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Robbins Geller Rudman & Dowd LLP Announce Proposed Settlement in the Valeant Securities Settlement
[February 13, 2020]

Robbins Geller Rudman & Dowd LLP Announce Proposed Settlement in the Valeant Securities Settlement


The following statement is being issued by Robbins Geller Rudman & Dowd LLP regarding the Valeant Securities Settlement:





 

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

In re VALEANT PHARMACEUTICALS

)

Master No. 3:15-cv-07658-MAS-LHG

INTERNATIONAL, INC. SECURITIES LITIGATION

)

CLASS ACTION

 

)

Judge Michael A. Shipp

This Document Relates To:

)

Magistrate Judge Lois H. Goodman

Case No. 3:15-cv-07658-MAS-LHG.

)

Special Master Hon. Dennis M. Cavanaugh, U.S.D.J. (Ret.)

 

)

 

 

SUMMARY NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION

 

TO:

 

ALL PERSONS AND ENTITIES THAT PURCHASED OR OTHERWISE ACQUIRED VALEANT PHARMACEUTICALS INTERNATIONAL, INC. ("VALEANT," NOW KNOWN AS BAUSCH HEALTH COMPANIES INC.) COMMON STOCK, VALEANT DEBT SECURITIES, OR CALL OPTIONS ON (News - Alert) VALEANT COMMON STOCK, OR SOLD PUT OPTIONS ON VALEANT COMMON STOCK, DURING THE PERIOD BETWEEN JANUARY 4, 2013 AND MARCH 15, 2016, INCLUSIVE (THE "CLASS PERIOD")

THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION. PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY.

YOU ARE HEREBY NOTIFIED that a hearing will be held on May 27, 2020, at 10:00 a.m., before the Honorable Dennis M. Cavanaugh, U.S.D.J. (Ret.), Special Master, at the Clarkson S. Fisher Building & U.S. Courthouse, 402 East State Street, Courtroom 1, Trenton, New Jersey 08608, to determine whether: (1) the proposed settlement (the "Settlement") of the above-captioned action as set forth in the Stipulation of Settlement ("Stipulation")1 for $1,210,000,000.00 in cash should be approved by the Court as fair, reasonable and adequate; (2) the Judgment as provided under the Stipulation should be entered dismissing the Litigation against all Defendants with prejudice except PriceWaterhouseCoopers LLP ("PwC"); (3) the Class should be finally certified for purposes of the Settlement only; (4) to award Lead Counsel attorneys' fees and charges and expenses out of the Settlement Fund (as defined in the Notice of Pendency and Proposed Settlement of Class Action ("Notice"), which is discussed below) and, if so, in what amount; (5) to award Plaintiffs out of the Settlement Fund pursuant to 15 U.S.C. §78u-4(a)(4) in connection with their representation of the Class and, if so, in what amount; and (6) the Plan of Allocation should be approved by the Court as fair, reasonable and adequate.

IF YOU PURCHASED OR OTHERWISE ACQUIRED VALEANT SECURITIES2 BETWEEN JANUARY 4, 2013 AND MARCH 15, 2016, INCLUSIVE, YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT OF THIS LITIGATION.

To share in the distribution of the Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release form by mail (postmarked no later than May 6, 2020) or online (no later than May 6, 2020). Your failure to submit your Proof of Claim and Release by May 6, 2020, will subject your claim to rejection and preclude your receiving any of the recovery in connection with the Settlement of this Litigation. To exclude yourself from the Class, you must submit a written request for exclusion so that it is postmarked no later than May 6, 2020, in accordance with the instructions set forth in the Notice. If you request exclusion, you will not recover money pursuant to the Settlement.

If you have not received a copy of the Notice, which more completely describes the Settlement and your rights thereunder (including your right to exclude yourself from the Class or to object to the Settlement), and a Proof of Claim and Release, you may obtain these documents, as well as a copy of the Stipulation and other settlement documents, online at www.ValeantSecuritiesSettlement.com, or by writing to:

Valeant Securities Settlement
c/o Gilardi & Co. LLC
P.O. Box (News - Alert) 43337
Providence, RI 02940-3337

Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.

Inquiries, other than requests for the Notice or for a Proof of Claim and Release, may be made to a representative of Lead Counsel:

ROBBINS GELLER RUDMAN & DOWD LLP
Rick Nelson
c/o Shareholder Relations
655 West Broadway, Suite 1900
San Diego, CA (News - Alert) 92101
Telephone: 800/449-4900

IF YOU ARE A CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF ALLOCATION, THE REQUEST BY LEAD COUNSEL FOR AN AWARD OF ATTORNEYS' FEES AND EXPENSES AND/OR THE AWARDS TO PLAINTIFFS PURSUANT TO 15 U.S.C. §78u-4(a)(4) IN CONNECTION WITH THEIR REPRESENTATION OF THE CLASS. ANY OBJECTIONS MUST BE FILED WITH THE COURT AND MAILED TO LEAD COUNSEL AND VALEANT'S COUNSEL BY MAY 6, 2020, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE.

 

DATED: January 23, 2020

BY ORDER OF THE

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

 
____________________

1 The Stipulation can be viewed and/or obtained at www.ValeantSecuritiesSettlement.com. Capitalized terms not otherwise defined herein have the meaning given to them in the Stipulation.

2 "Valeant Securities" means Valeant equity securities as defined in 15 U.S.C. §78c(11) and 17 C.F.R. §240.3a11-1, and Valeant debt securities, including Valeant common stock; options on Valeant common stock, defined to be the purchase or acquisition of call options and the sale of put options; and the following Valeant senior notes: (1) 5.375% senior notes due 2020; (2) 5.875% senior notes due 2023; (3) 6.125% senior notes due 2025; (4) 5.5% senior notes due 2023; (5) 5.625% senior notes due 2021; (6) 6.75% senior notes due 2018; (7) 7.5% senior notes due 2021; (8) 6.375% senior notes due 2020; (9) 7.25% senior notes due 2022; (10) 6.75% senior notes due 2021; or (11) 7.0% senior notes due 2020. This definition does not include securities at issue in the Canadian Actions.

 


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