When and Where will the Court decide whether to approve the Settlement? Do I have to come to the hearing? May I speak at the hearing if I don’t like the Settlement?

Settlement Class Members do not need to attend the Settlement Hearing.  The Court will consider any submission made in accordance with the provisions below even if a Settlement Class Member does not attend the hearing.  You can participate in the Settlement without attending the Settlement Hearing

The Settlement Hearing will be held on November 6, 2019 at 3:30 p.m., before the Honorable Edgardo Ramos at the United States District Court for the Southern District of New York, Thurgood Marshall United States Courthouse, Courtroom 619, 40 Foley Square, New York, NY 10007.  The Court reserves the right to approve the Settlement, the Plan of Allocation, Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses and/or any other matter related to the Settlement at or after the Settlement Hearing, and to adjourn the Hearing date, without further notice to the members of the Settlement Class.

Any Settlement Class Member who or which does not request exclusion may object to the Settlement, the proposed Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses.  Objections must be in writing.  You must file any written objection, together with copies of all other papers and briefs supporting the objection, 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 October 16, 2019.  You must also serve the papers on Lead Counsel and on Defendants’ Counsel at the addresses set forth below so that the papers are received on or before October 16, 2019.

Clerk’s Office

United States District Court
Southern District of New York
Clerk of the Court
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007

Lead Counsel

Glancy Prongay & Murray LLP
Attn: Charles Linehan
1925 Century Park East,
Suite 2100
Los Angeles, CA 90067

-and-

Berger Montague
Attn: Lawrence Deutsch
1818 Market Street, Suite 3600
Philadelphia, PA 19103

Defendants’ Counsel

Sheppard, Mullin, Richter & Hampton, LLP
Attn: John P. Stigi III
1901 Avenue of The Stars, Suite 1600
Los Angeles, CA 90067

-and-

Cahill Gordon & Reindel LLP
Attn: Bradley J. Bondi
1990 K Street, N.W., Suite 950
Washington, D.C. 20006

-and-

Marcos D. Jiménez, P.A.
Attn: Marcos Daniel Jiménez
255 Alhambra Circle, Suite 800 Coral
Gables, FL 33134

Any objection (a) must state the name, address and telephone number of the person or entity objecting and must be signed by the objector; (b) must contain a statement of the Settlement Class Member’s objection or objections and the specific reasons for each objection, including any legal and evidentiary support the Settlement Class Member wishes to bring to the Court’s attention; and (c) must include documents sufficient to prove membership in the Settlement Class, including the number of shares of Patriot National common stock that the objecting Settlement Class Member purchased/acquired and/or sold during the Settlement Class Period (i.e., between January 15, 2015 and November 28, 2017, inclusive), as well as the dates and prices of each such purchase/acquisition and sale.  You may not object to the Settlement, the Plan of Allocation or Lead Counsel’s motion for attorneys’ fees and reimbursement of Litigation Expenses if you exclude yourself from the Settlement Class or if you are not a member of the Settlement Class.

You may file a written objection without having to appear at the Settlement Hearing.  You may not, however, appear at the Settlement Hearing to present your objection unless you first file and serve a written objection in accordance with the procedures described above, unless the Court orders otherwise.

If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses, and if you timely file and serve a written objection as described above, you must also file a notice of appearance with the Clerk’s Office and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth above so that it is received on or before October 16, 2019.  Persons who intend to object and desire to present evidence at the Settlement Hearing must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and exhibits they intend to introduce into evidence at the hearing.  Such persons may be heard orally at the discretion of the Court.

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing.  However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth above so that the notice is received on or before October 16, 2019.

The Settlement Hearing may be adjourned by the Court without further written notice to the Settlement Class.  If you intend to attend the Settlement Hearing, you should confirm the date and time with Lead Counsel.

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 shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses.  Settlement Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval.

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