LEAD PLAINTIFF FILINGS The New York State Common Retirement Fund, the nation's second-largest public pension fund, has been appointed to serve as Lead Plaintiff in the WorldCom Securities Litigation and in the Salomon Analyst WorldCom Litigation. Click on any of the below links to download a particular filing in Adobe Acrobat format. If you do not have Adobe Acrobat on your system and wish to install it, please click here. Complaints Memoranda of Law Letters Bankruptcy Proofs of Claim Bankruptcy: Objection to WorldCom's Disclosure Statement Complaints 12/01/03 - Corrected First Amended Class Action Complaint (WorldCom Securities Litigation) 08/01/03 - First Amended Class Action Complaint (WorldCom Securities Litigation) 10/11/02 - Class Action Complaint (WorldCom Securities Litigation) Memoranda of Law Lead Plaintiff’s Notice of Motion to Conduct a Second Distribution of the Net Settlement Fund [Proposed] Order Approving Lead Plaintiff’s Motion to Conduct a Second Distribution of the Net Settlement Fund Joint Declaration of Jeffrey N. Leibell and Jeffrey W. Golan in Support of Lead Plaintiff’s Motion to Conduct a Second Distribution of the Net Settlement Fund Affidavit of Shandarese Garr in Support of Lead Plaintiff’s Motion to Conduct a Second Distribution of the Net Settlement Fund Lead Plaintiff's Letter to Judge Cote Regarding Notice of Motion for Second Distribution of the Net Settlement Fund Proposed Order Approving Lead Plaintiff's Motion to Conduct an Initial Distribution of the Net Settlement Fund 11/21/06 - Lead Plaintiff's Notice of Motion to Conduct an Initial Distribution of the Net Settlement Fund 11/21/06 - Lead Plaintiff's Letter to Judge Cote Regarding Notice of Motion for Initial Distribution of the Net Settlement Fund 11/20/06 - Joint Declaration of John P. Coffey and Jeffrey W. Golan in Support of Lead Plaintiff's Motion to Conduct an Initial Distribution of the Net Settlement Fund 11/20/06 - Affidavit of Shandarese Garr in Support of Motion for Initial Distribution of the Net Settlement Fund and Supporting Exhibits 11/21/06 - Independent Accountant's Report on Applying Agreed-Upon Procedures 09/28/06 - Lead Plaintiff's Letter to Judge Cote Regarding Filing of Notice of Lead Plaintiff's Motion to Extend Termination Date of Third Party Claims Fund Attachments: > 09/28/06 - Notice of Lead Plaintiff's Motion to Extend the Termination Date of the Third Party Claims Fund Established Pursuant to the Class's Settlement with Bernard J. Ebbers > 09/28/06 - Declaration of Alan P. Lebowitz, General Counsel to the Comptroller of the State of New York, in Support of Extension of the Termination Date of the Third Party Claims Fund Established Pursuant to the Class's Settlement with Bernard J. Ebbers > 09/28/06 - Proposed Order Regarding Termination Date of the Third Party Claims Fund 09/01/05 - Lead Plaintiff's Letter to Judge Cote Regarding Filing of a) Reply Memorandum of Law in Further Support of Final Approval of Settlements with the Remaining Defendants, Lead Plaintiff's Plans of Allocation, Lead Plaintiff's Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses; and b)- Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey in Further Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation, Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses Attachments: > 09/02/05 - Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey in Further Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation, Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > 09/02/05 - Exhibits A, B & C to Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey > 09/02/05 - Exhibits D & E to Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey > 09/02/05 - Reply Memorandum of Law in Further Support of Final Approval of Settlements with the Remaining Defendants, Lead Plaintiff's Plans of Allocation, Lead Plaintiff's Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > 09/02/05 - (Proposed) Judgment Approving the Underwriter Settlements and Dismissing the Action Against the Settling Underwriter Defendants > 09/02/05 - (Proposed) Judgment Approving Settlement and Dismissing Action Against Bernard Ebbers 07/28/05 - Lead Plaintiff’s Letters to Judge Cote and Clerk of Court Regarding Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation and Awards for Attorneys Fees and Expenses Attachments: > 07/28/05 - Notice of Motion of Lead Plaintiff for Final Approval of Settlements with the Settling Defendants and Lead Plaintiff's Proposed Plans of Allocation > 07/28/05 - Notice of Motion of Lead Plaintiff for Final Approval of Lead Plaintiff's Proposed Supplemental Plan of Allocation > 07/28/05 - Notice of Motions of Lead Counsel for Awards of Attorney's Fees and Reimbursement of Expenses > 07/28/05 - Declaration of Jeffrey W. Golan and John P. Coffey in Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, Lead Plaintiff's Proposed Supplemental Plan of Allocation, and Lead Counsel's Requests for Awards of Attorneys' Fees and Reimbursement of Expenses Exhibits to Declaration: > Exhibit 1 - Declaration of Alan P. Lebowitz, General Counsel to the Comptroller of the State of New York, in Support of Final Approval of Settlements with the Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, Lead Plaintiff's Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > Exhibit 2 - Affidavit of Shandarese Garr, dated July 27, 2005 > Exhibit 2 - Part 2 > Exhibit 2 - Part 3 > Exhibit 3 - Mediators' Statement dated April 22, 2005 > Exhibit 4 - Notice of Proposed Settlements of Class Action With Settling Defendants and Bar