Pension Trust Fund For Operating Engineers v. DeVry Education Group, Inc. et al

Northern District of Illinois, ilnd-1:2016-cv-05198

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Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 1 of 39 PageID #:3005 Exhibit 6 Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 2 of 39 PageID #:3005 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PENSION TRUST FUND FOR OPERATING ENGINEERS, Individually and on Behalf of All Case No. 1: 16-CV-05198 Others Similarly Situated, Hon. Mary M. Rowland Plaintiff, V. DEVRY EDUCATION GROUP, INC., DANIEL HAMBURGER, RICHARD M. GUNST, PATRICK J. UNZICKER, AND TIMOTHY J. WIGGINS, Defendants. DECLARATION OF MARK R. MILLER ON BEHALF OF WEXLER WALLA CE LLP IN SUPPORT OF APPLICATION FOR AN A WARD OF ATTORNEYS' FEES AND EXPENSES I, MARK R. MILLER, declare as follows, pursuant to 28 U.S.C. §1746: 1. I am a partner of the law firm of Wexler Wallace LLP. I am submitting this declaration in support of my firm's application for an award of attorneys' fees and expenses in connection with services rendered in the above-entitled action (the "Action") from inception through October 15, 2019 (the "Time Period"). 2. My firm, which served as Liaison Class Counsel in the Action, was involved in various aspects of the litigation, such as drafting and/or revising motions and pleadings, appearing in court for case management conferences and to argue motions, participating in communications with the Court, and assisting Lead Counsel on issues of litigation and procedural strategy. 3. The information in this declaration regarding my firm's time and expenses is taken from time and expense records prepared and maintained by the firm in the ordinary course of business. These records (and backup documentation where necessary) were reviewed to confirm Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 3 of 39 PageID #:3005 both the accuracy of the entries as well as the necessity for and reasonableness of the time and expenses committed to the Action. The review also confirmed that the firm's guidelines and policies regarding expenses were followed. As a result of this review, reductions were made to time in the exercise of billing judgment. As a result of this review and the adjustments made, I believe that the time reflected in the firm's lodestar calculation and the expenses for which payment is sought are reasonable in amount and were necessary for the effective and efficient prosecution and resolution of the Action. In addition, I believe that the expenses are all of a type that would normally be charged to a fee-paying client in the private legal marketplace. 4. The schedule attached hereto as Exhibit A is a summary indicating the amount of time spent by attorneys and professional support staff members of my firm who were involved in the prosecution of the Action, and the lodestar calculation based on my firm's current hourly rates. For personnel who are no longer employed by my firm, the lodestar calculation is based upon the rates for such personnel in his or her final year of employment by my firm. The schedule was prepared from daily time records regularly prepared and maintained by my firm, which are available at the request of the Court. Time expended in preparing this application for fees and payment of expenses has not been included in this request. 5. The total number of hours spent on this Action reported by my firm during the Time Period is 67.50. The total lodestar amount for reported attorney/professional staff time based on the firm's current rates is $43,832.50. 6. The hourly rates for the attorneys and professional support staff of my firm included in Exhibit A are my firm's usual and customary hourly rates, which have been approved by Courts in other securities class action litigations. My firm's lodestar figures are based upon the firm's hourly rates, which do not include charges for expense items. Expense items are recorded separately and are not duplicated in my firm's hourly rates. -2- Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 4 of 39 PageID #:3005 7. As detailed in Exhibit B, my firm has incurred a total of $100.51 in expenses in connection with the prosecution of the Action. The expenses are reflected on the books and records of my firm. These books and records are prepared from expense vouchers, check records, and other source materials and are an accurate record of the expenses incurred. 8. With respect to the standing of my firm, attached hereto as Exhibit C is a brief biography of my firm as well as biographies of the firm's partners and of counsels. I declare under penalty of perjury that the foregoing is true and correct. Executed this 25th day of October, 2019. -3- Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 5 of 39 PageID #:3005 Exhibit A Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 6 of 39 PageID #:3005 Pension Trust Fund for Operating Engineers v. DeVry Education Group, Inc., et al. No. 01:16-cv-05198 (N.D. Ill.) EXHIBIT A LODESTAR REPORT FIRM: Wexler Wallace LLP REPORTING PERIOD: INCEPTION THROUGH OCTOBER 15, 2019 HOURLY PROFESSIONAL STATUS RATE HOURS LODESTAR Mark R. Miller P 750.00 47.10 $ 35,325.00 Bethany Turke P 750.00 0.20 $ 150.00 Amy E Keller A 485.00 10.90 $ 5,286.50 Adam Prom A 340.00 7.90 $ 2,686.00 Ashtin Otto PL 275.00 1.40 $ 385.00 TOTAL 67.5 $ 43,832.50 Partner (P) Staff Attorney (SA) Of Counsel (OC) Investigator (I) Associate (A) Paralegal (PL) Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 7 of 39 PageID #:3005 Exhibit B Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 8 of 39 PageID #:3005 Pension Trust Fund/or Operating Engineers v. DeVry Education Group, Inc., et al. No. 01:16-cv-05198 (N.D. Ill.) EXHIBIT B EXPENSE REPORT FIRM: Wexler Wallace LLP REPORTING PERIOD: INCEPTION THROUGH OCTOBER 15, 2019 CATEGORY TOTAL AMOUNT Long Distance Telephone/ Fax/ Conference Calls $8.40 Computer Research Fees $92.11 TOTAL $100.51 Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 9 of 39 PageID #:3005 Exhibit C Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 10 of 39 PageID #:3005 Pension Trust Fund for Operating Engineers v. DeVry Education Group, Inc., et al. No. 01:16-cv-05198 (N.D. Ill.) EXHIBIT C WEXLER WALLA CE FIRM RESUME Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 11 of 39 PageID #:3005 FIRM RESUME WEXLER WALLACE LLP 55 W. Monroe St. Suite 3300 II Chicago, IL 60603 Phone 312.346.2222 II Fax 312.346.0022 www.wexlerwallace.com II info@wexlerwallace.com WEXLER WALL.ACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 12 of 39 PageID #:3005 www. wexlerwa II ace.com Table of Contents The Firm 2 Leadership Positions ......................................................................... 