844471.2

Lieff, Cabraser, Heimann & Bernstein, LLP

Responses To

The State Board of Administration of Florida’s Invitation to Negotiate –

Securities Litigation Counsel - Search to Update Pool of Law Firms

Services Questionnaire

Issue Date: October 19, 2009

Richard M. Heimann Lieff, Cabraser, Heimann & Bernstein, LLP 275 Battery Street San Francisco, CA 94111 Tel.: (415) 956-1000 Fax.: (415) 956-1008 Email: rheimann@lchb.com

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Lieff, Cabraser, Heimann & Bernstein, LLP (“LCHB”) submits the following responses to the Services Questionnaire set forth in Appendix I of the State Board of Administration of Florida’s Invitation to Negotiate – Securities Litigation Counsel – Search to Update Pool of Law Firms (the “ITN”). Per the instructions in the ITN, each question and request is duplicated herein and immediately precedes our respective answer or response thereto. A. Firm Background Information

1. Provide the full name of the firm, the address of the principal place of business, the name, phone number, and email of the primary contact, and the primary location from which the firm would provide legal services to the SBA. Attach a copy of the firm’s resume or brochure.

Lieff, Cabraser, Heimann & Bernstein, LLP (“LCHB”) maintains is principal office at 275 Battery Street in San Francisco, California. The principal LCHB contact for our response to the ITN is LCHB Partner and Chair of LCHB’s Securities and Financial Fraud practice, Richard M. Heimann (Telephone: (415) 956-1000, Email: rheimann@lcb.com). LCHB’s San Francisco and New York offices would be the primary locations from which LCHB would provide legal services to the SBA. For additional information, please see LCHB’s Firm Resume, attached hereto as Exhibit A.1

2. Briefly describe the firm, including the following information:

a. the year the firm was established;

LCHB was founded in 1972.

b. office locations, including the number of attorneys that are resident in each office;

In addition to our principal office in San Francisco, California, we also maintain offices in New York, New York and Nashville, Tennessee. We have 59 full-time lawyers, including three attorneys of counsel. In addition, we have seven contract attorneys who work on case specific matters. The number of resident attorneys (including of counsel attorneys and contract attorneys) in each of our offices is as follows: San Francisco - 46 attorneys; New York - 16 attorneys; and Nashville - four attorneys.

c. the firm’s ownership structure (include a chart detailing the structure);

LCHB is a California limited liability partnership comprised of 17 equity/owner partners. The following is a chart describing the percentage ownership of LCHB of each of our equity partners as of January 1, 2009: 1 We understand that the inclusion of our Firm Resume in our responses to the Services Questionnaire does not violate Section III.B. of the ITN with respect to references to attachments and the applicable page limitation.

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LCHB Equity Partner Percentage Ownership of LCHB

Elizabeth J. Cabraser 9.60%

Richard M. Heimann 9.60%

William Bernstein 8.55%

Joseph R. Saveri 7.85%

Donald C. Arbitblit 6.30%

Steven E. Fineman 8.30%

Robert J. Nelson 6.90%

Kelly M. Dermody 7.85%

Jonathan D. Selbin 7.35%

Barry R. Himmelstein 7.45%

Michele C. Jackson 4.50%

Michael W. Sobol 6.00%

David S. Stellings 6.25%

Kathryn E. Barnett 1.25%

Eric B. Fastiff 1.25%

Wendy R. Fleishman 0.50%

Joy A. Kruse 0.50%

d. the total number of employees by practice area and category, including the number of licensed lawyers, the number of partners and associates, the number of legal and other support staff, and the number of women and minorities by practice area and category;

LCHB is comprised of 191 employees, including 66 licensed lawyers (17 equity partners, 13 non-equity partners, three attorneys of counsel, 26 associates, and seven contract attorneys), and 125 support staff personnel. Of the firm’s 191 employees, 99 are women (12 partners, one attorney of counsel, 12 associates, six contract attorneys, and 68 support personnel), and 57 are minorities (9 associates, two contract attorneys, and 46 support personnel).

The firm has six practice areas, namely, Securities and Financial Fraud, Antitrust, Consumer Fraud, Employment (including discrimination, wage and hour and ERISA cases), Injury/Torts (including aviation, personal injury, automobile injury, environmental/toxic injury

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and mass tort cases) and Non-Injury Product Liability. The chart below describes the number of employees who work in each of our practice groups:2

Practice Area

No. of Partners

No. of Associates

No. of Attorneys Of Counsel

No. of Contract Attorneys

No. of Support Staff

No. of Women (Partners/Of Counsel/ Associates/Contract Attorneys/ Support Staff)

No. of Minorities (Partners/Of Counsel/Associates/Contract Attorneys/ Support Staff)

Securities and Financial Fraud

10 8 2 0 5 9 (4 Partners/1 Of Counsel/3 Associates /1 Support Staff)

4 (3 Associates/ 1 Support Staff)

Antitrust 8 10 0 2 6 9 (3 Partners/ 1 Of Counsel/ 3 Associates/1 Support Staff)

4 (3 Associates/ 1 Support Staff)

Consumer Fraud

13 8 0 0 1 8 (4 Partners/4 Associates)

2 (2 Associates)

Employment 5 11 0 0 1 14 (4 Partners/7 Associates/ 3 Support Staff)

5 (5 Associates)

Injury/Torts 17 6 0 0 2 9 (7 Partners/2 Associates)

3 (3 Associates)

Non-Injury Torts

11 7 0 0 3 7 (4 Partners/3 Associates)

4 (4 Associates)

e. a breakdown of the type of clients the firm represents, (e.g. public funds, corporate, endowments, etc.);

The firm represents a variety of clients, including public pension funds, municipalities, private institutional investors, Taft-Hartley funds, small- and medium-sized businesses, and individuals.

f. the year the firm first began securities litigation work; and

LCHB began its securities litigation practice in the mid-1970’s.

g. the number of attorneys that specialize in securities litigation.

In our Securities and Financial Fraud practice, there are 20 attorneys, including 10 partners, two attorneys of counsel, and eight associates, who specialize in securities litigation.

2 The chart accounts for the fact that many of our attorneys and support personnel work in more than one of the firm’s practice areas. In addition, certain LCHB employees are not assigned to any practice areas (e.g., word processors, librarians, service department staff members), and therefore, are not accounted for in the chart.

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3. In the past three years (as of the issuance date of this ITN), have there been any significant developments in your firm, including changes in ownership, a merger and/or substantial sale or purchase of assets/practice or restructuring?

There have been no material developments in ownership, personnel, business, or otherwise, at LCHB over the past three years other than the retirement of LCHB’s founding partner, Robert L. Lieff (who remains of counsel to the firm).

4. Do you anticipate any of the significant changes described in No. 3 above in

the future? If so, please describe.

We do not anticipate any significant changes described in No. 3 above in the future.

5. Identify any relevant special services the firm provides, particularly those that may not be offered by other law firms.

As described below, LCHB has extensive experience providing portfolio monitoring, advisory, and securities litigation services to institutional and other investors. We believe our experience and expertise will assist us in providing the services required by the State Board of Administration of Florida (the “SBA”).

a. Securities Portfolio Monitoring We provide investment portfolio monitoring services to institutional investors, including

numerous state, county and city public retirement systems and Taft-Hartley funds. We utilize Verteris Portfolio Litigation Monitoring Services to provide such services to our clients so that they (i) are advised if and when they have suffered securities portfolio losses due to fraud; (ii) are provided a legal and financial case evaluation in such circumstances, including an evaluation of different litigation choices if litigation is recommended; and (iii) may file proofs of claims in securities class cases that have been settled in which they have losses. We counsel our clients on their economic losses and recoverable economic damages in potential and pending securities actions. We also advise our clients on their litigation options, including whether they should seek lead plaintiff status in federal securities class litigation or bring their own, independent action.

As part of our portfolio monitoring services, we work with numerous custodians to obtain and transmit investment portfolio data and in the analysis of our clients’ investment losses under various accounting methodologies. LCHB provides quarterly portfolio investment reports and also provides client data access through a web-based interface. These services assist clients in assessing claims and calculating potential damages. Upon request we will review a client’s proofs of claim in securities case class settlements as prepared by their custodian to verify accuracy.

We provide portfolio monitoring and related advisory services to our clients at no charge. To the extent that a client does not require our monitoring services, but nevertheless would like

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to be apprised of meritorious cases and receive our evaluations of such cases, we also provide this service at no charge.

b. Securities Case Evaluation

We also have extensive experience providing securities case evaluation services to our institutional investor clients, including providing them with comprehensive memoranda setting forth our evaluation and recommendations with respect to securities fraud actions. For example, we routinely provide such evaluation memoranda to the following public and private institutional investors: Alaska Permanent Fund Corporation; Retirement Systems of Alabama; California State Teachers’ Retirement System; The Employees’ Retirement System Of the State of Hawaii; Maine Public Employees Retirement System; State Retirement and Pension System of Maryland; Minnesota Attorney General’s Office; Public Employees’ Retirement System of Mississippi; New York State Common Retirement Fund (“NYSCRF”); New York State Teachers’ Retirement System; New York City Pension Funds; State of Ohio, Office of the Attorney General; Washington State Investment Board, Office of the Attorney General of the State of Washington; Los Angeles County Employees Retirement Association; Sacramento County Employees’ Retirement System; Fire and Police Pension Association of Colorado; Denver Employees Retirement Plan; San Francisco Employees Retirement System; City of Boca Raton Police and Fire Fighters Retirement System; New York City Pension Funds; Regents of the University of California Retirement Plan; BlackRock Funds, Inc.; Nuveen Funds; Amalgamated Bank; Bricklayers Local No. 55 Pension Plan; I. B. E. W. Local 32 – N. E. C. A. Pension Plan; New York City Plumbers’ Local No. 1 Trust Funds; and Plumbers and Pipefitters Local No. 166 (Fort Wayne, Indiana), Pension and Retirement Plan.