Order Notice, dated July 1, 2005 > Exhibit 5 - WorldCom Securities Litigation, Time and Expense Chart, Inception through June 30, 2005 > Exhibit 6 - Check Register, WorldCom Litigation Fund, c/o Barrack Rodos & Bacine > 07/28/05 - Memorandum of Law in Support of Lead Plaintiff's Motion for Final Approval of Settlements with Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, and Lead Plaintiff's Proposed Supplemental Plan of Allocation > 07/28/05 - Memorandum of Law in Support of Lead Counsel's Requests for Awards of Attorneys' Fees and Reimbursement of Expenses > 07/28/05 - [Proposed] Order Approving Plans of Allocation With Respect to Settlements with the Underwriter Defendants > 07/28/05 - [Proposed] Order Approving Plans of Allocation With Respect to Settlements with the Director Defendants, Arthur Andersen LLP, Bernard Ebbers and Scott Sullivan > 07/28/05 - [Proposed] Order Approving Lead Plaintiff's Supplemental Plan of Allocation > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for an Award of Attorney's Fees Relating to Settlements with the Underwriter Defendants > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for an Award of Attorney's Fees Relating to Settlements with the Director Defendants and Arthur Andersen LLP > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for Reimbursement of Expenses 07/27/05 - Lead Plaintiff's Appellate Brief in Support of Citigroup Settlement 03/21/05 - Lead Plaintiffs Memorandum of Law in Response to Objections to Preliminary Approval of the Settlement Between Lead Plaintiff and Certain of the Director Defendants 03/14/05 - Lead Plaintiff's Memorandum of Law in Opposition to Certain Underwriter-Related Defendants' Motion for Reconsideration of This Court's Feb. 22, 2005 Order Concerning Lead Plaintiff's Motion in Limine No. 1 03/14/05 - Lead Plaintiff's Memorandum of Law in Response to Objection of J.P. Morgan Chase & Co., et al. to Preliminary Approval of the Settlements Between Lead Plaintiff and Other Underwriter Defendants 03/10/05 - Lead Plaintiff's Memorandum in Response to the Motion of Defendant Bernard Ebbers to Sever Claims Against Him Pursuant To F.R.C.P. 21 03/03/05 - Lead Plaintiff's Memorandum in Opposition to the Motion for Leave to Amend the Directors' Answer 02/25/05 - Supplemental Memorandum of Law Regarding Lead Plaintiff's Calculation of Section 11 Aggregate Damages 02/04/05 - Lead Plaintiff's Responses And Objections To The Underwriter-Related Defendants’ First Requests For Judicial Notice And Lead Plaintiff’s First Request For Judicial Notice 01/31/05 - Lead Plaintiff's Memorandum Of Law In Response To The Underwriter Defendants' And Andersen's Oppositions To The Lead Plaintiff's Pre-Trial Memorandum 01/28/05 - Lead Plaintiff's Memorandum In Opposition To The Underwriter Defendants' Supplemental Memorandum Of Law In Support Of Their Motion For Summary Judgment 01/28/05 - Declaration Of John P. Coffey In Support Of Lead Plaintiffs Opposition To The Underwriter-Related Defendants' Supplemental Memorandum Of Law In Support Of Their Motion For Summary Judgment 01/28/05 - Lead Plaintiff's Opposition To The Underwriter Defendants' Motion For Reconsideration Of Or, In The Alternative, To Clarify, The Court's December 15, 2004 Summary Judgment Order On The Issue Of Lead And Named PLaintiffs' Standing 01/21/05 - Lead Plaintiff’s Memorandum Of Law In Opposition To The Underwriter Defendants’ And Arthur Andersen LLP’s Motions In Limine To Exclude Certain Damages-Related Opinion Testimony Of Blaine F. Nye, Ph.D. 01/21/05 - Lead Plaintiff’s Memorandum Of Law In Response To The Underwriter Defendants’ Motions In Limine Nos. 1 – 8 And 10 01/21/05 - Lead Plaintiff’s Memorandum Of Law In Opposition To The Underwriter Defendants’ Motion In Limine No. 11 To Exclude Certain Testimony Of James F. Miller 01/21/05 - Lead Plaintiff’s Objections And Responses To The Underwriter Defendants’ Proposed Jury Instructions, Jury Interrogatories And Forms Of Verdict 01/21/05 - Declaration Of John P. Coffey In Support Of Lead Plaintiffs’ January 21, 2005 Filings (Exhibits A through KK attached) 01/21/05 - Declaration Of John P. Coffey In Support Of Lead Plaintiffs’ January 21, 2005 Filings (Exhibits LL through VV attached) 01/21/05 - Lead Plaintiffs Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude Evidence of the Restatement 01/21/05 - Declaration of Jeffrey W. Golan, With Exhibits, in Response to the Motion of Arthur Andersen LLP to Exclude Evidence of the Restatement 01/21/05 - Lead Plaintiffs Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude Evidence of the SIC Report, Interview Memoranda and the Bankruptcy Examiner’s Reports 01/21/05 - Lead Plaintiffs Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude Reference to any of Its Liability Insurance 01/21/05 - Lead Plaintiffs Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude Certain Testimony of Eugene Morse 01/21/05 - Lead Plaintiffs Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude KPMG’s Material Weakness Letter 01/21/05 - Lead Plaintiff's Memorandum of Law in Response to the Motion of Arthur Andersen LLP to Exclude Evidence of Andersen's Unrelated Conviction as Well as Its Current Business Status, Audit Work for Companies that Have Been or are the Subject of Litigation and/or Federal or State Investigation, and Settlements in Other Cases 01/21/05 - Declaration of Jeffrey W. Golan, With Exhibits, In Response to Motions of Arthur Andersen LLP to Exclude: (1) the SIC Report, Interview Memoranda, and the Bankruptcy Examiners Reports; (2) Reference to any of Its