Free Proposed Order - District Court of Delaware - Delaware

Case 1 :07-cv-00717-SLR Document 25 Filed O1/30/2008 Page 1 of 4 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE i
INTERNATIONAL BROTHERHOOD ) .
OF ELECTRICAL WORKERS LOCAL 98 ) I
PENSION FUND, )
I
Plaintiff, )
I
vs. )
I .
ANGELO R. MOZILO, HENRY G. ) CA No. 07 — 00372 "°""" (MPT) I
CISNEROS, ROBERT L. DONATO, ) ·
HARLEY W. SNYDER, JEFFREY M. ) _ 3
CUNNINGHAM, MARTIN R. MELONE, ) A
ROBERT T. PARRY, OSCAR P. ) Jury Trial Dcmauded
ROBERTSON, KEITH P. RUS SELL, ’ ) z
MICHAEL E. DOUGHERTY, and ) .
COUNTRYWIDE FINANCIAL )
CORPORATION, )
Defendants. g
I
a
ADAM BLUIVIBERG, )
. Plaintiff, )
I I
vs. . )
I
ANGELO R. MOZILO, HENRY G. ) CA N0. 07 »— 00717 *** (MPT)
CISNEROS, ROBERT L. DONATO, ) g
· HARLEY W. SNYDER, JEFFREY M. ) T
CUNNINGHAM, MARTIN R. MELONE, )
ROBERT T. PARRY, OSCAR P. ) Jury Trial Dcmanded ?
ROBERTSON, KEITH P. RUSSELL )
MICHAEL E. DOUGHERTY, DAVID ) _
SAMQBOL, KATPILEEN BROWN and I . I
COUNTRYWIDE FINANCIAL ) {
CORPORATION, )
I
Defe11da11ts. )

PROPOSED ORDER CONSOLIDATING RELATED
STOCKHOLDER DERIVATIVE ACTIONS

Case 1:07-cv-00717-SLR Document 25 Filed O1/30/2008 Page 2 of 4
In accordance with Fed. R. Civ. P. 42, it is hereby Ordered:
I. CONSOLIDATION
The above-captioned actions and all other stockholder’s derivative cases that relate to the
same subject matter that are subsequently filed in or transferred to this Court are hereby A
consolidated into one action (hereinafter, the "Consolidated Action") for all purposes, pursuant
to Fed. R. Civ. P. 42. This Order (the "Order") shall apply as specified to the Consolidated
Action and to each case that relates to the same subject matter that is subsequently filed in this
Court, removed, or transferred to this Court and is consolidated with the Consolidated Action. `
II. MASTER DOCKET AND MASTER FILES
I. A Master File is hereby established for this proceeding. This Master File shall be
Case No. 1:07-cv-00372 **"‘ (MPT). The Clerk shall file all pleadings in the Master File and
note such filings on the Master Docket.
2. An original of this Order shall be filed by the Clerk in the Master File, in Blumberg,
07—7l7, and in all related cases. I
III. CAPTION OF THE CASE *
_ Every pleading filed inthe Consolidated Action shall have the following caption:
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE I
IN RE COUNTRYWIDE FINANCIAL ) Master Docket No. l:07—cv—OO372°‘°*"‘ (MPT)
CORPORATION DERIVATIVE )
LITIGATION ) (Consolidated Action)
)
I .
TI—IIS RELATES TO ALL ACTIONS [or to) g
a particular case] ) Magistrate Judge Mary Pat Thynge i
l ]
(

Case 1:07-cv-00717-SLR Document 25 Filed O1/30/2008 Page 3 of 4
IV. NEWLY-FILED OR TRANSFERRED ACTIONS i
This Court requests the assistance of counsel in calling to the attention of the Clerk of this
Court the filing, removal, or transfer of any case that might properly be consolidated as part of _
the Consolidated Action.
VVhen a case that arises out of the same subject matter of the Consolidated Action is
hereinafter tiled in this Court, removed to this Couit, or transferred from another Court, the Clerk
of this Court shall:
l. File a copy of this Order in the separate tile for such action;
2. Mail a copy of this Order to the attorneys for the plaintiff(s) in the newly-filed, i
removed, or transferred case and to any new defendant(s) in the newly—filed, removed, or
transferred case; and
3. Make the appropriate entry in the Master Docket for the Consolidated Action.
Each new case that arises out of the subject matter of the Consolidated Action which is ·
filedinwthis Court, removed, or transferred to this Court, shall be consolidated with the
Consolidated Action and this Order shall apply thereto, unless a party objects to consolidation, as
provided for herein, or any provision of this Order, within 10 days after the date upon which a
copy of this Order is served on counsel for such party, by tiling an application for relief and this
Court deems it appropriate to grant such application.
VI. CONSOLIDATED COMPLAINT
Plaintiffs shall e—iile a Consolidated, Amended, and Supplemental Complaint (the
"Consolidated Complaint"). The Consolidated Complaint shall supersede all existing complaints
3

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tiled in the Consolidated Action. Service shall be effected with respect to any defendant named f
in any ofthe Consolidated Actions by e—tiling the Consolidated Complaint. E
SO ORDERED, this __ day of , 2008
A United States Magistrate Judge a
couwmy/coNsoLmArE -1
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