations of the Securities Act of 1933 .Leadis designs, develops and markets mixed-signal semiconductors that enable and enhance the features andcapabilities of small panel displays . The Company's core products are color display drivers with integratedcontrollers, which are critical components of displays used in mobile consumer electronics devices .

The complaint alleges that on June 16, 2004, Leadis accomplished its IPO of 6 million shares for net proceeds of$76.6 million, pursuant to a Registration Statement and Prospectus . The Registration Statement and Prospectusfailed to disclose that Leadis was engaging in overshipments of its OLED product .

Then, on October 22, 2004, Leadis announced that its fourth quarter results would be much lower than analysts'expectations . Leadis admitted that a drop in sales from OLED was going to hurt profit in the quarter as handsetmakers bought less expensive equipment . The shares fell $8.15 to $8 .79 on October 22, 2004 . Later, on January 10,2005, Leadis announced it was not comfortable with the First Call estimates of its revenues for the first quarter of2005. On this news, Leadis stock dropped further to below $8 per share .

Plaintiff seeks to recover damages on behalf of all those who acquired Leadis common stock pursuant to theCompany's false and misleading Registration Statement and Prospectus for its IPO on June 16, 2004 . The plaintiff isrepresented by Lerach Coughlin, which has expertise in prosecuting investor class actions and extensive experiencein actions involving financial fraud .

Lerach Coughlin, a 140-lawyer firm with offices in San Diego, San Francisco, Los Angeles, New York, Boca Raton,Washington, D .C., Houston, Philadelphia and Seattle, is active in major litigations pending in federal and state courtsthroughout .the United States and has taken a leading role in many important actions on behalf of defraudedinvestors, consumers, and companies, as well as victims of human rights violations . Lerach Coughlin lawyers havebeen responsible for more than $20 billion in aggregate recoveries . The Lerach Coughlin Web site

(htcp Jlnnvw,.lerachlaw . com) has more information about the firm .

Contact:

http:/Ibiz .yahoo.comlbw/050302/25958_ 1 .html?printer=l 5/2/2005

--

Lerach Coughlin Stoia Geller Rudman & Robbins LLP

William Lerach/Darren Robbin s

800-449-4900 or 619-231-1058

wsl@lerachlaw .com

Source: Lerach Coughlin Stoia Geller Rudman & Robbins LL P

Copyright © 2005 Yahoo! Inc . All rights reserved . Privacy Policy - Terms of Service - Copvriant Policy - Ad FeedbackCopyright 0 2005 E3 iness Wire. All rights reserved. All the news releases provided by Business Wire are copyrighted . Any forms of copying other

than an individual user's personal reference without express written permission is prohibited . Further distribution of these materials by posting ,` archiving in a public web site or database, or redistribution in a computer network is strictly forbidden .

http:I/biz .yahoo . com/bw/050302/25958_1 .html?p rinted 5/2/2005

EXHIBIT C

LEADIS TECHNOLOGY, INC. ESTIMATED LOSSESf 3

PUItCHAS1 `t RANSACTIONS SALES TRANSACTI ONS

PLAINTIFF DATE SHARESSHARE

PRICE

PURCHASE

AMOUNT DATE SHARES

SHARE

PRICE

SALES

AMOUNT

ESTIMATED

LOSSES

Ngoan Van Le 7/6/2004 3,835 13.5400 51,925.90 7/27/2004 4,835 10.6000 51,251 .00 (674.90 )

7/23/2004 1,000 10 .2000 10,200 .00 7/30/2004 5,000 10 .9000 54,500 .00 44,300 .0 0

7/29/2004 5,000 11 .0100 55,050 .00 9/27/2004 14,400 11 .3900 164,016 700 108,966 .0 09/13/2004 5,200 12 .9100

T m67,132 .00 10/21/2004 13,000 16 .9000 219,700 .00 152,568 .0 0

9/13/2.00 2 ,100 13 .9500 29,295.00 RETAINS 1,100 6.0732 6,680.52 i l) (22,614.48 )9/13/2004 1,900 13 .5000 25,650.00 (25,650.00)9/1312004 2,800 14.0000 39,260 .00 (39,200.00)9/13/2004 3,000 13.5500 40,650.00 (40,65 0.00)

9/15/2004 5,000 12.5000 62,500 .00 (62,500.00)10/8/2004 560 14 .9500 8,372 .00 (8,372.00)

10/11/2004 4,100 15.9000 65,190.00 (65,190.00)10/14/2004 3,840 15 .4200 59,212 .80 59,212.80 )

38,335 38,335 (18,230.1 8

Richard Beedenbender 10/13/2004 1,000 15 .7000 1 15,700.00 RETAINED 1,000 6 .0732 6,073,20 (1) (9,626 .80 )1,000 1,000 (9,626 .8 0

Scott Strouse 10/21/2004 600 16 .6900 10,014 .00 RETAINS 600 6 .0732 3,643 .92 (I)' (6,370 .08 )600 600 (6,370 .08 )

TOTAL FOR THE L G ROUP (34,227 .06 )

CLASS PERIOD : Pursuant and/or traceable to the Company's initiialpublic offering (" IPO") on or aobut dune 16, 200 4

__.-(1) For shares retained at the end of the Class Period, estimated lama e s are calculated by multiplying tho se shares

by the moving mean average price per share of Leadis Technology, Inc . during the 90-days after date of the fir s tfiled Complaint, Safi-o n Capilat Corp. v. Leadis Technology, Inc, , No. C-05-882 (N . D- Cal. filed March 2, 2005) .The price used is $6 .0732 as of A_ ri129, 2005. j

EXHIBIT D

ISCH1FFR . N & BARR 7 , LITv,

Firm Biography

Schiffrin & Barroway, LLP, located just outside of Philadelphia, has specialized in

complex class action litigation for nearly twenty years, representing shareholders and

consumers in class action litigation in state and federal courts throughout the United States .

During the firm's successful history, Schiffrin & Barroway has recovered billions of 'dollars for

defrauded stockholders and aggrieved consumers . The firm, which has developed a

nationwide reputation for excellence, is led by its senior partners, Richard S . Schiffrin and

Andrew L. Barroway, with assistance from partners, Marc A . Topaz, David Kessler, Katharine

M . Ryan, Stuart L. Berman, Gregory M . Castaldo, Michael K . Yarnoff, Joseph H . Meltzer, and

numerous experienced associates and staff .

The firm focuses primarily on the prosecution of securities fraud litigation, derivative

actions and transactional litigation brought against public companies, executives, auditors

and investment banking firms . In addition, Schiffrin & Barroway represents consumers in

drug and product litigation as well as employees in ERISA/401K litigation .

Schiffrin & Barroway has represented various public and Taft-Hartley pension funds ,

private institutional investors, and hundreds of individual investors as Lead or Co-Lead

Counsel in class action litigation in state and federal courts throughout the United States .

Currently, Schiffrin & Barroway is acting as Lead or Co-Lead Counsel in class action suits

against such companies as Tyco, Tenet Healthcare, and Sprint . Schiffrin & Barroway is

currently involved in several other high profile cases across the country . Of particular note,

we are currently prosecuting the action In re Initial Public Offering Securities Litigation,

Master File No . 21 MC 92 (S .D .N .Y . Dec . 12, 2 002)(SAS), as one of only six law firms

comprising Plaintiffs' Counsel's Executive Committee . Our firm was selected from over

sixty law firms which had brought such actions . This litigation, which is pending in the

Southern District of New York, challenges the legality of the IPO allocation practices of

virtually all of the major investment banking firms from 1998 through 2000 and

encompasses over 300 coordinated actions . The litigation has produced a $1 billion

settlement with the issuer defendants which was recently granted preliminary approval from

the Court and continues against the underwriter banks . In addition, we are particularly

proud of the results recently achieved as sole lead counsel before the Honorable Joel A .

Pisano in In re AremisSoft Corp . Sec. Litig ., C .A . No . 01-CV-2486 (D .N .J . 2002) . This cas e

was extraordinarily complex as it involved the embezzlement of hundreds of millions of

dollars by former officers of the Company who are now fugitives . The settlement of the

action against the Company allowed for the Company to be reorganized so it could continue

operations while establishing a litigation trust to pursue claims against the Company's

auditors, its counsel, as well as those individuals that looted the Company . The Settlement

provides the class with a majority of the equity in the new company, Softbrands, as well as

their pro rata share of all monies recovered by the litigation trust . The Court-appointed co-

trustees of the litigation trust have retained Schiffrin & Barroway to continue prosecuting

the actions on behalf of the litigation trust . In this capacity, we have filed an action in th e

Isle of Man successfully freezing more than $200 million of stolen funds and are in the

process of attempting to recover the money . In addition, we are continuing to pursue the

litigation trust's claims . The AremiSoft litigation is a perfect example of one area of the

firm's expertise, which is to creatively structure settlements with financially troubled

companies .

Indeed, Schiffrin & Barroway is often commended by courts throughout the country

for its excellent work :

"I know you know that I take this responsibility seriously and try to think hardabout these issues . And I do want to compliment class counsel . I think that

you behaved responsively here and gave very good service to the class . They

were well served by you . "

- The Honorable Denise Cote of the United States District Court for theSouthern District of New York approving the settlement of In re InterpublicSecurities Litigation .

"Now, this goes back to the original approval of the securities fraudsettlement because I found in my opinion approving the settlement that

counsel for the class were to be commended because they cast their lot alongwith their clients . That is to say that counsel's fees were to be determinedand paid in accordance with the way the class members were going to bepaid ; that this was, in my view, a creative and unique approach to theproblem of paying fees to class counsel in a securities fraud case . "

- The Honorable Joel A . Pisano of the United States District Court for theDistrict of New Jersey approving the settlement in In re AremisSoft

Corporation Securities Litigation .