Recently, we have provided case evaluation memoranda to our clients regarding their potential involvement in securities actions involving Eli Lily & Co., Countrywide Financial, Bear Stearns, Citigroup, Lehman Brothers, Merck & Co., Inc., Bank of America/Merrill Lynch, and Merrill Lynch (mortgage pass-through certificates).

In addition, LCHB was recently retained by several Ohio state pension funds to serve as Co-Lead Counsel and to investigate and file claims on behalf of the funds against major credit ratings agencies. Moreover, we have also recently been retained by NYSCRF to serve as Co-Counsel in investigating and bringing potential claims to recover NYSCRF’s losses in connection with its investments in publicly traded companies involved in the subprime mortgage finance industry.

For additional information regarding LCHB’s securities case evaluation services, please

see Section B.6. herein.

c. Securities Litigation

LCHB has significant experience and expertise in providing securities litigation services to our institutional and individual investor clients. We have been successful in recovering our clients’ assets in a variety of securities actions, including securities fraud class and individual actions and shareholder derivative actions, several of which were resolved through mediation

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with individual and corporate defendants, and/or their insurers or after multi-week trials conducted by LCHB attorneys.

The following is a description of cases that are representative of LCHB’s securities litigation experience:

• In re Tyco International, Ltd. Securities, Derivative & “ERISA” Litigation, MDL

No. 1335 (D.N.H.) (“Tyco”). LCHB filed individual, opt-out securities fraud actions on behalf of over 30 BlackRock funds (approximately $11.8 billion in assets/$1.1 trillion under management) and four Nuveen mutual and investment funds (approximately $336 million in assets/$162 billion under management) alleging violations of federal securities laws and state law. The Tyco litigation recently settled for a confidential amount. Our clients recovered many multiples more in the individual actions than they would have received in the settlement of the class litigation against Tyco.

• In re Brooks Automation, Inc. Securities Litigation, No. 06-11068-RWZ (D. Mass.) (“Brooks”). LCHB served as Lead Counsel for Lead Plaintiff Los Angeles County Employees Retirement Association (“LACERA”) (approximately $38.2 billion in assets) and additional class representative Sacramento County Employees’ Retirement System (“SCERS”) (approximately $4.4 billion in assets) in securities fraud class litigation arising under the Securities Exchange Act of 1934 (the “Exchange Act”) concerning the backdating of stock options. The action settled in 2008 for $7.75 million, representing approximately 34 percent of total losses suffered by the class.

• In re Qwest Communications International, Inc. Securities and “ERISA” Litigation, No. 06-cv-17880-REB-PAC (MDL No. 1788) (D. Col.) (“Qwest”). LCHB represented the NYSCRF (approximately $109 billion in assets), the Fire and Police Pension Association of Colorado (“FPPAC”) (approximately $2.6 billion in assets), the Denver Employees Retirement Plan (“DERP”) (approximately $1.5 billion in net assets), the San Francisco Employees Retirement System (“SFERS”) (approximately $15.8 billion in net assets), and more than 30 BlackRock mutual funds (more than $22 billion in assets) in individual, opt-out securities fraud actions. Late in 2006, all Qwest opt-out actions, including cases brought on behalf of LCHB’s clients, were settled; the cases brought on behalf of LCHB’s clients were settled prior to an adjudication of defendants’ motions to dismiss and for amounts in significant excess of what they would have recovered in the class case against Qwest. For instance, NYSCRF’s specific recovery in this settlement was $50,969,514.37 on $235.7 million of estimated losses and $98.5 million of estimated damages (under the federal securities laws). In addition, under the settlement, NYSCRF recovered an additional amount equal to LCHB’s lodestar and costs (just under $1 million) incurred on NYSCRF’s behalf. The total recovery for NYSCRF is approximately $49.7 million more than the amount NYSCRF would have received had it participated in the class settlement. In total, our clients recovered more than $85 million, representing approximately 80 percent of their estimated damages.

• In Re Broadcom Corp. Derivative Litigation, No. C-06-3252 R (CWx) (C.D. Cal.) (“Broadcom”). LCHB serves as Lead Counsel in this derivative case involving more than $2.2 billion of allegedly unlawfully backdated stock options. Plaintiffs successfully defeated

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defendants’ motions to dismiss the action and reached a settlement with certain defendants and insurers for $118 million which was recently granted preliminarily approval by the court.

• In re Cablevision Systems Corp. Shareholder Derivative Litig., No. 06-CV-4130-DGT-AKT (E.D.N.Y.) (“Cablevision”). LCHB served as Co-Lead Counsel in this shareholder derivative action involving stock options backdating. The case has settled in 2008 for the equivalent of $34.4 million.

• In re Amgen Inc. Securities Litigation, No. 07-cv-02356-PSG-PLA (C.D. Cal.) (“Amgen”). LCHB was retained by the Maine Public Employees Retirement System (“MPERS”) (approximately $10.5 billion in net assets) to seek lead plaintiff status in securities fraud class litigation arising under the Exchange Act. Another fund or funds had greater losses than MPERS and its application for lead plaintiff was denied.

• In re Dell, Inc. Securities Litigation, No. 1:06-cv-00726-SS (W.D. Tex.) (“Dell”). LCHB was retained by the City of Boca Raton Police and Firefighters Retirement System (“City of Boca Raton”) (approximately $180 million in assets) to seek lead plaintiff status in securities fraud class litigation arising under the Exchange Act. Another fund or funds had greater losses than the City of Boca Raton and its application for lead plaintiff was denied.

• Alaska State Department of Revenue, et al. v. America Online, Inc., et al., No. 1JU-04-503 (Sup. Ct. Alaska) (“America Online”). LCHB represented the Alaska State Department of Revenue, the Alaska State Pension Investment Board (approximately $15.5 billion in assets) and the Alaska Permanent Fund Corporation (approximately $33 billion in assets) in an independent, opt-out securities fraud action against America Online, Inc., Time Warner, Inc., and other defendants in state court in Alaska alleging violations of Alaska Trade and Commerce statutes and Alaska common law, and for professional negligence and malpractice. LCHB achieved a $50 million settlement for its clients, representing approximately 71 percent of the $70 million in total losses estimated by the Alaska Attorney General when the action was filed, and more than 50 times what they would have recovered had they remained in the class litigation against America Online.

• Newby v. Enron Corp., No. 4:01-cv-3624 (S.D. Tex.). LCHB was retained by certain New York City Pension Funds (approximately $110 billion in assets) to seek lead plaintiff status. Another fund or funds had greater losses and LCHB’s application for lead plaintiff/lead counsel positions was denied.

• DB Alex. Brown Exchange Fund I and II Litigation: Albert, et al. v. Alex. Brown Management Services, Inc., et al., No. 762-N (Del. Chancery Ct.); Baker, et al. v. Alex. Brown Management Services, Inc., et al., No. 763-N (Del. Chancery Ct.) (“Alex. Brown”). LCHB represented 70 high net worth investors in a financial vehicle known as an “exchange fund” in a combination derivative and direct breach of fiduciary duty action. After extensive litigation, in 2006, the litigation was resolved with our clients recovering approximately 70% of their original investments (the specific amounts are subject to a confidentiality order).

• Allocco et al. v. Gardner et al., No. GIC 806450 (Cal. Super. Ct.) (“Peregrine”). LCHB represents the co-founder and former Chief Executive Officer of Remedy Corporation

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and 24 other former senior executives and directors of Remedy Corporation in a securities fraud lawsuit against former executives and the Chairman of Peregrine Systems, Inc., Peregrine’s accounting firm, and certain entities that entered into fraudulent transactions with the company. The lawsuit arises out of Peregrine’s August 2001 acquisition of Remedy and alleges that plaintiffs were induced to exchange their Remedy stock for Peregrine stock on the basis of defendants’ false and misleading representations. Settlements thus far in the case have produced approximately $45 million in recovery for LCHB’s clients.

• In re National Century Financial Enterprises, Inc. Investment Litigation, MDL No. 1565 (S.D. Ohio) (“NCFE”). LCHB serves as the sole outside counsel for New York City Employees Retirement System, Teachers Retirement System for the City of New York, New York City Police Pension Fund, and New York City Fire Department Pension Fund (collectively, the “New York City Pension Funds”) in this multidistrict litigation arising from fraud in connection with NCFE’s issuance of notes backed by healthcare receivables. The action charges defendants with violations of the anti-fraud provisions of the federal securities laws and state law violations. The New York City Pension Funds suffered approximately $89 million in losses. To date, the funds have recovered approximately 70% of their losses primarily through partial settlements achieved by LCHB. The case is proceeding against several of NCFE’s founders.