Liability Insurance; (3) Certain Testimony of Eugene Morse; (4) the KPMG Material Weakness Letter; and (5) Andersen’s Unrelated Convictions as Well as Its Current Business Status, Audit Work for Other Companies that Have Been or are the Subject of Litigation and/or Federal or State Investigation, and Settlement in Other Cases 01/21/05 - Lead Plaintiff's Response to Arthur Andersen LLP’s Requested Jury Instructions and Jury Interrogatories 01/21/05 - Lead Plaintiff's Response to Defendant Bert C. Roberts, Jr.’s Requested Jury Instructions and Jury Interrogatories 01/07/05 - Lead Plaintiff's Pre-Trial Memorandum 01/07/05 - Lead Plaintiff's Memorandum of Law in Opposition to the Underwriter Defendants' Motion to Phase the Trial and in Support of Its Motion in Limine No. 1: To Exclude Evidence Relating to the Individualized Issues of the Class Representatives from the Plenary Trial 01/07/05 - Lead Plaintiff's Motion in Limine No. 2: To Preclude Purported Lay Opinion Testimony that Falls Under Fed. R. Evid. 702 and Cumulative Expert Testimony 01/07/05 - Lead Plaintiff's Motion in Limine No. 3: To Preclude Purported Testimony of Randall Chafetz 01/07/05 - Lead Plaintiff's Motion in Limine No. 4: To Preclude the Defendants from Introducing Evidence Relating to Witnesses' Invocation of the Fifth Amendment 01/07/05 - Lead Plaintiff's Motion in Limine No. 5: To Preclude Defendants from Introducing Evidence Concerning an Alleged Conflict Regarding KPMG's Audit of the WorldCom Restatement 01/07/05 - Lead Plaintiff's Memorandum of Law in Support of Its Motion in Limine No. 6: To Preclude Defendants from Introducing the Criminal Indictments of Bernard Ebbers, Scott Sullivan, David Myers, Buford Yates, Troy Norman and Betty Vinson 01/07/05 - The Declaration of John P. Coffey in Support of the Various Motions Described Above 01/07/05 - Lead Plaintiff's Proposed Jury Instructions 01/07/05 - Lead Plaintiff's Proposed Examination of Prospective Jurors 01/07/05 - [Proposed] Joint Pre-Trial Order (Exhibit A attached) 01/07/05 - Exhibit B, Volume 1 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit B, Volume 2 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit C, Volume 1 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit C, Volume 2 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit C, Volume 3 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit C, Volume 4 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit D, Volume 1 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit D, Volume 2 to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit E to [Proposed] Joint Pre-Trial Order 01/07/05 - Exhibit F to [Proposed] Joint Pre-Trial Order 10/25/04 - Lead Plaintiff's Memorandum of Law in Opposition to Petition for Attorneys' Fees by Counsel for William H. Miller 10/22/04 - Reply Memorandum of Law in Support of Final Approval of Settlement with the Citigroup Defendants, Lead Plaintiff's Proposed Plan of Allocation, and An Award to Lead Counsel of Attorney's Fees and Reimbursement of Expenses 10/22/04 - Supplemental Declaration of Jeffrey W. Golan and John P. Coffey in Support of Final Approval of Settlement with the Citigroup Defendants, Lead Plaintiff's Proposed Plan of Allocation, and an Award of Attorney's Fees and Reimbursement of Expenses 10/08/04 - Lead Plaintiff’s Response To Motion Of Individual Action Liaison Counsel For An Order Awarding Fees And Expenses To Liaison Counsel From The Class Settlement Fund 10/01/04 - Lead Plaintiff's Reply Memorandum of Law In Response to Memoranda Filed by Defendants Arthur Andersen LLP's, Bert C. Roberts', and the Underwriter-Related Defendants in Opposition to Lead Plaintiff's Motion for Partial Summary Judgment 10/1/04 - Declaration of Mark R. Rosen in Support of Lead Plaintiff's Reply Memorandum of Law in Response to Memoranda Filed by Defendants Arthur Andersen, LLP, Bert C. Roberts, Jr. and the Underwriter-Related Defendants in Opposition to Lead Plaintiff's Motion for Partial Summary Judgment 09/30/04 - Lead Plaintiff’s Response Pursuant to Local Rule 56.1(b) to Defendant Bert C. Roberts, Jr.’s Statement of Material Facts not in Dispute 09/29/04 - Reply Report of Harris L. Devor (Amended Exhibit 5 attached) 09/24/04 - Notice of Motion of Lead Plaintiff for Final Approval of Settlement with the Citigroup Defendants and Lead Plaintiff's Proposed Plan of Allocation 09/24/04 - Memorandum of Law in Support of Final Approval of Settlement with the Citigroup Defendants and Lead Plaintiff's Proposed Plan of Allocation 09/24/04 - Notice of Motion of Lead Counsel for an Award of Attorney's Fees and Reimbursement of Expenses 09/24/04 - Memorandum of Law in Support of an Award to Lead Counsel of Attorney's Fees and Reimbursement of Expenses 09/24/04 - Joint Declaration of Jeffrey W. Golan and John P. Coffey in Support of Final Approval of Settlement with the Citigroup Defendants, Lead Plaintiff's Proposed Plan of Allocation, and an Award of Attorney's Fees and Reimbursement of Expenses 09/24/04 - Exhibits to Joint Declaration of Jeffrey W. Golan and John P. Coffey in Support of Final Approval of Settlement with the Citigroup Defendants, Lead Plaintiff's Proposed Plan of Allocation, and an Award of Attorney's Fees and Reimbursement of Expenses 09/24/04 - Declaration Of Alan P. Lebowitz, General Counsel To The Comptroller Of The State Of New York, In Support Of Final Approval Of Settlement With The Citigroup Defendants, Lead Plaintiff's Proposed Plan Of Allocation, And An Award Of Attorney's Fees And Reimbursement Of Expenses 09/17/04 - Lead Plaintiff's