4 Successes 7 Practice Areas and Representative Cases 10 Antitrust 10 Business and Commercial Litigation 12 Consumer Protection 13 Government Representation 13 Healthcare Litigation 14 Mass Torts 14 Securities and Corporate Governance 15 Whistleblower and False Claims 16 Our Professionals 17 Page 1 WEXLER. WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 13 of 39 PageID #:3005 www.wexlerwallace.com The Firm WHO WE ARE. Wexler Wallace LLP is nationally recognized as a leading firm in complex class action and multidistrict litigation, from investigation to trial and appeals, within the following legal areas: // Antitrust // Business and Commercial Litigation // Consumer Protection // Government Representation // Healthcare Litigation // Mass Torts // Securities and Corporate Governance // Whistleblower and False Claims WE WORK FOR ALL. At Wexler Wallace, we rely on the justice system to hold the powerful accountable for conduct that harms others. We are dedicated to protecting the rights and interests of all and, in this pursuit, represent shareholders, consumers, pension plans, institutional investors, businesses, governments, and organizations from all over the world. We act with the utmost integrity in our determination to achieve the most meaningful relief for our clients. WE GET RESULTS. Wexler Wallace is frequently retained by clients to pursue high-stakes litigation - often against some of the largest corporations represented by the most renowned law firms in the country. We regularly are asked by co-counsel to work with them and their clients on cases of wide-ranging importance. Through this work, we have helped shape the law and continue to pave the way for future successes for those aggrieved by fraud, antitrust violations, unfair competition, and other types of unlawful conduct. Page 2 WEXLER: WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 14 of 39 PageID #:3005 www.wexlerwallace.com OUR WORK IS RECOGNIZED. Wexler Wallace attorneys have been recognized by their peers as well as by legal organizations for their outstanding level of service and commitment to the firm's cases and clients. Partners Ken Wexler and Ed Wallace each have an AV Preeminent rating from Martindale-Hubbell - the highest peer review rating. Ken has been named an Illinois Super Lawyer since 2008, Ed was named a Super Lawyer in 2014 and 2015, and other attorneys have been named Rising Stars. Wexler Wallace was named a highly recommended Illinois litigation firm in the 2012 inaugural edition of Benchmark Plaintiff, with both partners named local litigation stars. The firm and its named partners have received the same honors every year since. "Despite a small roster of attorneys, (Wexler Wallace LLP) regularly goes toe-to-toe with some of the largest companies and corporations in the world." Benchmark Plaintiff, 201 2 11 11 wanted to express appreciation again to class 1 admire very much the work that you have 1 counsel for taking this case. I believe these are the done in this case, and you have taught me kind of cases Federal Courts should do and are something. I think I'm more knowledgeable appropriate for class resolution." and a better judge because I've had contact Hon. Patti B. Saris, In re Pharmaceutical Industry with you. And thank you very much." Average Wholesale Price Litig., MDL No. 1456, No. Hon. G. Patrick Murphy, Clancy-Gernon Funeral Ol -cv-12257-PBS (D. Mass.) (final settlement Homes, Inc. v. Merrill Lynch, Pierce, Fenner & hearing, with defendant GlaxoSmithKline, July 19, Smith, Inc., No. 09 Civ. 1 008 (S.D. Ill.) 2007) "[T]his multiplier is justified by the risk of non-recovery in this case and the need to reward counsel for their significant achievement on behalf of the End-Payor Class ... End-Payor Plaintiffs' counsel are highly experienced in complex antitrust class action litigation .... they have obtained a significant settlement for the Class despite the complexity and difficulties of this case." Hon. John R. Padova, Nichols v. SmithKline Beecham Corp., No. 00 Civ. 6222, 2005 U.S. Dist. LEXIS 7061, at *71 -72, 79 (E.D. Pa. Apr. 22, 2005) Page 3 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 15 of 39 PageID #:3005 ww w.wexlerw allace.com Leadership Positions Wexler Wallace is frequently appointed as lead counsel and to plaintiff steering committees in complex, high-stakes litigation. Some of those appointments include: CASE COURT APPOINTMENT In re Comcast Corp. Set-Top Cable Television Box E.D. Pa Co-Lead Counsel Antitrust Litigation, No: 2:09-MD-02034 Coordinated Essure® Litigation TBD Plaintiffs' Executive Committee Wolosyzn v. General Mills Inc., No: 0:16-cv-02869 D. Minn. Plaintiffs' Executive Committee In re Broiler Chicken Antitrust Litigation No. 16-cv-8637 N.D.111. Liaison Class Counsel Gibson v. The Quaker Oats Co., No. 1:16-cv-04853 N.D.111. Interim Liaison Class Counsel Edward Shapiro and Pacific Holistic Dental, INC., v. 3M D. Minn. Plaintiffs' Executive Committee Company, No. 0:16-cv-02606 Pension Trust Fund for Operating Engineers v. DeVry N.D.111. Interim Liaison Class Counsel Education Group, Inc., et al., No. 16-cv-05198 United Food and Commercial Workers Unions and D.C. Mass. Co-Lead Counsel Employers Midwest Health Benefits Fund, et. al. v. Allergan, PLC No.: 15-cv-12731 Lynch v. Motorola Mobility LLC et al., No. 1:16-cv-04524 N.D.111. Interim Co-Lead Class Counsel In re Windsor Wood Clad Window Products Liability E.D. Wis. Plaintiffs' Steering Committee Litigation, MDL No. 2688 In re VTech Data Breach Litigation, No. 1:15-cv-10889 N.D.111 Interim Liaison Class Counsel In re Nexium (Esomeprazole) Antitrust Litig., 12-md- D. Mass. Co-Lead Counsel 02409 In re: Fluidmaster, Inc., Water Connector Components N.D.111. Interim Liaison Class Counsel Prods. Liab. Litig In re Actos End-Payor Antitrust Litigation, Case No. 13-cv- S.D.N.Y. Interim Co-Lead Counsel 09244 Page 4 'WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 16 of 39 PageID #:3005 www.wexlerwallace.com CASE COURT APPOINTMENT Underwood v. I.F.F.A. Servs., No. 09-390-GPM; Clancy- S.D.II1. Lead Settlement Class Counsel Gernon Funeral Homes, Inc. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., No. 09-1008-GPM; Pettett Funeral Home, Ltd. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., No. 10-1000-GPM Celebrex Antitrust Litigation No: 14-cv-0395 E.D. Va Interim Co-Lead Class Counsel In re Suboxone Antitrust Litigation, MDL 2445 E.D. Pa. Interim Co-Lead Class Counsel In re Niaspan Antitrust Litigation, Case No. 13-md-02460 E.D. Pa. Interim Co-Lead Counsel In re Kugel Mesh Hernia Patch Products Liability D.R.I Plaintiffs' Steering Committee Litigation, MDL No. 1842 Levine v. American Psychological Association, Inc., Case D.D.C. Co-Lead Class Counsel No. 10-cv-01780 Roberts v. Electrolux Home Products Inc., Case No. 12-cv- C.D. Cal Co-Lead Class Counsel 1644 In re Skelaxin (Metaxalone) Antitrust Litigation, MDL No. E.D. Tenn. Plaintiffs' Executive Committee 2343 In re Effexor XR Antitrust Litigation, Case No. 11-cv-05661 D.N.J. Plaintiffs' Executive Committee In re Flonase Antitrust Litigation, Case No. 08-cv-3301 E.D. Pa. Plaintiffs' Executive Committee In re Prograf Antitrust Litigation, Case No. 11-cv-11870 D. Mass. Plaintiffs' Executive Committee In re Lipitor Antitrust Litigation, MDL No. 2332 D.N.J Interim Co-Lead Class Counsel Gomez v. PNC Bank, National Association No. 1:12-cv- N.D.111. Lead Class Counsel 1274 In re Wellbutrin XL Indirect Purchaser Antitrust Litigation, E.D. Pa. Co-Lead