For clients with large investments, Schiffrin& Barroway will monitor their securitie s

holdings, calculate their losses and alert them when actions relating to their holdings hav e

been filed and/or settled . We also offer advice regarding joining an action, seeking to be a

lead plaintiff, opting out of an action, bringing an individual action, and/or filing proofs o f

claim in order to share in a recovery as a class member.

Further information regarding the firm, the services which we provide, and case s

which we are currently litigating can be found on our web-site a t

http ://www .sbclasslaw .com .

Richard S . Schiffrin , founding partner of the firm, is licensed to practice law i n

Illinois and Pennsylvania, and has been admitted to practice before numerous United StatesDistrict Courts . In his seven years of practice with the Office of the Public Defender of CookCounty, Illinois, Mr . Schiffrin represented hundreds of clients in both bench and jury trials,as well as appeals . Mr. Schiffrin has also taught legal writing and appellate advocacy atJohn Marshall Law School and has served as a faculty member at numerous legal seminarsincluding the Annual Institute on Securities Regulation, NERA :Finance, Law & Economics -Securities Litigation Seminar, the Tulane Corporate Law Institute, and the CityBar Center for

CLE (NYC) :Ethical Issues in the Practice of Securities Law . Most recently Mr . Schiffri nspoke at the MultiPensions 2004 conference in Amsterdam . Netherlands . Mr. Schiffrinoversees all aspects of litigation on behalf of the firm . Mr. Schiffrin has been recognized forhis expertise in numerous cases including most prominently :

In re AremisSoft Corp. Sec. Litig ., C.A . No . 01-CV-2486 (D.N.J. 2002)

In settling this action, which involved the embezzlement of hundreds of millions of dollarsby former officers of the Company who are now fugitives, Mr . Schiffrin assisted inreorganizing the Company to allow for it to continue operations, while successfullyseparating out the securities fraud claims and the bankrupt Company's claims into alitigation trust . Mr. Schiffrin, along with Schiffrin & Barroway partner Stuart Berman, crafteda settlement which calls for the class to receive the majority of the equity in the newcompany, as well as their pro rata share of any amounts recovered by the litigation trust . Inaddition, Court-appointed co-trustees of the litigation trust, Joseph P . LaSala, Esq . and FredS . Zeidman, chose to retain Mr . Schiffrin and the firm to continue to prosecute the actionson behalf of the litigation trust . In this capacity, the firm filed an action in the Isle of Manand successfully froze more than $200 million of stolen funds and is in the process ofattempting to recover the money on behalf of the litigation trust . In addition, Mr . Schiffrin

and the firm continues to litigate the trust's claims .

Henry v . Sears, et al, Case No, 98 C 4110 (N .D. III . 1999)

Schiffrin & Barroway served as Lead Counsel on behalf of the largest class of credit cardholders in history . At stake was the right of Sears and its newly formed affiliate, SearsNational Bank ("SNB"), to retroactively increase the interest rates on eleven million creditcard accounts with outstanding balances resulting from purchases made prior to theaccounts being transferred to SNB . Schiffrin & Barroway alleged that such conduct violatedthe Truth-in-Lending Act ("TILA"), the National Banking Act and state consumer fraud

statutes . After extensively litigating various aspects of liability, an additional nine monthswere then spent determining damages, The extraordinary complexity of the damagecalculations required Mr . Schiffrin and experts from both parties to develop, test, and utilizea novel computer model to ascertain total damages for the class and individualized damagesfor each class member . Ultimately, Mr . Schiffrin and his partner, Mr . Kessler, were able to

negotiate a $11 56 million settlement, which represented approximately 66% of totaldamages . In approving the settlement, District Court Judge Leinenwebber of the NorthernDistrict of Illinois stated :

I am pleased to approve the settlement. I think it does the best that could be done

under the circumstances on behalf of the class . . . . The litigation was complex in bothliability and damages and required both professional skill and standing which class counsel

demonstrated in abundance .

The entire settlement fund of $156 million was distributed without the filing of a single proofof claim form by any class member .

Wanstrath v. Doctor R. Crants, et al., C.A . No. 99-171 9-1II (Tenn . Chan. Ct., 20th

Judicial District, 1999) :

Schiffrin & Barroway served as Lead Counsel in a derivative action filed against the officersand directors of Prison Realty Trust, Inc ., challenging the transfer of assets from the

Company to a private entity owned by several of the Company's top insiders . Numerous

federal securities class actions were pending against the corporation at this time . Throughthe derivative litigation, the Company's top management was ousted, the composition ofthe Board of directors was significantly improved and important corporate governance

provisions were put in place to prevent future abuse . Mr. Schiffrin, in addition to achievingthese desirable results, was able to personally effectuate a global settlement of all pending

litigation against the backdrop of an almost certain bankruptcy . The case was resolved inconjunction with the federal securities cases for the payment of approximately $50 millionby the Company's insurers and the issuance of over 46 million shares to the class members .

Jordan v. State Farm Insurance Company, Case No . 97 CH 11 (Circ . Ct., McLea n

County, 111.1998)

Schiffrin & Barroway brought a claim on behalf of multiple plaintiffs alleging that State Farmhad engaged in fraudulent sales practices by "churning" policies and marketing and selling"vanishing premium" policies that never "vanished ." After several years of discovery, motion

practice and settlement negotiations, Mr . Schiffrin played a critical role in resolving theaction for $225 million in cash, dividend enhancements and other monetary benefits forcurrent and former State Farm policyholders . Schiffrin & Barroway also has achievedsubstantial settlements in 20 additional cases alleging fraudulent sales practices by various

insurance companies .

Mr . Schiffrin also has represented defrauded shareholders and companies in complex classand derivative actions including the following :

Huscher v . Curley, et. al ., No. 00 Civ. 21379 (Mich . Cir . Ct., 2000) (In re Sotheby's

Holdings, Inc . Derivative Litigation) :

Schiffrin & Barroway served as Lead Counsel in a derivative action arising out of Sotheby'salleged antitrust price fixing conspiracy with auction house rival Christie's International PLC .

A multi-million dollar settlement was negotiated by Mr . Schiffrin whereby Diana Brooks

(Sotheby's President at the time of the alleged wrongdoing) agreed to'relinquish all of herSotheby's stock options and the Company's insurance carrier made a substantial monetary

payment to the Company . In addition, significant changes in the Company's top

management and Board of Directors were achieved in conjunction with the settlement of the

litigation .

Andrew L . Barroway, managing pa rtner of the firm, received his law degree fro m

the University of Pennsylvania Law School, where he was a member of the ABA Negotiation

team . He is licensed to practice law in Pennsylvania and New Jersey, and has been admittedto practice before the United States District Court for the Eastern District of Pennsylvania .

Mr . Barroway frequently lectures on securities class action and lead plaintiff issues andrecently spoke at the 2005 Institutional Investor Hedge Fund Workshop in New York City

and the Public Funds Summit 2005 in Phoenix, Arizona . Mr . Barroway has been actively

involved in all aspects of litigation on behalf of the firm, and co-manages the firm's

securities department . Of his numerous successful representations of shareholders, the

following stand out as exceptional :

In re : Digital Lightwave, Inc . Securities Litigation, Consolidated Case No . 98-152-

CIV-T-24E (M .D. Fla . 1999) :

Schiffrin & Barroway served as Co-Lead Counsel in one of the nation's most successful

securities class actions . After extensive litigation and negotiations, Mr. Barroway negotiated

a settlement of over $180 million in cash and stock, a recovery representing in excess oftwo hundred percent (200%) of class members' losses . Schiffrin & Barroway believes that

this settlement represents the largest percentage recovery for shareholders in securities

class action history .

In re PaineWebber Short-Term U .S. Government Fund Securities Litigation, No . 94-

3820 (S.D.N.Y. 1994) :

Schiffrin & Barroway served as Co-Lead Counsel on behalf of plaintiffs alleging violations ofthe federal securities laws based upon material misrepresentations concerning the Fund's

investment objectives and the risks associated with the Fund . Pursuant to the settlement,

defendants made payments and provided fee waivers totaling more than $36 million, $33

million of which was in cash . In addition, defendant PaineWebber repurchased te n

mortgage-backed securities from the Fund for an aggregate price in excess of $50 million,

thus removing the illiquid securities from the Fund .

Mr. Barroway, along with his partner, Mr . Kessler, has also recently negotiated substantial

settlements of securities class actions in which Schiffrin & Barroway was Lead or Co-LeadCounsel against Pinnacle Holdings, Cell Pathways, Gateway, Mercator and NetSolve . Mr .

Barroway currently represents numerous public and private investment funds, moneymanagement firms and individuals in securities fraud litigation as Lead Counsel in actionsagainst Accelerated Networks, ATI Technologies, CompUSA, Livent, NX Networks, Penn

Treaty, Performance Technologies, Republic New York, Steven Madden, Vari-L, KindredHealthcare, The Interpubiic Group of Companies, Tenet Healthcare Corporation, and various

others .

