By submitting this form, you are acknowledging that you have agreed to be represented by Ryan & Maniskas, LLP and such co-counsel as they deem appropriate to associate with in this action.
We have advised you that we have conducted a thorough investigation into the facts and circumstances surrounding the allegations contained in the Complaint, and we believe them to be meritorious. You understand that in seeking to be a plaintiff, you are undertaking certain fiduciary duties and responsibilities, which require you to adequately and fairly represent the class by becoming generally familiar with this litigation so that you can monitor, review and participate with counsel in the prosecution of the action. You may and should confer with us at any time you feel it is appropriate to do so. Additionally, you understand that in order to prosecute this action that you must retain some of your shares.
Our firm prosecutes class actions and is seeking to undertake this litigation on a contingent fee basis. This means we will not seek payment of any fees unless the lawsuit generates a recovery or benefit for the class. The payment of our fees in this suit is subject to court approval, and we generally seek to have our fees calculated as a percentage of the full amount of the funds recovered, i.e., as a percentage of the amount recovered before the deduction of our fees and expenses.
We will advance all costs and expenses that we deem necessary to pursue an appropriate recovery in this suit. Typical costs and expenses include, but are not limited to, telephone, fax transmission, court costs, computer research, copy, and postage expenses, as well as more substantial items, such as the cost of travel, deposition, trial, mediation expenses, and expert witness and consultant fees. If the lawsuit generates a recovery for the class, we will apply to the Court to have our costs and expenses reimbursed from the settlement fund remaining after the attorneys’ fees have been paid. If there is no recovery, you will not be responsible for any costs.
In the course of the lawsuit, we may, without notice to you, retain and/or work with other law firms, in which case, we would divide any legal fees we receive with such other firms. You agree that we may divide fees with other attorneys for serving as local counsel, or for referral fees, or other services performed. You also agree that with respect to situations in which our co-counsel perform services, they may be entitled to receive between 5% and 10% of our firm’s overall fee. The division of attorneys’ fees with other counsel may be determined upon a percentage basis or upon time spent in assisting the prosecution of the action. The division of fees with other counsel is our sole responsibility and will not increase the fees described above. If we determine at any time that the prosecution of these claims is not feasible or is contrary to justice or the standards of good faith, we are then entitled to withdraw from the representation in the action, with reasonable notice to you. This agreement shall be governed by the laws of the Commonwealth of Pennsylvania. All disputes, disagreements and claims arising out of or related to this agreement shall be resolved exclusively through binding arbitration pursuant to the Rules of the American Arbitration Association.
We look forward to working with you.