Class Counsel Case No. 2:08-CV-02433-MAM Carter v. Allstate Ins. Co., Case No. 02-CH-16092 Cir. Ct. Ill. - Co-Lead Counsel Cook County In re Webloyalty.com, Inc. Marketing and Sales Practices D. Mass. Co-Lead Counsel Litigation No.: MDL No. 1820 Page 5 WEXLER WALL.ACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 17 of 39 PageID #:3005 www. wex lerwa I lace.com CASE COURT APPOINTMENT In re C.R. Bard, Inc. Pelvic Repair Systems Products Multiple MDL Plaintiffs' Steering Committee Liability Litigation (MDL No. 2187); In re American Cases Medical Systems, Inc. Pelvic Repair Systems Products Liability Litigation (MDL No. 2325); In re Boston Scientific Corp. Pelvic Repair Systems Products Liability Litigation (MDL No. 2326); In re Ethicon, Inc. Pelvic Repair Systems Products Liability Litigation (MDL No. 2327) Levie v. Sears Roebuck & Co. et al, No. 1:04-cv-7643 N.D.II1. Liaison Class Counsel In re Medtronic, Inc. Implantable Defibrillators Products D. Minn. Plaintiffs' Steering Committee Liability Litigation, MDL No. 1726 I In re Pet Foods Products Liability Litigation, MDL No. 1850 D.N.J. Co-Lead Counsel New England Carpenters Health Benefits Fund v. First D. Mass. Co-Lead Class Counsel Databank, Case No. 1:05-CV-11148 In re BP Products North America, MDL No. 1801 N.D.1I1. Co-Lead Class Counsel In re Hypodermic Products Antitrust Litigation No.: MDL D.N.J Co-Lead Class Counsel No. 1730 In re Pharmaceutical Industry Average Wholesale Price D. Mass. Co-Lead Counsel Litigation, MDL No. 1456 Nichols v. SmithKline Beecham Corp., Case No. 2:00-CV- E.D. Pa. Co-Lead Class Counsel 06222-JP Virginia M. Damon Trust v. Mackinac Financial Corp., f/k/a W.D. Mich. Co-Lead Counsel North Country Financial Corp., Case No. 2:03-CV-0135 Stephen A. Ellerbrake and John E. Casey v. Campbell- Cir. Ct. Ill. - St. Co-Lead Counsel Hausfeld et al. No.: 01-L-540 Clair County Successes Page 6 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 18 of 39 PageID #:3005 www.wexlerwallace.com Since its founding in 2000, Wexler Wallace has achieved millions of dollars in settlements and savings for its clients and consumers. In cases in which the firm has served as Co-Lead Counsel, it has recovered over a billion dollars for its clients. Listed below are some of the firm's representative settlements and verdicts. SIGNIFICANT RECOVERIES AND VERDICTS CASE COURT RECOVERY Glenn Burton, JR. v. American Cyanamid CO., et al. E.D. Wis. $6M (jury verdict) - Case No. 07-cv-0303; Ravon Owens v. American Cyanamid CO., et al. - Case No. 07-cv-0441; Cesar Sifuentes v. American Cyanamid Co., et al. - Case No. 10-cv-0075 Barbara Kaiser et al v. Eth icon, Inc. et al., Case N.D. Ind. $35M (jury verdict) Number 2:17-cv-00114 The jury awarded $10M in injury compensation, as well as $25M in punitive damages. Jammal, et al. v. American Family Insurance, Case N.D. Oh Unanimous advisory jury verdict; No.: 13-cv-00437 Formal ruling and damages proceeding pending Huskey v. Ethicon, Case No. 12-cv-0521 S.D.W. Va. $3.27M (jury verdict) Roberts v. Electrolux Home Products, Inc., Case No. C.D. Cal. Settlement valued at more than 12-cv-01644 $35.SM In re Hypodermic Products Antitrust Litigation, D.N.J. $22M MDL No. 1730 New England Carpenters Health Benefits Fund v. D. Mass $350M settlement with McKesson; First Databank, Case No. 05-cv-11148 $2.7M with FDB and Medispan \ In re Pharmaceutical Industry Average Wholesale D. Mass. Multiple settlements totaling more Price Litigation, MDL No. 1456 than $350M In re Guidant Defibrillators Products Liability D. Minn. $195M Litigation, MDL No. 1708 Page 7 WEXLER WALL.ACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 19 of 39 PageID #:3005 ww w.w exlerw allace.com CASE COURT RECOVERY Underwood v. I.F.F.A. Servs., No. 09-390-GPM; S.D.II1. $41.15M Clancy-Gernon Funeral Homes, Inc. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., No. 09-1008- GPM; Pettett Funeral Home, Ltd. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., No. 10-1000-GPM In re Flonase Antitrust Litigation, Case No. 08-cv- E.D. Pa. $46M 3301 In re OSB Antitrust Litigation, Case No. 06-cv- E.D. Pa. $120M 00826 In re Air Cargo Shipping Services Antitrust E.D.N.Y. $85M Litigation, MDL. No. 1775 In re Pet Food Products Liability Litigation, MDL D.N.J. $24M No. 1850 In re Webloyalty.com, Inc. Marketing and Sales D. Mass. Allowed customers to recover up Practices Litigation, MDL No. 1820 to 100% of unauthorized charges In re BP Prods. North America, Inc. Antitrust N.D.111. $15.25M Litigation, MDL No. 1801 In re Medtronic Inc. Implantable Defibrillator D. Minn. $75M Products Liability Litigation, MDL No. 1726 Wington v. CB Richard Ellis, Inc., Case No. 02-cv- N.D.II1. A favorable settlement that made 6832 available monetary relief for eligible claimants, as well as a charitable contribution to the Commercial Real Estate Women Network In re Pressure Sensitive Labclstocl< Antitrust E.D. Pa. $'16.5M Litigation, MDL No. 1556 In re Synthroid Marketing Litigation, MDL No. 1182 N.D.I11. $87.4M Vista Healthplan, Inc. v. Bristol-Myers Squibb Co., D.D.C. $13SM settlement Case No. 01-cv-01295 Nichols v. Smithkline Beecham Corp. ("Paxil"), Case E.D. Pa. $65M No. 00-cv-6222 Page 8 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 20 of 39 PageID #:3005 www.wexlerwallace.com Page 9 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 21 of 39 PageID #:3005 www.wexlerwallace.com Practice Areas Wexler Wallace is a nationally-recognized leader in complex class action and multidistrict litigation, with a commitment to excellence and achieving meaningful relief for its clients. The firm's diverse litigation practice spans the areas of antitrust, business and commercial litigation, consumer fraud litigation, government representation, healthcare litigation, mass torts, securities and corporate governance, and whistleblower and false claims litigation. ANTITRUST Unfortunately, individuals and businesses sometimes violate the rules of our market-based system, imposing artificially inflated prices on market participants. Conduct prohibited by state and federal antitrust laws can take the form of illegally-maintained monopolies, price fixing, the improper exchange of competitive information, patent abuses, and other forms of unfair competition. Wexler Wallace is a leader in private antitrust enforcement, litigating a wide variety of class action cases involving many prominent industries, including the pharmaceutical, entertainment, service rental, lumber, energy, and electronic products industries. Representative cases in the firm's antitrust practice area include: IN RE BROILER CHICKEN ANTITRUST LITIGATION, 16-CV-8637 (N.D. ILL.) Wexler Wallace, along with co-counsel, filed this class action alleging that the nation's largest chicken producers {such as Tyson and Pilgrims) agreed with each other to limit the supply of broiler chickens, in order to raise the prices on chicken and chicken products. The Court appointed Wexler Wallace as Liaison Counsel on behalf of a class of restaurants {and institutions, such as prisons and nursing homes) that purchased the defendants' chicken from a wholesaler. The