• Merrill Lynch Fundamental Growth Fund, Inc., et al. v. McKesson HBOC, Inc., et al., No. CGC 02-405792 (Cal. Super. Ct.) (“McKesson”). LCHB represented two large mutual funds in a private lawsuit filed and litigated in California state court alleging a massive accounting fraud at HBOC & Co. On behalf of its clients, within weeks of the trial date scheduled in the action, LCHB negotiated settlements in which the funds recovered approximately $145 million, representing nearly 104% of their damages. LCHB’s clients recovered approximately $115 million to $120 million more than they would have recovered had they participated in the class settlement.

• Kofuku Bank Ltd. and Namihaya Bank Ltd. v. Republic New York Securities Corp., et al., No. 00 CIV 3298 (S.D.N.Y.); and Kita Hyogo Shinyo-Kumiai v. Republic New York Securities Corp., et al., No. 00 CIV 4114 (S.D.N.Y.) (“Republic/HSBC”). LCHB represented three Japanese financial institutions (and their successor-in-interest, the Resolution Collection Corporation of Japan) in individual lawsuits against HSBC, Inc., the successor-in-interest to Republic New York Corporation, Republic New York Bank and Republic New York Securities Corporation, and Martin A. Armstrong for alleged violations of federal securities and racketeering laws. Through a group of interconnected companies owned and controlled by Armstrong -- the Princeton Companies -- Armstrong and the Republic Companies promoted and sold notes to more than 80 of the largest companies and financial institutions in Japan. LCHB’s lawsuits, as well as the lawsuits of dozens of other investors, alleged that the Princeton and Republic Companies made fraudulent misrepresentations and non-disclosures in connection with the promotion and sale of the notes, and that investors’ moneys were commingled and misused to the benefit of Armstrong and the Princeton Republic Companies. In December 2001, the claims of LCHB’s clients and those of the other investors were settled. As part of the settlement, our clients recovered more than $50 million, which represented 100% of the value of their principal investments.

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• In re Network Associates, Inc. Securities Litigation, No. C-99-1729-WHA (N.D. Cal.) (“Network Associates”). Following a competitive bidding process, the court appointed LCHB as Lead Counsel for the Lead Plaintiff and a class of investors. The complaint alleged that Network Associates violated federal securities laws by engaging in improper accounting practices in order to inflate its stock price. In May 2001, the court granted approval to a $30 million class settlement.

• Informix/Illustra Securities Litigation, No. C-97-1289-CRB (N.D. Cal.) (“Informix/Illustra”). Lieff Cabraser represented the former Chief Executive Officer and President of Illustra Information Technologies, Inc. and a class of Illustra shareholders in suit on behalf of all former Illustra securities holders who tendered their Illustra preferred or common stock, stock warrants or stock options in exchange for securities of Informix Corporation in connection with Informix's 1996 purchase of Illustra. The complaint alleged claims for common law fraud and violations of federal securities law arising out of the acquisition. The global settlement of the litigation for $136 million constituted one of the largest settlements ever involving a high technology company alleged to have committed securities fraud. Our clients, the Illustra shareholders, received approximately 30% of the net settlement fund.

• In re FPI/Agretech Securities Litigation, MDL No. 763 (D.Haw.) (“FPI/Agretech”). Mr. Heimann served as lead and trial counsel on behalf of multiple classes of investors defrauded in a limited partnership investment scheme. Following court-approved partial settlements, the court approved $15 million in partial pretrial settlements. At trial, the jury returned a $25 million verdict, which included $10 million in punitive damages against non-settling defendant Arthur Young & Co. On appeal, the compensatory damages judgment was affirmed and the case was remanded for retrial on punitive damages. The court thereafter approved a $17 million class settlement with Ernst & Young.

• In re California Micro Devices Securities Litigation, No. C-94-2817-VRW (N.D. Cal.) (“California Micro Devices”). Lieff Cabraser served as Liaison Counsel for the Colorado Public Employees’ Retirement Association and the California State Teachers’ Retirement System, and the class they represented. Prior to 2001, the Court approved $19 million in settlements. In May 2001, the Court approved an additional settlement of $12 million, which, combined with the earlier settlements, provided class members an almost complete return on their losses. The settlement with the company included multi-million dollar contributions by the former Chairman of the Board and Chief Executive Officer.

• In re Scorpion Technologies, Inc. Securities Litigation I, No. C-93-20333-EAI (N.D. Cal.) (“Scorpion I”); Dietrich v. Bauer, No. C-95-7051-RWS (S.D.N.Y.); Claghorn v. Edsaco, No. 98-3039-SI (N.D. Cal.). Lieff Cabraser served as Lead Counsel in three separate class action suits arising out of an alleged fraudulent scheme by Scorpion Technologies, Inc., certain of its officers, accountants, underwriters and business affiliates to inflate the company’s earnings through reporting fictitious sales. The Scorpion I and Dietrich v. Bauer cases settled. In Claghorn v. Edasco, a federal jury in San Francisco, California returned a $170.7 million verdict against Edsaco Ltd. in April 2002. The jury verdict was one of the largest in the U.S. in 2002 and produced a recovery for the class of nearly 100%. The jury found that Edsaco aided Scorpion in setting up phony European companies as part of a scheme in which Scorpion

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reported fictitious sales of its software to these companies, thereby inflating its earnings. Included in the jury verdict was $165 million in punitive damages. Mr. Heimann conducted the trial for plaintiffs.

6. What arrangement does the firm have in place or expect to use regarding retention and compensation of experts and third parties?

In providing securities litigation services to the SBA, LCHB may use, as necessary, experts in issues such as damages calculations. The retention of any experts and third parties by LCHB on matters for the SBA would be at LCHB’s expense.

7. Does the firm have a diversity policy? If so, please describe.

LCHB is an equal opportunity employer and is a leader in the plaintiffs bar in creating meaningful opportunities, including positions of leadership, for women and minorities. LCHB has implemented and strictly abides by our own diversity and affirmative action plan pursuant to which we make a good faith effort to recruit and employ members of all protected classes in a non-discriminatory manner.

The success of our affirmative action plan is clear: as mentioned in Section A.2.d. herein, LCHB presently has 191 employees, 98 of whom are women and 57 of whom are minorities. Several of our female attorneys serve in leadership roles at the firm, including Elizabeth J. Cabraser who, in addition to her role in LCHB’s Securities and Financial Fraud Practice Group, is the chair of the firm’s Torts Practice Group and is a member of the firm’s six person Executive Committee. In addition, Kelly M. Dermody, resident in the firm’s San Francisco office, is the chair of the firm’s Employment Practice Group, is also a member of the firm’s Executive Committee. Moreover, LCHB’s Securities and Financial Fraud practice group is comprised of 20 attorneys, nine of whom are women and six of whom are minorities.

LCHB’s commitment to diversity is also evident in our membership of the Bar Association of San Francisco, California (“BASF”) and in our support for BASF’s initiative with respect to the hiring and advancement of minority attorneys. LCHB has voluntarily adopted the diversity initiative of the BASF Diversity Task Force (of which Ms. Dermody is a member) which sets forth goals and timetables through year 2010 for the hiring and advancement of minority attorneys. LCHB is proud to be on track to exceed those goals with respect to minority associates. Specifically, as of 2009, approximately 18 percent of attorneys employed at LCHB are minority.

8. What is the firm’s policy and practice as to continuing legal education for its attorneys?

LCHB’s policy with respect to continuing legal education (“CLE”) for our attorneys is to ensure that all of our attorneys have the opportunity to satisfy their CLE requirements and to attend and participate in CLE programs that will enhance their professional careers. To that end, LCHB is a certified CLE provider (California) and frequently provides CLE courses in-house. The Firm also pays for the costs of our attorneys to attend CLE programs or conferences for which CLE credit is provided, subject to certain limitations.

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B. The Firm’s Securities Litigation Experience

1. Provide a representative list of the institutional investors the firm actively represented in securities litigation matters in the last ten (10) years; including the following information for each:

a. the type of case/claim (e.g. class action, individual and/or opt-out case and/or derivative litigation);

b. the name of the firm’s lead attorney on a case/claim;

c. the type of client (i.e. whether public fund or other institutional investor), and

d. include a brief description of the litigation and the outcome (e.g. dismissal, settlement, win, or loss), including whether your firm filed a motion for Lead Plaintiff status, the name and contact information of all defendants and their counsel. The list should be limited to no more than 20 clients.