Marc A. Topaz , a partner of the firm, received his law degree from Temple Universit y

School of Law, where he,was an editor of the Temple Law Review and a member of the Moot

Court Honor Society . He also received his Master of Law (L .L .M .) in taxation from the NewYork University School of Law where he served as an editor of the New York University Tax

Law Review . He is licensed to practice law in Pennsylvania and New Jersey, and has beenadmitted to practice before the United States District Court for the Eastern District of

Pennsylvania . Mr. Topaz manages the firm's derivative and transactional departments . In

this regard, Mr . Topaz has been actively involved in litigating the following prominent cases :

In re MTC Electronic Shareholder Litigation, No . CV-93-0876 (E.D .N .Y. 1993) :

Schiffrin & Barroway served as co-counsel in a case involving securities fraud by MTC, its

officers and directors, underwriters and accountants . The case presented novel issues of

Chinese law and required the construction of a database of hundreds of thousands ofdocuments utilized in numerous party and non-party depositions . A $72 million settlement

was achieved on the eve of trial .In re Oppenheimer Capital, L .P., Unitholders Litigation, Consolidated No . 16022N C

(Del . Ch. Ct. 1997) :

Schiffrin & Barroway served as Co-Lead Counsel on behalf of plaintiffs alleging that amerger proposed by Pimco Advisors benefitted certain Pimco insiders by disproportionately

allocating tax benefits achieved from the restructuring of a limited partnership and failing toprovide adequate compensation to the Oppenheimer shareholders . Plaintiffs moved toenjoin the transaction and a settlement was reached whereby defendants agreed to pay a

special dividend to Oppenheimer limited partners of approximately $16 million .

Wanstrath v. Doctor R . Crants, et al ., C.A . No . 99-1 719-JII (Tenn. Chan . Ct., 20'

Judicial District, 1999) : (description above)

David Kessler , a partner of the firm, graduated with distinction from the Emory

School of Law . He is licensed to practice in Pennsylvania and New Jersey, and has beenadmitted to practice before the United States District Court for the Eastern District ofPennsylvania and the United States District Court for the District of New Jersey . He is also a

Certified Public Accountant in Pennsylvania . Mr . Kessler co-manages the firm's nationally

recognized securities department . In addition, Mr . Kessler often lectures on securties

litigation and recently was a featured speaker on hot topics in securities litigation in aseminar entitled The Explosion and Evolution of Class Action Law in December, 2004 inPhiladelphia, Pennsylvania and the Corporate Governance Summit on CorporateAccountability in July, 2003 in New York City . Mr . Kessler has achieved the following

outstanding results in federal securities cases :In re Initial Public Offering Securities Litigation, Master File No. 21 MC 92 (S .D .N.Y .

Dec. 12, 2002)(SAS) :

Mr . Kessler, along with Mr . Schiffrin, is presently heading up the firm's litigation efforts in

its prominent position as an executive committee member in this action . Of the sixty

plaintiffs firms which originally filed actions in these coordinated proceedings, Schiffrin &Barroway was one of only six selected to serve on the executive committee . The coordinatedactions, which have been filed against 308 separate issuers of publicly traded securities,

challenge the legality of the practices which accompany the allocations of shares in initial

public offerings . In addition to suing the issuers of such securities, the 308 coordinatedactions also name as defendants the primary investment banking firms which underwrote

the offerings . This case, which has received a great deal of national and international mediaattention, is widely considered the largest securities class action litigation in history .

In re Assisted Living Concepts, Inc . Securities Litigation, Lead Case No . 99-167-AA

(D.Or . 1999) :

Schiffrin & Barroway served as Co-Lead Counsel and was instrumental in obtaining a $30million recovery for class members from the Company, its executive officers and directors,and several underwriters for their role in an alleged complex accounting fraud involving theuse of a purportedly independent joint venture to absorb the Company,'s start-up losses .

Even after this $30 million recovery, through counsel's efforts, an additional $12 .5 million

was obtained from the auditors providing for a total recovery of $42 .5 million .

In re Twiniab Corporation Securities Litigation, Master File No. 98-CV-7425 (E .D .N.Y .

1998) :

Schiffrin & Barroway served as Co-Lead Counsel and successfully litigated the action andwas able to negotiate a settlement in the amount of $26 million plus interest which was

recently approved by the Court .

In re Cumulus Media Inc . Sec. Litig., Lead Case No . 00-C-391 (E.D . Wis. 2000) :

Schiffrin & Barroway served as Lead Counsel and successfully litigated the action andnegotiated a settlement of $13 million in cash and 240,000 shares of freely tradable stock inCumulus Media, which traded for approximately $19 per share, for a total settlement value

of $17 .5 million at the time the settlement was approved by the Court .

Stuart L. Berm an, a partner of the firm, received his law degree from George

Washington University National Law Center, and his undergraduate degree from Brandeis

University . He is licensed to practice law in Pennsylvania and New Jersey, and has beenadmitted to practice before the United States District Court for the Eastern District,ofPennsylvania and the United States District Court for the District of New Jersey . Mr. Berman

has specialized in the area of securities litigation for the past eight years and serves in thefirm's case and client development department, which involves working with clients,analyzing cases and developing litigation strategy . In addition, Mr . Berman manages the

firm's lead plaintiff department and has been instrumental in enabling various of the firm'sinstitutional and individual clients to serve as lead plaintiffs in important cases, such as In

re Tenet Healthcare Corp . Securities Litigation, No . CV-02-8462-RSWL (C .D . Ca . 2002), In

re Interpublic Securities Litigation, No . 02 Civ . 6527 (S .D .N .Y. 2002)), State of New Jersey

and Its Division of Investment v. Sprint Corporation, et al . No . 03-2071-]WL (D . Kan .

2003), In re Ariba Inc . Securities Litigation, Master File No . 03-00277 JF (N .D . Cal . 2003),

Richard Wagner v. Barrick Gold Corporation, et al ., No . 1 :03cv4302 (S .ILN .Y . 2003), In re

Vaxgen Inc. Securities Litigation, No. C 03-01129 JSW (N .D . Cal . 2003), In re American

Business Financial Services, Inc ., Civil Action No . 04-0265 (E .D . Pa . 2004), Anne

Brumbaugh, et al . v. Wave Systems Corporation, et al ., No . 04-30022-MAP (D . Mass . 2004),

and In re Vaso Active Pharmaceuticals Securities Litigation, No . 04-10708-RCL (D . Mass .

2004) .

Mr. Berman, along with Richard Schiffrin, serve as lead counsel in In re AremisSoft Corp .

Sec. Litig ., C .A . No . 01-CV-2486 (D .N .J . 2002) in which certain former officers of the

Company are alleged to have stolen hundreds of millions of dollars . They negotiated a

complex settlement with the Company, which provided for the successful reorganization ofthe Company and which provided the class with the majority of the equity in the new

company . In addition, the settlement established a litigation trust in which all claims owned

by the class as well those owned by the Company were assigned for purposes of recoveringthe substantial losses incurred by the shareholders . The firm and co-counsel are litigating inthe Isle of Man where we were successful in freezing more than $200 million of funds stolen

by insiders . In addition, Mr . Berman and the firm continue to litigate the trust's claims .

Katharine M . Ryan , a partner of the firm , graduated cum laude from Villanov aUniversity School of Law in May 1984 . Ms . Ryan is admitted to practice before the United

States District Court for the Eastern District of Pennsylvania, the Court of Appeals for theThird Circuit and the United States Supreme Court . Ms . Ryan recently participated as aspeaker in a legal teleconference entitled "Is the PSLRA's Safe Harbor Provision Safe?" Ms .Ryan is actively involved in litigating several of the firms most prominent cases and wasintegral in the excellent results achieved in the following cases :

In re The Interpublic Group of Companies Securities Litigation, No. 02 Civ. 6527

(S. D . N . Y . 2002) :

S&B served as sole lead counsel in this action on behalf of an institutional investor andrecently received final approval of a settlement consisting of $20 million in cash and6,551,725 shares of IPG common stock with expected distribution by early summer 2005 .As of February, 2005 the stock had an approximate value of $87 million, resulting in a totalsettlement value of approximately $107 million . In granting its approval, the Court praisedS&B for acting responsibly and noted the firm's professionalism, competence andcontribution to achieving such a favorable result . S&B actively litigated this case while atthe same time engaging in mediation over the course of several months before arriving atthis excellent result for the class .

In re New Power Holdings, Inc. Sec . Litig ., C .A . No . 02 Civ. 1550 (S .D .N .Y . 2002) :

Schiffrin & Barroway served as Co-Lead Counsel and was instrumental in obtaining arecovery of $41 million in cash for class members against a bankrupt company, certain of itsofficers anti directors and the underwriters of the Companies offering . Claims involved NewPower, an offshoot of Enron, that was formed to re-enter the deregulated energy marketand pursued an IPO with no viable plan to hedge against volatile energy prices . The casecontinues to be litigated against the underwriters of the Company's offering .

Gregory M . Cas aldo , a partner of the firm, received his law degree from Loyol aLaw School, where he received the American Jurisprudence award in legal writing . Hereceived his undergraduate degree from the Wharton School of Business at the University ofPennsylvania . He is licensed to practice law in Pennsylvania and New Jersey . Mr . Castaldohas been actively involved in litigating the following cases :

In re Unigraphics Solutions Inc . Shareholders Litigation, Cons . C.R. No. 18916,

Delaware Chancery Court, in which Class Counsel was partially responsible forcreating an aggregate financial benefit of approximately $35 million for members ofthe class ;

In re Prodigy Communications Corp . Shareholders Litigation, Cons . C.A. No . 1 9113-

NC,Delaware Chancery Court, in which Class Counsel was partially responsible forcreating an aggregate financial benefit of approximately $36 million for members ofthe class ; an d

In re Sodexho Marriot Shareholders Litigation, Cons . C.A . No . 18640-NC, Delawar e

Chancery Court, in which Class Counsel was partially responsible for creating anaggregate financial benefit of approximately $166 million for members of the class .

Michael K . Yarnoff , a partner in the firm's securities litigation department, ha s

been actively involved in a number of federal securities cases in which outstanding results

were achieved, including the following : In re Conseco Inc. Securities Litigation, C .A . No.