plaintiffs are seeking to recover damages suffered when they overpaid on purchases of the defendants' chicken. The defendants filed motions to dismiss the case, but in November of 2017 the Court denied those motions almost entirely, issuing a 92-page opinion. The parties are in the discovery phase of the case, which will last into 2019. FOREST RIVER FARMS V. MONSANTO COMPANY, NO. 4: 18-CV-00181 (E.D. MO.) Wexler Wallace and co-counsel filed this class action case against Monsanto in February 2018, alleging that Monsanto's rollout of genetically modified seeds that are resistant to the herbicide dicamba has created a distorted and monopolized market, manipulated by and susceptible to Monsanto's domination. Genetically-modified ("GM") crops and food are often touted to farmers and the public as miracle products. But when patented GM technology so changes the economics of agriculture that farmers have no choice but to use it, thus allowing biotech companies to charge monopoly prices and unfairly control the market, it is illegal conduct as alleged in the complaint. Monsanto knew that commercializing dicamba-resistant technology would cause a spike in the use Page l 0 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 22 of 39 PageID #:3005 www.wexlerwallace.com of dicamba, and conspired, agreed, and combined with other major biotech firms to unlawfully dominate the soy and cotton seed market. UNITED FOOD AND COMMERCIAL WORKERS UNIONS AND EMPLOYER$ MIDWEST HEALTH BENEFITS FUND, ET. AL. V. ALLERGAN, PLC NO.: 15-CV-12731 (D.C. MASS.) Wexler Wallace filed this case against Allergan in June 2015 on behalf of a putative class of end- payors alleging that Plaintiffs and all Asacol end-payors were harmed by defendants' conduct in engaging in an unlawful "product hop." Patients had always paid for the brand name version of Asacol. In July 2013, a generic version was planned for release on the market, but because of the defendant's withdrawal of the drug from the market, a generic version does not exist and consumers are still paying higher prices for similar brand name versions. Wexler Wallace was appointed co-lead counsel. The Hon. Judge Denise J. Casper of the United States District Court District of Massachusetts granted plaintiffs' motion for class certification and denied the defendants' motion for summary judgement. The First Circuit stayed the trial set to begin on January 22, 2018 pending the resolution of Defendants' appeal of the District Court's class certification decision. IN RE NEXIUM ANTITRUST LITIG., MDL NO. 2409 (D. MASS.) Wexler Wallace, along with co-counsel, filed this antitrust class action, alleging that defendant AstraZeneca entered into non-competition agreements with a number of generic pharmaceutical manufacturers in order to delay marketing entry of generic versions of its blockbuster drug Nexium. Starting in October 2014, Wexler Wallace participated in a six-week jury trial in the action; it was the first trial of a "reverse payment" antitrust action since the Supreme Court's Actavis decision. While the jury made several key findings in favor of the Plaintiffs, it ultimately returned a verdict in favor of defendants AstraZeneca and Ranbaxy. Plaintiffs have since moved for a new trial, and end- payor plaintiffs (represented by Wexler Wallace and others) have moved for injunctive relief. IN RE LIP/TOR ANTITRUST LITIG., MDL. NO. 2332 (D.N.J.) Wexler Wallace filed this class action against Pfizer Inc. and Ranbaxy Pharmaceuticals Inc., among others, seeking damages and equitable relief on behalf of end-payors of Lipitor and/or its generic bioequivalents for violations of antitrust and consumer protection laws. Plaintiffs allege that, among other things, defendants fraudulently procured a patent covering Lipitor and entered into an anticompetitive settlement with Ranbaxy in order to keep generic versions of the blockbuster drug off of the market. NICHOLS V. SMITHKLINE BEECHAM CORP. ("PAXIL"), NO. OO-CV-6222 (E.D. PA.) Wexler Wallace served as co-lead counsel in this case involving alleged efforts by GlaxoSmithKline, including "sham" patent litigation, to keep generic versions of Paxil off the market. This case is believed to be one of the first, if not the first, to allege misuse of patents to delay generic competition in a pharmaceutical market brought under Section 2 of the Sherman Act (rather than Section 1). The case settled for $65 million. IN RE EFFEXOR XR ANTITRUST LITIG., NO. 11-CV-5661 (D.N.J.) Page 11 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 23 of 39 PageID #:3005 www.wexlerwallace.com Wexler Wallace was appointed to the Indirect Purchaser Class Executive Committee in this antitrust litigation against pharmaceutical manufacturer Wyeth, Inc. regarding its antidepressant Effexor XR. The complaint alleges that Wyeth fraudulently obtained a number of method-of-use patents for Effexor XR and engaged in sham litigation against sixteen potential generic competitors in an effort to protect the Effexor XR monopoly. Plaintiffs further allege that Wyeth entered into an anticompetitive settlement with the first generic ANDA filer, Teva Pharmaceutical Industries, Ltd., and its US subsidiary Teva Pharmaceuticals USA, Inc., which delayed the entry of generic Effexor XR competitors for more than two years. For more information about the firm's Antitrust Litigation practice, please visit the firm's website, at http://www. wexlerwa I lace .com/practice-areas/ a ntitrust-1 itigatio n/. BUSINESS AND COMMERCIAL LITIGATION Confronting well-heeled and well-represented adversaries, Wexler Wallace attorneys represent businesses throughout the country in complex disputes ranging from breach of contract claims to business torts, including fraud, unfair competition, and breaches of fiduciary duty. The firm has represented small businesses on a contingency basis when those businesses were faced with litigating against larger adversaries that engaged in unfair and unlawful conduct. Although Wexler Wallace attorneys are always prepared to offer zealous advocacy for the firm's clients in state or federal courts, they also have employed creative approaches to successfully handle difficult cases through alternative dispute resolution such as mediation or arbitration. The firm's willingness to extend its services in cases that other firms are unwilling or unable to handle is just another testament to its commitment to positive change. For more information about the firm's Business and Commercial Litigation practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice- areas/business-commercial-litigation/. Page 12 'WEXLER WALLACE LLIP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 24 of 39 PageID #:3005 www.wexlerwallace.com CONSUMER PROTECTION Wexler Wallace is a national leader in prosecuting consumer protection claims on behalf of both businesses and individuals in state and federal courts throughout the country. The firm has successfully prosecuted cases involving, but not limited to: I I unlawful environmental dumping I I improper Internet "lead generation" practices II unfair billing practices of telecommunications