The following a representative list of securities actions in the last 10 years in which LCHB represented institutional investors:

Case Name LCHB Lead Attorney(s)

Client (Type) Case Description3 Outcome Defendants/Defense Counsel4

3 For additional information about the cases, please see Section A.5.c. herein. 4 Defendants and defense counsel in each of the actions are as follows: Tyco: McGuireWoods LLP, One James Center, 901 East Cary Street, Richmond, VA 23219 (Counsel for Tyco International Ltd., Tyco Electronics Ltd., Covidien Ltd., and Covidien (U.S.)); Wiggin & Nourie, P.A., 670 North Commercial Street; Suite 305, Manchester , NH 03101 (Counsel for L. Dennis Kozlowski); Stillman & Friedman PC, 425 Park Avenue, New York , NY 10022 (Counsel for Mark H. Swartz); Stroock Stroock & Lavan LLP, 180 Maiden Lane, New York , NY 10038 (Counsel for Frank E. Walsh, Jr.); Qwest: Boies, Schiller & Flexner LLP, 5301 Wisconsin Ave NW, Suite 800, Washington, DC 20015 (Counsel for Qwest Communications International Inc., Qwest Capital Funding, Inc. and Qwest Corporation); Rothgerber Johnson & Lyons LLP, 1 Tabor Ctr, Ste 3000, 1200 17th Street, Denver, CO 80202 (Counsel for Defendant Vinod Khosla); Stern & Kilcullen, 75 Livingston Ave., Roseland, NJ 07068 (Counsel for Joseph P. Nacchio); Holme Roberts & Owen LLP, 1700 Lincoln St, Ste 4100, Denver, CO 80203 (Counsel for Defendant Philip F. Anschutz); Perkins Coie LLP, 1899 Wynkoop St., Ste. 700, Denver, CO 80202 (Counsel for Defendant James A. Smith); Bird, Marella, Boxer, Wolpert, Nessim, Drooks &

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Lincenberg, P.C.,1875 Century Park East, 23rd Floor, Los Angeles, CA 90067 (Counsel for Defendant Robin R. Szeliga), Arnold & Porter LLP, 555 Twelfth St., NW, Washington, DC 20004 (Counsel for Arthur Andersen LLP and Gregory Casey); Clifford Chance LLP, 31 West 52nd Street, New York, NY 10166 (Counsel for Defendant Robert S. Woodruff); Isaacson, Rosenbaum P.C., 633 17th St, Suite 2200, Denver, CO 80202 (Counsel for Defendant Marc B. Weisberg); Cooley Godward LLP, 380 Interlocken Crescent, Suite 900, Broomfield, CO 80021 (Counsel for Defendant Drake S. Tempest); Morvillo, Abramowitz, Grand, Iason & Silberberg, P.C., 565 Fifth Avenue, New York, NY 10017 (Counsel for Defendant Afshin Mohebbi), Hogan & Hartson LLP, One Tabor Center, 1200 17th St, Ste 1500Denver, CO 80202 (Counsel for Stephen M. Jacobsen & Lewis O. Wilks); Brooks: Ropes & Gray LLP, One International Place, Boston, MA 02110 (Counsel for Brooks Automation, Inc., Joseph R. Martin, Edward C. Grady and Robert W. Woodbury); Mintz, Levin, Cohn, Ferris, Glovsky & Popeo, PC, One Financial Center, Boston, MA 02111 (Counsel for Defendant Robert J. Therrien); Goodwin Procter LLP, Exchange Place, 53 State Street, Boston, MA 02109 (Counsel for Ellen Richstone); Skadden, Arps, Slate, Meagher & Flom LLP, One Beacon Street, Boston, MA 02108 (Counsel for Roger D. Emerick and Amin J. Khoury); NCFE: Covington & Burling, 1330 Avenue of the Americas, New York, NY 10019 (Attorneys for Banc One Capital Markets Inc., Bank One National Association, Bank One, N.A.); Kelley Drye & Warren LLP, 101 Park Avenue, New York, NY 10178 (Attorneys for JP Morgan Chase & Co., JP Morgan Partners, LLC, JP Chase Bank, Beacon Group, LLC, JP Morgan Chase Partners, L.P., JPMorgan Chase Bank, N.A.); Fried, Frank, Harris, Shiver & Jacobson LLP, One New York Plaza, New York, NY 10004 (Attorneys for the Beacon Group III Focus Value Fund LP); McKee Nelson LLP, One Battery Park Plaza, 34th Floor, New York, NY 10004 (Attorneys for Credit Suisse Securities (USA) LLC); Baker & Hostetler LLP, 65 E. State St, Ste 2100, Columbus, OH 43215 (Attorneys for Credit Suisse Securities LLC); Cooley Godward Kronish LLP, 1114 Avenue of the Americas, New York, NY 10036 (Attorneys for Credit Suisse); Bartlit, Beck, Herman, Palenchar & Scott, Courthouse Place, 54 W Hubbard St, Ste 300, Chicago, IL 60610 (Attorneys for Deloitte & Touche, LLP); Paul, Weiss, Rifkind, Wharton & Garrison LLP, 1285 Avenue of the Americas, New York, NY 10019 (Attorneys for Fitch, Inc.); Williams & Connolly LLP, 725 Twelfth Street NW, Washington, DC 20005 (Attorneys for Joanne D. Purcell, Cary W. Purcell, and Purcell & Scott Co. LPA); Weil Gotshal & Manges, LLP, 767 Fifth Avenue, New York, NY 10153 (Attorneys for Kaye Scholer LLP); Zacks Law Group LLC, 33 S. James Rd, 3rd Fl., Columbus, OH 43213 (Attorney for Rebecca S. Parrett); Dickerson Law Group, 5003 Horizons Dr, Ste 200, Upper Arlington, OH 43220 (Attorney for Donald H. Ayers); Shumaker Loop & Kendrick, 41 S. High St, Ste 2210, Columbus, OH 43215 (Attorneys for Kuld Corporation, Lance K. Poulsen, Barbara Poulsen, Flohaz Partners, L.L.C., Healthcare Capital LLC, Intercontinental Investment Associates, Kachina, Inc., South Atlantic Investments, L.L.C., Thor Capital Holdings, L.L.C.); Simpson Thacher & Bartlett, LLP, 1 Riverside Plaza, 9th Floor, Columbus, OH 43215 (Attorneys for Thomas G. Mendell, Harold W. Pote and Eric R. Wilkinson); McCarter & English, Four Gateway Center, 100 Mulberry Street, Newark, NJ 07102 (Attorneys for Metropolitan Life Insurance Co.); Isaac Brant Ledman & Teetor, 250 E. Broad St, Ste 900, Columbus, OH 43215 (Attorneys for Lloyds TSB Bank plc); Satterlee, Stephens, Burke & Burke LLP, 230 Park Avenue, New York, NY 10169 (Attorneys for Moody's Investors Service, Inc.); Bickel &

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Brewer, 4800 Bank One Center, 1717 Main St, Ste 4800, Dallas, TX 75201 (Attorneys for Pharos Capital Partners LP); McGuire Woods LLP, 50 North Laura Street, Suite 3300, Jacksonville, FL 32202 (Attorneys for George A. Kuselias, Frank P. Magliochetti, Suzanne K. Hosch, Sam Romeo, Albert Martson, Cedric Johnson); Republic/HSBC: Cleary, Gottlieb, Steen & Hamilton, One Liberty Plaza, New York, NY 10006 (Counsel for Republic New York Securities Corp., Republic New York Corp., Republic National Bank of New York, HSBC USA, Inc., HSBC Bank USA); Morvillo, Abramowitz, Grand, Iason & Silberberg, P.C., 565 Fifth Avenue, New York, NY 10017 (Counsel for James E. Sweeney); Swidlre, Berlin, Shereff & Friedman, LLP, 405 Lexington Avenue, New York, NY (Counsel for William H. Rogers); America Online: Cravath, Swaine & Moore, Worldwide Plaza, 825 Eighth Ave., New York, NY 10019 (Counsel for America Online, Inc, Time Warner, Inc., Historic TW Inc., Stephen M. Case, Robert W. Pittman, J. Michael Kelly); Heller, Ehrman, White & McAuliffe LLP, 333 Bush Street, San Francisco, CA 94104 (Counsel for Ernst & Young LLP); Sullivan & Cromwell LLP, 125 Broad Street, New York, NY 10004 (Counsel for Morgan Stanley & Co., Inc.); Zuckerman Spaeder LLP, 1201 Connecticut Ave., N.W., Suite 1200, Washington, DC 20036 (Counsel for David Colburn); Latham & Watkins Two Freedom Square, 11955 Freedom Drive, Suite 500, Reston, VA 20190-5651 (Counsel for Eric Keller); McKesson: Skadden, Arps, Slate, Meagher, & Flom, LLLP, Four Times Square, New York, NY 10036 (Counsel for McKessonHBOC and McKesson Corporation); Orrick, Herrington & Sutcliffe LLP, Old Federal Reserve Bank Building, 400 Sansome Street, San Francisco, CA 94111 (Counsel for Richard Hawkins); Paul, Hastings, Janofsky & Walker LLP, 55 Second St, 24th Fl., San Francisco, CA 94105 (Counsel for Defendant Jay Gilbertson); Heller, Ehrman, White & Mcaulifee, 333 Bush Street, San Francisco, CA 94104 (Counsel for Defendant Charles W. McCall); Keesal, Young & Logan, 4 Embarcadero Center, Suite 1500, San Francisco, CA 94111 (Counsel for Jay M. Lapine); Law Offices of William Webb Farrer, 300 Montgomery Street, Suite 600, San Francisco, CA 94104 (Counsel for Michael Smeraski), Piper Rudnick LLP, 333 Market St, Ste 3200 San Francisco, CA 94105-3339 (Counsel for Mark Pulido); Cooley Godward, LLP, One Maritime Plaza, 20th Floor, San Francisco, CA 94111 (Counsel for Albert J. Bergonzi); Krieg, Keller, Sloan, Reilly & Roman LLP, 114 Sansome St, 7th Fl., San Francisco, CA 94104 (Counsel for Arthur Andersen, LLP); Farella, Braun & Martel, LLP, 235 Montgomery Street, Thirtieth Floor, San Francisco, California 94104 (Counsel for Heidi Yodowitz); Cadwalader, Wickersham & Taft, 100 Maiden Lane, New York, NY 10038 (Counsel for Bear Stearns & Co.); Quinn Emanuel Urquhart Oliver & Hedges, LLP, 865 Figueroa St, 10th Fl., Los Angeles, CA 90017-2543 (Counsel for General Electric Capital Corporation, Inc.); Boies Schiller & Flexner, LLP, 1999 Harrison Street, Suite 900, Oakland, CA 94612 (Counsel for WebMD Corp.); Covington & Burling, 1 Front St, 35th Floor, San Francisco, CA 94111 (Counsel for Computer Associates, Inc.); Bondurant, Mixson & Elmore, LLP, 3900 One Atlantic Center, 1201 West Peachtree St., Atlanta, GA 30309 (Counsel for Holcombe T. Green);

