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NORTEL II SETTLEMENT

NORTEL II COURT DOCUMENTS



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Nortel II Stipulation of Settlement

     •     Preliminary Order for Notice and Hearing (USDC SDNY) (Settlement Stipulation Exhibit A)

     •     Notice Plan (Settlement Stipulation Exhibit A-4)

     •     [Proposed] Order and Final Judgment (United States District Court)(Settlement Stipulation Exhibit B)

     •     Supplemental Agreement (Settlement Stipulation
Exhibit C)


     •     Preliminary Order for Notice and Hearing (Ontario Superior Court)(Settlement Stipulation Exhibit D)

     •     Preliminary Order for Notice and Hearing (Quebec Superior Court)(Settlement Stipulation Exhibit E)

     •     [Proposed] Final Order (Ontario Superior Court) (Settlement Stipulation Exhibit F)

     •     [Proposed] Final Order (Quebec Superior Court) Settlement Stipulation Exhibit G)

Nortel II US Complaint

Nortel II Judge's Rulings

     •     Order and Final Judgment

     •     Nortel I and II Ontario Court Decision by Mr. Justice Winkler Approving Settlement and Awarding Ontario Counsel Attorneys Fees

     •     Nortel II Quebec Court Decision Approving Settlement

Nortel II Court Documents in Support of the Settlement, Plan of Allocation and Application for Attorney's Fees

     •     Notice of Lead Plaintiffs' Motion for Final Approval of Proposed Settlement and Plan of Allocation; For Certification of the Class for Settlement Purposes; and for an Award of Attorneys' Fees and Reimbursement of Litigation Expenses

     •     Declaration of John P. Coffey in Support of Proposed Settlement, Plan of Allocation and Award of Attorneys' Fees and Reimbursement of Litigation Expenses

     •     Compendium of Declarations of Plaintiffs' Counsel in Support of Motion for Award of Attorneys' Fees and Reimbursement of Litigation Expenses

     •     Compendium of Relevant Information and Unreported Cases

     •     Memorandum of Law in Support of Lead Counsel's Application for an Award of Attorneys' Fees and Reimbursement of Litigation Expenses

     •     Lead Plaintiff’s Memorandum of Law in Support of Final Approval of Settlement and Plan of Allocation and Certification of the Class for Settlement Purposes

     •     Lead Plaintiffs' Reply Memorandum of Law in Further Support of (1) Lead Plaintiffs' Motion for Final Approval of Settlement and Plan of Allocation and Certification of the Class for Settlement Purposes; and (2) Lead Counsel's Application for an Award of Attorneys' Fees and Reimbursement of Litigation Expenses

     •     Lead Plaintiffs' Response to Late-Filed Objections

     •     Declaration of Jeffrey N. Leibell Submitting for Filing Herein Ontario Class Counsel's "Solicitor's Affidavit of Sakie Tambakos"

     •     Solicitor's Affidavit of Sakie Tambakos

     •     Supplemental Affidavit of David A. Isaac Relating to Late Exclusions and Late Objections

     •     Declaration of Jeanne C. Finegan, APR

     •     Letter to Judge Preska dated December 1, 2006

Nortel II Canadian Settlement Documents

     •     Ontario Settlement Agreement dated June 20, 2006

     •     Ontario Agreement and Confirmation of Supplemental Agreement dated June 20, 2006

     •     Ontario Statement of Claim

     •     Certification Order of Justice Winkler dated June 27, 2006

     •     Quebec Settlement Agreement dated June 20, 2006

     •     Quebec Agreement and Confirmation of Supplemental Agreement dated June 20, 2006

     •     Ontario Notice of Motion

     •     Affidavit of Peter Gallardi

     •     Affidavit of Ron Giammarino

     •     Affidavit of Sakie Tambakos in Support of Ontario National Class Counsel Fees

     •     Affidavit of Sakie Tambakos in Support of Settlement Approval

Nortel II Distribution Orders

     •     US Order

     •     Ontario Order

     •     Quebec Order