companies II mislabeling of dietary supplements II the sale of defective drugs and household appliances II unfair payment policies of health insurance companies II false advertising by Internet service providers II deceptive practices of social networking sites II unlawful debt reduction scams For more information about the firm's Consumer Protection practice, including summaries of I representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice- areas/consumer-protection/. GOVERNMENT REPRESENTATION Our state, local, and federal governments are often victims of the same securities and healthcare frauds that are inflicted on businesses and individuals in the private sector. The government is an insurer through Medicare or Medicaid, and therefore overpays when brand name pharmaceutical manufacturers unlawfully suppress generic competition for their drugs. Similarly, government entities are investors with respect to their treasuries and pension plans. Thus, when false and misleading statements are issued by public companies, government entities are entitled to the same securities fraud damages that are available to private investors. Governments are also owed fiduciary duties in certain circumstances, and are often parties to multi-million-dollar contracts, the breach of which can result in significant damages. Wexler Wallace helps government entities recover the funds taken from them through the unlawful conduct of others. Ultimately, those funds belong to taxpayers, who are the intended beneficiaries of government services. Wexler Wallace believes that government officials have not only the right, but also the obligation, to try to recover these assets for their constituents. Page l3 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 25 of 39 PageID #:3005 ww w.wexlerw allace.com For more information about the firm's Government Representation practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice- a reas/govern ment-representatio n/. HEALTHCARE LITIGATION In the wake of ever-rising healthcare costs, Wexler Wallace is at the forefront of legal action being taken nationwide to challenge wide-ranging fraudulent and unfair conduct in the healthcare industry. Wexler Wallace has prosecuted claims for: // reporting of fraudulent pharmaceutical prices // failures to recall defective health devices // an industry-wide conspiracy to increase the prices of over 400 brand name drugs // the filing of baseless lawsuits and administrative actions to delay generic drug entry // a pharmacy's illegal substitution of more expensive versions of generic drugs Bringing claims under RICO, the antitrust laws, state consumer protection statutes, and more, Wexler Wallace has successfully prosecuted cases against some of the largest companies in the healthcare industry, including McKesson Corp., Becton Dickinson, AstraZeneca, GlaxoSmithKline, Abbott Laboratories, Bristol-Myers Squibb, Johnson & Johnson, and Bayer Corporation. Wexler Wallace's case against McKesson Corp. for manipulating the reimbursement benchmark for drug purchases resulted in one of the largest, if not the largest, RICO settlements ever. For more information about the firm's Healthcare Litigation practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice-areas/healthcare- litigation/. MASS TORT LITIGATION Wexler Wallace is a nationally-recognized leader in complex mass tort litigation involving defective drugs and medical devices that have injured hundreds or even hundreds of thousands of individuals. The firm investigates and aggressively pursues mass tort claims to promote industry-wide changes intended to benefit the public, prevent future lawsuits, and provide the maximum remedies under the law for those who have been harmed. The firm's lawyers and staff are intimately familiar with the nuances of this Page 14 WEXLER: WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 26 of 39 PageID #:3005 www.wexlerwallace.com complicated practice area and continually track the impact of new technological and scientific developments on mass tort litigation. To deepen the legal team's medical knowledge and resources and to support those clients who have suffered injuries, Wexler Wallace employs a full-time registered nurse with certification as a Legal Nurse Consultant {LNC). Debbie A. Pritts, RN, LNCC has over twenty-five years of experience and works directly with the firm's clients throughout each stage of the legal process. For more information about the firm's Mass Torts practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice-areas/mass-tort-litigation/. SECURITIES AND CORPORATE GOVERNANCE Over the last few years, we have learned all too well that lack of regulation and oversight can lead to corrupt corporate leadership, lack of transparency regarding the risks of significant investments, and the repeated securitization of the same bad investments. Wexler Wallace has committed its resources to helping pension plans, governments, and others recover assets lost a~ a result of the weakness of mortgage-backed securities, auction rate securities, credit swaps, derivative swaps, and overextended securities lending programs. Through its membership in the National Association of State Treasurers, and its increased involvement in institutional finance and investment conferences, Wexler Wallace has catapulted itself to the forefront of this area of litigation, seeking redress and the recovery of assets lost through gross negligence and breaches of fiduciary duties by those in whom institutional investors placed their trust and confidence. Securities litigation can often result in changes to corporate governance and policies designed to prevent future misconduct. Wexler Wallace believes the importance of this work cannot be overstated. The firm seeks to ensure that corporate officers and directors fulfill their responsibilities and provide full disclosure and transparency to those buying and selling securities, helping to ensure that our capital markets truly reflect the accurate information that should underlie every commercial transaction. For more information about thfl firm's Securities and Corporate Governance practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice- a reas/secu rities-corp-gove rna nee/ Page 15 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 27 of 39 PageID #:3005 www.wexlerwallace.com WHISTLEBLOWER AND FALSE CLAIMS LITIGATION Under the Federal False Claims Act and state law counterparts, private citizens or "whistleblowers" may sue on behalf of the government for fraud committed against it. This type of fraud costs taxpayers billions of dollars each year. If a case is successful, the government may be able to recover treble damages and civil penalties for each violation and the private citizen or "relater" can receive his or her attorneys' fees and costs, as well as a portion of the funds awarded by the court. Wexler Wallace is committed to seeing companies and individuals held responsible for fraud against the government and to representing private citizens willing to come forward and expose fraud. For more information about the firm's