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I have personal knowledge of the matters set forth herein based on my active participation in the prosecution and settlement of the Actions, and, if called as a witness, could and would testify competently thereto. The purpose of this Declaration is to describe the nature and procedural history of the Actions, Plaintiffs' Counsel's investigation and prosecution of the Actions, the negotiations that led to the proposed Settlement, and the results achieved for the proposed Class. Ind.) (the “Garcia Action”); and (3) Stephen Bushansky v. Ultimately, Defendants agreed to provide Remy's stockholders with material information concerning, inter alia: (i) the financial forecasts of the Company; (ii) the material financial analyses UBS performed in connection with providing its fairness opinion; (iii) potential conflicts of interest faced by certain Company directors and Remy’s financial advisor UBS Securities LLC ("UBS") in connection with the Merger; and (iv) material information with respect to the sales process conducted by the Board and the background of the transaction. Cal.): A recovery of million was obtained for the class.
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