Supplemental Affidavit of Jose C. Fraga 1 Master File No. 3:12- cv-05980 CRB

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

IN RE HP SECURITIES LITIGATION, This Document Relates To: All Actions

MASTER FILE NO. 3:12-CV-05980-CRB

CLASS ACTION SUPPLEMENTAL AFFIDAVIT OF JOSE C. FRAGA REGARDING (A) MAILING OF THE NOTICE AND PROOF OF CLAIM FORM; (B) REQUESTS FOR EXCLUSION; AND (C) PROOF OF CLAIM FORMS RECEIVED TO DATE Date: November 13, 2015 Time: 10:00 a.m. Judge: Hon. Charles R. Breyer Courtroom: 6, 17th Floor

STATE OF NEW YORK ) ) ss.: COUNTY OF NASSAU )

JOSE C. FRAGA, being duly sworn, deposes and says:

1. I am a Senior Director of Operations for Garden City Group, LLC (“GCG”)1,

headquartered at 1985 Marcus Avenue, Suite 200, Lake Success, New York 11042. I submit this

affidavit to supplement my Affidavit Regarding (A) Mailing of the Notice and Proof of Claim

Form; (B) Publication of the Summary Notice; (C) Requests For Exclusion Received to Date; and

(D) Proof of Claim Forms, dated September 29, 2015 (the “September 29, 2015 Affidavit”) that

was previously filed with the Court. See ECF No. 270-1. The following statements are based on

my personal knowledge and information provided to me by other GCG employees familiar with this

matter.

1 Please note that the Garden City Group, Inc. is now Garden City Group, LLC.

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Supplemental Affidavit of Jose C. Fraga 2 Master File No. 3:12- cv-05980 CRB

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MAILING OF THE NOTICE AND PROOF OF CLAIM FORM

2. As set forth in the September 29, 2015 Affidavit, as of September 28, 2015, GCG

disseminated an aggregate of 680,679 Claim Packets2 to potential Settlement Class Members and

nominees, which included 855 Claim Packets that were re-mailed as a result of updated addresses

provided to GCG by the U.S. Postal Service.3

3. Since the execution of the September 29, 2015 Affidavit, GCG has continued to

receive requests from potential Settlement Class Members and nominees for copies of the Claim

Packet. As a result, additional Claim Packets have been disseminated such that as of October 31,

2015, GCG has disseminated an aggregate of 809,607 Claim Packets to potential Settlement Class

Members and nominees by first-class mail or bulk mail. Of the total Claim Packets mailed to

potential Settlement Class Members and nominees, 13,600 were returned as undeliverable. The

809,607 Claim Packets disseminated include 2,119 Claim Packets whose original mailing was

returned as undeliverable by the U.S. Postal Service and that were re-mailed as a result of updated

addresses provided to GCG by the U.S. Postal Service or obtained through a NCOA search.4

4. In addition, as set forth in footnote 5 of the September 29, 2015 Affidavit, GCG was

notified by one of the nominees who supplied GCG with a file of names and addresses in

accordance with the Notice that the submitted list was provided in error, and 2,841 names and

addresses on that list were not potential Settlement Class Members.5 On October 2, 2015, GCG 2 Capitalized terms used and not otherwise defined herein shall have the meanings given to them in the Stipulation of Settlement and Release filed June 9, 2015 (ECF No. 258), and the September 29, 2015 Affidavit. 3 GCG also performs a National Change of Address (“NCOA”) search for those undeliverable Claim Packets returned without an updated address from the U.S. Postal Service. 4 It is GCG’s practice to mail out Claim Packets to as broad a group as reasonably possible to ensure that the Settlement Class receives proper notice of the Settlement. In addition, GCG has no control over the search parameters that nominees utilize in determining which of their beneficiaries actually purchased or acquired HP common stock during the Settlement Class Period, rather than merely holding HP common stock at any point in time. As a result, it has been GCG’s experience that some of the notice recipients are not actually eligible nor do they submit claims for a variety of reasons. 5 This nominee subsequently provided GCG with a corrected list containing names and addresses of 50,079 potential Settlement Class Members and GCG promptly mailed Claim Packets to these individuals and entities.

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Supplemental Affidavit of Jose C. Fraga 3 Master File No. 3:12- cv-05980 CRB

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mailed a letter to these 2,841 individuals to notify them that they were mailed the Notice in error

and that they are not part of the Settlement Class. A copy of this letter is attached hereto as Exhibit

1.

