The Court has authorized the Detailed Notice because, as a potential Settlement Class Member, you have a right to know about your options before the Court rules on the proposed Individual Defendants Settlements in this Action. The issuance of the Detailed Notice is not an expression of any opinion by the Court concerning the merits of any claim against the Individual Defendants in the Action, and the Court still has to decide whether to approve the Individual Defendants Settlements.

Judge Naomi Reice Buchwald of the United States District Court for the Southern District of New York is overseeing this Action, which is captioned In re Aegean Marine Petroleum Network, Inc. Securities Litigation, No. 1:18-cv-04993 (NRB).

Aegean was an international marine fuel logistics company founded in 1995 by Defendant Dimitris Melissanidis. The Company held its initial public offering in December 2006 and, until its bankruptcy filing in the fall of 2018, its common stock traded on the New York Stock Exchange.

On November 2, 2018, following an internal investigation by outside counsel and retained forensic accountants, the Company announced that a newly-formed Audit Committee had determined that: (a) the Company’s financial results were manipulated by improperly booking approximately $200 million in accounts receivables from bogus transactions with four shell companies controlled by former employees or affiliates of the Company; (b) approximately $300 million in cash and assets had been misappropriated by former affiliates, including through a 2010 contract with OilTank Engineering & Consulting Ltd.; (c) Aegean’s management perpetrated and concealed the alleged financial fraud through various means including the falsification and forging of records such as bank statements, audit confirmations, contracts, invoices and third party certifications; (d) the revenues and earnings of the Company were substantially overstated in the years 2015, 2016 and 2017 and that both year-end and interim financials for these periods should no longer be relied upon and would need to be restated; (e) there were material weaknesses in the Company’s internal controls over financial reporting (“ICFR”) as of December 31, 2015, 2016 and 2017 and, as such, management’s annual report on ICFR as of December 31, 2015, and 2016 included in the Company’s Annual Reports on Form 20-F filed with the U.S. Securities and Exchange Commission (“SEC”), and also for the 2017 interim results, should no longer be relied upon and would need to be restated; (f) insiders had engaged in additional actions to defraud the Company, including engaging in prepayments for future oil deliveries which were never made; and (g) the U.S. Department of Justice had issued a grand jury subpoena in connection with suspected felonies. Then, on November 6, 2018, Aegean commenced bankruptcy proceedings under Chapter 11 of the U.S. Bankruptcy Code in the Southern District of New York, Case No. 18-13374 (MEW).

On February 1, 2019, Lead Plaintiff filed its Consolidated Class Action Complaint (the “Complaint”) alleging that certain officers and directors of Aegean (including Gianniotis and Melissanidis), PwC Greece, PricewaterhouseCoopers International Limited (“PwCIL”), PricewaterhouseCoopers LLP (“PwC US”), Deloitte Greece, Deloitte Touche Tohmatsu Limited (“DTTL”) and Deloitte & Touche LLP (“Deloitte US”) violated the federal securities laws. Among other things, Lead Plaintiff alleged that certain of the defendants engaged in a long-running, multi-faceted fraudulent scheme through which they (a) significantly overstated the Company’s income and revenue; (b) overstated the Company’s assets and the strength of its balance sheet; (c) misled investors concerning the adequacy of the Company’s ICFR; and/or (d) misappropriated Company assets. Lead Plaintiff further alleges that, as a result, Defendants were liable for false and misleading statements to the investors during the Settlement Class Period. In particular, Lead Plaintiff alleges that Gianniotis, who served as Aegean’s Chief Financial Officer since 2008, made false and misleading statements in press releases, at quarterly conference calls, in signed registration statements for the October 2013 and January 2015 public offerings, and in the Company’s certified Form 20-Fs, filed with the SEC. Lead Plaintiff further alleges that Melissanidis profited from the alleged fraud and engaged in insider trading when Aegean repurchased 11,303,031 common shares that he beneficially owned, representing approximately 22% of common shares then outstanding, for proceeds of nearly $100 million in 2016.

On March 29, 2021, the Court issued an order deciding the motions to dismiss filed by the Defendants to end the case. The Court (i) denied the motion by Gianniotis; (ii) denied PwC Greece and Deloitte Greece’s joint motion to dismiss; and (iii) denied Melissanidis’s motion to dismiss the insider trading claims, but granted his motion to dismiss the remaining claims asserted against him. The Court granted motions to dismiss filed by the other Defendants. The parties have since engaged in extensive document discovery. Lead Plaintiff filed a motion asking the Court to certify a class.