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Tyco Richard Heimann and Steve Fineman

30 BlackRock mutual funds and 4 Nuveen mutual and investment funds (private institutional investors)

Opt-out actions Settlement

Qwest Richard Heimann and Steve Fineman

NYSCRF, FPPAC, DERP, SFERS (public funds); and

30 BlackRock mutual funds (private institutional investors)

Opt-out actions Settlement

Brooks Steve Fineman LACERA and SCERS (public funds)

Class action Settlement

NCFE Steve Fineman New York City Pension Funds (public funds)

Individual action Partial settlement

Amgen: Amgen, Inc. , Kevin W. Sharer, Willard H. Dere, Richard D. Nanula, Dennis M. Fenton, Roger M. Perlmutter, Brian M. Mcnamee, George J. Morrow, Edward V. Fritzky, Gilbert S. Omenn, and Franklin P. Johnson, Jr. c/o One Amgen Center Drive, Thousand Oaks, CA 91320-1799; Dell: Jones, Day, 222 East 41st Street , New York , NY 10017 (Counsel for Dell Inc., Kevin B. Rollins, and James M. Schneider); Davis, Polk & Wardwell, 450 Lexington Avenue New York , NY 10017 (Counsel for PricewaterhouseCoopers LLP); and Enron: Dickstein Shapiro Morin & Oshinsky LLP, 2101 L Street, N.W., Washington, DC 20037 (Counsel for Duke Energy Trading and Marketing, LLC); Shea Stokes & Carter, 501 West Broadway, 15th Floor, San Diego, CA 92101 (Counsel for Duke Energy Trading and Marketing, LLC); BINGHAM McCutchen LLP, 3 Embarcadero Center, San Francisco, CA 94111 (Counsel for Reliant Energy Coolwater, Inc.; Reliant Energy Ellwood, Inc.; Reliant Energy Etiwanda, Inc.; Reliant Energy Mandalay, Inc.; Reliant Energy Ormond Beach, Inc.); Gray Cary Ware & Freidenrich, LLP, 4365 Executive Dr, Ste 1100, San Diego, CA 92121 (Counsel for Williams Energy Services; Williams Energy Marketing & Trading Companies); Pillsbury Winthrop LLP, SBC Building, 101 W Broadway, Ste 1800, San Diego, CA 92101 (Counsel for Dynegy, Inc.; Dynegy Power Marketing, Inc.; Cabrillo Power I LLC; Cabrillo Power II LLC; El Segundo Power LLC; Long Beach Generation LLC, Duke Energy Trading and Marketing, LLC, Reliant Energy Coolwater, Inc.; Reliant Energy Ellwood, Inc.; Reliant Energy Etiwanda, Inc.; Reliant Energy Mandalay, Inc.; Reliant Energy Ormond Beach, Inc., Williams Energy Services; Williams Energy Marketing & Trading Companies, Dynegy, Inc.; Dynegy Power Marketing, Inc.; Cabrillo Power I LLC; Cabrillo Power II LLC; El Segundo Power LLC; Long Beach Generation LLC).

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Republic/HSBC Steve Fineman The Resolution Collection Corporation of Japan as successor-in-interest to three Japanese financial institutions (private institutional investors)

Individual actions Settlement

America Online

Richard Heimann

Alaska State Department of Revenue, the Alaska State Pension Investment Board, the Alaska Permanent Fund Corporation (public funds)

Opt-out actions Settlement

McKesson Richard Heimann and Joy Kruse

Merrill Lynch Fundamental Growth Fund, Inc. And Merrill Lynch Global Value Fund, Inc. (private institutional investors)

Opt-out actions Settlement

Amgen Richard Heimann

MPERS (public fund) Class action Other investors appointed lead plaintiff

Dell Richard Heimann

City of Boca Raton Class action Other investors appointed lead plaintiff

Enron Richard Heimann and Steve Fineman

New York City Pension Funds (public funds)

Class action Other investors appointed lead plaintiff

2. Please provide historical data related to fees awarded when serving as Lead Plaintiff for securities class action litigation and fees otherwise paid in individual or opt-out or derivative litigation.

The amount of attorneys’ fees awarded to LCHB in securities cases in which it represented the lead plaintiffs was as follows: Tyco (12 percent of total (confidential) recovery); Brooks ($930,000, or 12 percent of the total class recovery); Qwest (approximately 15 percent of net recovery (after costs) by FPPAC, DERP, and SFERS; 3.5 times lodestar for work performed on behalf of NYSCRF; compensation for work on behalf of the BlackRock funds was on an hourly basis); Cablevision ($555,801); America Online ($4.2 million); Alex. Brown ($1.2 million); Peregrine ($5.7 million); McKesson ($8.3 million, or approximately five percent of total recovery); Republic/HSBC ($8.3 million); Network Associates ($2.1 million);

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Informix/Illustra ($3.4 million); Scorpion I ($1.2 million); FPI/Agretech ($5.1 million); California Micro Devices ($797,819); Dietrich v. Bauer ($402,056); and Claghorn v. Edasco ($3.5 million).

3. Does the firm employ a professional team or department dedicated to

securities litigation, evaluation, loss calculations, and analysis? If so, please describe. If not, please describe how your firm handles these matters.

Yes. LCHB’s Securities and Financial Fraud practice group is comprised of 20 attorneys, each of whom participates in providing securities case evaluation, advisory, and litigation services to our clients. In addition, our securities group includes investigators financial analysts, and paralegals. Robert De Maria, the former head of the FBI “White Collar Crime Division” in San Francisco, heads LCHB’s investigative team in identifying and conducting interviews with witnesses and performing other investigative tasks. Kirti Dugar is the firm’s chief financial analyst and is assisted by junior financial analyst, Arra Kharajian. Together, Messrs. Dugar and Kharajian analyze and provide assessments as to our clients’ losses, case damages, among other accounting and financial issues. In addition, Richard Texier and Melissa Matheny are the principal paralegals in the Securities and Financial Fraud group.

4. List all the attorneys that would be expected to render legal services to the SBA if the firm is selected to be included in the updated pool of eligible securities litigation firms, including the number of years each has been litigating securities cases, the proposed role of each on the SBA team, and any other relevant experience. Provide a resume for each. Identify the attorney who will be the primary contact and lead counsel in providing services to the SBA.

The primary contact and lead counsel in providing services to the SBA is Mr. Heimann. The attorneys who would be expected to render legal services to the SBA if LCHB is selected pursuant to the ITN are as follows:5

Richard M. Heimann Mr. Heimann has more than 25 years of securities litigation experience and is one of the nation’s most successful securities fraud trial lawyers. Mr. Heimann will serve as lead trial counsel in matters for the SBA and will play a leading role in case strategy, motion practice and discovery.

Mr. Heimann’s securities litigation includes successfully conducting the trial for plaintiffs in Claghorn v. Edasco, one of the largest securities fraud class action trial verdicts this decade ($170.7 million verdict, including $165 million in punitive damages). Mr. Heimann has also served or serves as LCHB’s lead counsel in the following securities matters: Tyco, Broadcom, Qwest, America Online, Peregrine, McKesson, and Network Associates. In addition, 5 A copy of the individual resume of each of our securities attorneys is attached hereto as Exhibit B. We understand that the inclusion of the resumes in our responses to the Services Questionnaire does not violate Section III.B. of the ITN with respect to references to attachments and the applicable page limitation.

844471.2 18

Mr. Heimann frequently provides securities litigation services and/or case evaluation advice to a number of public pension plans and private institutional investors. Moreover, Mr. Heimann is presently serving as co-lead counsel in one of the nation’s largest Sherman Act antitrust cases, In re TFT-LCD (Flat Panel) Antitrust Litigation, MDL No. 1827 (N.D. Cal.).

Elizabeth J. Cabraser Ms. Cabraser has more than 29 year of experience in securities and investment fraud matters. Ms. Cabraser will play a significant role in litigation strategy, class certification and motion practice, and appellate work on behalf of the SBA.