IP00-C-00585 (S .D . In . 2000) ($120 million cash settlement) ; In re Twinlab Corporation

Securities Litigation, Master File No . 98-CV-7425 (E .D .N .Y . 1998) ($26 million cash

settlement) ; In re Cumulus Media Inc . Sec. Litig ., Lead Case No . 00-C,-.391 (E .D . Wis. 2000)($13 million cash settlement plus stock) ; In re Cell Pathways, Inc . Securities Litigation II,

Master File No . 01-CV-1189 (E .D . Pa . 2001) ($2 million cash settlement plus stock) ;and Inre Riverstone Networks, Inc . Securities Litigation, C .A . No. CV-02-3581 (N .D . Cal . 2002)

($18 .5 million cash settlement) .

Mr . Yarnoff received his law degree from Widener University School of Law . He has beenpracticing law in Pennsylvania and New Jersey since 1991, and has been a member of the

Delaware Bar since 1995 . He is also admitted to practice before the United States DistrictCourt for the Eastern District of Pennsylvania .

Joseph H . Meltzer , a partner of the firm, received his law degree, with honors ,

from Temple University School of Law . He is licensed to practice law in Pennsylvania andNew Jersey, and has been admitted to practice before the United States District Court forthe Eastern District of Pennsylvania, the United States District Court for the District of NewJersey and the United States Court of Appeals for the Third Circuit .

Mr. Meltzer concentrates his practice in the areas of ERISA and antitrust complex litigation,and manages the firm's ERISA Litigation Department, which has excelled in the highlyspecialized area of prosecuting claims on behalf of retirement savings plans . Mr. Meltzer isLead Counsel in several pending nationwide class actions brought under ERISA .

Mr. Meltzer has helped obtain several multi-million dollar settlements on behalf of class

members, including the recent settlements in In re Global Crossing ERISA Litigation, 02 Civ .

7453 (S .D .N .Y .) ($79 million settlement) and In re Augmentin Antitrust Litigation, 02-442

(E .D . Va .) ($29 million settlement) . Mr . Meltzer also prosecutes claims on behalf of third-party payors and consumers and is currently serving as Lead Counsel in In re Remeron

Antitrust Litigation, 02-CV-2007 (D .N .J .) and In re Welibutrin SR/ yban Antitrust Litigation

(E .D . Pa .) .

Prior to joining Schiffrin & Barroway, Mr . Meltzer practiced at Barrack, Rodos & Bacine inPhiladelphia, where he had prominent roles in prosecuting several complex class actions to

successful conclusions, including In re Sorbates Direct Purchaser Antitrust Litigation, C 98-4886 (N .D . Cal. 2001) ($92 million settlement) and also defended clients in antitrust and

commercial litigation .

ASSOCIATES

Ian D . Berg, an associate of the firm, received his law degree from Northwestern

University School of Law, and his B .A . from Northwestern University. Prior to joining

Schiffrin & Barroway, Mr . Berg practiced at Barack Ferrazzano Kirschbaum Perlman &

Nagelberg LLC, in Chicago, IL . He is licensed to practice law in Illinois and Pennsylvania .

Robert W. Biela, an associate of the firm, received his law degree from the Penn

State Dickinson School of Law, where he served on the editorial board of the Environmental

Law and Policy Journal . Mr. Biela received his undergraduate degree from West Chester

University . Prior to joining the firm, Mr . Biela was an associate at Mager White andGoldstein, LLP, where he practiced in the areas of complex commercial litigation and

securities litigation . Mr. Biela is licensed to practice in Pennsylvania, and focuses his practice

in the area of securities litigation .

Katherine B. Bornstein , an associate of the firm, received her law degree from

Emory University School of Law . Ms. Bornstein received her undergraduate degree from the

University of Maryland . She is licensed to practice law in Pennsylvania and Maryland . Prior

to joining Schiffrin & Barroway, Ms . Bornstein was an associate at Provost & Umphrey LawFirm, LLP, where she worked on a number of complex litigation issues . Ms. Bornstei n

concentrates her practice at Schiffrin & Barroway in the areas of ERISA, antitrust and

consumer protection .

Trevan Borum , an associate of the firm, received his B .A . from Wake Forest

University in 1987, and his J .D . from Widener University Law School in 1992 . Mr . Borum

was the valedictorian of his law school class, and served as a Wolcott fellow with the

Delaware Supreme Court . He is licensed to practice law in Pennsylvania, and has beenadmitted to practice before the United States District Court for The Eastern District of

Pennsylvania . Prior to joining Schiffrin & Barroway, Mr . Borum served as an AssistantDistrict Attorney in Philadelphia for ten years . Mr . Borum also practiced criminal defense

after leaving the District Attorney's office . At Schiffrin & Barroway, Mr . Borum concentrates

his practice in securities litigation .

Jonathan R . Cagan , an associate of the firm, received his law degree from th e

Temple University School of Law . Mr . Cagan received his undergraduate degree, cum laude,

from Temple University . Mr . Cagan is licensed to practice law in New Jersey, and is

admitted to the Third Circuit Court of Appeals . Mr . Cagan concentrates his practice in the

area of securities litigation .

Edward W . Chang, an associate of the firm, received his law degree, with honors ,

from the George Washington University Law School . During law school, Mr . Chang servedas a staff member of the American Intellectual Property Law Association Quarterly Journal

and published Bidding on Trespass : eBay v . Bidder's Edge and the Abuse of Trespass Theory

in Cyberspace Law, 29 AIPLA Q.J . 445 (2001) . Mr. Chang received his undergraduate degree

in International Relations, cum laude, from the University of Pennsylvania .

Prior to joining Schiffrin & Barroway, Mr . Chang served as a law clerk to the Honorable Ann

O'Regan Keary of the Superior Court of the District of Columbia . He is licensed to practice inNew Jersey and Maryland, and has been admitted before the United States District Court for

the District of Maryland . Mr . Chang concentrates his practice in the areas of antitrust, ERISA

and consumer .protection .

Darren J . Check, an associate of the firm, received his law degree from Templ e

University School of Law . He received his undergraduate degree in History, with honors,

from Franklin & Marshall College . He is licensed to practice law in Pennsylvania and New

Jersey, and has been admitted to practice before the United States District Court for theEastern District of Pennsylvania, the United States District Court for the District of NewJersey, and the United States District Court for the District of Colorado .

Mr. Check concentrates his practice in the area of securities litigation, and has worked

extensively with partner David Kessler on In re Initial Public Offering Securities Litigation,Master File No . 21 MC 92 (S .D .N .Y . Dec . 12, 2002)(SAS) currently pending in the SouthernDistrict of New York. Mr . Check consults with institutional investors worldwide regardingserving as a lead plaintiff and recently spoke at the MultiPensions 2004 conference inAmsterdam, Netherlands and the European Pension Symposium in Florence, Italy .

Mr. Check serves in the firm's lead plaintiff department, which involves working with clients,litigation strategy and lead plaintiff issues . In addition, Mr . Check 'serves as the firm'sDirector of Institutional Relations and Business Development and works closely with thefirm's domestic and foreign institutional clients .

Edward W . Ciolko, an associate of the firm, received his law degree fro mGeorgetown University Law Center, and an MBA from the Yale School of Management . Priorto joining the firm, he served as an Attorney Advisor to Commissioner Sheila F . Anthony atthe Federal Trade Commission . He is licensed to practice law in the State of New Jersey, andhas been admitted to practice before the United States District Court for the District of NewJersey . Mr. Ciolko concentrates his practice in the areas of antitrust, ERISA, and consumerprotection .

Stephen E . Connolly , an associate of the firm, received his law degree fro m

Villanova University School of Law, and is a graduate of The Pennsylvania State University .Prior to joining Schiffrin & Barroway, Mr . Connolly was an associate at a Philadelphia firmwhere he practiced in the areas of complex litigation, securities and antitrust litigation . Mr .Connolly is licensed to practice law in Pennsylvania, and concentrates his practice in the

area of antitrust litigation .

Mark S . Danek, an associate of the firm, received his undergraduate degree i nArchitecture from Temple University in 1996, and his law degree from Duquesne UniversitySchool of Law in 1999 . Prior to joining Schiffrin & Barroway, Mr . Danek was employed as in-house counsel of a real estate investment trust corporation that specialized in the collectionof delinquent property tax receivables . '

He is licensed to practice law in the Commonwealth of Pennsylvania and has been admittedto practice before the Courts of the Commonwealth of Pennsylvania, the United StatesDistrict Court for the Western District of Pennsylvania and the Supreme Court of the UnitedStates of America . Mr. Danek concentrates his practice in the area of securities litigation .

Thomas W. Grammer , an associate of the firm, received his law degree, magna

cum laude, from Villanova Law School where he was a member of Order of the Coif . Mr.Grammer received his undergraduate degree from West Chester University . Beforepracticing at Schiffrin & Barroway, Mr . Grammer served as a clerk for Judge Richard B . Kleinof the Pennsylvania Superior Court, and prior to that, as a clerk for Judge Patricia A .McInerney of the Court of Common Pleas of Philadelphia County . A member of thePennsylvania bar, Mr . Grammer concentrates his practice in securities litigation andshareholder derivative actions .

Sean M . Handler , an associate of the firm, received his law degree, cum laude,

from Temple University School of Law . Mr . Handler received his undergraduate degree from

Colby College, with distinction in American Studies . He is licensed to practice law in

Pennsylvania, and has been admitted to practice before the Eastern District of Pennsylvania .

Prior to joining Schiffrin & Barroway, Mr . Handier practiced at Reed Smith, LLP in

Philadelphia . Mr. Handler concentrates his practice in the area of securities litigation, andserves in the firm's lead plaintiff department, which involves working with clients, litigationstrategy and lead plaintiff issues . In this role, Mr. Handler has assisted partner Stuart

Berman in enabling various of the firm's institutional and individual clients to serve as leadplaintiffs in important cases, such as In re Tenet Healthcare Corp . Securities Litigation, No .