Earlier, two settlements with PwC Greece and Deloitte Greece were reached (the “Auditor Settlements”). The Court granted final approval of the Auditor Settlements on September 14, 2023.

THE TIME TO OBJECT TO OR FILE REQUESTS FOR EXCLUSION FROM THE AUDITOR SETTLEMENTS HAS EXPIRED.

On October 25, 2022, at the end of a second mediation, Lead Counsel and Gianniotis’s Counsel reached an agreement in principle to settle all claims against Gianniotis. On March 22, 2023, following numerous rounds of negotiations with the Honorable Stewart Aaron, Lead Counsel and Melissanidis’s Counsel also reached an agreement in principle to settle all claims against Melissanidis.

A class action is a type of lawsuit in which the claims of a number of individuals are resolved together, thus providing the class members with both consistency and efficiency. In a class action lawsuit, the Court selects one or more people, known as class representative(s) or lead plaintiff(s), to sue on behalf of all people with similar claims, commonly known as the class or the class members. Once the class is certified, the Court must resolve all issues on behalf of the class members, except for any Persons who choose to exclude themselves from the class. (For more information on excluding yourself from the Settlement Class, see Question 13 of the Notice.) In the Action, the Court has directed that Lead Plaintiff and Lead Counsel have primary responsibility for prosecuting all claims against Defendants on behalf of investors in the Aegean Securities described above during the Settlement Class Period.

Lead Plaintiff and Lead Counsel believe that the claims asserted against the Individual Defendants have merit. Lead Plaintiff and Lead Counsel recognize, however, the risks and challenges to establishing liability and collecting a judgment against the Individual Defendants, particularly since they are two foreign nationals living in Greece. These risks are outlined in Lead Plaintiff’s Motion for Preliminary Approval of the Individual Defendants Settlements located on this site.

In light of the risks of collecting any sums after a trial as compared to the amount certain provided to the Settlement Class by way of the total payment of $11,949,999 (the “Individual Defendants Settlement Amount”) agreed to in the Individual Defendants Settlements, Lead Plaintiff and Lead Counsel believe that the proposed Individual Defendants Settlements are fair, reasonable and adequate, and in the best interests of the Settlement Class. Lead Plaintiff and Lead Counsel believe that the Individual Defendants Settlements provide a substantial benefit now, namely the payment of $11,949,999 ($11,000,000 from Gianniotis and $949,999 from Melissanidis), as compared to the risk that the claims asserted in the Complaint would produce a similar, smaller or no recovery after summary judgment, trial and appeals and collection efforts, possibly years in the future.

The Individual Defendants have denied and continue to deny each of the claims alleged by Lead Plaintiff in the Action. Each of the Individual Defendants has expressly denied and continues to deny all charges of wrongdoing or liability against him arising out of any of the conduct, statements, acts or omissions alleged, or that could have been alleged, in the Action. The Individual Defendants also have also denied and continue to deny, among other things, the allegations that Lead Plaintiff or the Settlement Class have suffered any damage or that Lead Plaintiff or the Settlement Class were harmed by the conduct alleged in the Action. Gianniotis and Melissanidis have asserted, and continue to assert, that their conduct was at all times proper and in compliance with all applicable provisions of law and believe that the evidence supports their position that they acted properly at all times and that the Action is without merit. Nevertheless, the Individual Defendants have taken the uncertainty and risks inherent in any litigation into account, especially in a complex case such as this. The Individual Defendants have concluded that further conduct of the Action would be protracted and expensive and that it is desirable that the Action be fully and finally settled against them in the manner and upon the terms and conditions set forth in the Individual Defendants Stipulations.

The proposed Individual Defendants Settlements represent a compromise of disputed claims and do not mean that the Individual Defendants have been found liable for any claims asserted by Lead Plaintiff.

If there were no Individual Defendants Settlements and Lead Plaintiff failed to establish any essential legal or factual element of its claims against the Individual Defendants, neither Lead Plaintiff nor the Settlement Class would recover anything from the Individual Defendants. Also, if the Individual Defendants were successful in proving any of their defenses, the Settlement Class could recover substantially less than the amount provided in the Individual Defendants Settlements, or nothing at all. Moreover, there is also a risk to collecting upon judgment against the Individual Defendants, who are Greek residents.

