1
.
PLAINTIFFS BRIEF IN SUPPORT OF THE PROPOSED SETTLEMENT AND APPLICATION FOR AN AWARD OF COUNSEL FEES AND REIMBURSEMENT OF EXPENSES
|
EXTRACTED KEY WORDS
SHERIDAN
COUNSEL
FEE
SETTLEMENT
COURT
PROPOSED SETTLEMENT
LITIGATION
REASONABLEAND
DEL
YORK
ATTORNEYS
VESTAR
EISENBERG
CONTINGENT NATURE
SHAREHOLDERS
DEFENDANTS
DISCLOSURES
CLASS ACTION CERTIFICATION
SHERIDAN HEALTHCARE
MANAGEMENT
TRANSACTION
NEGOTIATIONS
INDUSTRIES
CLASS MEMBERS
STULL
ALLIED ARTISTS
ARTISTS PICTURE
FINANCIAL ADVISORS
PRACTICE MANAGEMENT COMPANIES
|
IN THE COURT `OF CHANCERY OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
-----------------------------------------------~-------------~
STANLEY HENNER,
Plaintiff,
1'. C.A. No. 17067 NC
SHERIDAN HEALTHCARE, INC., et al., :
Def'endants.
--------------~------------------------------~---------------x
ROBERT BET%,
Plaintiff,
v. C A . N o . 1 7 0 7
SHERIDAN HEALTHCARE, INC., et al.,
Delend;mts.
___________---____--------" ---..----..___.._----.---------------- x
BOB SCHOENFIELD,
Plaintiff.
v. C.A. No. 17080 NC
SHERIDAN HEALTHCARE: INC., et al.,
De fendants.
-------------------------------------------------------------~
PLAINTIFFS BRIEF IN SUPPORT OF THE
PROPOSED SETTLEMENT AND APPLICATION
FOR AN AWARD OF COUNSEL FEES
AN11 REIMBURSEMENT OF EXPENSES
ROSENTHAL, MONHAIT, GROSS
& GODDESS, P.A.
Norman M. Monhait
Mellon Bank Center, Suite 1401
919 North Market Street
Wilmington, Delaware 1980 1
(302) 656-4433
Attorneys for Plaintiffs
SNIPPETS:
SHERIDAN HEALTHCARE, INC., et al.,
PROPOSED SETTLEMENT AND APPLICATION
New York, New York 10176
STULL STULL 8L BRODY
REASONABLEAND SHOULDBEAPPROVEDBYTHE
The Difficulty Of The Litigation
And The Efforts Of Plaintiffs'
Allied Artists Picture Corp. v Baron,
Citron v. -__ Earle M. Jorgensen Co:, Del.
In Re Cmntra Managed Care Shareholders
LRe Envirodyne Industries Inc. Shareholders Litig.,
and an award of counsel fees,
Plaintiffs filed three putative class action lawsuits against defendants
I The following actions are before the Court:
During the relevant time period, defendant Eisenberg was Chairman of the Board, President and
Sheridan Healthcare, Inc. and Vestar Capital Partners, Inc.
Offer and a Rule 13E-3 Transaction Statement.
extensive arm's-length negotiations regarding a potential settlement.
Sheridan/Vestar amended the Merger Agreement to reduce the termination fee from $6.4
application for attorneys' fees and expenses, and the date for filing objections has expired.
Sheridan is a physician practice management company which employs or
financial advisors continued discussions with the three entities.
regarding the adequacy of the disclosures.
Vestar's conclusion, based on the advice of its outside accounting advisors, that the
CLASS ACTION CERTIFICATION IS PROPER IN THIS CASE;
All Class members faced the same injury flowing from defendants'
the litigation and the efforts of counsel; the contingent nature of the case; and the
|
