Free Proposed Order - District Court of Delaware - Delaware

Case 1 :07-cv-00717-SLR Document 26 Filed O1/30/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE I
1N RE COUNTRY W IDE FINANCIAL ) Master Docket No. 1:07-cv-00372***(MPT)
CORPORATION DERIVATIVE )
LITIGATION ) (Consolidated Action)

)
THIS RELATES TO ALL ACTIONS ) Magistrate Judge Mary Pat Thynge

ORDER APPOINTING A LEADERSHIP STRUCTURE FOR PLAINTIFFS
In accordance with Fed. R. Civ. P. 42, it is hereby Ordered.:
ORGANIZATION OF PLAINTIFFS’ COUNSEL
The Lead Plaintiffs for the conduct of these consolidated actions are:
International Brotherhood Of Electrical Workers Local 98 Pension Fund and Adam Blumberg.
The Lead Plaintiff International Brotherhood Of Electrical Workers is the plaintiff in the initial
tiling in this stockholder derivative action on June 12, 2007 and has been, at all times,
represented by Barrack, Rodos & Bacine and Biggs and Battaglia.
The Lead Counsel for plaintiff for the conduct of these consolidated actions is:
Alexander Arnold Gershon
Regina M. Calcaterra
Gloria Kui
Barrack, Rodos & Bacine
1350 Broadway, Suite 1001
New York, New York 10018
Tel: (212) 688-0782
Fax: (212) 688-0783
Daniel E. Bacine
William J. Ban
Barrack, Rodos & Bacine

Case 1:07-cv-00717-SLR Document 26 Filed O1/30/2008 Page 2 of 3
Two Commerce Square
2001 Market Street Suite 3300
Pennsylvania, Pennsylvania 19103
Tel: (215) 963-0600
Plaintiffs’ Lead Counsel shall have authority to speak for plaintiffs in matters regarding
pre-trial procedure, trial, and settlement negotiations and shall make all work assignments in
such manners as to facilitate the orderly and efficient prosecution of this litigation and to avoid
duplicative or unproductive effort.
Plaintiffs’ Lead Counsel shall be responsible for coordinating all activities and
appearances on behalf of plaintiffs and for the dissemination of notices and orders of this Court.
No motion, request for discovery, or other pre-trial or trial proceedings shall be initiated or tiled
by any plaintiffs except through Plaintiffs’ Lead Counsel.
Plaintiffs’ Lead Counsel also shall be available and responsible for communications to
and from this Court, including distributing orders and other directions from this Court to counsel.
Plaintiffs’ Co-Lead Counsel shall be responsible for creating and maintaining a master service
list of all parties and their respective counsel.
Defendants’ counsel may rely upon all agreements made with any of Plaintiffs’ Lead
Counsel, or other duly authorized representative of Plaintiffs’ Lead Counsel, and such
agreements shall be binding on plaintiffs.
The Liaison Counsel for Plaintiffs for the conduct of these consolidated actions is:
Robert D. Goldberg
Biggs & Battaglia
921 North Orange Street
Wilmington, DE 19899
Tel: (302) 655-9677
Fax: (302) 655-7924
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Liaison Counsel is designated on behalf of all plaintiffs and in coordination with the Lead
Counsel to: (i) sign, tile, e—file, serve, receive and distribute all correspondence, motions,
pleadings and other documents concerning these cases; (ii) to communicate with the Court on
behalf of plaintiffs; (iii) assist Lead Counsel in resolving any questions or suggestions by the
Court or by any counsel for plaintiffs concerning pre—trial discovery, motions, interim appeals, or
the trial of the lawsuit; (iv) coordinate with Lead Counsel; (v) and perform such other functions
as may be expressly authorized by further order of this Court.
SO ORDERED, this __ day of , 2008
)
United States Magistrate Judge
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