Memorandum of Law in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Lead Plaintiff’s Counter Statement of Material Facts Pursuant to Local Rule 56.1 09/17/04 - Lead Plaintiff’s Response Pursuant to Local Rule 56.1(b) to the Underwriter Defendants’ Statement of Material Uncontested Facts 09/17/04 - Declaration of Beata Gocyk-Farber in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 1-30 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 31-32 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 33-38 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 39-71 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 72-90 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 91-122 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 123-160 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Exhibits 161-175 to Declaration of Jennifer L. Edlind in Opposition to the Underwriter-Related Defendants' Motion for Summary Judgment 09/17/04 - Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion to Delineate the Class Period as Beginning on March 24, 2000 with Respect to Arthur Andersen LLP 09/17/04 - Memorandum of Law of Lead Plaintiff Alan G. Hevesi, Comptroller of the State of New York, as Administrative Head of the New York State and Local Retirement Systems and as Trustee of the New York State Common Retirement Fund, in Opposition to Motion For Summary Judgment of Defendant Bert C. Roberts, Jr. 09/17/04 - Declaration of Jeffrey W. Golan in Support of the Memorandum of Law of Lead Plaintiff Alan G. Hevesi, Comptroller of the State of New York, as Administrative Head of the New York State and Local Retirement Systems and as Trustee of the New York State Common Retirement Fund, in Opposition to Motion for Summary Judgment of Defendant Bert C. Roberts, Jr. (Exhibits 1-48 attached) 09/17/04 - Lead Plaintiff’s Response to Arthur Andersen LLP’s Statement of Material Facts Pursuant to Local Rule 56.1 09/17/04 - Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 09/17/04 - Declaration of Jeffrey W. Golan in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment (Rebuttal Report of Harris L. Devor and exhibits attached) 09/15/04 - Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment (Exhibits 1-20 attached) 09/15/04 - Exhibits 21-40 to Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 09/15/04 - Exhibits 41-80 to Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 09/15/04 - Exhibits 81-90 to Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 09/15/04 - Exhibits 91-126 to Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 09/15/04 - Exhibits 127-141 to Declaration of Jeffrey A. Barrack in Support of Lead Plaintiff’s Memorandum of Law in Opposition to Arthur Andersen LLP’s Motion for Summary Judgment 08/20/04 – Lead Plaintiff’s Notice of Motion And Local Rule 56.1 Statement In Support Of Motion For Partial Summary Judgment 08/20/04 – Lead Plaintiff’s Memorandum Of Law In Support Of Motion For Partial Summary Judgment 08/20/04 – Declaration Of John P. Coffey In Support Of Lead Plaintiff’s Motion For Partial Summary Judgment – Vol I 08/20/04 – Declaration Of John P. Coffey In Support Of Lead Plaintiff’s Motion For Partial Summary Judgment – Vol II 06/21/04 – Lead Plaintiff’s Response in Opposition to a Petition for a Writ of Mandamus Submitted by Certain Underwriter-Related Defendants and Arthur Andersen LLP (Second Circuit Court of Appeals) 06/21/04 – Appendix (Exhibits A-G) to Lead Plaintiff’s Response in Opposition to a Petition for a Writ of Mandamus Submitted by Certain Underwriter-Related Defendants and Arthur Andersen LLP (Second Circuit Court of Appeals) 06/21/04 – Appendix (Exhibits H-O) to Lead Plaintiff’s Response in Opposition to a Petition for a Writ of Mandamus Submitted by Certain Underwriter-Related Defendants and Arthur Andersen LLP (Second Circuit Court of Appeals) 06/04/04 – Reply Memorandum in Support of the Joint Motion by the SSB Defendants and Lead Plaintiff for Issuance of the Mandate of the May 11, 2004 Decision by the U.S. Court of Appeals for the Second Circuit (Second Circuit Court of Appeals) 05/17/04 - Joint Motion and Brief Filed by Lead Plaintiff and the SSB Defendants for Issuance of the Mandate of the May 11, 2004 Decision by the U.S. Court of Appeals for the Second Circuit (Second Circuit Court of Appeals) 04/16/04 – Brief of the Securities and Exchange Commission Regarding the Proper Interpretation of the Fraud-on-the-Market Presumption Under Section 10(b) of the Securities Exchange Act of 1934, Amicus Curiae (Second Circuit Court of Appeals) 04/12/04 – Lead Plaintiff’s Brief in Opposition to the Salomon Defendants’ Appeal Pursuant to Rule 23(f) (Second Circuit Court of Appeals) 03/15/04 - Lead Plaintiff's Response to the Underwriter-Related Defendants' Second Request for the Production of Documents (WorldCom Securities Litigation) 03/08/04 - Lead Plaintiff's Memorandum of Law in Opposition to Defendant's Motion to Modify the Pre-Trial Scheduling Order (WorldCom Securities Litigation) [Excerpts Redacted Pursuant to Court Order] 03/08/04 - Declaration of John P. Coffey in Support of Lead Plaintiff's Memorandum of Law in Opposition to Defendant's Motion to Modify the Pre-Trial Scheduling Order (WorldCom Securities Litigation) 02/13/04 - Lead Plaintiff’s Memorandum of Law in Opposition to the Motions to Dismiss Counts IV and V of the Corrected First Amended Complaint (WorldCom Securities Litigation) 01/14/04 - Lead Plaintiff’s Omnibus Memorandum in Support of the Motions of Individual Action Plaintiffs for Voluntary Dismissal (WorldCom