REQUESTS FOR EXCLUSION RECEIVED

5. The Notice informed potential Settlement Class Members that requests for exclusion

from the Settlement Class must be addressed to In re HP Securities Litigation Settlement, c/o GCG,

Claims Administrator, P.O. Box 10224, Dublin, OH 43017-5724, such that they are received no

later than October 14, 2015. GCG has monitored and will continue to monitor all mail delivered to

this P.O. Box.

6. As reported in the September 29, 2015 Affidavit, GCG received twelve (12) requests

for exclusion. Since that date, GCG has received sixteen (16) additional requests for exclusion

from the Settlement Class. Of these sixteen (16) additional requests for exclusion, twelve (12)

requests were received on or before the October 14, 2015 deadline and four (4) requests were

received after the October 14, 2015 deadline.6

7. In total, as of the date of this Affidavit, GCG has received a total of twenty-eight

(28) requests for exclusion from the Settlement Class, as set forth on Exhibit 2 hereto.

8. Four (4) of the twenty-eight (28) requests for exclusion did not include any

information regarding their transactions in HP common stock during the Settlement Class Period as

required by the Notice. Pursuant to the direction of Lead Counsel, GCG attempted to contact these

four individuals in order to obtain their transactional information. GCG contacted two of these

individuals by telephone and received the requested transactional information. For the two

individuals who could not be reached by telephone, GCG sent a letter advising them of the missing

transactional information and requesting that they provide this information. Copies of these letters

are attached hereto as Exhibit 3. To date, GCG has not received any additional information from

these two individuals.

6 Of the four requests for exclusion received after the October 14, 2015 deadline, two of these requests were received by GCG on October 15, 2015, mailed priority express mail with a postmark date of October 13, 2015.

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EXHIBIT 1

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In re HP Securities Litigation Settlement c/o GCG Claims Administrator P.O. Box 10224 Dublin, OH 43017-5724

FORWARDING SERVICE REQUESTED

TD Ameritrade - HP Stockholder – Retraction Communication for HP You were inadvertently sent a notice about the settlement of a pending class action litigation titled HP Securities Litigation, No. 3:12-cv-05980-CRB. You were sent this notice because your broker provided the administrator with a shareholder list containing some shareholders of Helmerich & Payne, Inc. (stock ticker symbol HP). The settlement reached in the HP Securities Litigation is only for eligible shareholders of Hewlett-Packard Company (stock ticker symbol HPQ). Since you are not an eligible shareholder of Hewlett-Packard Company, please disregard the previous notice. We apologize for any inconvenience this may have caused. Dated: October 2, 2015

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EXHIBIT 2

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In re HP Securities Litigation Settlement - Exclusion List

Count Name City, State, Country Date Received

1 Charles A. Hoefer Cedar Rapids, IA, US 08/25/2015

2 Ingeborg Schuster Dresher, PA, US 08/25/2015

3 Ronald L. Tooker San Diego, CA, US 08/28/2015

4 Märta Hage Kista, Sweden 09/08/2015

5 Gary L. Hemdal Burke, VA, US 09/08/2015

6 Andrew Malcom

George Clarke Nailsea, North Somerset, UK

09/03/2015

7 Patricia L. Von

Posch Little Neck, NY, US 09/21/2015

8 Agnes Blair Central Region, United Kingdom

09/22/2015

9 Steven J. Snider Newton, MA, US 09/24/2015

10 Shoichi Katayama Tokyo, Japan 09/24/2015

11 Joginder Diocee Winnipeg, Canada 09/25/2015

12 Robert L. & Ellen C.

Sprague Horseheads, NY, US 09/25/2015

13 Karen J. Beam Evans, CO, US 10/01/2015

14 John C. Wiley Kansas City, MO, US 10/02/2015

15 Paul Cumberlidge Belair, Australia 10/05/2015

16 Vira V. Haller Casper, WY, US 10/05/2015

17 Phoebe A. Dill Roanoke, TX, US 10/09/2015

18 Gregory D. Tolmachoff

Fresno, CA, US 10/13/2015

19 Sushovan Hussain Riverhead, Sevenoaks,

UK 10/13/2015

20 Gisbert Wolfram Ebersberg, Germany 10/13/2015

21 Walter R. & Karen

L. Egged Hardin, MT, US 10/13/2015

22 Rainer Weihrauch Salzgitter, Germany 10/13/2015

23 Cornell W. Affeldt San Clemente, CA, US 10/13/2015

24 Helena Smolova Praha, Czech Republic 10/13/2015

25 Chickasaw Foundation

Ada, OK, US 10/15/2015

26 Paul H. & Carrie L.

Higo Honolulu, HI, US 10/15/2015

27 Ruth Daniels Garden Grove, CA, US 10/19/2015

28 Vladimir Libkhen Brooklyn, NY, US 10/19/2015

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