Ms. Cabraser has served as lead or co-lead counsel, with her partners, in a number of LCHB’s securities litigations. Ms. Cabraser is one of the most recognized attorneys in United States civil litigation. She has been acknowledged by the national legal press as one of the best and most influential lawyers in the country, and has repeatedly been cited as one of the country’s top female lawyers. As described in Ms. Cabraser’s resume, from the 1970s through the late 1990s, Ms. Cabraser served as class counsel in numerous securities and financial fraud class actions. During most of this decade Ms. Cabraser has primarily served in leadership positions in many of the country’s largest mass actions, e.g., In re Diet Drugs Products Liability Litigation, MDL No. 1203 (E.D. Pa.) (Steering Committee); In re Baycol Products Litigation, MDL No. 1431 (D. Minn.) (Co-Lead Counsel); In re Tri-State Crematory Litigation, MDL No. 1467 (N.D. Ga.) (Lead and Class Counsel); In re Vioxx Products Liability Litigation, MDL No. 1657 (E.D. La.) (Management Committee); In re Bextra/Celebrex Marketing Sales Practices and Products Liability Litigation, MDL 1699 (N.D. Cal.) (Liaison Counsel); In re Guidant Implantable Defibrillators Products Liability Litigation, MDL No. 1708 (D. Minn.) (Co-Lead Counsel); and In re ConAgra Products Liability Litigation, MDL No. 1845 (N.D. Ga.) (Lead Counsel).

William Bernstein Mr. Bernstein is an experienced and accomplished litigation partner with more than 25 years of securities litigation experience. Mr. Bernstein will participate in strategy, class certification and motion practice and discovery in matters for the SBA. Mr. Bernstein has significant securities litigation experience representing investors in cases involving Ponzi schemes, municipal bond defaults, and other matters. In addition, Mr. Bernstein has had leading roles in a variety of multidistrict and complex litigation including In re Natural Gas Antitrust Cases I, II, III and IV, JCCP Nos. 4221, 4224, 4226 and 4228, Nuanes, et al. v. Insignia, et al., (Cal. Sup. Ct.), In re Toys ‘R’ Us Antitrust Litigation, MDL No. 1211, In re Synthroid Marketing Litigation, MDL No. 1182, Richison, et al. v. American Cemwood, et al. (Cal. Sup. Ct.), and Ziontz v. Unocal Corp., Civil No. BC 096183.

Steven E. Fineman Mr. Fineman, LCHB’s Managing Partner, has more than 20 years of experience in prosecuting complex civil litigation, including class and individual securities fraud actions. Mr. Fineman will serve as trial counsel, and will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Mr. Fineman has provided litigation services and/or case evaluation advice to a number of public pension plans and private institutional investors with regard to securities law matters. Mr. Fineman is the firm’s lead counsel in representing New York City Pension Funds in the NCFE. In addition, Mr. Fineman served as LCHB’s lead counsel in Brooks and played a leading role in the firm’s successful representation of public and private pension funds in Qwest and

844471.2 19

Tyco. Moreover, Mr. Fineman served as the firm’s lead counsel in Republic/HSBC and in Alex. Brown. Mr. Fineman has also had leading roles in several major mass tort cases, is a member of the Executive Committee of the Board of Directors of the Public Justice Foundation and a member of the Board of Trustees of the Civil Justice Foundation. Mr. Fineman also writes and speaks frequently on complex litigation and federal court practice. In 2002, the National Law Journal, in an article entitled “40 under 40,” recognized Mr. Fineman as one the nation’s most successful young litigators.

David Stellings Mr. Stellings is an experienced and accomplished securities litigation partner with more than three years of securities litigation experience. Mr. Stellings will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Mr. Stellings has significant securities litigation experience, including serving in a leading role in Mazzaro de Abreu, et al. v. Bank of America Corporation, et al., No. 06-CV-673 (LMM) (S.D.N.Y.) in which LCHB represents 100 individual Brazilian investors and entities who lost approximately $125 million in a financial fraud in which Edemar Cid Ferreira, a Brazilian billionaire, stole the money plaintiffs deposited in Ferreira’s offshore Bank of Europe. Mr. Stellings had and has additional significant responsibility for client communication regarding litigation events and strategy in the above-mentioned and other cases.

Joy A. Kruse Ms. Kruse is an experienced and accomplished securities litigation partner with more than nine years of securities litigation experience. Ms. Kruse will serve as trial counsel, and participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Ms. Kruse played a leading role in the day-to-day litigation and resolution of the highly successful McKesson, America Online, Peregrine, and Network Associates cases. In both McKesson and American Online, Ms. Kruse had substantial responsibility for client communications (the Merrill Lynch funds and the State of Alaska, respectively). Ms. Kruse is also presently engaged in managing much of the day-to-day litigation in the Broadcom derivative litigation.

Daniel P. Chiplock Mr. Chiplock is an experienced and accomplished securities litigation partner with more than nine years of securities litigation experience. Mr. Chiplock will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Mr. Chiplock played an active day-to-day role in the litigation and resolution of McKesson, Qwest, Brooks, Cablevision, and Alex. Brown, and is presently engaged in managing much of the day-to-day litigation in Tyco and other matters. Mr. Chiplock had and has additional significant responsibility for client communication regarding litigation events and strategy in the above-mentioned cases.

Mark P. Chalos Mr. Chalos is an experienced and accomplished litigation partner with

more than two years of securities litigation experience. Mr. Chalos will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

844471.2 20

Mr. Chalos has significant experience representing entities and individuals who have suffered losses due to fraud and other economic wrongs, as well as individuals who suffered catastrophic personal injuries. In addition, Mr. Chalos has tried jury and bench trials in federal and state court and has experience practicing in the areas of white-collar criminal defense and complex civil litigation. Mr. Chalos has substantial responsibility for client communications and case evaluation and development of securities matters.

Lexi Hazam Ms. Hazam is an experienced and accomplished partner with more than two years of securities litigation experience. Ms. Hazam will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Ms. Hazam participates in case evaluation analysis and development of securities matters. In addition to her securities litigation experience, Ms. Hazam has significant experience in the litigation of mass tort actions, including serving in a leading role in litigating and settlement implementation of cases involving contaminated and defective blood factor products produced by American pharmaceutical companies. In addition, Ms. Hazam has significant experience in aviation and employment litigation.

Jennifer Gross Ms. Gross is an experienced and accomplished partner with more than five years of securities litigation experience. Ms. Gross will participate in strategy, class certification and motion practice and discovery in matters for the SBA.

Ms. Gross participates in case evaluation analysis and development of securities matters. In addition to her securities litigation experience, Ms. Gross has significant experience in the litigation mass tort, and antitrust actions.

Lydia Lee Ms. Lee specializes in corporate governance and fiduciary matters and has more than 10 years of securities litigation experience. Ms. Lee is of-counsel to LCHB. Ms. Lee will advise on issues relating to corporate governance in matters for the SBA and is available to serve as governmental liaison to the SBA.

As mentioned, Ms. Lee is the former President of the National Association of Public Pension Plan Attorneys and the former General Counsel of the Oklahoma Public Employees’ Retirement System. Ms. Lee has substantial responsibility for client communications.

Bruce W. Leppla Mr. Leppla is an experience and accomplished securities litigation attorney who is of-counsel to LCHB. Mr. Leppla has more than 10 years of securities litigation experience. Mr. Leppla will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Mr. Leppla had a significant role in the litigation of the America Online and McKesson cases. In addition, Mr. Leppla has substantial responsibility for client communications.

Brendan J. Glackin Mr. Glackin is an associate and has more than seven years of securities litigation experience. Mr. Glackin will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

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Mr. Glackin has significant class action litigation experience, including assisting in the litigation of securities and antitrust actions. In addition, Mr. Glackin participates in case evaluation analysis and development of securities matters.

Sharon M. Lee Ms. Lee is an associate and has more than seven years of securities litigation experience. Ms. Lee will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Ms. Lee has significant securities litigation experience, including assisting in the litigation of the Qwest action. In addition, Ms. Lee participates in securities case evaluation analysis and development and the initiation of securities actions.

Nancy Chung Ms. Chung is an associate and has more than six years of securities litigation experience. Ms. Chung will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Ms. Chung has significant securities litigation experience, including assisting in the day-to-day litigation of the America Online, Peregrine, and Broadcom actions. In addition, Ms. Chung participates in case evaluation analysis and development of securities matters.

Michael J. Miarmi Mr. Miarmi is an associate and has more than more than four years of securities litigation experience. Mr. Miarmi will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Mr. Miarmi has significant class action litigation experience, including assisting in handling the day-to-day litigation in NCFE and assisting in the Tyco litigation. In addition, Mr. Miarmi participates in case evaluation analysis and development of securities matters.

Daniel M. Hutchinson Mr. Hutchinson is an associate and has more than four years of securities litigation experience. Mr. Hutchinson will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Mr. Hutchinson has significant class action litigation experience, including assisting in the America Online and Peregrine cases. In addition, Mr. Hutchinson has significant experience prosecuting financial fraud under ERISA law, including assisting in the litigation on behalf of a certified class of 3,500 R.J. Reynolds Tobacco Co. employees charging that the company breached its fiduciary duty by selling at a loss Nabisco stocks held in the employee 401(k) plan even though market analysts recommended buying or holding the stocks.

Allen Wong Mr. Wong is an associate and has approximately one year of securities litigation experience. Mr. Wong will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Mr. Wong’s securities litigation experience includes assisting in the Tyco litigation. In addition, Mr. Wong participates in case evaluation analysis and development of securities matters.

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Mikaela Bernstein Ms. Bernstein is an associate and has approximately one year of securities litigation experience. Ms. Bernstein will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Ms. Bernstein’s securities litigation experience includes assisting in the Broadcom litigation. In addition, Ms. Bernstein participates in case evaluation analysis and development of securities matters.

