Objection Instructions
At the Settlement Hearing, any Class member may appear personally or by counsel, and show cause, if any, why the Settlement in accordance with and
as set forth in the Stipulation should not be approved as fair, reasonable, and adequate and in the best interests of the Class; why the Proposed Order
and Partial Judgment should not be entered in accordance with and as set forth in the Stipulation; or why the Court should not grant any application
for a Fee and Expense Award or Incentive Award; provided, however, that unless the Court in its discretion otherwise directs, no Class member,
or any other person, shall be entitled to object to any terms or condition of the proposed Settlement, or the Proposed Order and Partial Judgment to be
entered thereon, or any Fee and Expense Award or Incentive Award, and no papers, briefs, pleadings, or other documents submitted by any
Class member or any other person (excluding a party to the Stipulation) shall be received or considered, except by order of the Court for good cause shown,
unless no later than ten calendar days prior to the Settlement Hearing, such person files with the Register in Chancery, the Court of Chancery of the
State of Delaware, and serves on the attorneys listed below:
(a) a written and signed notice of intention to appear, which states the name, address, telephone number, and email address (if available)
of the objector and, if represented, his, her, or its counsel;
(b) documentation evidencing membership in the Class;
(c) a written and detailed statement of objections to any matter before the Court; and
(d) the grounds therefor or the reasons for wanting to appear and be heard, as well as all documents or writings the Court shall be asked to consider.
These writings must also be served, on or before such filing with the Court, by hand or first-class mail upon the following attorneys:
R. Bruce McNew
Cooch & Taylor, P.A.
The Brandywine Building
1000 N. West Street, Suite 1500
Wilmington, Delaware 19801
Christopher M. Mason
Nixon Peabody LLP
Tower 46
55 West 46th Street
New York, New York 10036
David A. Dorey
Blank Rome LLP
1201 Market Street, Suite 800
Wilmington, Delaware 19801
For more information, please see the Scheduling Order or
Settlement Agreement.