CERTIFICATION OF LEAD PLAINTIFF

Pursuant to Federal Securities Laws

SAMPLE

  1. I make this declaration pursuant to Section 101 of the Private Securities Litigation Reform Act of 1995 as required by Section 21D(a)(2) of Title I of the Securities Exchange Act of 1934.
  2. I have reviewed a version of the Complaint and authorize its filing on my behalf and on behalf of all others similarly situated.
  3. I did not purchase shares of ABC Company common stock, the security that is the subject of this action, at the direction of counsel or in order to participate in any action arising under Title I of the Securities Exchange Act of 1934.
  4. I am willing to serve as a representative party on behalf of the class, including providing testimony at deposition and trial, if necessary.
  5. To the best of my current knowledge, the following are all of my transactions in ABC Company securities during the class period specified in the Complaint:
    Date Number of Shares Purchase or Sale Price
           
           
           
           
  6. During the three year period preceding the date on which this certification is signed, I have either:
    1. Not sought to serve as a representative party on behalf of a class under Title I of the Securities Exchange Act of 1934.

      OR

    2. Served or sought to serve as a representative party on behalf of a class under Title I of the Securities Exchange Act of 1934 in the following action(s):

       

  7. I will not accept any payment for serving as a representative party on behalf of the class beyond plaintiff's pro rata share of any recovery, except as ordered or approved by the court, including any award for reasonable costs and expenses (including lost wages) directly relating to the representation of the class.
  8. I make this declaration without waiver of any applicable privileges and without waiver of any right to challenge the necessity for, or the constitutionality of, this declaration or to object to the filing of this declaration on any ground whatsoever.
  9. The matters stated in this declaration are true to the best of my current knowledge, information and belief.
  10. I hereby certify, under penalty of perjury, that the foregoing is true and correct.