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Lead Counsel respectfully submits that JNL’s work has added significant value for Settlement Class Members with respect to the proper Administration Process and protecting against distributing the Net Settlement Fund to potentially improper claimants.

In re Teva Securities Litigation

Memorandum in Support of Class Representatives

Motion for Initial Distribution of the Net Settlement Fund

CLASS ACTION LEGAL RESEARCH

UNDER AMENDED RULE 23, EFFECTIVE SETTLEMENT MANAGEMENT IS NOT JUST A GOOD IDEA, IT'S THE LAW

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The most recent amendments to Rule 23(e)(2)(C), which became effective on December 1, 2018 (the “2018 Amendments”), added new criteria that emphasize the importance that effective and proactive class action settlement management – the shepherding of a settlement from handshake to distribution – has on obtaining with as little delay as possible approval of class action settlements and of their distribution to class members, as well as on the payment to class counsel of their court-awarded attorneys’ fees. Under the interpretation that courts of appeals already have given to one new factor added by the 2018 Amendments – that fairness determinations must consider actual results of the claims process – district courts may decide to wait to rule on settlement fairness until administrations are sufficiently complete to provide for their consideration claims results.

CLASS ACTION LEGAL RESEARCH

"LOW COST" CLASS ACTION CLAIMS ADMINISTRATORS: WHAT YOU DON'T KNOW WILL HURT YOU

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As a direct result of inferior claims administrations performed by claims administrators selected based primarily on their low bids, “legitimate claimants” – those class action claimants that are class members and that submit proofs of claim that comply with judicially approved requirements – have suffered substantial financial harm and will continue to do so. Among claims administrators, there are substantial differences in accuracy and efficiency; those claims administrators that, to get selected, offer low bids cannot afford to, and, therefore, have not and will not, perform the tasks necessary to administer class action settlements accurately or efficiently. 

Notable Class Action Settlement Experience

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CLASS ACTION SPOTLIGHT

Cendant Corp.

$3.3 billion

In addition to prosecuting the action, Jeff designed the plan of allocation to address several complex issues — that plan of allocation withstood appeal to the third circuit — and established standards for the distribution of large class action settlement funds.

Securities Class Action

CLASS ACTION SPOTLIGHT

WorldCom

$6.2 billion

Jeff designed a methodology to allocate $6.2 billion of class action settlement funds to hundreds of thousands of class members which involved multiple defendants, multiple securities, and different claims.

Civil Litigation

CLASS ACTION SPOTLIGHT

Nortel Networks Corp.

$1.1 billion

Jeff negotiated the terms of settlement to address securities and tax issues internationally, which involved addressing the issues related to receiving in settlements a substantial amount of Nortel stock and distributing them to claimants.

Securities Fraud

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