CV-02-8462-RSWL (C .D . Ca . 2002), In re Interpublic Securities Litigation, No. 02 Civ . 6527

(S .D .N .Y. 2002)), State of New Jersey and Its Division of Investment v. Sprint Corporation,

et a! . No . 03-2071-JWL (D . Kan . 2003), In re Ariba Inc . Securities Litigation, Master File No .

03-00277 JF (N .D . Cal . 2003), Richard Wagner v . Barrick Gold Corporation, et al ., No .

1 :03cv4302 (S .D .N .Y. 2003), In re Vaxgen Inc. Securities Litigation, No. C 03-01129 J5W

(N .D . Cal . 2003), In re American Business Financial Services, Inc ., Civil Action No . 04-0265

(E .D . Pa . 2004), Anne Brumbaugh, et al. v. Wave Systems Corporation, et al., No . 04-

30022-MAP (D . Mass . 2004), and In re Vaso Active Pharmaceuticals Securities Litigation,

No. 04-10708-RCL (D . Mass . 2004) .

John A. Kehoe , an associate of the firm, received a B.A . from Depaul University i n

1986, and a Master's degree in Public Administration from the University of Vermont in

1994 . He received his ) .D :, magna cum laude, from Syracuse University College of Law in1997, where he was an Associate Editor of the Syracuse Law Review, an Associate Memberof the Moot Court Board, and an alternate member on the National Appellate Team . Mr.

Kehoe islicensed to practice law in the State of New York, and has been admitted to practicebefore the United States District Court for the Southern District of New York .

Prior to joining Schiffrin & Barroway, Mr . Kehoe had extensive securities litigation

experience as an associate at Bernstein, Litowitz, Berger & Grossman, LLP, and prior to that,at Clifford Chance US LLP . Before attending law school, Mr. Kehoe worked as a police officerin Burlington and Brattleboro, Vermont, and served as the lead investigator in numerous

felony and misdemeanor complaints . Mr . Kehoe concentrates his practice in the area ofsecurities litigation, and has worked extensively with partner David Kessler on In re Initial

Public Offering Securities Litigation, Master File No . 21 MC 92 (S .D .N .Y . Dec . 12,

2002)(SAS), currently pending in the Southern District of New York . .

Hal J . Kleinman , an associate of the firm, received his law degree from The Joh n

Marshall Law School, and his undergraduate degree from Ithaca College . Mr. Kleinman islicensed in Illinois and Pennsylvania, and has been admitted to practice before the NorthernDistrict of Illinois, the Eastern District of Pennsylvania, the Court of Appeals for the SeventhCircuit, the Court of Appeals for the Third Circuit, and the United States Court of Claims .

Prior to joining Schiffrin & Barroway, Mr . Kleinman practiced law in Chicago, where hispractice concentrated in the area of Complex Litigation, Mass Torts and Class Actions . Mr.Kleinman was a member of the law and briefing committee that successfully obtained class

certification in In re Hartmarx Securities Litigation, United States District Court for the

Northern District of Illinois, Case No . 0 1 C 7832 . In addition, he was appointed to the Class

Counsel Management Committee in Cress, et a! . v. Sara Lee Corporation, Circuit Court of

Cook County, Illinois, Case no . 98 L 15072 . For his work in this matter, Mr .Kleinman wasasked to be a guest lecturer at the University of Chicago law School's Class ActionControversies Seminar and to discuss the Sara Lee litigation . He also was responsible forrepresenting hundreds of clients in various Mass Torts including MDL-1431, In re BaycolProducts Liability Litigation ; MDL-1373, In re Bridgestone/Firestone, Inc . ATX, ATX II andWilderness Tires Products Liability Litigation ; MDL-1203, In re Diet Drugs (Phentermine/Fenfluramine/Dexfenfluramine) Products Liability Litigation ; and MPL-926, In re Silicone GellBreast Implants Product Liability Litigation . Mr. Kleinman concentrates his practice in thearea of Mass Torts .

Eric Lechtzin , an associate of the firm, received his law degree from the Temple

University School of Law in 1991 . Mr. Lechtzin received his undergraduate degree inPolitical Science and Economics, magna cum laude, from Temple University where, he

received Phi Beta Kappa honors . Mr. Lechtzin is licensed to practice law in Pennsylvania andNew Jersey, and has been admitted to practice before the United States District Courts forEastern District of Pennsylvania and the District of New Jersey .

Prior to joining Schiffrin & Barroway, Mr . Lechtzin was an associate with the firm of Grant &

Eisenhofer, P .A ., where his practice was concentrated in federal securities class actions andcorporate governance litigation . Mr. Lechtzin spent the first ten years of his career at twolarge Philadelphia firms where he represented corporate and public sector clients in a widerange of complex commercial litigation including toxic torts, labor and employment,insurance, and environmental law . Mr . Lechtzin has extensive trial experience and hasargued appeals before the Supreme Court of Pennsylvania and other appellate courts .

Mr . Lechtzin concentrates his practice with Schiffrin & Barroway in the area of securitiesclass action litigation .

Richard A. Maniskas , an associate of the firm, received his law degree fro m

Widener University School of Law, and received his undergraduate degree from theUniversity of Pittsburgh . While in law school, Mr. Maniskas served as Internal Editor of theWidener Journal of Public Law . He is licensed to practice law in Pennsylvania and the Districtof Columbia, and has been admitted to practice before the United States District Court forthe Eastern District of Pennsylvania . Mr. Maniskas works in the firm's case developmentdepartment .

Tobias L . Milirood , an associate of the firm, co-manages the mass tort department

at Schiffrin & Barroway along with David Kessler . Mr . Millrood has been actively involved inmass tort litigation involving Prempro (Hormone Therapy), Vioxx, Fen-Phen, Baycol, Meridia,Thimerosal, Ephedra and Zyprexa . Mr. Miiirood currently serves as Liaison Counsel in In ReHormone Therapy Litigation, Philadelphia Court of Common Pleas . Mr. Milirood also serveson the Plaintiffs' Steering Committee in MDL 1507 - In Re Prempro Products Liability and isChair of the Association of Trial Lawyers of America (ATLA) Hormone Therapy LitigationGroup . In Baycol, Mr . Millrood served as a Co-Chair of the Expert Committee in In ReBaycol Litigation, Philadelphia Court of Common Pleas . In Meridia, Mr . Millrood is Co-Chairof the ATLA Meridia Litigation Group . He also served on the Executive Committee of MDL1481, In re Meridia Products Liability . In Thimerosal, Mr . Millrood serves on the ExecutiveCommittee of the Omnibus Autism Proceedings before the National Vaccine InjuryCompensation Program . In August, 2003, Mr . Milirood's article on Hormone Therapy waspublished in Trial magazine . Mr. Miilrood speaks frequently at various seminars, on thetopics of Mass Tort Litigation, Hormone Therapy, Meridia, the Ethics of Settling Mass TortCases and Electronic Discovery . Mr. Millrood is a former member of the Pennsylvania Trial

Lawyers Board of Governors and the Executive Committee of the Philadelphia BarAssociation Young Lawyers' Division :

In addition to his drug litigation achievements, Mr . Millrood has garnered several othernotable achievements, including a $22 million medical malpractice verdict in Wallace v .

Fraider, Phila . CCP, March 2001, one of the highest in state history . He also wrote and

argued cases resulting in significant changes to Pennsylvania law : Cullen v . Pennsylvania

Prop . & Cas. Ins. Guar. Assn, 760 A .2d 1198 (Pa . Commw . 2000) (Pennsylvania workers'compensation carrier could not assert a subrogated claim for benefits that its in§ured'semployee was precluded from recovering in settlement of a related medical malpractice

claim .) ; and Estate of Magette v . Goodman, 2001 WL 218981 (Pa . Super . 2001) (Failure toretain evidence of EKG strip during orthopedic surgery that resulted in death of patient

required new trial where court failed to give jury adverse inference instruction .) .

Todd Mosser , an associate of the firm, received his law degree, cum laude, from Th e

University of Pittsburgh School of Law in 2001, where he was inducted into The Order of the

Barristers . Mr. Mosser received his undergraduate degree in Criminal Justice fromShippensburg University in 1998, where he was inducted into Who's Who in American

Colleges and Universities .

Prior to joining Schiffrin &,Barroway, Mr . Mosser was an Assistant District Attorney in theAppeals Unit in the Philadelphia District Attorney's Office . He successfully briefed and

argued a number of published cases, including : Commonwealth v . Young, 849 A .2d 1152

(Pa . 2004) ; Commonwealth v. Dillon, 2004 Pa . Super 457, (en bane) ; Commonwealth v .

Butler, 856 A .2d 131 (Pa . Super . 2004) ; and Commonwealth v . Jackson, 849 A .2d 1254 (Pa .

Super . 2004) .

Mr. Mosser is also a First Lieutenant in the United States Army Reserves, JAG Corps . Mr .Mosser is licensed to practice law in Pennsylvania . He concentrates his practice at Schiffrin &Barroway in the areas of securities litigation .

Christopher L . Nelson , an associate of the firm, received his law degree fro m

Duke University School of Law, and his undergraduate degree in Business, Economics, and

the Law from Washington University in St . Louis . Prior to joining Schiffrin & Barroway, Mr .

Nelson practiced with the Philadelphia law firm of Berger & Montague, P .C ., where he was a

securities litigator .