For the purposes of the Individual Defendants Settlements, with the few exceptions listed in Question 7 of the Notice, everyone who fits the following description is a Settlement Class Member (the “Settlement Class”): All Persons who purchased or otherwise acquired Aegean Securities or sold Aegean put options between February 27, 2014 through November 5, 2018, inclusive (the “Settlement Class Period”), and were allegedly damaged thereby. For the purposes of the Individual Defendants Settlements, a “Person” means an individual, corporation, partnership, limited partnership, limited liability partnership, marital community, association, joint stock company, joint venture and joint venturer, estate, legal representative, trust, unincorporated association, government or any political subdivision or agency thereof, and any other business or legal entity.

All Settlement Class Members are entitled to share in the Gianniotis Net Settlement Fund created pursuant to the Gianniotis Settlement and the Melissanidis Net Settlement Fund created pursuant to the Melissanidis Settlement. The “Gianniotis Net Settlement Fund” and the “Melissanidis Net Settlement Fund” are the Settlement Amounts paid by each of the Individual Defendants plus any and all interest earned thereon (respectively, the “Gianniotis Settlement Fund” and the “Melissanidis Settlement Fund”) (together, the “Individual Defendants Settlement Funds”) less (a) any Taxes (“Tax” or “Taxes” means any and all taxes, fees, levies, duties, tariffs, imposts and other charges of any kind (together with any and all interest, penalties, additions to tax and additional amounts imposed with respect thereto); (b) any Notice and Administration Costs (“Notice and Administration Costs” means the costs, fees and expenses that are incurred by the Claims Administrator in connection with (i) providing notice to the Settlement Class; and (ii) administering the Individual Defendants Settlements claims process); (c) any Litigation Expenses (“Litigation Expenses” refers to the reasonable costs and expenses incurred in connection with commencing, prosecuting and settling the Action, which may include the costs and expenses of Lead Plaintiff directly related to its representation of the Settlement Class) awarded by the Court; (d) any attorneys’ fees plus interest awarded by the Court; (e) any other costs expenses or amounts as may be approved by the Court.

RECEIPT OF NOTICE DOES NOT NECESSARILY MEAN THAT YOU ARE A SETTLEMENT CLASS MEMBER OR THAT YOU ARE ENTITLED TO RECEIVE PROCEEDS FROM THE INDIVIDUAL DEFENDANTS SETTLEMENTS.

If you are still not sure whether you are included, you can ask for free help by calling (877) 354-3789. You can also fill out and return the Claim Form to see if you qualify.

Individual Defendants have paid or will pay a total of $11,949,999 into an escrow account ($11,000,000 from Gianniotis and $949,999 from Melissanidis). The $11,949,999 from the Individual Defendants will earn interest, as provided for in the Individual Defendants Stipulations, for the benefit of all Settlement Class Members as provided herein. After deduction of (i) Taxes imposed by any governmental authority, including, but not limited to, any local, state and federal taxes); (ii) Notice and Administration Costs; (iii) Litigation Expenses awarded by the Court; (iv) attorneys’ fees plus interest awarded by the Court; and (v) any other costs, Litigation Expenses or amounts as may be approved by the Court, the balance of the escrow account (the Gianniotis Net Settlement Fund and the Melissanidis Net Settlement Fund) will be distributed to Settlement Class Members in accordance with the Individual Defendants Plan of Allocation, as applicable, discussed in Question 10 of the Notice.

In exchange for the Individual Defendants’ payments, the claims described in response to Question 11 of the Notice will be released, relinquished, discharged and dismissed with prejudice.

Details regarding these Individual Defendants Settlements, as well as the Auditor Settlements are available on this site.

receive from the Individual Defendants Settlements. Your share of the Gianniotis Net Settlement Fund and/or the Melissanidis Net Settlement Fund will depend on the number of valid and timely Claim Forms that Settlement Class Members send in, how many units of Aegean common stock, debt-securities (notes) and/or options you bought and sold, and when you bought and sold them.

You should look at the Individual Defendants Plan of Allocation for a description of the calculations to be made by the Claims Administrator in computing the amounts to be paid to the “Authorized Claimants,” that is, those investors who submit valid and timely Claim Forms establishing that they are Settlement Class Members. See this site.

The Individual Defendants Plan of Allocation will be submitted for the Court’s approval; however, such approval shall in no way disturb or affect the Court’s approval of the Individual Defendants Stipulations and shall be considered separate from the Court’s “Order and Final Judgment Regarding Gianniotis” (defined in the Gianniotis Stipulation) and the Court’s “Order and Final Judgment Regarding Melissanidis” (defined in the Melissanidis Stipulation) discussed in response to Question 11 of the Notice.