Whistleblower and False Claims Litigation practice, including summaries of representative cases, please visit the firm's website, at http://www.wexlerwallace.com/practice-areas/whistleblower-false-claims-litigation/. Page 16 WE.XLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 28 of 39 PageID #:3005 www.wexlerwallace.com Our Professionals Our legal team consists of professionals with a broad range of experiences and diverse backgrounds. Many of our lawyers serve as leaders in charitable institutions, teach at universities, and are members of national, state, and local bar associations. All of our professionals have earned the respect and admiration of our clients, judges, and co-counsel by the strength of their experience, diverse backgrounds, and overall commitment to excellence. OUR PARTNERS The partners of Wexler Wallace have been selected 15 times as "Super Lawyers" and "Rising Stars" in Illinois. Named partners, Kenneth A. Wexler and Edward A. Wallace, are each rated AV® Preeminent™ by Martindale-Hubbell, the highest rating in legal ability and ethics a lawyer can obtain. In addition, they have been named Illinois Local Litigation Stars by Benchmark Plaintiff every year since 2012. OUR ASSOCIATES Our associates hail from some of the top schools in the nation and have been recognized for outstanding academic achievement. As law students, Wexler Wallace associates served on the editorial boards of law reviews and journals, received academic honors, acted as student leaders, and participated in a variety of clinical programs to receive real-world legal experience before entering practice. Combined, our associates garnered 17 top of the class CALI awards for the highest grades in their courses and graduated with GPAs that placed them near the top of their respective law school classes. Page 17 WEXLER WALL.ACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 29 of 39 PageID #:3005 www.wexlerwallace.com KENNETH A. Kenneth A. Wexler, the founder of the firm, is a 1980 graduate of the WEXLER Georgetown University Law Center. He received a Bachelor of Arts degree in 1977, summa cum laude, from Washington University in St. Louis, MANAGER AND Missouri. FOUNDING PARTNER For over 30 years, Ken has devoted himself to helping those whose rights have been denied, or who have been victims of the unscrupulous or fraudulent actions of others, typically more powerful persons or entities. Founder of Wexler Wallace, Ken was also a founding partner of the firm formerly known as Miller Faucher Cafferty and Wexler LLP. He began his career and was a partner in the Chicago law firm now known as Much Shelist Dennen berg Ament & Rubenstein, PC. Ken has been in leadership positions in cases with far-ranging subject matters, including brand name manufacturer suppression of competition from generic drugs, fraudulent and deceptive product overcharges, discrimination and harassment, corporate waste and mismanagement, cost recovery for defective medical devices, false advertising, and government fraud. Ken's practice is devoted to complex class action and commercial litigation, which includes a substantial amount of health care litigation, claims brought under federal and state false claims statutes, and cases alleging violations of the securities and antitrust laws. At present, Ken is particularly focused on protecting issuers of municipal bonds, recovering losses for pension funds and other investors that were victimized by unlawful and improvident securities lending practices, and cost-recovery for victims of health care fraud, including Taft-Hartley Funds, self-insured employers, and government entities. Ken is a member of the Chicago Bar Association, Illinois State Bar Association, Federal Bar Association, American Bar Association, Chicago Council of Lawyers, American Association for Justice, and the Illinois Trial Lawyers Association. He is admitted to the bar in Illinois and is licensed to practice before the Illinois Supreme Court, United States District Court for the Northern and Southern Districts of Illinois, the United States Court of Appeals for the First, Second, Third, Sixth, and Seventh Circuits, and the United States Court of Appeals for the District of Columbia. With so many of the firm's cases pending in jurisdictions across the country, Ken has also been admitted to practice pro hac vice in United States District Courts of California, Connecticut, the District of Columbia, Florida, Maine, Maryland, Massachusetts, Minnesota, Missouri, New Jersey, New Mexico, New York, Page 18 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 30 of 39 PageID #:3005 www.wexlerwallace.com Ohio, Pennsylvania, South Dakota, Tennessee, Virginia, and Wisconsin. Along with bar activities, Ken is a fellow of The Roscoe Pound Institute and is a member of the American Constitution Society for Law and Policy, the Center for International Legal Studies, the National Association of State Treasurers, and the Executive Committee of the Civil Rights for the Anti- Defamation League. Ken also volunteers with the Chicago coalition for the Homeless and is a lifetime member of the 100 Club of Chicago. Page 19 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 31 of 39 PageID #:3005 www.wexlerwallace.com EDWARD A. Ed joined the firm in February 2000, a little over a month after its founding. WALLACE Since then, he has helped lead the firm to national prominence. He became a partner of the firm in 2003 and joined Ken Wexler as an equity PARTNER partner in 2006. Ed focuses his practice on large scale multi-party complex litigation, and has been asked to serve in leadership positions in numerous high-profile cases, including recent appointments in securities litigation and mass torts. In August 2014, Ed led a trial team that achieved the first verdict involving a transvaginal sling mesh (a device used to treat stress urinary incontinence) in federal court. Wexler Wallace, along with co-counsel, tried this defective mesh product case, securing a $3.27 million verdict for Plaintiff Jo Huskey, a 52-year-old woman who was implanted with the mesh in 2011. Ed has been critical in the development of the firm's mass tort practice, and, in the process, he has gained a national reputation for integrity, efficiency, strategic planning, understanding the relevant science, and achieving success. Ed's hard work led to his recognition as an Illinois Super Lawyer in 2014 and 2015, an award given annually to no more than 5 percent of lawyers in the state. Ed has an AV® Preeminent™ rating by Martindale-Hubbell, the highest rating a lawyer can obtain, indicating a very high to preeminent legal ability and exceptional ethical standards. Every year since its inaugural edition in 2012, Ed also has been named an Illinois Local Litigation Star by Benchmark Plaintiff. He is admitted to the bar in Illinois and is licensed to practice before the Illinois Supreme Court, the United States District Court for the Northern and Southern Districts of Illinois, the United States District Court for the Western District of Michigan, the United States District Court for the District of Colorado, and