Mr. Nelson is admitted to practice law in the Commonwealth of Pennsylvania, the SupremeCourt of the United States, the United States Court of Appeals for the Fourth, Fifth and Ninth

Circuits, and the United States District Court for the Eastern District of Pennsylvania .

Mr . Nelson concentrates his practice in the area of securities litigation, and is Lead or Co-Lead Counsel in numerous pending nationwide class action securities cases .

Michelle N . Peterson , an associate of the firm, received her law degree fro m

Widener University School of Law in 1999 . Ms . Peterson received her undergraduate degree

from Temple University . Ms . Peterson is licensed to practice law in Pennsylvania and NewJersey, and has been admitted to practice before the Eastern District of Pennsylvania and

District of New Jersey . Prior to joining Schiffrin & Barroway, Ms . Peterson was an associate

with the law firm of Grant & Eisenhofer, P .A ., where she practiced complex commercial

litigation, including the areas of securities litigation and consumer class actions . Ms .

Peterson concentrates her practice with Schiffrin & Barroway in the area of securities

litigation .

Nicholas S . Pullen , an associate of the firm, received his law degree, cum laude ,

from the Georgetown University Law Center in 2000 . Upon graduation, Mr. Pullen worked at

two prominent Philadelphia law firms . In 2003, he joined the administration of Governor

Edward G . Rendall, where he served as Chief Counsel to the Pennsylvania Commission on

Crime and Delinquency . Most recently, Mr . Pullen served as campaign manager for the Jim

Eisenhower for Attorney General Campaign . He is licensed to practice law in Pennsylvania,

and has been admitted to practice in the United States District Court for the District of

Colorado, Mr. Pullen serves in the firm's Institutional Relations department .

Karen E . Reilly , an associate of the firm, received her law degree from Pac e

University School of Law, where she was a member of the Moot Court Board and National

Moot Court Team . Ms . Reilly received her undergraduate degree from the State University of

New York College at Purchase . She is licensed to practice law in Pennsylvania, New Jersey,

New York, Connecticut and Rhode Island, and has been admitted to practice before theEastern District of Pennsylvania, District of New Jersey, Southern and Eastern Districts ofNew York, and the District of Connecticut .

Prior to joining Schiffrin & Barroway, Ms . Reilly practiced at Pelino & Lentz, P .C . in

Philadelphia, where she litigated a broad range of complex commercial cases . Ms . Reilly

concentrates her practice in the area of securities litigation .

Steven D . Resnick, an associate of the firm, received his law degree from The

Dickinson School of Law of The Pennsylvania State University, and his undergraduate

degree, cum laude, from West Chester University . Mr. Resnick is licensed to practice law in

Pennsylvania and New Jersey, and has been admitted to practice before the United StatesDistrict Court for the Eastern District of Pennsylvania, the United States Court of Appeals forthe Third Circuit, the United States District Court for the District of New Jersey and the

United States District Court for the District of Nebraska . Prior to joining Schiffrin &

Barroway, Mr . Resnick was an associate at the firm of German, Gallagher & Murtagh, where

his practice concentrated in the defense of medical malpractice, products liability and

premises liability . Mr. Resnick now concentrates his practice in the area of mass tort

litigation .

Lee D . Rudy , an associate of the firm, received his law degree from Fordha m

University in 1996 . He is licensed to practice law in Pennsylvania and New York . From 1996

to 2002, Mr. Rudy was an Assistant District Attoreny in the Manhattan DA's Office, where he

prosecuted dozens of felony jury trials to verdict, including robbery, rape, and murder cases .

From 2003 to 2005, Mr . Rudy was an Assistant United States Attorney in the District of New

Jersey, where he investigated and prosecuted numerous fraud and violent crime cases, and

where he tried three major fraud cases to verdict in federal court . Mr. Rudy, along with Marc

Topaz and Eric Zagar manages the firmsMergers and Acquisition and Shareholder Derivative

litigation department .

Manny Shachmurove , an associate of the firm, received his law degree from Th eUniversity of Michigan Law Scholl, where he was an Associate Editor of the Michigan Journal

of Law Reform . Mr. Shachmurove received his Batheclor of Science of Economics, cum

laude, from The Wharton .School at the University of Pennsylvania, where he was a Joseph

Wharton Scholar .

Kay E . Sickles , an associate of the firm, received her law degree from the Universit y

of Pennsylvania School of Law . She received her undergraduate degree from ColgateUniversity, graduating with Honors from the History department . Prior to joining the firm,

Ms . Sickles was an associate with Sandals & Langer, LLP, where she litigated complex class

actions, arising out of violations of the ERISA and Antitrust statutes . She is licensed topractice law in Pennsylvania and New Jersey, and has been admitted to practice before theUnited States District Court for the Eastern District of Pennsylvania and the United States

District Court for the District of New Jersey .

Ms . Sickles concentrates her practice in the area of securities litigation and specializes insettlement matters .

Tamara Skvlrsky, an associate of the firm, received her law degree, with honors ,

from The George Washington University Law School . Ms . Skvirsky received herundergraduate degree, cum laude, from the University of Pennsylvania . Ms . Skvirsky is

licensed to practice law in Pennsylvania and New Jersey, and concentrates her practice inthe firm's case development department .

Sandra G . Smith , an associate of the firm, received her law degree from Templ e

University School of Law, where she was Editor-in-Chief of The Temple Environmental Law

and Technology Journal . Ms. Smith is also a graduate of St . Joseph's University, where shereceived her B .A . in History . Prior to joining Schiffrin & Barroway, Ms . Smith practiced as asecurities litigator with the Philadelphia law firm of Berger & Montague, P .C . Ms . Smith is

licensed to practice in Pennsylvania and is admitted to practice before the United States

District Court of the Eastern District of Pennsylvania . Ms . Smith concentrates her practice in

the area of Mergers and Acquisition litigation .

Benjamin J . Sweet, an associate of the firm, received his juris doctor from th e

Dickinson School of Law, and his BA, cum laude, from the University Scholars Program of

The Pennsylvania State University . While in law school, Mr . Sweet served as Articles Editor

of the Dickinson Law Review, and was also awarded Best Oral Advocate in the ATLA Junior

Mock Trial Competition . Prior to joining Schiffrin & Barroway, Mr . Sweet practiced in thePittsburgh office of Reed Smith LLP, where he specialized in complex civil litigation . While at

Reed Smith, Mr. Sweet co-authored Assignability of Non-Compete Covenants, 74 Pa . Bar . Q .

64 (April 2003) . Mr. Sweet is licensed to practice law in the Commonwealth of

Pennsylvania, the U .S . District Court for the Western District of Pennsylvania and the United

States Courts of Appeals for both the Second and Ninth Circuits .

Mr . Sweet concentrates his practice in the area of securities litigation and has helped obtain

several multi-million dollar settlements on behalf of class members in several nationwidefederal securities class actions, including In re Flextronics Intl Ltd . Secs . Litig ., No . 03-cv-

2102 (N .D . Cal . 2004), In re Black Box Corp . Secs . Litig ., No . 03-cv-412 (W .D . Pa . 2004)

and In re Zomax Inc . Secs. Litig ., No . 04-cv-1155 (D . Minn . 2005) . Mr. Sweet is currently

Lead or Co-Lead Counsel in several pending nationwide class action securities cases .

Heather Tashman , an associate of the firm, received her IaW`degree, cum laude,

from Villanova University School of Law where she was an Associate Editor of OutsideArticles for the Villanova Environmental Law Journal . She also received an MBA from

Villanova University in 2003 . Ms . Tashman received her undergraduate degrees, cum laude,

in Art History and Psychology from Tulane University in 2000 . Prior to joining Schiffrin &

Barroway, Ms . Tashman was an associate at Drinker Biddle and Reath LLP, where she

specialized in insurance litigation .

Ms . Tashman is admitted to practice law in Pennsylvania and New Jersey . She has also been

admitted to practice before the United States District Court for the Eastern District of

Pennsylvania . Ms . Tashman concentrates her practice at Schiffrin & Barroway in the areas of

securities litigation .

Gerald D . Wells, III, an associate of the firm, received his law degree fro m

Temple University School of Law, where he served on the editorial board of the Environment

Law & Technology Journal, and was President of the Student Bar Association . Prior to joining

the firm, Mr . Wells was an associate at Mager White & Goldstein, LLP, where he practiced inthe areas of complex commercial litigation, antitrust and securities litigation . He is,licensed

to practice in Pennsylvania and New Jersey, and has been admitted to practice before theUnited States District Court for the District Court of New Jersey . Mr . Wells concentrates his

practice in the areas of antitrust, ERISA, and consumer protection .

Robin Winchester , an associate of the firm, received her law degree fro m

Villanova University School of Law, and received her undergraduate degree in Finance from

St. Joseph's University . Prior to joining Schiffrin & Barroway, Ms . Winchester served as a law

clerk to the Honorable Robert F . Kelly in the United States District Court for the Eastern

District of Pennsylvania . Ms . Winchester is licensed to practice law in Pennsylvania and NewJersey, and has been admitted to practice before the United States District Court for the

Eastern District of Pennsylvania . She concentrates her practice in the area of securities

litigation, and serves in the firm's lead plaintiff department which involves working withclients, litigation strategy and lead plaintiff issues .

Mr. Willner is Lead or Co-Lead counsel in several pending nationwide class action securities

cases, including In re Corning Sec . Litig., No . 01-CV-6580 (W .D .N .Y.) ; Spagnola v. Kilrea et

al., (HA-LO Industries, Inc .) No . 02 C 0270 (E .D . Ill .) ; D .E. & J . Ltd. Partnership v . Conaway

et al ., (Kmart Corporation) No . 02-70684 (E .D . Mich .) ; and In re Interpublic Sec . Litig ., No .