The objective of the Individual Defendants Plan of Allocation is to equitably distribute the Gianniotis Net Settlement Fund and/or the Melissanidis Net Settlement Fund to those Settlement Class Members who allegedly suffered economic losses as a result of the alleged wrongdoing against each of the Individual Defendants. Payment pursuant to the Individual Defendants Plan of Allocation will be conclusive against Authorized Claimants. No Person will have any claim against Lead Plaintiff, Lead Counsel, any other Plaintiff and Plaintiff’s Counsel in the Action, the Individual Defendants, Gianniotis’s Counsel, Melissanidis’s Counsel, the other relevant Individual Defendants’ released parties (as defined in Question 11 of the Notice) or their counsel, or the Claims Administrator or other agents designated by Lead Counsel, arising from distributions made substantially in accordance with the Individual Defendants Stipulations, the Individual Defendants Plan of Allocation or further orders of the Court. Gianniotis, Melissanidis, Gianniotis’s Counsel, Melissanidis’s Counsel, the other relevant Individual Defendants’ released parties and their counsel will have no responsibility or liability whatsoever for the investment or distribution of the Gianniotis Settlement Fund and/or the Melissanidis Settlement Fund, the Individual Defendants Plan of Allocation or the determination, administration, calculation or payment of any Claim Form or nonperformance of the Claims Administrator, the payment or withholding of Taxes owed by the Gianniotis Settlement Fund and/or the Melissanidis Settlement Fund or any losses incurred in connection therewith. Lead Plaintiff, the Escrow Agent and the Claims Administrator likewise will have no liability for their reasonable efforts to execute, administer and distribute the Individual Defendants Settlements.

Each Settlement Class Member will be deemed to have submitted to the jurisdiction of the United States District Court for the Southern District of New York with respect to his, her or its Claim Form. Persons and entities that exclude themselves from the Settlement Class will not be eligible to receive a distribution from the Gianniotis Net Settlement Fund and/or the Melissanidis Net Settlement Fund and should not submit Claim Forms.

The Court has reserved jurisdiction to allow, disallow or adjust on equitable grounds the claim of any member of the Settlement Class.

Each of the Individual Defendants Settlements are conditioned on two main events: (a) the entry of Judgment by the Court, after the Court holds a hearing to decide whether to approve the specific the Individual Defendants Settlements, as provided for in the Gianniotis Stipulation and/or in the Melissanidis Stipulation (“Final Approval Hearing”); and (b) the expiration of the applicable period to file all appeals from the Orders and Final Judgments Regarding Gianniotis and/or Melissanidis. If either or both of the Individual Defendants Settlements are approved, it is possible there may be an appeal by someone. There is always uncertainty as to how these appeals will be resolved, and resolving them can take time, perhaps more than a year. Also, if certain conditions of the Gianniotis Settlement or the Melissanidis Settlement, as described in the Individual Defendants Stipulations, are not met, said Individual Defendants Settlements might be terminated and become null and void. In addition, the Claims Administrator will need time to process all of the timely claims before any distribution can be made.

Claim Forms previously submitted in the Auditor Settlements will automatically be considered for recovery in the Individual Defendants Settlements and should not be re-submitted in the Individual Defendants Settlements. Recovery for new Claim Forms submitted in the Individual Defendants Settlements will likewise be considered for recovery in the Gianniotis and Melissanidis Net Settlement Funds as well as the Net Settlement Funds for the Auditor Settlements.

If either or both Individual Defendants Settlements are approved, the Court will enter an order and final judgment with prejudice for each, among other things, dismissing the claims against the Individual Defendants.

The Order and Final Judgment Regarding Gianniotis will dismiss the claims against Gianniotis with prejudice and will provide that Lead Plaintiff and all other Settlement Class Members will be deemed to have―and by operation of the Order and Final Judgment Regarding Gianniotis will have―released, relinquished, dismissed and forever discharged the Gianniotis Released Claims, including Unknown Claims, against each and all of the Gianniotis Released Parties. The terms “Gianniotis Released Claims,” “Unknown Claims,” “Gianniotis Released Party” and “Gianniotis Released Parties” are defined in the Gianniotis Stipulation, which is uploaded on this site.

