IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`EFiled: May 11 2015 01 A2PHEEDT
`Transaction ID 57217397
`{>ETL)
`Case No. 6511-VCL
`EXSoyyy
`
`OF pes
`
`IN RE PRIMEDIA,INC.
`STOCKHOLDERSLITIGATION
`
`)
`)
`
`CONSOLIDATED
`C.A. No. 6511-VCL
`
`AFFIDAVIT OF JOSEPHINE BRAVATA CONCERNING
`MAILING OF THE NOTICE AND CLAIM FORM,
`ISSUING PRESS RELEASE OF THE SUMMARYNOTICE,
`AND OBJECTIONS RECEIVED TO DATE
`
`STATE OF PENNSYLVANIA
`COUNTY OF DELAWARE
`
`)
`)
`
`~
`
`I, Josephine Bravata, being duly sworn, depose and say:
`
`1,
`
`I am the Quality Assurance Manager of Strategic Claims Services
`
`(“SCS”), a nationally recognized class action administration firm.
`
`I have over
`
`thirteen years of experience specializing in the administration of class action
`cases.
`SCS was established in April 1999 and has administered over three
`
`hundred (300) class action cases since its inception. Pursuant to the Court’s
`Scheduling Order dated March 9, 2015 (the “Scheduling Order’),
`the Court
`
`appointed SCS to act as the claims administrator for the settlement reached in the
`
`above-captioned litigation (the “Litigation”).
`
`I am over 21 years of age and am
`
`not a party to this Litigation.
`
`I have personal knowledge of the facts set forth
`
`herein.
`
`2.
`
`I respectfully submit this affidavit in order to provide the Court and
`
`the parties to the Litigation with information regarding: the mailing of the Notice
`
`EFiled: May 11 2015 01:42PM EDT
`Transaction ID 57217397
`Case No. 6511-VCL
`
`
`
`
`
`
`
`
`
`EFiled: May 11 2015 01 A2PHEEDT
`Transaction ID 57217397
`{>ETL)
`Case No. 6511-VCL
`EXSoyyy
`
`OF pes
`
`IN RE PRIMEDIA,INC.
`STOCKHOLDERSLITIGATION
`
`)
`)
`
`CONSOLIDATED
`C.A. No. 6511-VCL
`
`AFFIDAVIT OF JOSEPHINE BRAVATA CONCERNING
`MAILING OF THE NOTICE AND CLAIM FORM,
`ISSUING PRESS RELEASE OF THE SUMMARYNOTICE,
`AND OBJECTIONS RECEIVED TO DATE
`
`STATE OF PENNSYLVANIA
`COUNTY OF DELAWARE
`
`)
`)
`
`~
`
`I, Josephine Bravata, being duly sworn, depose and say:
`
`1,
`
`I am the Quality Assurance Manager of Strategic Claims Services
`
`(“SCS”), a nationally recognized class action administration firm.
`
`I have over
`
`thirteen years of experience specializing in the administration of class action
`cases.
`SCS was established in April 1999 and has administered over three
`
`hundred (300) class action cases since its inception. Pursuant to the Court’s
`Scheduling Order dated March 9, 2015 (the “Scheduling Order’),
`the Court
`
`appointed SCS to act as the claims administrator for the settlement reached in the
`
`above-captioned litigation (the “Litigation”).
`
`I am over 21 years of age and am
`
`not a party to this Litigation.
`
`I have personal knowledge of the facts set forth
`
`herein.
`
`2.
`
`I respectfully submit this affidavit in order to provide the Court and
`
`the parties to the Litigation with information regarding: the mailing of the Notice
`
`EFiled: May 11 2015 01:42PM EDT
`Transaction ID 57217397
`Case No. 6511-VCL
`
`
`
`
`
`
`
`
`
`of Proposed Settlement of Class Action, Settlement Hearing and Right to Appear
`
`(the “Notice”) and the Proof of Claim and Release form (the “Claim Form” and,
`
`together with the Notice, the “Notice Claim Form”); issuing the press release of
`
`the summary notice (the “Summary Notice”); and the objections to the Settlement
`‘Class receivedto date.
`|
`
`MAILING OF THE NOTICE CLAIM FORM AND
`PRESS RELEASE OF THE SUMMARY NOTICE
`
`3.
`
`In connection with the Settlement, SCS has performed or will
`
`perform the following services, among others:
`(i) printing the Notice Claim
`Forms; (ii) distributing the Notice Claim Forms to the Settlement Class; (iii)
`
`arranging the press release of the Summary Notice;
`
`(iv) establishing and
`
`maintaining the website (www.PrimediaSettlement.com);
`
`(v) notifying and
`
`corresponding with brokerage firms and other nominee accounts in order to
`
`effectuate appropriate notice to Settlement Class members;
`
`(vi) answering
`
`inquiries by Settlement Class members; (vii) accepting and processing submitted
`
`Claim Forms; (viii) developing a program for the implementation of the plan of
`
`allocation and claims processing;
`
`(ix) reviewing submitted Claim Forms for
`
`accuracy and completeness and to ensure they are supported by sufficient
`
`documentary evidence; (x) providing notices to those claimants whose Claim
`
`' Formsare deficient or rejected, when appropriate; (xi) calculating each claimants’
`
`
`
`allocated share of the Settlement Fund; and (xii) performing all other services
`
`necessary to administer this class action Settlement.