Securities Litigation) 12/31/03 - Lead Plaintiff’s Memorandum of Law in Support of the Motion by the Metropolitan Government of Nashville and Davidson County, Tennessee to Voluntarily Dismiss Its Complaint Without Prejudice Pursuant To Rule 41(A)(2) (WorldCom Securities Litigation) 11/26/03 - Lead Plaintiff's Brief in Opposition to Petitions for Permission to Take Interlocutory Appeals Pursuant to Federal Rule of Civil Procedure 23(f) (Second Circuit Court of Appeals) 11/14/03 - Lead Plaintiff's Memorandum of Law in Opposition to the Salomon Defendants' Motion to Stay Merits-Based Deposition Discovery in this Action (WorldCom Securities Litigation) 11/07/03 – Lead Plaintiff’s Reply Memorandum of Law in Further Support of Motion for Leave to File a Corrected First Amended Complaint and Declaration of Steven B. Singer (WorldCom Securities Litigation) 11/04/03 - Lead Plaintiff's Memorandum of Law in Opposition to Milberg Weiss and in Further Support of Lead Plaintiff's Request for an Order Pertaining to Misleading Solicitations of Class Members (WorldCom Securities Litigation) 11/03/03 - Lead Plaintiff’s Response to Motion by SSB Defendants for a Leave to File an Oversized Petition in Support of Their Upcoming Application for an Interlocutory Review of Judge Cote’s October 28, 2003 Order Granting Class Certification (Second Circuit Court of Appeals) (WorldCom Securities Litigation) 10/17/03 – Lead Plaintiff’s Memorandum of Law in Opposition to the Audit Committee Defendants’ Motion to Dismiss the First Amended Complaint (WorldCom Securities Litigation) 10/15/03 - Lead Plaintiff’s Memorandum of Law in Opposition to the Underwriter Defendants' Motion to Strike (WorldCom Securities Litigation) 10/10/03 - Lead Plaintiff’s Memorandum of Law in Opposition to the Salomon Defendants' Cross-Motion for Certification of Appeal of the Court's Order Denying the Salomon Defendants' Motion to Dismiss (WorldCom Securities Litigation) 10/09/03 - Lead Plaintiff’s Response to Petition for Writ of Mandamus Re Consolidation Order (Second Circuit Court of Appeals) 10/09/03 - Lead Plaintiff’s Notice of Motion for Leave to File a Corrected First Amended Complaint and Memorandum of Law in Support of Motion (WorldCom Securities Litigation) 09/26/03 - Lead Plaintiff's Memorandum of Law in Response to Defendants' Opposition to Lead Plaintiff's Motion for Class Certification (WorldCom Securities Litigation) 09/26/03 - Exhibits Filed in Further Support of Lead Plaintiff's Memorandum of Law in Response to Defendants' Opposition to Lead Plaintiff's Motion for Class Certification (Volume One of Two) (WorldCom Securities Litigation) 09/26/03 - Exhibits Filed in Further Support of Lead Plaintiff's Memorandum of Law in Response to Defendants' Opposition to Lead Plaintiff's Motion for Class Certification (Volume Two of Two) (WorldCom Securities Litigation) 06/04/03 - Lead Plaintiff's Motion for Class Certification, Memorandum of Law in Support of Motion for Class Certification and Proposed Order (WorldCom Securities Litigation) 05/09/03 - Lead Plaintiff's Memorandum of Law in Opposition to Motions to Dismiss the Class Action Complaint of Defendants Andersen UK, Mark Schoppet and Andersen Worldwide SC (WorldCom Securities Litigation) 1/24/03 - Lead Plaintiff's Memorandum of Law in Opposition to Defendants' Motions to Dismiss the Class Action Complaint (WorldCom Securities Litigation) 12/10/02 - Lead Plaintiff's Memorandum of Law in Opposition to Salomon Smith Barney, Inc.'s Motion to Sever (WorldCom Securities Litigation) 11/20/02 - Lead Plaintiff's Reply Memorandum of Law re Motion to Lift the Discovery Stay (WorldCom Securities Litigation) 11/12/02 - Lead Plaintiff's Memorandum of Law re Motion to Lift the Discovery Stay (WorldCom Securities Litigation) 10/02/02 - Lead Plaintiff's Memorandum of Law re Motion for a Modification of the Automatic Stay (Bankruptcy Court) 07/01/02 - Memorandum of Law in Support of Motion for Appointment as Lead Plaintiff (WorldCom Securities Litigation) Letters 09/16/05 - Lead Plaintiff's Letter to Judge Cote in Response to Objection of Kenneth D. Laub to the Proposed Order Approving the Modified Supplemental Plan of Allocation Attachments: > 09/16/05 - Lead Plaintiff's Response to Objection of Kenneth D. Laub to the Proposed Order Approving the Modified Supplemental Plan of Allocation 09/13/05 - Notice of Filing of Lead Plaintiff's Letter to Judge Cote Regarding Submittal Modification of Supplemental Plan of Allocation and Additional Information Requested by the Court at Settlement Hearing on September 9, 2005 09/13/05 - Lead Plaintiff's Letter to Judge Cote Regarding Submittal Modification of Supplemental Plan of Allocation and Additional Information Requested by the Court at Settlement Hearing on September 9, 2005 Attachments: > 09/13/05 - TAB A - Graph - Price of WorldCom Group Stock (4/29/99-6/25/02) > 09/13/05 - TAB B - Graph - WorldCom Group Stock v. Competitor Stock (4/29/99-6/25/02) > 09/13/05 - TAB C - Graph - WorldCom Group Stock v. Competitor Stock (4/29/99-6/25/02) - (Indexed to $55.92 for comparative purposes) > 09/13/05 - TAB D - Chart - WorldCom Group Stock - Share Price and Volume Data (12/31/97-10/31/02) > 09/13/05 - TAB E - Chart - AT&T Stock Prices (4/29/99-6/25/02) > 09/13/05 - TAB F - Chart - Sprint Stock Prices (4/29/99-6/25/02) > 09/13/05 - TAB G - [Proposed] Order Approving the Modified Supplemental Plan of Allocation 09/08/05 - Lead Plaintiff's Letter to Judge Cote Regarding Ebbers Trust Assets 09/01/05 - Lead Plaintiff's Letter to Judge Cote Regarding Filing of a) Reply