the United States Court of Appeals for the Third and Seventh Circuits. He also has been admitted pro hoc vice in many courts around the country. Ed is a member of the American Bar Association and is a former Consumer Protection Law Subcommittee Newsletter Co-Chair. He also is a member of the Chicago Bar Association, where he is a member of the Class Action Committee, the Illinois State Bar Association, the National Association of Shareholder and Consumer Attorneys, Public Justice, and the American Association for Justice ("AAJ"). Within AAJ, he belongs to the Commercial Page 20 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 32 of 39 PageID #:3005 www.wexlerwallace.com Law Section, the Product Liability Section, and the Section on Toxic, Environmental and Pharmaceutical Torts. At the AAJ's recent annual convention, Ed was re-elected co-chair for the Kugel Mesh Litigation Group. Ed is a 1995 graduate of DePaul University College of Law. He received a Bachelor of Arts degree in 1991 from Eastern Illinois University. Page 21 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 33 of 39 PageID #:3005 www.wexlerwallace.com KAR A A. E LG ER SM A Kara A. Elgersma is a 2000 graduate of Georgetown University Law Center, with Bachelor of Arts Degrees in English and History obtained from the PARTNER University of Kansas in 1997. Kara came to Wexler Wallace from K&L Gates LLP, where she was a partner. At K&L Gates, Kara was a member of the Antitrust and Trade Regulation Department, focusing on antitrust litigation, franchising and dealership disputes, class actions and other complex commercial litigation, as well as advising clients on a variety of regulatory matters, including antitrust, FCC, and energy regulatory policies. Kara's experience includes all aspects of complex commercial litigation. In addition, she is well-versed in arbitration, including pre-hearing case development and management, as well as the conduct of full hearings. For six months in 2004, Kara was "on loan" to Kraft Foods Global, Inc., Northfield, Illinois, where she directly assisted the Chief Litigation Counsel for the company and handled a wide variety of litigation matters, including small and large product liability claims, general commercial litigation, civil investigative demands, business subpoenas, labor and employment litigation, and bankruptcy matters; She is admitted to the bars of the Supreme Court of Illinois and Wisconsin, the District of Columbia Court of Appeals, the United States District Courts for the Northern District of Illinois, the District of Columbia, the District of Colorado and the Western District of Wisconsin, the United States Courts of Appeals for the Third, Fourth, Sixth, Seventh, and Tenth Circuits, and the Supreme Court of the United States. Kara is a member of the American Bar Association, the Illinois State Bar Association, and the District of Columbia Bar Association. She was a Board Member of the Competition Law360 Advisory Board for 2009 to 2010, and she was involved as a Board Member for Girls On The Run of Northern Virginia, as well as a volunteer with Chicago Volunteer Legal Services. Page 22 'WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 34 of 39 PageID #:3005 www. wex lerwa I lace.com MARK R. MILLER Mark R. Miller received his J.D. from Loyola University Chicago School of Law in 2004 after graduating from Central Michigan University with a PARTNER Bachelor of Science in History in 2001. Over the last decade, Mark has represented both plaintiffs and defendants in all phases of complex litigation-from the investigation and filing of the complaint through discovery, motion practice, class certification, summary judgment, and trial or settlement. Since joining Wexler Wallace in 2006, his practice has included handling a wide variety of consumer protection, antitrust, securities, banking regulation, business, and contractual class action cases. In addition to his background in commercial and consumer litigation, his practice has evolved to focus on products liability mass torts; and he has recently played pivotal roles in the jury trials of several mass tort MDL cases. His work in those cases included working with experts, taking fact and expert witness depositions, participating on bellwether trial teams, and drafting much of the briefing addressing complex discovery, pre-trial, and post-trial motions. In doing so, he has enhanced the firm's reputation and developed solid relationships with judges, co-counsel, and clients alike. Mark is admitted to the bar of the State of Illinois, the United States Court of Appeals for the First Circuit, and the United States District Courts for the Northern District of Illinois, Southern District of Illinois, and Eastern District of Michigan. BETH ANY R. TURKE Bethany R. Turke joined Wexler Wallace after practicing in the New York and Chicago offices of Latham & Watkins LLP. Bethany's practice at Latham PARTNER involved a wide range of civil and criminal litigation matters, including securities litigation, contract disputes, government investigations, and employment matters. She was also very active in Latham's pro bona practice, working tirelessly on behalf of clients facing various immigration, employment, and housing discrimination issues. Before joining Latham & Watkins, Bethany served as a law clerk to the Honorable Cheryl L. Pollak of the United States District Court for the Eastern District of New York. She received her J.D. from Harvard Law School in 2006. Bethany is actively involved on cases in a number of Wexler Wallace's practice specialties, including the firm's antitrust, healthcare, and Page 23 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 35 of 39 PageID #:3005 www.wexlerwallace.com consumer protection practice areas. Justin N. Boley's principal area of practice is complex class action litigation in antitrust matters. Since joining the firm, he has been heavily involved JUSTIN N. BOLEY with virtually all of the firm's pharmaceutical antitrust cases, including, among others: In re Nexium (Esomeprazole) Antitrust Litigation, In re PARTNER Wellbutrin XL Antitrust Litigation; In re Prograf Antitrust Litigation, In re Lipitor Antitrust Litigation, In re Effexor Antitrust Litigation, In re Androgel Antitrust Litigation, and In re Skelaxin (Metaxalone) Antitrust Litigation. He has also worked on antitrust cases involving price-fixing in international commodities markets and manipulation of benchmark interest rates, and he has taken the lead on investigations into the cartelization of the credit derivatives market and price-fixing among online travel sites and hotels. Justin came to the firm after attending school abroad and obtaining a Master's Degree in International Relations. During law school, Justin's focus on corporate law, finance, and complex litigation earned him numerous top-of-the-class academic honors; he was awarded CALI Awards in Antitrust, Contracts, Legal Analysis, Research, and Writing 111, Commercial Arbitration, Natural Resource Law, and Legal Profession (Ethics). Justin was a member of the Public Interest Law Committee at De Paul College