Jaron Shipp Mr. Shipp is an associate and has approximately one year of securities litigation experience. Mr. Shipp will participate in case evaluation analysis, case development, motion practice and discovery in matters for the SBA.

Mr. Shipp’s securities litigation experience includes assisting in the Broadcom litigation. In addition, Mr. Shipp has experience representing employees and consumers in various employment and consumer class actions.

5. Describe the firm’s backup procedures in the event one or more attorneys assigned to the SBA leave the firm or is unavailable to work on a case.

In the event an attorney assigned to the SBA leaves the firm or is unavailable to work on a case, LCHB would ensure that our work for the SBA continues uninterrupted. LCHB requires all employees who leave the firm or are reassigned to work on other matters to prepare a comprehensive memorandum describing their work and responsibilities to date and to meet with a superior to discuss same. The superior will then arrange for the transition of responsibilities to existing or newly assigned personnel on the matter.

6. Describe the evaluation process and methodology the firm currently has in

place or that you would utilize to determine if any client generally should join a class action, pursue lead or co-lead plaintiff status in a class action, or choose to opt out and pursue an action independent of the class action suit. Specifically –

a. What factors should be considered in evaluating whether to advise a client to pursue an option other than lead plaintiff status?

b. Should a threshold amount be utilized as a prerequisite to pursuing a case?

c. Describe the process that your firm believes should be used to analyze potential damages and determine likely recovery projections.

As part of securities case evaluation services, we monitor newly filed federal and state securities class actions and other securities cases and significant developments in existing cases. We utilize RiskMetrics Group’s Securities Class Action Services, the Stanford University Securities Class Action Clearinghouse, Courthouse News, and other services to monitor securities litigation filings and claims filing notices and deadlines. LCHB also monitors events in the business community that might impact institutional client portfolios. The firm has several Bloomberg terminals that provide company-specific financial information and news, including

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SEC filings and share price activity. Attorneys coordinate with our investigative team, financial analysts and outside experts (as necessary) to evaluate possible claims. This information is compiled and summarized regularly and reviewed by LCHB’s Securities and Financial Fraud practice group, which meets weekly.

Generally, all cases of significance are reviewed by a senior attorney in the group, who then circulates an internal memorandum concerning the case to other group members. At the direction of one of LCHB’s partners, if deemed advisable, a further, comprehensive internal analysis of the case is prepared and reviewed. Typically, LCHB will conduct an investigation of the key facts of the case, including a review of SEC, DOJ or other governmental or administrative proceedings, review the financial statements of the companies involved and all relevant public filings and press releases or other statements. In addition, we evaluate the seriousness of the fraud, the likelihood of prevailing on various legal theories against different defendants, the solvency of the defendants and similar factors, and assess our client’s overall likelihood of success. Moreover, we review, evaluate and determine feasible litigation options, conduct preliminary loss and damage calculations for institutional investor clients, and prepare a memorandum to our clients that discussing the strengths and weaknesses of a case.

Based on our case evaluation and analysis of our clients’ losses, we may recommend that our clients seek appointment as lead or co-lead plaintiff in securities class litigation. Our recommendation to seek appointment as lead or co-lead plaintiff will depend, in part, on whether (1) our clients’ losses, as calculated according to the Private Securities Litigation Reform Act of 1995 (“PSLRA”), are competitive with the losses of other investors who may seek lead plaintiff status such that there is a substantial likelihood that our clients would be successful in winning lead plaintiff appointment, (2) there is significant indicia of fraudulent conduct by defendants; and (3) our clients have compelling causation arguments. If our clients decide to proceed in seeking lead plaintiff status, we would prepare and file a motion on our clients’ behalf and handle any necessary briefing and oral argument in connection therewith.

Alternatively, we may recommend that our clients bring an independent, or “opt-out,” action after considering various factors, including (1) whether the clients have suffered large losses/provable damages; (2) the likelihood that fraud occurred; and (3) the likelihood that the clients will obtain a much greater recovery than they would in the class case. In our experience, it is typically best to wait and see whether the class litigation survives a motion to dismiss before deciding whether to opt-out of the litigation and pursue and independent action.

Should the SBA desire, LCHB and the SBA will determine a threshold amount of losses and/or damages (as calculated under the federal securities laws) that the SBA must have before LCHB notifies the SBA it has a significant claim worthy of evaluating for an active litigation role. To accomplish that, we recommend that the SBA provide LCHB with access to its securities portfolio transactional data so that LCHB can monitor and analyze the SBA’s losses and evaluate whether it should get involved in pending securities litigation.

LCHB’s utilizes “event studies” in securities fraud litigation to analyze the artificial inflation in the price of the subject security(s) and the resulting damages. Event studies provide a statistical measure of whether a particular “event(s)” or disclosure(s) during the relevant period in the litigation caused a significant change in the total mix of information that determines the

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price of a security. Event studies also involve an assessment of the movement, if any, in the price of a security(s) and whether and to what extent it may be attributable to an company-specific event/disclosure and/or market-wide and industry factors at or around the same time.

To estimate class-wide damages, we estimate the aggregate number of shares of the subject security that were “traded in to the class” (i.e., the number of shares transacted and damaged during the relevant period). We then estimate the amount of inflation in the price of the security caused by fraud, determine the true value of the security, and then determine how many shares were “damaged” and the extent of those damages based on the level of artificial inflation.

For recovery projections, we conduct an in depth analysis of a defendant's financial condition and ability to pay estimated damages as above.

7. List the instances during the last eight (8) years in which securities litigation cases initiated by the firm were dismissed. For each such dismissed case, describe the name and docket number of the case, the judge’s name, the type of motion, the date of the decision and citations to any published opinion.

We only recommend our clients’ involvement in cases we deem meritorious based on our comprehensive research and evaluation. The level of expertise we have in that regard is demonstrated by the fact that no court has ever dismissed a securities action initiated by LCHB and in which LCHB served as plaintiffs’ lead counsel.

8. Describe any innovative strategy the firm may have used to obtain recovery for a client in a securities litigation matter and provide a detailed explanation of the facts and circumstances.

In our Securities and Financial Fraud practice, we have been particularly successful in recovering our clients’ assets in securities class and individual actions and shareholder derivative actions. We attribute our success, in part, to our commitment to taking our cases through trial and our preparation and litigation in anticipation thereof. (See, e.g., Section A.6.c. herein for a description of LCHB’s trial experience and success in Claghorn v. Edasco and FPI/Agretech). In addition, in resolving cases, we have utilized innovative strategies to recover our clients’ losses, including seeking recovery from the personal assets of individual corporate officials as a way of ensuring meaningful corporate governance reforms. For example, in Broadcom, although a partial $118 million settlement has been reached in the case, LCHB is continuing to pursue the claims against three senior corporate officials, the primary wrongdoers in the case. In addition, in Brooks, the settlement provides for a number of corporate governance reforms, including the elimination of Brooks’s ability to issue backdated stock options.

Moreover, as described in the legal and financial press, LCHB’s recovery thus far in Broadcom has been described as an “extraordinary accomplishment” largely because it is to be funded by Broadcom’s directors and officers insurance carriers, some of whose obligation to pay

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under the company’s complex insurance policies would not have been triggered but for LCHB’s claims against certain individual officers and directors of Broadcom.6

9. Describe the firm’s ability to finance litigation until resolution in connection with complex, large, lengthy and contentious securities litigation matters.

Founded in 1972, LCHB has successfully represented plaintiffs for more than 37 years. We have a comprehensive and diverse practice and are accustomed to litigating large, complex, multi-party cases from inception through resolution. Throughout our history, including the present, we routinely advance tens of millions of dollars worth of case costs on a contingent basis. The firm’s size and diversity of cases allows us to do so. Moreover, as mentioned above, we have funded cases on behalf of public and private institutional investors and we have funded cases against major corporations. We are confident we have the resources and stability to finance through resolution any complex, large, lengthy and contentious securities litigation we bring on behalf of the SBA.

10. Describe the firm’s expertise in corporate governance matters.

As described in Section B.8., we believe that one of the most effective ways to ensure meaningful corporate governance reform is by seeking recovery of personal assets from individual corporate defendants and, to the extent they have participated in misdeeds, from company auditors, accountants and other advisors. For example, as described in Section B.8., in Brooks, we were successful in obtaining corporate governance reforms that effectively eliminated Brooks’s ability to issue backdated stock options.

LCHB frequently counsels public funds and other institutional investors with respect to corporate and board governance and fiduciary liability issues. In that regard, we are pleased to present the counsel of Lydia Lee, a member of LCHB’s Securities and Financial Fraud practice group and an expert in the fields of fiduciary duties and corporate governance matters, has a significant role in advising our clients on such issues. Ms. Lee is a nationally known expert in the fields of fiduciary duties and corporate governance matters, particularly as they relate to defined benefit and defined contribution retirement plans. In addition, Ms. Lee is the former President of the National Association of Public Pension Plan Attorneys (“NAPPA”) and the former General Counsel of the Oklahoma Public Employees’ Retirement System. Ms. Lee is available to advise the SBA on corporate governance issues on securities litigation and other matters.

6 See, e.g., Kevin LaCroix, D&O Insurers Fund $118 Million Partial Settlement of Broadcom Options Backdating Derivative Suit, The D&O Diary, available at www.dandodiary.com (Sept. 1, 2009) (“Given the number of carriers involved, the complexity of the coverage issues and the sheer quantity of dollars involved, the completion of this settlement is an extraordinary accomplishment.”).