Memorandum of Law in Further Support of Final Approval of Settlements with the Remaining Defendants, Lead Plaintiff's Plans of Allocation, Lead Plaintiff's Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses; and b)- Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey in Further Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation, Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses Attachments: > 09/02/05 - Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey in Further Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation, Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > 09/02/05 - Exhibits A, B & C to Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey > 09/02/05 - Exhibits D & E to Supplemental Joint Declaration of Jeffrey W. Golan and John P. Coffey > 09/02/05 - Reply Memorandum of Law in Further Support of Final Approval of Settlements with the Remaining Defendants, Lead Plaintiff's Plans of Allocation, Lead Plaintiff's Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > 09/02/05 - (Proposed) Judgment Approving the Underwriter Settlements and Dismissing the Action Against the Settling Underwriter Defendants > 09/02/05 - (Proposed) Judgment Approving Settlement and Dismissing Action Against Bernard Ebbers 07/29/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Revisions to Notice of Settlements With Former WorldCom Executive Defendants Attachments: > 07/29/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants > 07/29/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants ("Blacklined" Draft Marked to Reflect Proposed Revisions of the Court Provided on July 29, 2005) 07/28/05 - Lead Plaintiff’s Letters to Judge Cote and Clerk of Court Regarding Motions for Final Approval of Settlements with Settling Defendants, Proposed Plans of Allocation and Awards for Attorneys Fees and Expenses Attachments: > 07/28/05 - Notice of Motion of Lead Plaintiff for Final Approval of Settlements with the Settling Defendants and Lead Plaintiff's Proposed Plans of Allocation > 07/28/05 - Notice of Motion of Lead Plaintiff for Final Approval of Lead Plaintiff's Proposed Supplemental Plan of Allocation > 07/28/05 - Notice of Motions of Lead Counsel for Awards of Attorney's Fees and Reimbursement of Expenses > 07/28/05 - Declaration of Jeffrey W. Golan and John P. Coffey in Support of Lead Plaintiff's Motions for Final Approval of Settlements with Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, Lead Plaintiff's Proposed Supplemental Plan of Allocation, and Lead Counsel's Requests for Awards of Attorneys' Fees and Reimbursement of Expenses Exhibits to Declaration: > Exhibit 1 - Declaration of Alan P. Lebowitz, General Counsel to the Comptroller of the State of New York, in Support of Final Approval of Settlements with the Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, Lead Plaintiff's Proposed Supplemental Plan of Allocation, and Awards of Attorney's Fees and Reimbursement of Expenses > Exhibit 2 - Affidavit of Shandarese Garr, dated July 27, 2005 > Exhibit 2 - Part 2 > Exhibit 2 - Part 3 > Exhibit 3 - Mediators' Statement dated April 22, 2005 > Exhibit 4 - Notice of Proposed Settlements of Class Action With Settling Defendants and Bar Order Notice, dated July 1, 2005 > Exhibit 5 - WorldCom Securities Litigation, Time and Expense Chart, Inception through June 30, 2005 > Exhibit 6 - Check Register, WorldCom Litigation Fund, c/o Barrack Rodos & Bacine > 07/28/05 - Memorandum of Law in Support of Lead Plaintiff's Motion for Final Approval of Settlements with Settling Defendants, Lead Plaintiff's Proposed Plans of Allocation, and Lead Plaintiff's Proposed Supplemental Plan of Allocation > 07/28/05 - Memorandum of Law in Support of Lead Counsel's Requests for Awards of Attorneys' Fees and Reimbursement of Expenses > 07/28/05 - [Proposed] Order Approving Plans of Allocation With Respect to Settlements with the Underwriter Defendants > 07/28/05 - [Proposed] Order Approving Plans of Allocation With Respect to Settlements with the Director Defendants, Arthur Andersen LLP, Bernard Ebbers and Scott Sullivan > 07/28/05 - [Proposed] Order Approving Lead Plaintiff's Supplemental Plan of Allocation > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for an Award of Attorney's Fees Relating to Settlements with the Underwriter Defendants > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for an Award of Attorney's Fees Relating to Settlements with the Director Defendants and Arthur Andersen LLP > 07/28/05 - [Proposed] Order Granting Lead Counsel's Motion for Reimbursement of Expenses 07/28/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Revisions to Notice of Settlements With Scott D. Sullivan, Buford Yates and David Myers Attachments: > 07/28/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants > 07/28/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants ("Blacklined" Draft Marked to Reflect Proposed Revisions Court Provided in July 28, 2005 Order) 07/27/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Settlements With Scott D. Sullivan, Buford Yates and David Myers Attachments: > 07/27/05 - [Proposed] Preliminary Approval Order Regarding Settlement with Buford Yates and David Myers (with revisions to July 26, 2005 version) > 07/27/05 - [Proposed] Preliminary Approval Order Regarding Settlement with Scott D. Sullivan (with revisions to July 26, 2005 version) > 07/27/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants > 07/27/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants ("Blacklined" Draft Marked to Reflect Proposed Revisions