In re Fannie Mae Securities Litigation

District of Columbia, dcd-1:2004-cv-01639

AFFIDAVIT re 436 Reply to opposition to Motion for Class Certification by KPMG by OHIO PUBLIC EMPLOYEES RETIREMENT SYSTEM, STATE TEACHERS RETIREMENT SYSTEM OF OHIO.

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UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA) In re Federal National Mortgage Association) MDL No. 1668 Securities, Derivative, and "ERISA" Litigation))) In re Fannie Mae Securities Litigation) Consolidated Civil Action.) No. 1:04-cv-1639 (RLJ)) DECLARATION OF JAMES R. CUMMINS IN SUPPORT OF LEAD PLAINTIFFS' REPLY MEMORANDUM OF LAW TO THE OPPOSITION TO CLASS CERTIFICATION FILED BY DEFENDANT KPMG LLP I, James R. Cummins, being duly sworn, hereby state as follows: 1. I am an attorney in the law firm of Waite, Schneider, Bayless & Chesley, Co., L.P.A., Lead Counsel for the Lead Plaintiffs in the above-captioned securities class action. I submit this declaration in support of Lead Plaintiffs' Reply Memorandum of Law to the Opposition to Class Certification filed by Defendant KPMG. 2. Attached as Exhibit A hereto is a true and accurate copy of the Distribution Plan submitted by the SEC to this Court on April 9, 2007 in the related matter of SEC v. Fannie Mae, Case No. 1:06-cv-00959 (D.D.C.) and subsequently approved by the Court. 3. Attached as Exhibit B hereto are true and accurate copies of excerpts from Morgan Stanley analyst Kenneth A. Posner's April 11, 2007 deposition. 4. Attached as Exhibit C hereto are true and accurate copies of excerpts from Lehman Brothers analyst Bruce W. Harting's April 12, 2007 deposition. 5. Attached as Exhibit D hereto is a true and accurate copy of Arthur R. Miller's June 11, 2007 Declaration in Support of Lead Plaintiffs' Proposed Class Period. Signed under penalty of perjury this 15th day of June 2007. S/s James R. Cummins James R. Cummins 2