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11. Describe why the firm and the services offered by the firm are superior to the firm’s competitors and the firm’s competitive advantages (if any).

LCHB has the experience, expertise, and resources to provide the services sought by the SBA. LCHB has 30+ years of securities litigation experience and has recovered hundreds of millions of dollars on behalf of our clients and class members in securities class and individual actions and shareholder derivative actions. Our success in securities litigation is largely attributable to the fact that, unlike many of our competitors, we do not file “stock drop” only lawsuits, nor do we recommend our clients’ involvement in such cases. Rather, we only pursue cases involving serious fraudulent conduct, our clients have compelling causation arguments, and they suffered significant losses as a result of the fraud.

In addition, unlike many other firms, we are committed to, and have been successful in, taking cases through trial and prepare for and litigate our cases accordingly. As described in Section A.5.c. herein, we have successfully tried two securities fraud cases to verdict. (Claghorn v. Edasco and FPI/Agretech). Moreover, in McKesson, LCHB negotiated settlements on behalf of its clients within weeks of the trial date scheduled in the action. Because we are prepared to take our cases to trial, we believe we are in a position to obtain the maximum possible recoveries for our clients.

Moreover, because of geographical breadth and our size, LCHB offers our clients to unique benefits and advantages of a firm that is able to handle large, complex litigation internally and in an economical manner. In addition to our securities litigation partners and associates, we retain investigators, financial analysts, information technology and document management specialists, word processors, and dozens of paralegals to prepare and try cases.

Described by The American Lawyer as “one of the nation’s premier plaintiffs’ firms,” we enjoy a national reputation for professional integrity and the successful prosecution of our clients’ claims. In addition, in 2009, the National Law Journal selected LCHB as one of the top plaintiffs law firms in the nation for the seventh year in a row. In compiling the “Plaintiffs’ Hot List,” the Law Journal examined recent verdicts and settlements, and sought recommendations nationally from plaintiffs and defense counsel, as well as dozens of corporate general counsel. We are one of only two law firms in the nation to receive this award each of the last seven years.

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12. Please provide no less than four (4) securities litigation clients references; preferably, at least two of the four should be public funds.

New York State Common Retirement Fund Contact: Luke Bierman, Esq. General Counsel New York State Office of the Comptroller 110 State Street, 14th Floor Albany, NY 12236 Tel.: (518) 474-3444 Email: lbierman@osc.state.ny.us

Los Angeles County Employees Retirement Association Contact: Michael D. Herrera, Esq. Senior Staff Counsel 300 North Lake Avenue, Suite 620 Pasadena, CA 91101 Tel: (626) 564-2336 Email: mherrera@lacera.com

Alaska Permanent Fund Corporation; Alaska Office of the Attorney General Contact: Michael A. Barnhill, Esq. Assistant Attorney General State of Alaska, Department of Law 123 4th Street, 6th Floor Juneau, AK 99801 Tel.: (907) 465-4118 Email: mike_barnhill@law.state.ak.us

State of Ohio, Office of the Attorney General Contact: Albert Lin, Esq. General Counsel State of Ohio, Office of the Attorney General 30 E. Broad St., 16th Floor Columbus, OH 43215 Tel.: (614) 728-4128 Fax: (614) 466-5087 Email: albert.lin@ohioattorneygeneral.gov

C. Disclosure and Mitigation of Conflicts of Interests

1. How does your firm identify and mitigate actual or potential conflicts of interest? Does the firm have its own distinct code of conduct? Identify the position or committee at your firm that is responsible for enforcing any code of conduct.

LCHB maintains and strictly enforces a policy against potential and actual conflicts of interest between LCHB employees and existing or potential clients. This policy is set forth in LCHB’s Firm Policy Manual which is distributed to all employees upon hire and made available on the firm’s intranet. Under this policy, if an LCHB employee is asked to become involved in a matter involving an individual or entity with or for which s/he may have had contact, exposure, or worked in a previous job, the LCHB employee is required to promptly notify his/her immediate supervisor and refrain from performing any work involving the individual or entity. The supervisor is required to then notify LCHB’s “Conflicts Team,” led by LCHB partner, Daniel P. Chiplock, which is responsible for investigating the matter and making a determination as to whether the employee should be “screened” from performing any work relating to the individual or entity. In addition, during the pre-employment stage, a potential employee is required to complete a conflict check application that shall be maintained by the Conflicts Team

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and used to determine whether an applicant’s past legal work conflicts with current and/or active cases of the firm. Moreover, LCHB’s policy is to conduct a conflict check and screen off appropriate employees, as necessary, before the firm agrees to represent and work on any matters for a potential client. LCHB’s Executive Committee has principal responsibility for enforcing the firm’s policy regarding conflicts of interests.

In addition, LCHB’s Firm Policy Manual identifies and addresses types of conduct that are impermissible at the firm and states the firm’s policies with respect to confidentiality, conflicts of interest, and use of electronic information resources, among other matters. The firm’s managing partner, Mr. Fineman, and the firm’s Executive Committee, strictly enforce and monitor compliance with these policies.

2. Are there any actual, potential or perceived conflict of interest issues that the firm may have in representing or working for the State Board of Administration of Florida (SBA)? If so, describe them and include responses to the following:

We are unaware of any actual, potential or perceived conflicts of interests issues that LCHB may have in representing for the SBA.

a. Has the firm or any person in the firm ever made any political contribution, directly or indirectly (including through committees covered by Section 527 of the Internal Revenue Code or otherwise), to any person in a position to exert any influence regarding this ITN (including to any member of the Board of Trustees). If so, please disclose to whom and the amount.

No.

b. Has the firm, or any person in the firm ever, directly or indirectly, paid or agreed to pay any one (e.g., lobbyist, third party marketer) to assist in obtaining business from or otherwise to contact for any reason whatsoever, the SBA. If so, please disclose to whom and the amount.

No.

c. Disclose any relationship(s), whether business or personal, that the firm, or any principal or employee (or any family member thereof) of the firm, has with a person known to work for or have substantial business dealings with the SBA, any employee of the SBA, any member of the Board of Trustees and their respective staffs, consultants or managers.

None.

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d. Indicate whether the firm is (a) currently a member of the SBA securities litigation pool or (b) has provided services to the SBA within the last ten (10) years.

LCHB is not currently a member of the SBA securities litigation pool and has not provided services to the SBA within the last ten (10) years.

3. List and describe any services your firm has provided in the last three (3) years to the State of Florida, or any official of the State of Florida.

None.

4. Describe whether the firm (or any attorney currently with the firm) has ever represented a client against the SBA, taken any action or position adverse to the SBA (either individually or in conjunction with another firm, entity, organization, association or person) or engaged or retained any firm, entity, organization, association or person to take any action or position adverse to the SBA.

Neither LCHB nor any personnel has ever represented a client against the SBA, taken any action or position adverse to the SBA (either individually or in conjunction with another firm, entity, organization, association or person) or engaged or retained any firm, entity, organization, association or person to take any action or position adverse to the SBA.

D. Disclosure of Disciplinary Actions and Mitigation of Liability

1. Has the firm, or an attorney in the firm, ever been disciplined or censured by any court or regulatory body, or been involved in any litigation, regulatory, legal or other proceeding (including relating to malpractice) or any state or federal investigation? If so, describe the principal facts and status, outcome and/or disposition.

During its 37 years of business, LCHB has been sanctioned twice under FRCP Rule 11, and in one of those instances, the sanctions order was reversed on appeal. The following is a summary of each of those matters:

In 1995, in In re Keegan Management Co. Securities Litigation, LCHB, along with co-counsel, was sanctioned under Rule 11 for purportedly failing to conduct an adequate pre-filing investigation of certain facts included in a complaint against Keegan Management Co., a franchisee of Nutri/System Weight Loss Centers. On appeal the FRCP sanctions were reversed. See 78 F.3d 431 (9th Cir. 1995).

In 1994, in In re Omnitrition International, Inc. Securities Litigation, an LCHB attorney, signed experts’ names to two declarations (based on reports prepared by the experts) without indicating that the signatures were not those of the experts. United States District Court Judge Armstrong imposed Rule 11 sanctions against LCHB and the attorney. LCHB was not aware of the attorney’s conduct at the time it occurred, and his employment was terminated by the firm as a result of the incident.

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2. Describe the level of coverage for legal malpractice insurance and any other fiduciary or professional liability insurance the firm carries, including the name of the insurers, rating of insurers, insurance types and coverage amounts.

LCHB’s malpractice insurer is Westport Insurance Corporation in Chicago, Illinois (current A.M. Best Financial Strength Rating (“FSR”) of “A” and Issuer Credit Rating (“ISR”) of A+). We maintain insurance in the amount of $10,000,000 (per claim and aggregate for period including damages and claims expenses).

In addition, we maintain general liability and fidelity bond insurance. Our general liability insurer is Vigilant Insurance Company, a subsidiary of Chubb Group in Warren, New Jersey (current FSR of A++ and ISR of AA+). The limit on our general liability policy is $12,250,000.

Moreover, our fidelity bond insurer is Fidelity and Deposit Company of Maryland (current FSR of A and ISR of A+). Our fidelity insurance policy has a limit of $500,000.