of Law for three years. He also worked as a member of the New Media Team in President Obama's Presidential campaign headquarters in Chicago, where he helped facilitate the online organizing efforts of grassroots groups nationwide. Justin is admitted to the bar of the State of Illinois, Western District of Wisconsin, United State Court of Appeals, Seventh Circuit, and the United States District Court for the Northern District of Illinois. Page 24 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 36 of 39 PageID #:3005 www.wexlerwallace.com TIMOTHY E. Timothy E. Jackson began work at Wexler Wallace as a summer associate JACKSON while in law school. Tim received his J.D. from The Ohio State University Michael E. Moritz College of Law in 2010, where he was a Managing Editor ASSOCIATE on The Ohio State Journal on Dispute Resolution. He received his M.S. in Psychology from Tulane University in 2007 and his B.S. in Psychology from Tulane in 2006. Tim's primary practice areas at Wexler Wallace are medical device litigation, product liability law and mass tort litigation. TYLER J. STORY Beginning in law school, Tyler J. Story has focused his attention towards antitrust litigation. While a student at Pennsylvania State University, he ASSOCIATE held two antitrust research assistant positions: one in which he explored issues of indirect purchaser standing in state antitrust suits, the other in which he focused specifically on the application of antitrust law and economics in the pharmaceutical industry Since joining Wexler Wallace, Tyler has been actively involved in various aspects of litigation concerning brand name manufacturer suppression of competition from generic drugs. LAU R E N C. KAPLAN Lauren C. Kaplan joined Wexler Wallace in the fall of 2017, where she uses her experience in medical malpractice, professional negligence, and ASSOCIATE commercial litigation to assist with the firm's numerous mass tort cases. Lauren received a Bachelor's of Science in Public Affairs from Indiana University in 2011. Since receiving her J.D. from Chicago-Kent College of Law in 2014, Lauren has focused her career on helping clients who had been the victims of negligence, medical and professional carelessness, fraud, and similar legal disputes. Lauren has been deeply involved with all aspects of the legal process throughout her career. From co-drafting an Illinois Supreme Court brief to sitting second chair in a negligence trial that secured a multi-million dollar jury verdict, Lauren possesses a keen legal mind and a desire to seek justice Page 25 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 37 of 39 PageID #:3005 www.wexlerwallace.com for her clients. MICHELLE Michelle Perkovic's tenure at Wexler Wallace began in the Summer of PERKOVIC 2017, where she served as a law clerk while completing her legal degree. Michelle's impressive work and passion for helping clients left a lasting ASSOCIATE impression, making her a natural fit for the firm. Michelle returned to Wexler Wallace after graduating in the fall of 2018, where she lends her talents and passion to the firm's antitrust and mass tort litigation. Daniel P. Kelly has been involved with numerous aspects of legal work throughout his career. From drafting and preparing documents to serving DANIEL P. KELLY on trial teams, Daniel has a profound understanding of the role each facet ASSOCIATE plays in shaping the outcome of a case. Daniel joined Wexler Wallace in the fall of 2018, where his thoroughness and attention to detail is utilized in document review for the firm's antitrust, business, and securities cases. Daniel's first exposure to the world of high-stakes litigation began in 2012, when he served as a member of a trial team during a seven-week, multi-count white collar federal criminal trial. Daniel worked closely with outside counsel to prepare expert witnesses for trial and created demonstrative exhibits summarizing evidence for use during opening arguments and testimony. Daniel received a Bachelor of the Arts degree in Political Science from Southern Illinois University Carbondale in 2005 and earned his Juris Doctor from the University of Chicago Law School in 2008. Daniel has previously volunteered for the Chicago Justice Project to improve public access to criminal justice related information. Umar Sattar is actively involved in the firm's class action, product liability, False Claims Act, and antitrust practice areas. Umar served as a member of the trial team that achieved a $6 million jury verdict in Burton v. American Cyanamid, et al in the Eastern District of Page 26 WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 38 of 39 PageID #:3005 ww w.wexlerwallace.com UMAR SATTAR Wisconsin. There, Umar was involved in legal briefing prior to and during the trial. Umar's contributions to the case involved drafting briefing on ASSOCIATE numerous dispositive motions, drafting directed verdict arguments, and working with expert witnesses. Umar continues to be involved in the case's post-trial briefing. Prior to joining Wexler Wallace in 2019, Umar served as a prosecutor in the Manhattan District Attorney's Office in New York City, where he tried numerous cases to verdict before judges and juries. Umar also led grand jury investigations in the areas of cybercrime, identity theft, and sex crimes. Debbie A. Pritts, R.N., LNCC is a Registered Nurse with more than 20 years of clinical experience in Oncology, Med-Surg, Endoscopy, Ambulatory/Outpatient Care, Orthopedics, Ophthalmic Laser, Home Health and Utilization Review. She has been certified in BLS (Basic Life Support), ACLS (Advanced Cardiac Life Support) and Chemotherapy DEBBIE A. PRITTS Administration. Debbie achieved the status as Legal Nurse Consultant Certified (LNCC) through the American Association of Legal Nurse LEGAL NURSE Consultants (AALNC) in November 2005. LNCC certification is designated CONSULTANT after successfully meeting the requirements through examination and experience that validate qualifications, knowledge, and practice in the field of legal nurse consulting. LNCC is the only legal nurse consulting credential recognized by American Association of Legal Nurse Consultants and accredited by the American Board of Nursing Specialties (ABNS). Debbie has experience in Product Liability, Medical Malpractice, Personal Injury, and Workers Compensation. Debbie is a member of the American Association of Legal Nurse Consultants and the West Virginia Upper Ohio Valley Chapter of the AALNC, presently serving as the chapter's president. She has been a Member of the Board of Directors since 2005, serving as a past Treasurer and is Chair of the Website Committee. Additionally she is a founding member of the WV Bar Association, Legal Nurse Consultant Section. She works directly with clients of Wexler Wallace, from the first time they contact the firm, through trial. Her expertise and passion for the Page 27 'WEXLER WALLACE LLP Case: 1:16-cv-05198 Document #: 154-6 Filed: 11/01/19 Page 39 of 39 PageID #:3005 www.wexlerwallace.com job has provided the firm's clients with the service they deserve. Page 28 WEXLER. WALLACE LLP