The Order and Final Judgment Regarding Melissanidis will dismiss the claims against Melissanidis with prejudice and will provide that Lead Plaintiff and all other Settlement Class Members will be deemed to have―and by operation of the Order and Final Judgment Regarding Melissanidis will have―released, relinquished, dismissed and forever discharged the Melissanidis Released Claims, including Unknown Claims, against each and all of the Melissanidis Released Parties. The terms “Melissanidis Released Claims,” “Unknown Claims,” “Melissanidis Released Party” and “Melissanidis Released Parties” are defined in the Melissanidis Stipulation, which is uploaded on this site.

The Gianniotis Stipulation and the Melissanidis Stipulation, available on this site, describe the released claims and released Persons in detail. Please read the Gianniotis Stipulation and the Melissanidis Stipulation carefully. If you have any questions, you can talk to the law firm listed in Question 23 of the Notice, at no cost to you.

If you purchased or otherwise acquired the Aegean Securities described above, are not excluded by the definition of the Settlement Class and do not elect to exclude yourself from the Settlement Class, then you are a Settlement Class Member. As such, you will be bound by the proposed Individual Defendants Settlements if the Court approves either or both of them, and by any judgment or determination of the Court affecting the Settlement Class.

To qualify for payment from the Gianniotis Net Settlement Fund and/or the Melissanidis Net Settlement Fund, you must have recognized loses under the Individual Defendants Plan of Allocation and you must timely send in a Claim Form to the Claims Administrator. Claim Forms submitted for the Auditor Settlements will automatically be considered for recovery in the Individual Defendants Settlements, unless you request exclusion from the Individual Defendants Settlements, and should NOT be re-submitted for the Individual Defendants Settlements.

You may obtain a Claim Form on the Settlement Website maintained by the Claims Administrator, on this site. Read the instructions carefully, fill out the Claim Form, include all supporting documentation the Claim Form asks for, sign it, and either mail it postmarked no later than September 20, 2023 or submit it electronically online no later than September 20, 2023. Please retain all records of your ownership of and transactions in the Aegean Securities, as they may be needed to document your claim.

Unless the Court orders otherwise, if you have not or do not timely submit a Claim Form, you will be barred from receiving any payments from the Gianniotis Net Settlement Fund and/or the Melissanidis Net Settlement Fund but will in all other respects be bound by the Order and Final Judgment Regarding Gianniotis and the Order and Final Judgment Regarding Melissanidis.

Each Settlement Class Member will be bound by all determinations and judgments in this lawsuit, including those concerning the Individual Defendants Settlements, whether favorable or unfavorable, unless such Person or entity mails, by first class mail (or its equivalent outside the U.S.), or otherwise delivers a written Request for Exclusion from the Settlement Class, addressed to:

Yes. The Court appointed Berman Tabacco as Lead Counsel to represent all Settlement Class Members. Lead Counsel may be contacted at the address and phone number listed in response to Question 23 of the Notice. There is no need to retain your own lawyer. If you want to be represented by your own lawyer, you may hire one at your own expense.

At the Final Approval Hearing, Lead Counsel will ask the Court to approve (a) payment of up to 25% of the Individual Defendants Settlement Funds, or approximately $2,987,499.75 plus interest, for attorneys’ fees; and (b) for reimbursement of Counsel’s out-of-pocket expenses that were not reimbursed from the Auditor Settlements, which are estimated not to exceed $120,000. The attorneys’ fees requested will compensate Lead Counsel for their work in continuing the prosecution of the Action and achieving the Individual Defendants Settlement Funds. The Court may, however, award less than this amount. In that case the difference will remain with the Individual Defendants Settlement Funds. Litigation Expenses may include reimbursement of the expenses of Lead Plaintiff in accordance with 15 U.S.C. § 78u-4(a)(4). Any fees and expenses awarded by the Court will be paid from the Individual Defendants Settlement Funds. Settlement Class Members are not personally liable for any such fees or expenses. The estimated average cost for such fees and expenses, if the Court approves Lead Counsel’s fee and expense application, is approximately $0.04 per affected common share. In connection with the Auditor Settlements, the Court approved Lead Plaintiff’s request for a Litigation Expense Fund of $500,000 for the continued prosecution of the case. Lead Plaintiff’s request for expenses in connection with the Individual Defendants Settlements will be separate and apart from this Litigation Expense Fund, which currently has a balance of $249,342.42 which belongs to the Settlement Class and will be returned to the Auditor Settlements Fund.