Court Provided in July 27, 2005 Order) > 07/27/05 - Email Correspondence Apparently Intended for Court Which Sent to the United States Attorney's Office and Forwarded to Lead Plaintiff 07/26/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Stipulations of Settlement With Scott D. Sullivan, Buford Yates and David Myers Attachments: > 07/26/05 - Stipulation of Settlement with Scott D. Sullivan > 07/26/05 - Stipulation of Settlement with Buford Yates and David Myers > 07/26/05 - Notice of Proposed Settlements of Class Action With Former WorldCom Executive Defendants 07/06/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Stipualtion of Settlement With Bernard J. Ebbers Attachments: > 07/06/05 - Stipulation of Settlement with Bernard J. Ebbers > 07/06/05 - [Proposed] Judgment Approving Settlement and Dismissing Action Against Bernard Ebbers > 07/06/05 - [Proposed] Order for Preliminary Approval Regarding Settlement with Bernard J. Ebbers 04/25/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Stipualtion of Settlement With Arthur Andersen 03/25/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Authenticity 03/24/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Roscitt Deposition, Sullivan Criminal Testimony, Renna Trial Deposition, Stipulations and Miscellaneous Issues 03/21/05 - Lead Plaintiff’s Letter to Judge Cote Enclosing Lead Plaintiff's Memorandum of Law in Response to Objection of J.P. Morgan Chase & Co., Et Al., to Preliminary Approval of the Settlements Between Lead Plaintiff and Other Underwriter Defendants 03/17/05 - Lead Plaintiff's Letter to Judge Cote Regarding Stipulations and Agreement of Settlements of Lead Plaintiff and Other Named Plaintiffs with Defendants J.P. Morgan Chase, Blaylock & Partners and Utendahl Capital Partners 03/17/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with Defendant J.P. Morgan Chase 03/17/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with Defendant Blaylock & Partners 03/17/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with Defendant Utendahl Capital Partners 03/15/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with Defendant Caboto Holding SIM S.p.A. 03/15/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with Defendants WESTLB AG, Mizuho International plc, BNP Paribas Securities Corp. and Mitsubishi Securities International plc 03/15/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiffs with ABN AMRO, Inc. 03/15/05 - Stipulation and Agreement of Settlement of Lead Plaintiff and Other Named Plaintiff with Deutsche Bank 03/15/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Handwritten Revisions to the Settlement Agreements with Defendants Banc of America Securities LLC, Fleet Securities, Inc., Lehman Brothers Inc., Credit Suisse First Boston LLC, Goldman, Sachs & Co., and UBS Warburg - Revisions Attached 03/15/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Dispute of Testimony of Richard Roscitt 03/14/05 - Lead Plaintiff’s Letter to Judge Cote Enclosing Lead Plaintiff's Memorandum of Law in Opposition to Certain Underwriter-Related Defendants' Motion for Reconsideration of This Court's Feb. 22, 2005 Order Concerning Lead Plaintiff's Motion in Limine No. 1 03/10/05 - Lead Plaintiff’s Letter to Judge Cote Regarding the Proposed Settlement with Defendant Deutsche Bank Securities Inc./Deutsche Bank Alex. Brown Inc., and a Joint Application on Behalf of Lead Plaintiff and Settling Defendant to Sever the Class' Claims Against the Settling Defendant - Memorandum of Agreement Attached 03/10/05 - Lead Plaintiff’s Letter to Judge Cote Regarding the Proposed Settlement with Defendants WestLB AG and Caboto Holding SIM S.p.A. and a Joint Application on Behalf of Lead Plaintiff and Settling Defendants to Sever the Class' Claims Against the Settling Defendants - Memoranda of Agreements Attached 03/10/05 - Lead Plaintiff’s Letter to Judge Cote Regarding the Proposed Settlement with Defendants Lehman Brothers, Inc., Credit Suisse First Boston LLC, Goldman, Sachs & Co., and UBS Warburg - Stipulation and Agreement of Settlement Attached 03/09/05 - Lead Plaintiff’s Letter to Judge Cote Regarding the Proposed Settlement with Defendants ABN AMRO Incorporated, Mitsubishi Securities International plc, BNP Paribas Securities Corp. and Mizuho International plc and a Joint Application on Behalf of Lead Plaintiff and Settling Defendants to Sever the Class' Claims Against the Settling Defendants - Memoranda of Agreements Attached 03/08/05 - Lead Plaintiff’s Letter to Judge Cote Regarding Pre-Trial Matters - Trial Hours, Peremptory Strikes, Class Representatives, J.P. Morgan Emails, Intermedia 03/04/05 - Lead Plaintiff's Letter to Judge Cote Regarding a Joint Application for an Order Severing the Class' Claims Against Defendants with Memo of Agreement 03/03/05 - Lead Plaintiff's Letter to Judge Cote Regarding the Proposed Settlement with the BOA Defendants and a Joint Application on Behalf of Lead Plaintiff and the BOA Defendants to Sever the Class' Claims Against the BOA Defendants 02/18/05 - Lead Plaintiff's Letter to Judge Cote Regarding Continuance and Other Pre-Trial Matters 02/07/05 - Lead Plaintiff's Letter to Judge Cote in Response to the Underwriter Defendants’ Motion to Adjourn Trial 02/03/05 - Lead Plaintiff's Letter to Judge Cote in Response to the Underwriter Defendants’ February 3, 2005 Letter Concerning, inter alia, Defendants’ Objections to Lead Plaintiff’s Trial Exhibit List 02/02/05 - Lead Plaintiff's Letter to Judge Cote re: Lead Plaintiff's Withdrawal of its Request for Preliminary Approval of