`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MINNESOTA
`
`IN RE: CENTURYLINK SALES
`PRACTICES AND SECURITIES
`LITIGATION,
`
`This Document Relates to:
`Civil File No. 18-296 (MJD/KMM)
`
`MDL No. 17-2795 (MJD/KMM)
`
`PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION,
`APPOINTMENT OF CLASS REPRESENTATIVES AND
`APPOINTMENT OF CLASS COUNSEL
`
`Court-appointed Lead Plaintiff, the State of Oregon by and through the Oregon State
`
`Treasurer and the Oregon Public Employee Retirement Board, on behalf of the Oregon
`
`Public Employee Retirement Fund (“Oregon”), and named plaintiff Fernando Alberto
`
`Vildosola, as trustee for the AUFV Trust U/A/D 02/19/2009 (“Vildosola,” and collectively
`
`with Lead Plaintiff, “Plaintiffs”), by their counsel, hereby move this Court for an entry of
`
`an Order in the above-captioned action:
`
`(1)
`
`certifying pursuant to Rule 23 of the Federal Rules of Civil Procedure of all
`
`persons or entities that purchased or otherwise acquired publicly traded
`
`CenturyLink, Inc. (“CenturyLink”) common stock or 7.60% Senior Notes due
`
`September 15, 2039 during the period between March 1, 2013 to July 12, 2017,
`
`inclusive, and who were damaged thereby;
`
`(2)
`
`appointing Oregon and Vildosola as Class Representatives;
`
`
`
`CASE 0:18-cv-00296-MJD-KMM Document 188 Filed 01/21/20 Page 2 of 3
`
`(3)
`
`appointing Bernstein Litowitz Berger & Grossmann LLP and Stoll Berne
`
`Lokting & Shlachter P.C. as Class Counsel.
`
`This Motion is based on this Notice of Motion, the accompanying Memorandum of
`
`Law in Support of Plaintiffs’ Motion for Class Certification and Appointment of Class
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`Representatives and Class Counsel, the Declaration of Michael D. Blatchley with
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`supporting exhibits A to E, including the Expert Report of Michael L. Hartzmark, Ph.D.,
`
`the papers and pleadings filed in this action, and such further argument and matters as may
`
`be offered at the time of hearing on this Motion.
`
`Dated: January 21, 2020
`
`Respectfully submitted,
`
`
`/s/ Michael D. Blatchley
`John C. Browne, NYS Bar No. 3922747
`Michael D. Blatchley, NYS Bar No. 4747424
`Michael M. Mathai, NYS Bar No. 5166319
`Julia Tebor, NYS Bar No. 5119284
`BERNSTEIN LITOWITZ BERGER &
`GROSSMANN LLP
`1251 Avenue of the Americas
`New York, New York 10020
`Telephone: (212) 554-1400
`Facsimile: (212) 554-1444
`johnb@blbglaw.com
`michaelb@blbglaw.com
`michael.mathai@blbglaw.com
`Julia.tebor@blbglaw.com
`
`Keith S. Dubanevich, OSB No. 975200
`Timothy S. DeJong, OSB No. 940662
`Keil M. Mueller, OSB No. 085535
`STOLL STOLL BERNE LOKTING &
`SHLACHTER P.C.
`209 SW Oak Street, Suite 500
`Portland, OR 97204
`Telephone: (503) 227-1600
`
`2
`
`
`
`CASE 0:18-cv-00296-MJD-KMM Document 188 Filed 01/21/20 Page 3 of 3
`
`Facsimile: (503) 227-6840
`kdubanevich@stollberne.com
`tdejong@stollberne.com
`kmueller@stollberne.com
`
`Special Assistant Attorneys General and Counsel
`for Lead Plaintiff the State of Oregon by and
`through the Oregon State Treasurer and the
`Oregon Public Employee Retirement Board, on
`behalf of the Oregon Public Employee Retirement
`Fund and Plaintiff Fernando Alberto Vildosola,
`as trustee for the AUFV Trust U/A/D 02/19/2009,
`and Lead Counsel for the Class
`
`Richard A. Lockridge, MN No. 64117
`Gregg M. Fishbein, MN No. 202009
`Kate M. Baxter-Kauf, MN No. 392037
`LOCKRIDGE GRINDAL NAUEN P.L.L.P.
`100 Washington Avenue S, Suite 2200
`Minneapolis, MN 55401
`Telephone: (612) 596-4044
`Facsimile: (612) 339-0981
`ralockridge@locklaw.com
`gmfishbein@locklaw.com
`kmbaxter-kauf@locklaw.com
`
`Liaison Counsel for Plaintiffs
`
`3
`
`
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