02 Civ . 6527 (S .D .N .Y .) .

Eric L. Zagar , an associate of the firm, received his law degree from the University o f

Michigan Law School, cum laude, where he was an Associate Editor of the Michigan Law

Review . He has practiced law in Pennsylvania since 1995, and previously served as a lawclerk to Justice Sandra Schultz Newman of the Pennsylvania Supreme Court . He is admitted

to practice law in Pennsylvania .

Mr . Zagar concentrates his practice in the area of shareholder derivative litigation . Mr . Zagar

has served as Lead or Co-Lead counsel in numerous derivative actions in courts throughout

the nation, including DaVid v. Wolfen, Case No . 01-CC-03930 (Orange County, CA)

(Broadcom Corp . Derivative Action) ; `In re PolyMedica Corporation Shareholder Derivative

Litigation, Case No . 01-3446 (Middlesex County, MA) ; In Re Dynacq Intl . Shareholder

Derivative Litigation, Case No . 2002-07135 (Harris County, TX) ; and Castillo V . Cavallaro, et

al., Case No . A467663 (Clark County, NV) (Station Casinos, Inc . Class and Derivative

Action) . Mr. Zagar has successfully achieved significant monetary and corporate governancerelief for the benefit of shareholders, and has extensive experience litigating matters

involving Special Litigation Committees . In addition, Mr . Zagar along with Marc,Topaz andEric Zagar manages the firms Mergers and Acquisition and Shareholder Derivative litigation

department.

Andrew I .. . ZiV1tZ, an associate of the firm, received his law degree from Duk e

University School of Law, and received a Bachelor of Arts degree with distinction from the

University of Michigan, Ann Arbor . Prior to joining Schiffrin & Barroway, Mr . Zivitz practiced

with the Philadelphia law firms of Klehr, Harrison, Harvey, Branzburg & Ellers, LLP andDrinker Biddle & Reath, LLP, where he litigated complex commercial and environmental

matters .

Mr. Zivitz is admitted to practice law in Pennsylvania and New Jersey, and has been

admitted to practice before the United States District Court for the Eastern District ofPennsylvania and the United States District Court for the District of New Jersey .

Mr. Zivitz concentrates his practice in the area of securities litigation, and is Lead or Co-LeadCounsel in several of the largest class action securities cases currently pending nationwide .

In addition, Mr . Zivitz has been instrumental in recovering more than $100 million for

aggrieved investors in numerous securities class action litigations including In re Computer

Associates, No . 02-CV-1226 (E.D .N .Y .) and In re Aon Corp ., No . 02 CV 5631 (N .D .III) .

Kendall S . Zyistra, an associate at the firm, received his law degree from Temple

University School of Law, where he graduated with the Temple Law Alumni/ae Moot Court

Award . Mr. Zylstra is licensed to practice law in Pennsylvania, and has been admitted topractice in the United States Court of Appeals for the Ninth Circuit, the United States District

Court for the Eastern District of Pennsylvania, the District of Oregon, the Eastern District ofWashington, the Western District of Washington, and the New Jersey Superior Court .

Prior to joining Schiffrin & Barroway, Mr . Zyistra practiced law at Berger & Montague, P .C .,where he concentrated on antitrust and complex consumer protection litigation . He was an

Assistant District Attorney in Philadelphia from 1991 to 1996, primarily prosecuting sexualassault and domestic violence cases . Mr . Zylstra also represented two classes of victims of

human radiation experimentation conceived and conducted by the federal government inconjunction with state and private contractors as part of the U .S . atomic weapons research

program during the Cold War . He was principally responsible for all areas of litigation onbehalf of prisoner experimentation subjects, helping obtain settlements for over $4 .7 millioncombined, and significantly contributed to a reversal by the Ninth Circuit Court of Appeals of

a summary judgment dismissal of one of those cases on statute of limitations grounds . See

Bibeau, et al . v . Pacific Northwest Research Foundation, et al ., 188 F.3d 1 105 (9th Cir .

1999) . In addition, Mr . Zylstra made significant contributions in winning substantial

recoveries in the Phen Fen litigation . Mr. Zylstra, along with David Kessler manages thefirm's Antitrust department .

CONSULTANTS

Kevin P . Cauley serves in the firm's Institutional Relations department . Mr . Caule y

is a graduate of Temple University . Prior to joining the firm, Mr . Culey was Director of

Business Development for MBP Associates, one of the country's top multi-family offices in

New York City . Mr. Cauley has experience in institutional fiduciary investment consulting,money manager selection, best trade executions, and asset allocation modeling . He has held

the Series 7, 24, 63, and 65 licenses with the NASD . Mr. Cauley has also done politicalconsulting in coordinating and directing various aspects of field operations for local, state,

and national campaigns in Southeastern Pennsylvania .

Roy Jones serves in the firm's Institutional Relations Department . Mr. Jones was

educated at Oxford and Cambridge Universities in the United Kingdom, and has a broad and

deep understanding of the European pension world and its key players . Furthermore, Mr .

Jones is an acknowledged expert on global corporate governance trends, where he has

advised the Organization for Economic Cooperation and Development and the World Bank,

among others . Mr . Jones works closely with many of the firm's European clients .

EXHIBIT E

G R E E N a W E L L I N G L L P

FIRM RESUME

Litigation Approach

The Firm's business strategy is to aggressively develop and pursue opportunities in thefield of class action litigation . The Firm's principals have many years of experience in class

action litigation . The Firm relies heavily on a fully networked computer system to generateefficiencies in legal research and drafting, time-keeping, financial control and planning .

The Firm's class action practice involves claims relating to violations of consumerprotection laws, truth in lending legislation, financial services, securities offerings, accountingmalpractice, breach of fiduciary duties of corporate officers and directors, and products liability .

The aggressive, result-oriented approach to client representation applied by the Firm andits principals has been demonstrated in the following litigation :

In Re: Providian Credit Card Cases. Robert S . Green, then of Girard &Green, LLP, was appointed co-lead counsel in this national class action broughton behalf of Providian credit card customers who were improperly charged latefees, higher interest rates on balance transfers , and fees for add-on products,including Credit Protection, Price -Pro, Drive Pro, HealthPro, and credit lineincreases . The San Francisco Superior Court approved a settlement for $105million, which covered restitution to Providian customers , " in-kind" payments tocustomers , and the costs and expenses of the litigation .

XO Communications, Inc. Securities Litigation Green Welling LLP representedshareholders in class litigation pending in Delaware who suffered losses inconnection with XO's slide into bankruptcy in 2002 . In September 2002, theSupreme Court of New York approved a global settlement of the New York andDelaware class action cases that provided a cash fund of over $8 million toshareholders .

McKesson Inc. Derivative Litigation . McKesson-HBOC, Inc . lost $9 billion instock market capitalization in one day during April 1998 after announcing thatprior financial statements would be restated due to accounting errors . Rather thanpursuing the individuals and companies who participated in the conduct that led tothe accounting restatements, the company sued its own shareholders in a case thatwas promptly dismissed by the Ninth Circuit U .S . Court of Appeals . As co-counsel for plaintiff shareholders seeking to recover money on behalf of thecorporation from the wrongdoers, the firm obtained an important decision fromthe Delaware Supreme Court expanding the rights of shareholders to obtain an d

235 PINE ST ■ FIFTEENTH FLOOR - SAN FRAN CI SCO ■ CALIFORNIA 9410 4

TEL (415)477-6700 ■ FAX (415)477-6710 = EMAIL GW@CLASSCOUNSEL .COM ■ www CLASSCOUNSEL .COM

Page 2

inspect corporate documents where there is a proper purpose for investigatingpotential wrongdoing . See Saito v . McKesson HBOC, Inc., 806 A.2d 113 (Del .

Supr. 2002) . We are continuing to seek recovery in Delaware Chancery Court onbehalf of the company .

Mitchell v. American Fair Credit Association . In February 2003, attorneys forGreen Welling LLP with co-counsel negotiated an $8 .6 million cash fund to bedistributed to victims of AFCA's credit repair scheme. Through the settlement,consumers also obtained debt forgiveness for outstanding membership dues andcredit repair .

Prata v. Bank One . Green Welling LLP represented the plaintiff class in this caseinvolving "Same as Cash" credit card financing claims . On December 12, 2002,the Superior Court in Los Angeles approved a $3 million cash settlement forCalifornia consumers who participated in the "Same as Cash" financing plan .

Prata v. GE Capital . Green Welling LLP restored another $2 .5 million toCalifornians who were duped by the "Same as Cash" advertising slogan andprogram that GE bought from Bank One . GE also agreed to refrain from using the"Same as Cash" slogan to advertise financing plans that require minimum monthlypayments .

Calvin v . Zaken . Green Welling LLP attorneys represented retired and disabledindividuals who were drawn into the Zaken Company's work at home scheme .The case asserted claims under California's elder abuse statutes, the ConsumerLegal Remedies Act and California's Unfair Competition Law. Green Wellingobtained significant monetary relief for the plaintiffs and an enforceableagreement strictly regulating the advertising and business practices of thedefendants .

Equitec Roll-Up Litigation . In 1994, Robert Green was a key member of the trialteam in this federal securities class action . Plaintiffs asserted claims in connectionwith the merger or "roll-up" of ten real estate limited partnerships . By the end of asix month trial, the defendants including Dean Witter, Smith Barney, Hallwoodand others had settled for over $30 million .

Brauer v. Primetime 24 Joint Venture and DirecTV, Inc . In this national classaction, the Plaintiff sought damages for a class of 900,000 subscribers to satelliteTV, whose network programming (ABC, CBS, NBC, Fox) was cut off afterDirecTV and PrimeTime were found to have violated the United States CopyrightAct by retransmitting the programming to those subscribers . Under a settlementvalued at $44 million, the defendants provided a package of free, premium movieprogramming to the class . The settlement was approved April 200 .1 .

