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The Honorable Marsha J. Pechman






UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE












Case No.: C09-1557 (MJP)

ECF CASE




ORAL ARGUMENT REQUESTED

v.

Plaintiff,

DORAL BANK PUERTO RICO, on Behalf of
Itself and All Others Similarly Situated,





WASHINGTON MUTUAL ASSET
ACCEPTANCE CORPORATION; DAVID
BECK; DIANE NOVAK; THOMAS
LEHMANN; STEPHEN FORTUNATO;
DONALD WILHELM WAMU CAPITAL
CORPORATION; MOODY’S INVESTORS
SERVICES, INC.; THE MCGRAW-HILL
COPMANIES, INC.; FIRST AMERICAN
CORPORATION and FIRST AMERICAN
EAPPRAISEIT, LLC,



Defendants.





















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DECLARATION OF CHRISTOPHER LOMETTI IN SUPPORT OF DORAL BANK

PUERTO RICO’S MOTION FOR APPOINTMENT OF LEAD PLAINTIFF AND

APPROVAL OF SELECTION OF LEAD COUNSEL


No. C09-1557-MJP





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I, Christopher Lometti, swear as follows:

1.

I am Of Counsel to the law firm of Cohen Milstein Sellers & Toll PLLC (“Cohen

Milstein”), counsel of record for Doral Bank Puerto Rico (“Doral Bank”). I make this

declaration in support of the motion of Doral Bank for Appointment as Lead Plaintiff and

Approval of its Selection of Lead Counsel. I have personal knowledge of the matters stated

herein and, if called upon, I could and would competently testify thereto.

2.

Attached are true and correct copies of the following exhibits:

Exhibit A:

Exhibit B:

Exhibit C:

Exhibit D:

December 24, 2009 PSLRA Notice;

Doral Bank’s Certification of Securities Class Action;

Cohen Milstein Sellers & Toll PLLC firm résumé.

Doral Bank’s Amended Securities Class Action Complaint;

3.

Cohen Milstein is currently serving as lead counsel in several securities class




actions which involve the issuance of mortgage-backed securities, including:

In re Bear Stearns Mortgage Pass-Through Certificates Securities Litigation,

08-cv-8093-LTS (S.D.N.Y.)



In re Lehman Brothers Mortgage-Backed Securities Litigation, 09-md-2017-

LAK, 08-cv-6762-LAK (S.D.N.Y.)

4.

I declare under penalty of perjury under the laws of the United States of America



that the foregoing is true and correct.

Executed this 22nd day of February, 2010, at New York, New York.













/s/ Christopher Lometti



Christopher Lometti





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CERTIFICATE OF SERVICE

I hereby certify that on the 22nd day of February, 2010, I electronically filed the

foregoing with the Clerk of the Court using the CM/ECF system which will send notification of

such filing all counsel of record.

DATED this 22nd day of February, 2010 at New York, New York.







By: /s/ Daniel B. Rehns
Daniel B. Rehns (Pro Hac Vice)
150 East 52nd Street, Thirtieth Floor
New York, New York 10022
Telephone: (212) 838-7797
[email protected]








No. C09-1557-MJP

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