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Case 3:10-cv-00132-ECR -WGC Document 97-2 Filed 03/27/12 Page 6 of 21 or otherwise actionable under the securities laws; (3) the extent (if any) that the alleged misrepresentations and omissions influenced the trading prices of Ormat securities during the relevant period; and (4) the method for determining whether, and the extent to which, purchasers of Ormat stock suffered injury and damages that could be recovered at trial. Attorneys’ Fees and Expenses: Co-Lead Counsel have not received any payment for their work or expenses incurred in investigating the facts, conducting this Litigation, and negotiating the Settlement on behalf of the Lead Plaintiffs and the Class. Co-Lead Counsel will ask the Court for attorneys’ fees not to exceed 30% of the Settlement Fund and expenses not to exceed $195,000 to be paid from the Settlement Fund. If the above amounts are requested and approved by the Court, the average cost per share of securities will be approximately $0.11 per share, making the estimated recovery per share after fees and expenses approximately $0.18. Dismissal and Releases: If the proposed Settlement is approved, the Court will enter a Final Judgment and Order of Dismissal with Prejudice (the “Judgment”). The Judgment will dismiss the Released Claims with prejudice as to the Released Persons, which include the Defendants, Plaintiffs, and their respective Related Parties (including, but not limited to, their parents, subsidiaries and affiliates, and all of their employees, directors and officers). The Judgment will provide that all Class Members shall be deemed to have released and forever discharged all Released Claims (to the extent Members of the Class have such claims) against all Released Persons. The terms of the releases, including the meaning of the term “Released Claims,” are set forth in the Proof of Claim and Release form that is enclosed. Deadlines: Submit Claim: File Objection: Request Exclusion Court Hearing on Fairness of Settlement: _______________, 2012 _______________, 2012 2012 2012 4PDF Image | Lawsuite ORMAT TECHNOLOGIES
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