In Re: Prison Realty Securities Litigation . In this lawsuit, shareholders of CCAPrison Realty Trust and Corrections Corporation of America sought damages onbehalf of investors against a real estate investment trust and its officers and

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directors, following defendants' alleged false statements made in the context of amerger between Corrections Corporation of America and CCA Prison RealtyTrust and subsequent operation of the merged entity . On February 13, 2001, theCourt granted final approval to a settlement for over $104 million in cash andstock.

In re Salomon Analyst Litigation . Green Welling LLP serve as co-lead counselfor the class . Pending in the U .S . District Court for the Southern District of NewYork, this case asserts claims against the securities analyst, Jack Grubman, and hisemployers at Solomon Smith Barney for manipulating the price of XO stock inorder to gain investment banking business .

In Re : Digex, Inc . Shareholder Litigation . Minority shareholders of Digex, Inc .sued to enjoin MCI WorldCom's planned acquisition of a controlling interest inDigex through a merger with Intermedia Communications, Inc ., the majority

shareholder . In a settlement approved by Delaware Chancery Court on April 6,2000, a fund consisting of $165 million in MCI Worldcom stock and $15 millionin cash was secured for Digex shareholders, as well as non-cash benefits valued at$450 million .

Isco v. Kraemer (In re UDC Homes, Inc) . Securities class action against officersand directors of real estate development company and its auditors . Robert Greenassumed lead role in obtaining $16.75 million in partial settlements . Mr. Greenalso participated as trial counsel in a five month trial against the company' s

outside auditors .

In re Bridgestone/Firestone, Inc ., ATX, ATX II and Wilderness AT Tires Products

Liability Litigation . Robert Green is chairman of the Law Committee of thisnationwide MDL products liability action brought on behalf of owners of certainFirestone tires and Ford Explorers asserting claims under the Magnuson-MossWarranty Act, 15 U.S .C. §§ 2301 et seq ., state consumer protection statutes andcommon law . In March 2004, a Texas court approved a nationwide settlementwith Firestone. Firestone agreed to spend $15 .4 million on consumer educationfor three years and to implement tire design changes to provide better high speedcapacity. Firestone also will replace any recalled tires still on consumers' vehiclesat no charge .

In re: Tenet Healthcare Cases H. Jenelle Welling serves on the Plaintiffs'Executive Committee in this consolidated action seeking redress for uninsuredconsumers who received treatment from one of Tenet Healthcare's 42 Californiahospitals. The class action complaint alleges Tenet charged exorbitant andunconscionable prices, for example, making up prescription drugs 1,038% onaverage, to increase revenues and profits .

Page 4

Partners

Robert S. Green has practiced extensively in the fields of complex and class actionlitigation since 1988 . Before forming Green Welling, Mr. Green was a partner in the firm of

Girard & Green. He graduated with honors from the University of the Pacific, McGeorge Schoo l

of Law in 1984. Mr. Green received his Masters of Business Administration degree fromCalifornia State University-Sacramento in 1989 and his undergraduate degree with distinctionfrom Oregon State University in 1981 . He is an active member of the National Association ofConsumer Attorneys (NACA) and of the Association of Trial Lawyers of America (ATLA), and

is an Editorial Advisor for the Consumer Financial Services Law Report . Mr. Green is also a

member of the Partners' Council for the National Consumer Law Center and is a formerChairman of the Board of Marin AIDS Interfaith Network .

Jenelle Welling graduated from the University of California Hastings College of the Lawin 2000, where she was honored with the American Jurisprudence Award in both Moot Court and

Trial Advocacy. She also was a member of the Hastings Women's Law Journal . Prior to law

school, Ms . Welling received a Masters Degree in Public Policy from the University ofCalifornia at Berkeley . She graduated with Highest Honors from the University of California atSan Diego with a Bachelor of Arts degree in Political Science . Ms. Welling is an active memberof the Bar Association of San Francisco (BASF), Consumer Attorneys of California (CAOC),and Association of Trial Lawyers of America (ATLA) .

Associates

Kamon Naddaf graduated from UC Berkeley School of Law, Boalt Hall in 2003. She

was a member of the Berkeley Women's Law Journal and the Asian Law Journal . Ms. Naddaf

received two BAs from UC Berkeley where she graduated with distinction in general scholarshipand majored in both Political Science and Rhetoric . After earning her BA, she worked forAmericorps focusing on homeless policy reforms in the Bay Area .

John W. Pillette graduated from the University of Maryland School of Law in 1998 andhas worked exclusively in the area of complex litigation . Mr. Pillette worked for the

Washington, D .C . consumer law firm of Moore & Brown and simultaneously served as an editor,researcher, writer, and consultant with that firm's associated bimonthly legal periodical Class

Action Reports . He has written the following articles : Aggregation of Class Action Claims to

Satisfy 28 U.S. C. §1332s Amount in Controversy Requirement, 22 Class Action Rep . 408

(2001); and The "Plain Meaning Rule "-Constructive or Reductive? (The Split Over 28 U .S.C.

1367), 23 Class Action Rep . 1 (2002) . He is admitted to practice before the state courts ofMaryland and California, the United States District Courts for the Northern, Central, Southern,and Eastern Districts of California, and the Ninth Circuit Court of Appeals . He is a member of

the American Trial Lawyers Association (ATLA) and the American Society of Writers on LegalSubjects (Scribes) . He received his undergraduate degree from St . John's College .

Page 5

Avin P. Sharma graduated from UC Hastings College of the Law in 2004 . He was a

member of the Hastings International and Comparative Law Review . Mr. Sharma was a judicial

extern at the San Francisco Superior Court for the Honorable A . James Robertson u, the

Honorable James J . McBride, and the Honorable Ronald E . Quidachay. He was also a judicial

extern for the Honorable Saundra B. Armstrong of the U.S . District Court for the Northern

District of California . Mr. Sharma received a B .A. in Business Economics and a B .A. in Political

Science from the University of California at Santa Barbara .

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Robert S . Green (State Bar No . 136183) (rsg@classcounsel .com)GREEN WELLING LLP235 Pine Street, 15`h FloorSan Francisco, CA 94104Telephone : (415) 477-6700Facsimile : (415) 477-6710

[Proposed] Liaison Counsel

Stuart L . Berman (sberman@sbclasslaw .com)Sean M. Handler (shandler@ sbclasslaw .corn)Robin Winchester (rwinchester@sbclasslaw .com)SCHIFFRIN & BARROWAY, LLP280 King of Prussia RoadRadnor, PA 19087Telephone: (610) 667-7706Facsimile: (610) 667-7056

[Proposed] Lead Counsel

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

In re LEADIS TECHNOLOGY, INC . ,

This Document Relates To : All Actions

Case No. C 05-1034 CRB

PROOF OF SERVICE

Date: June 10, 2005Time. 10:00 a.m .Dept: Courtroom 8, 19`h FloorJudge: Hon . Charles R . Breyer

I, Kim O. Trinh, hereby declare as follows-

I am employed by Green Welling, A Limited Liability Partnership, 235 Pine Street, 15th

Floor, San Francisco, California 94104. I am over the age of eighteen years and am not a party to

this action . On May 2, 2005, 1 served the within document(s) :

1 . NOTICE OF MOTION AND MOTION TO APPOINT THE LE GROUP ASLEAD PLAINTIFF AND FOR APPOINTMENT OF LEAD COUNSEL ;MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORTTHEREOF ;

Proof of Servic eCase No . C-5-0882-CRB 1

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2. DECLARATION OF ROBIN WINCHESTER IN SUPPORT OF MOTION TOAPPOINT THE LE GROUP AS LEAD PLAINTIFF PURSUANT TOSECTION 27 OF THE SECURITIES ACT OF 1933 AND TO APPROVEPLAINTIFF'S CHOICE OF COUNSEL ;

3. PROPOSED] ORDER APPOINTING THE LE GROUP AS LEAD PLAINTIFFAND APPOINTING LEAD COUNSEL ; and

4. PROOF OF SERVIC E

XX by electronic transmission of a Notice of Electronic Filing via the United States DistrictCourt, Northern District of California's Electronic Case File program the above listeddocument(s) to the email address(es) registered in the case on this date .

XX by placing the document(s) listed above for collection and mailing following the firm'sordinary business practice in a sealed envelope with postage thereon fully prepaid for depositin the United States mail at San Francisco , California addressed as set forth below .

SEE ATTACHED SERVICE LIS T

I declare under penalty of perjury under the laws of the State of California that the above

is true and correct, executed May 2, 2005, at San Francisco, California .

Kim O. Trinh

Proof of Servic eCase No. C-5-0882-CRB 2

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Leadis Technology, Inc.

Service List

Sean Handler, Esq .Schiffrin & Barroway, LLP280 King of Prussia RoadRadnor, PA 1908 7

Nancy Kulesa, Esq .Schatz & Nobel, PCOne Corporate Plaza20 Church StreetHartford, CT 06103

Paul Scarlato, Esq .Goldman Scarlato & Karon, PC1845 Walnut StreetPhiladelphia, PA 19103

Evan Smith, Esq .Brodksy & Smith, LLCTwo Bala Plaza, Suite 602Bala Cynwyd, PA 19004

Charles Piven, Esq .Law Office of Charles J . PivenThe World Trade Center - Baltimore401 East Pratt Street, Suite 2525Baltimore, NID 21202

Jack Fruchter, Esq .Abraham Fruchter & Twersky, LLPOne Pennsylvania Plaza, Suite 2805New York, NY 10119