`
`5.
`
`In order to provide notice to those persons and entities who were
`
`stockholders of Primedia, Inc. between January 11, 2011 and July 13, 2011 and
`
`pursuant to the Court’s Scheduling Order, SCS mailed, by first class mail, the
`
`Notice Claim Form approved by the Court to all individuals and organizations
`
`identified on the stockholder list provided to SCS by the Primedia. This list
`contained names and addresses for stockholders of Primedia common stock
`
`between January 11, 2011 and July 13, 2011. The Notice Claim Forms mailed to
`
`the stockholders were personalized with the class members’ address information
`
`and the number of Primedia shares the class members owned on July 13, 2011.
`
`The Notice Claim Forms were mailed on or before March 23, 2014, as required by
`
`the Court’s Scheduling Order. A copy of the personalized Notice Claim Form is
`
`attached hereto as Exhibit A and a copy of the non-personalized Notice Claim
`
`Form 1s attached hereto as Exhibit B.
`
`6.
`
`In addition, SCS mailed or e-mailed a letter to all brokerage
`
`companies, banks, trust companies and other nominees contained on SCS’s master
`
`mailing list (the “Broker Letter”). The master mailing list consists of the 904
`
`largest banks and brokerage companies (the “Nominee Account Holders”), as well
`
`as 731 mutual funds, insurance companies, pension funds, and money managers
`
`(the “Institutional Groups”) who may have traded Primedia common stock in their
`
`3
`
`
`
`accounts or their clients’ accounts. The Broker Letter instructed the Nominee
`
`Account Holders and Institutional Groups, within ten (10) days of receiving the
`
`Broker Letter, either to mail a copy of the Notice Claim Form to their beneficial
`
`purchasers/owners directly, or provide SCS withalist of the names and addresses
`
`of such beneficial purchasers/owners so that SCS could mail Notice Claim Forms
`
`directly to them. The Broker Letter was mailed or emailed on or before March 23,
`
`2015. A copy of the Broker Letter is attached hereto as Exhibit C.
`
`7.
`
`SCS also sent the Depository Trust Company (“DTC”) the Notice
`
`Claim Form for the DTC to publish on the Legal Notice System (“LENS”). LENS
`
`provides DTC participants the ability to search and downloadlegal notices as well
`
`as receive email alerts based on particular notices or particular CUSIPs once the
`
`legal notice is posted.
`
`8.
`
`SCS established the website, www.PrimediaSettlement.com. The
`
`website contains a home page with a summary notice; an important documents
`
`page with the Notice Claim Form, Stipulation of Settlement, and Scheduling
`
`Order; and a “contact us” page that allows class members to email us. A toll-free
`
`number, as set forth in the Notice, is also available to potential Settlement Class
`
`Members so they can contact SCS for more information regarding the Settlement.
`
`9.
`
`As required by the Court’s Scheduling Order, the Summary Notice
`
`was transmitted once over the PR Newswire on March 30, 2015. Attached hereto
`
`as Exhibit D is the confirmation of transmission.
`
`4
`
`
`
`10.
`
`The notice procedures described above are consistent with the
`
`procedures I have used in each of the securities-related class action settlements in
`
`which I have been involved overthe past thirteen years.
`
`11.
`
`In addition to the 1,635 Broker Letters that were mailed or e-mailed
`
`to the Nominee Account Holders and Institutional Groups, SCS has mailed a total
`
`of 3,735 Notice Claim Formsto potential Settlement Class Members or nominees.
`
`Specifically, of the 3,735 Notice Claim Forms mailed:
`
`(i) 646 Notice Claim
`
`Forms were mailed to the individuals and organizations contained on the
`stockholder list provided by Primedia’s transfer agent; and (ii) an additional 3,089
`
`Notice Claim Forms were mailed in response to requests by Nominee Account
`
`Holders and Institutional Groups, for forwarding, and by other individuals.
`
`12. Out of the 3,735 Notice Claim Forms mailed, 144 were returned. Of
`
`these, the post office provided forwarding addresses for 25; SCS immediately
`
`mailed another Notice Claim Form to these Class Members at
`
`the updated
`
`addresses. The remaining 119 Notice Claim Formsreturned as undeliverable were
`
`“skip-traced” to obtain updated addresses and re-mailed if updated addresses were
`
`provided.
`
`OBJECTIONS RECEIVED TO DATE
`
`13.
`
`To date, SCS has received no objections to the Settlement. The
`
`deadline to file an objection is May 11, 2015.
`
`
`
`
`
`FAYE $sms
`
`Public
`Notary P
`MARPLE TWP, DELAWARE COUNTY
`
`My Commission Expires Aug 27, 2017
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