the Stipulation of Settlement With the Settling Directors and Insurers 02/02/05 - Lead Plaintiff's Letter to Judge Cote Requesting that Underwriter Defendants Immediately Make Potential Witness Natalia Klykova of J.P. Morgan Available for Deposition 01/31/05 - Lead Plaintiff's Letter to Judge Cote in Response to Arthur Andersen's January 27, 2005 Letter Seeking to Prohibit Lead Plaintiff from Calling Live Witnesses at Trial 01/11/05 - Lead Plaintiff's Letter to Judge Cote in Response to Objections of Underwriter Defendants and Arthur Andersen to Lead Plaintiff’s Request to Sever the Class’ Claims Against the Settling Director Defendants from Claims Going to Trial in February 2005 01/07/05 – Joint Application Letter to Judge Cote and Stipulation of Settlement Between Lead Plaintiff and Director Defendants Clifford L. Alexander, Jr., James C. Allen, Judith Areen, Carl J. Aycock, Max E. Bobbitt, Stiles A. Kellett, Jr., Gordon S. Macklin, John A. Porter, Estate of John W. Sidgmore, Lawrence C. Tucker 11/01/04 - Lead Plaintiff's Letter to Judge Cote re: Objections of Defendants with Respect to Citigroup Settlement (enclosing copies of all objections received by Lead Counsel) 10/12/04 - Lead Plaintiff's Letter to Judge Cote re: Certain Issues Regarding the Pending Motions for Summary Judgment 09/28/04 - Lead Plaintiff's Letter to Judge Cote re: Upcoming Expert Depositions 06/07/04 - Lead Plaintiff's Letter to Judge Cote re: the Underwriter Defendants' Newly-Disclosed Due Diligence Participants 05/10/04 - Lead Plaintiff's Letter to Judge Cote Regarding a Joint Application on Behalf of Lead Plaintiff and the SSB Defendants re: (1) Severing the Class' Claims Against the SSB Defendants; (2) Allowing for a Three Week Suspension of All Discovery-Related Proceedings; and (3) Modifying Certain Pre-Trial Deadlines Set Forth in the Court's November 14, 2003 Scheduling Order (As Amended) 03/08/04 - Lead Plaintiff's Letter to Judge Cote re: Defendants' Over-Designation of Documents as "Confidential" 02/27/04 - Lead Plaintiff's Letter to Judge Cote re: Identification of Due Diligence Documents by Underwriter Defendants 02/26/04 - Lead Plaintiff's Letter to Judge Cote re: Timely Production of Certain E-mails by Underwriter Defendants 02/19/04 - Lead Plaintiff's Letter to Judge Cote in Response to Milberg Weiss's February 18, 2004 Letter re: the Extended Opt-Out Date 01/28/04 – Lead Plaintiff’s Letter to Judge Cote re: Proposed Discovery Coordination Order 01/15/04 - Lead Plaintiff's Letter to Judge Cote re: SSB Defendants' Production of Certain E-mails from Current and Former SSB Employees 12/15/03 - Lead Plaintiff's Letter to Judge Cote Responding to Milberg Weiss' December 4, 2003 Letter re: Coordination Between the Class and Individual Actions 12/08/03 - Lead Plaintiff's Letter to Judge Cote re Issues Concerning the Coordination of Depositions With Counsel for the Individual Actions 12/01/03 - Lead Plaintiff's Letter to Judge Cote re The Public and Private Pension Funds' Motion to Defer Consideration of Motions Directly Impacting Their Cases or Sending Class Notice Pending Resolution of the Remand Issue by the Second Circuit 12/01/03 - Lead Plaintiff's Letter to Judge Cote re Issues Arising From the Court's November 21, 2003 Order With Regard to the Contents of the Curative Notice 11/26/03 - Lead Plaintiff's Letter to Judge Cote re Issues Concerning Certain Underwriter Defendants' Proposed Schedule for Electronic Discovery 11/11/03 – Lead Plaintiff’s Letter to Judge Cote re Declaration of John Gentile Regarding Solicitations to Class Members 11/10/03 – Lead Plaintiff’s Letter to Judge Cote re SSB Defendants’ Production of Electronic Documents 11/10/03 – Lead Plaintiff’s Letter to Judge Cote re Issues Concerning Certain Underwriter-Related Defendants’ Production of Electronic Documents 11/10/03 – Lead Plaintiff’s Letter to Judge Cote re Defendants’ Upcoming Proposals to Modify the Proposed Plan for Deposition Discovery 10/29/03 - Lead Plaintiff's Letter to Judge Cote re Solicitations To Class Members 10/29/03 - Lead Plaintiff's Letter to Judge Cote Responding to Motions by the Government and Certain Defendants to Stay Discovery and Addressing Certain Issues Concerning the Deposition Schedule 10/24/03 - Lead Plaintiff's Letter to Judge Cote re: Proposed Deposition Schedule 06/25/03 - Lead Plaintiff's Letter to Judge Cote re In Response to Defendants' Request for Extension to File their Opposition to Lead Plaintiff's Motion for Class Certification 03/28/03 - Lead Plaintiff's Letter to Judge Cote re Consolidation of Individual Actions 03/21/03 - Lead Plaintiff's Letter to Judge Cote re Consolidation of Individual Actions 02/04/03 - Lead Plaintiff's Letter to Judge Cote re Status of Document Production from WorldCom, Inc. 01/21/03 - Lead Plaintiff's Letter to Judge Cote re Salomon Smith Barney Inc.'s Motion to Sever 12/19/02 - Lead Plaintiff's Letter to Judge Cote re Consolidation of Individual Actions 11/25/02 - Lead Plaintiff's Letter to Judge Cote re Salomon Smith Barney, Inc.'s Motion to Sever 11/22/02 - Lead Plaintiff's Letter to Judge Cote re Salomon Smith Barney, Inc.'s Motion to Sever 11/13/02 - Lead Plaintiff's Letter to Judge Cote re Motion to Lift the Discovery Stay 11/06/02 - Lead Plaintiff's Letter to Judge Cote re Motion to Lift the Discovery Stay Bankruptcy Proofs of Claim 01/21/03 - Class Proof of Claim (Stock Claim) 01/21/03 - Class Proof of Claim (Bond Claim) Bankruptcy: Objection to WorldCom's Disclosure Statement 05/13/03 - Lead Plaintiff's Objection to the Debtor's Disclosure Statement