The following statement is being issued by Gardy & Notis, LLP and Wolf Haldenstein Adler Freeman & Herz LLP regarding Rubinstein v. Gonzalez, No. 14-cv-9465 (N.D. Ill.) (the “Litigation”).
TO: ALL PERSONS WHO PURCHASED OR OTHERWISE ACQUIRED AMERICAN DEPOSITARY SHARES (“ADS”) OR PURCHASED CALL OPTIONS OR SOLD PUT OPTIONS OF SHIRE PLC BETWEEN SEPTEMBER 29, 2014 AND OCTOBER 14, 2014 (THE “CLASS”). PLEASE READ THIS NOTICE CAREFULLY. YOUR RIGHTS WILL BE AFFECTED BY A CLASS ACTION LAWSUIT PENDING IN THIS COURT.
YOU ARE HEREBY NOTIFIED that pursuant to Rule 23 of the Federal Rules of Civil Procedure and an Order of the United States District Court for the Northern District of Illinois that the Litigation has been certified as a class action on behalf of the Class, except for certain persons and entities who are excluded from the Class by definition as set forth in the full printed Notice of Proposed Settlement of Class Action (the “Notice”).
YOU ARE ALSO NOTIFIED that Plaintiff in the Litigation on behalf of herself and the other Members of the Class, have reached a proposed settlement of the Litigation with the defendants for the sum of $16,750,000 in cash (the “Settlement”). If the Settlement is approved, it will resolve all claims in the Litigation.
A hearing will be held on October 22, 2019, at 10:00 a.m. CT, before the Honorable Robert M. Dow Jr at Everett McKinley Dirksen United States Courthouse, 219 South Dearborn Street, Courtroom 2303, Chicago, IL 60606, for the purpose of determining: (1) whether the proposed Settlement should be approved by the Court as fair, reasonable and adequate; (2) whether, thereafter, this Litigation should be dismissed with prejudice against the Defendants as set forth in the Stipulation of Settlement dated May 31, 2019; (3) whether the Plan of Allocation of Settlement proceeds is fair, reasonable, and adequate and therefore should be approved; and (4) the reasonableness of the application of Lead Counsel for the payment of attorneys’ fees and expenses incurred in connection with this Litigation, together with interest thereon (which request may include a request for reimbursement of Plaintiffs’ reasonable costs and expenses pursuant to the Private Securities Litigation Reform Act of 1995).
You may comment on the Settlement no later than October 1, 2019, and the Court will consider your views at the hearing. You can also appear at the hearing or hire your own attorney at your own cost to represent you at the hearing if you choose. You do not need to attend the hearing to have your comments considered. Details on the process to comment on the Settlement or appear at the hearing are explained in detail on the website or in the detailed Notice.
If you have not received a detailed Notice and Claim Form you may obtain copies by writing to AbbVie Securities Settlement, Claims Administrator, c/o Epiq, P.O. Box 4087, Portland, OR 97208-4087, or by downloading this information at www.AbbVieSettlement.com. If you are a Class Member, in order to share in the distribution of the Net Settlement Fund, you must submit a Claim Form no later than December 4, 2019, online, by email or by U.S. mail establishing that you are entitled to a recovery. You will be bound by any judgment in the Litigation unless you request to be excluded, in writing, postmarked by October 1, 2019. Please review the Settlement website or the detailed Notice to get instructions on how to exclude yourself.
Any objection to any aspect of the Settlement must be filed with the Clerk of the Court and also delivered by hand or First-Class Mail to each of the following addresses such that it is received no later than October 1, 2019:
Gardy & Notis LLP
126 East 56th Street, 8th Floor
New York, NY 10022
Joshua Z. Rabinovitz
Kirkland & Ellis LLP
300 North LaSalle
Chicago, IL 60654
PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE REGARDING THIS NOTICE.
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