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NORTEL I SETTLEMENT

NORTEL I COURT DOCUMENTS



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• Nortel I Stipulation of Settlement
     •     Preliminary Order for Notice and Hearing (USDC SDNY) (Settlement Stipulation Exhibit A)
     •     Notice Plan (Settlement Stipulation Exhibit A-4)
     •     [Proposed] Order and Final Judgment (United States District Court)(Settlement Stipulation Exhibit B)
     •     Supplemental Agreement (Settlement Stipulation
Exhibit C)
     •     Preliminary Order for Notice and Hearing (Ontario Superior Court)(Settlement Stipulation Exhibit D)
     •     Preliminary Order for Notice and Hearing (Quebec Superior Court)(Settlement Stipulation Exhibit E)
     •     Preliminary Order for Notice and Hearing (British Columbia Supreme Court) (Settlement Stipulation Exhibit F)
     •     [Proposed] Final Order (Ontario Superior Court) (Settlement Stipulation Exhibit G)
     •     [Proposed] Final Order (Quebec Superior Court) (Settlement Stipulation Exhibit H)
     •     [Proposed] Final Order (British Columbia Supreme Court) (Settlement Stipulation Exhibit I)
• Nortel I US Complaint
• Nortel I Judge's Rulings
     •     Order on Class Certification -- Global Class -- Certified by US Court, Judge Berman (9/5/2003)
     •     Order Appointing Lead Plaintiff -- Global Class -- Order by US Court, Judge Berman (1/10/2002)
     •     Order Appointing Lead Plaintiff's Counsel -- Global Class -- Order by US Court, Judge Berman (2/1/2002)
     •     Decision Approving Settlement in Ontario and awarding Ontario Counsel's fees -- Ontario National Class -- in Nortel I and Nortel II in Ontario Court - Justice Winkler (1/18/2007)
     •     Decision / Reasons Approving Settlement in British Columbia and Awarding British Columbia Counsel's fees -- British Columbia Class -- Justice Groberman (1/19/2007)
     •     Order Approving Settlement in Quebec -- Quebec Class -- Justice Monast (1/31/2007)
     •     Decision and Order Approving Nortel I Settlement -- Global Class -- Judge Berman (12/26/2006)
     •     Order and Final Judgment Approving Nortel I Settlement, Plan of Allocation, US Counsel Fees -- Global Class -- Judge Berman (1/29/2007)
     •     Order Approving Settlement in Ontario and awarding Ontario Counsel's fees -- Ontario National Class -- in Nortel I in Ontario Court - Justice Winkler (1/18/2007)
     •     Order Approving Settlement in British Columbia and Awarding British Columbia Counsel's fees -- British Columbia Class -- Justice Groberman (1/19/2007)
• Nortel I Court Documents in Support of the Settlement, Plan of Allocation and Application for Attorney's Fees
     •     Joint Declaration of Sanford P. Dumain, Daniel B. Scotti and Murray Gold in Support of Proposed Class Action Settlement, Plan of Allocation, and Petition for an Award of Attorneys’ Fees and Reimbursement of Expenses
     •     Declaration Submitting for Filing a True Copy of the: Declaration of Heather Gavin, Chief Administrative Officer and Plan Manager of the Ontario Public Service Employees' Union ("OPSEU") Pension Plan Trust Fund, in Support of Final Approval of Settlement and Award to Counsel of Attorneys' Fees and Reimbursement of Expenses
     •     Joint Declaration of David C. Light, Managing Director of Duff & Phelps, LLC and Joseph E. Mullin, Assistant Vice President of WL Ross & Co. LLC, in Support of Final Approval of Settlement and Awards to Counsel of Attorney’s Fees and Reimbursement of Expenses
     •     Declaration of Jane D. Nettesheim in Support of Approval of Proposed Plan of Allocation for Proceeds of Settlement of Nortel I Action
     •     Affidavit of Neil L. Zola Regarding the Mailing of the Nortel I Settlement Notice and Proof of Claim Form
     •     Lead Plaintiff’s Memorandum of Law in Support of Final Approval of the Proposed Nortel I Class Action Settlement and Proposed Plan of Allocation
     •     Compendium of Affidavits or Declarations of Plaintiff Counsel in Support of Lead Plaintiff’s Counsel’s Motion for an Award of Attorneys’ Fees and Reimbursement of Expenses
     •     Memorandum of Law in Support of Plaintiff Counsels’ Application for an Award of Attorneys’ Fees, Reimbursement of Expenses and an Award to Lead Plaintiffs
     •     Lead Plaintiff's Reply Memorandum of Law In Further Support of Final Approval of Settlement, Plan of Allocation and Lead Counsel's Application for an Award of Attorneys' Fees and Reimbursement of Litigation Expenses
     •     Affidavit of David A. Isaac Regarding Exclusion Requests and Objections Received for Nortel I
     •     Declaration of Jeanne C. Finegan, APR
     •     Supplemental Affidavit of David A. Issac Relating to Late Exclusion Requests and Late Objections
     •     Affidavit of Randi Alarcon Collotta Relating to Additional Responses to Objections Filed
     •     Supplemental Affidavit of Randi Alarcon Collotta Relating to Additional Exclusions and Objections Filed
     •     Supplemental Affidavit Relating to Additional Exclusions and Objections
     •     Letter to Judge Berman dated December 5, 2006
     •     Supplemental Affidavit Relating to Additional Late Exclusions (Fifth GCG Report)
• Nortel I Canadian Settlement Documents
     •     Ontario Settlement Agreement dated June 20, 2006
     •     Ontario Agreement and Confirmation of Supplemental Agreement dated June 20, 2006
     •     Ontario Second Fresh as Amended Statement of Claim
     •     Certification Order of Justice Winkler dated June 27, 2006
     •     British Columbia Settlement Agreement dated June 20, 2006
     •     British Columbia Agreement and Confirmation of Supplemental Agreement dated June 20, 2006
     •     British Columbia Amended Statement of Claim
     •     Certification Order of Justice Groberman dated June 27, 2006
     •     Quebec Settlement Agreement Dated June 20, 2006
     •     Quebec Agreement and Confirmation of Supplemental Agreement dated June 20, 2006
     •     Ontario Notice of Motion

     •     Affidavit of Leslie Frohlinger

     •     Affidavit of Ron Giammarino
     •     Affidavit of Sakie Tambakos in Support of Ontario National Class Counsel Fees
     •     Affidavit of Sakie Tambakos in Support of Settlement Approval
• Nortel I Distribution Orders
     •     US Order
     •     British Columbia Order
     •     Ontario Order
     •     Quebec Order