If you are a Settlement Class Member and do not request exclusion in accordance with the response to Question 13 of the Notice, you can tell the Court that you do not agree with either or both of the Individual Defendants Settlements or any part of them, the Individual Defendants Plan of Allocation, Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses.

Objections or oppositions must be in writing. You must file any written objection or opposition, together with copies of all other supporting papers and briefs, with the Clerk’s Office at the United States District Court for the Southern District of New York at the address set forth below on or before September 28, 2023. You must also serve the papers on Lead Counsel for the Settlement Class and counsel for the Individual Defendants at the addresses set forth below so that the papers are postmarked on or before September 28, 2023.

The Final Approval Hearing on these Individual Defendants Settlements will be held on October 19, 2023, at 11:00 a.m., before the Honorable Naomi Reice Buchwald, United States District Judge, at the United States District Court for the Southern District of New York, either telephonically, via video conference or at 500 Pearl Street, Courtroom 21A, New York, New York 10007.

Unless the Court orders otherwise, any Settlement Class Member who does not object in the manner described above will be deemed to have waived any objection and will be forever foreclosed from making any objection to the proposed Individual Defendants Settlements, the Gianniotis Plan of Allocation, the Melissanidis Plan of Allocation, and/or Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses. Settlement Class Members do not need to appear at the hearing or take any other action to indicate their approval.

If there are objections, the Court will consider them. The Court has discretion to listen to people who have made a written request to speak at the hearing. After the hearing, the Court will decide whether to approve either or both of the Individual Defendants Settlements, the Gianniotis Plan of Allocation, the Melissanidis Plan of Allocation, Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses. We do not know how long these decisions will take.

The hearing may be held telephonically, virtually or moved to a different location or time without additional notice, so it is a good idea to check with Lead Counsel, www.aegeansecuritieslitigation.com or call 1-877-888-9760.

No. Lead Counsel will answer questions the Judge may have. But you are welcome to come at your own expense.

Any Settlement Class Member who did not request to be excluded from the Settlement Class is entitled to appear at the Final Approval Hearing, in person or through a duly authorized attorney, and to show cause (a) why either or both of the Individual Defendants Settlements should not be approved as fair, reasonable and adequate (b) why the Gianniotis Plan of Allocation and/or the Melissanidis Plan of Allocation should or should not be approved; (c) why judgments should not be entered thereon; or (d) why Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses should not be granted. However, you may not be heard at the Final Approval Hearing unless, on or before September 28, 2023, you file a Notice of Intent to Appear and a statement of the position that you will assert and the grounds for the position, together with copies of any supporting papers or briefs with the Clerk of the Court, United States District Court, Southern District of New York, 500 Pearl Street, New York, New York 10007, as described in response Question 16 of the Notice.

Any Settlement Class Member who did not request to be excluded from the Settlement Class is entitled to appear at the Final Approval Hearing, in person or through a duly authorized attorney, and to show cause (a) why either or both of the Individual Defendants Settlements should not be approved as fair, reasonable and adequate (b) why the Gianniotis Plan of Allocation and/or the Melissanidis Plan of Allocation should or should not be approved; (c) why judgments should not be entered thereon; or (d) why Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses should not be granted. However, you may not be heard at the Final Approval Hearing unless, on or before September 28, 2023, you file a Notice of Intent to Appear and a statement of the position that you will assert and the grounds for the position, together with copies of any supporting papers or briefs with the Clerk of the Court, United States District Court, Southern District of New York, 500 Pearl Street, New York, New York 10007, as described in response Question 16 of the Notice.

Yes. The Notice summarizes the proposed Individual Defendants Settlements. More details (including definitions of various terms used in the Detailed Notice) are contained in the pleadings and other papers in this Action, including the Individual Defendants Stipulations, which have been filed with the Court. Lead Plaintiff’s final submissions in support of the Individual Defendants Settlements will be filed with the Court prior to the Final Approval Hearing. In addition, information about the Individual Defendants Settlements (including, among other documents, copies of the Gianniotis Stipulation, the Melissanidis Stipulation, the Claim Form and the Complaint) will be posted on this Settlement Website. If you have any further questions, you may contact Lead Counsel identified in the response to Question 23 of the Notice. You may also call the Claims Administrator at 1-877-888-9760 (Toll Free) to find answers to common questions about the Individual Defendants Settlements and obtain information about the status of the settlement approval process.

All inquiries concerning the Detailed Notice or the Claim Form should be directed to either: