United States District Court for the Central District of California

Loan Depot Inc.

Motion Deadline: 
Saturday, November 6, 2021
Summary: 

Bottini & Bottini, Inc., a law firm specializing in securities class action litigation, announces that it has filed a class action lawsuit on behalf of all persons who purchased the common stock of LOAN DEPOT, Inc. (NYSE: “LDI”) pursuant to the Registration Statement issued in connection with the Company’s February 16, 2021 initial public offering (“IPO”). The lawsuit—pending in the United States District Court for the Central District of California —seeks to recover damages under the federal securities laws for those who purchased LOAN DEPOT stock.
If you purchased shares of LOAN DEPOT Holdings, Inc. and would like to assist with the case as a lead plaintiff, you must, no later than November 6, 2021, request that the Court appoint you a lead plaintiff of the proposed class.

Company Name:

Stock Symbol:

Date Filed: 
Friday, September 3, 2021
Retention Agreement: 

This Retention Agreement governs the retention of Bottini & Bottini, Inc. (the “Attorneys”) by those institutions or individuals (the “Client”) who have authorized the Attorneys to prosecute claims arising out of their purchase of Loan Depot Inc.'s stock.
WHEREAS the Client has authorized the Attorneys to prosecute claims relating to the securities of Loan Depot Inc. (the “Litigation”);
WHEREAS the Litigation entails numerous complex factual and legal issues and entails considerable risk;
WHEREAS the Litigation requires the expenditure of substantial resources by the Attorneys retained to prosecute the Litigation;
WHEREAS the Client seeks to maximize their recovery while limiting the expenditure of their own resources; and
NOW, THEREFORE, the Client and the Attorneys AGREE AS FOLLOWS:
I. SCOPE OF SERVICES/CASE HANDLING
A. Upon execution by Client, Attorneys are retained to provide legal services for the purpose of seeking damages and other relief in the Litigation. Client provides authorization to seek appointment as Lead Plaintiff in the class action, while the Attorneys will seek to be appointed Class Counsel. If this occurs, the Litigation will be prosecuted as a class action.
B. Attorneys are authorized to prosecute the Litigation. The appointed Lead Plaintiffs will monitor, review and participate with counsel in the prosecution of the Litigation. The Attorneys shall consult with the appointed Lead Plaintiffs concerning all major substantive matters related to the Litigation, including, but not limited to, the complaint, dispositive motions and settlement. Because of potential differences of opinion between Clients concerning, among other things, strategy, goals and objectives of the Litigation, the Attorneys shall consult with the appointed Lead Plaintiffs as to the courses of action to pursue. The Client agrees to abide by the decisions of the appointed Lead Plaintiffs, which shall be final and binding on all Clients.
C. The Attorneys shall provide sufficient resources, including attorney time and capital for payment of costs and expenses, to vigorously prosecute the Litigation.
D. Any recovery will be divided among Clients based on the recognized loss by each Client as calculated by a damage allocation plan which will be prepared by a financial expert, provided to the appointed Lead Plaintiffs, be subject to the Court's approval and will account for such factors as size of stock ownership, date of purchase, date of sale and continued holdings, if any.
II. CONTINGENT FEE AGREEMENT
A. The Attorneys shall advance all expenses in the Litigation. The Client is not liable to pay any of the expenses of the Litigation, whether attorneys' fees or costs. Recovery of costs and other expenses is contingent upon a recovery being obtained. If no recovery is obtained, Client will owe nothing for costs and other expenses. In the event that an order is entered awarding costs and expenses in favor of defendants, Attorneys will be responsible for such costs and expenses, not the Client.
B. If there is a recovery in the Litigation, whether by settlement or judgment, the Attorneys shall be compensated via payment of a reasonable percentage of any recovery as approved by the Court, which amount shall include attorneys’ fees plus reasonable disbursements in the Litigation. “Disbursements” shall include, but not be limited to, costs of travel, telephone, copying, fax transmission, depositions, investigators, messengers, mediation expenses, computer research fees, court fees, expert fees, other consultation fees and paralegal expenses. Any recovery in the Litigation shall first be used to reimburse disbursements.
C. In the event that the Litigation is resolved by settlement under terms involving any “in-kind” payment, such as stock, the contingent fee agreement shall apply to such “in-kind” payment.
III. GENERAL REQUIREMENTS
A. This Agreement may not be assigned by the Attorneys.
B. Client agrees to cooperate in the prosecution of the suit including providing documents to substantiate the Client's claim, and to cooperate in providing discovery information, including a deposition if necessary.
C. Client recognizes that the Attorneys are representing other Loan Depot Inc. investors in the Litigation. The Client agrees that any conflicts caused by such representation are waived.
IV. TERMINATION
A. Client may terminate this Agreement as to any Attorneys, with or without cause and without penalty, by providing the Attorneys with written notice of termination. Attorneys may terminate this agreement with or without cause and without penalty, by providing client with written notice of termination if the Client fails to cooperate in the prosecution of this action or such other reason as may be approved upon application to the Court.
B. If the Attorneys are terminated for any reason, Attorneys shall be entitled (a) to be reimbursed, pursuant to §II above, for reasonable out-of-pocket costs and expenses that they incurred, but only if and when recovery is obtained, and (b) to be paid such compensation as might be payable to them in accordance with this Agreement, but only if and to the extent and at the time compensation is payable to the Attorneys from any recovery in the Litigation pursuant to §II above.
V. NOTICE
A. All notices to be given by the parties hereto shall be in writing and served by depositing same in the United States Post Office, postage prepaid and registered as follows:
TO THE CLIENT
The address set out in the Authorization to File Loan Depot Inc. Claim form.
TO ATTORNEYS

Bottini & Bottini, Inc.

7817 Ivanhoe Ave., Suite 102

La Jolla, California 92037

Attention: Francis A. Bottini, Jr.

B. Any actions arising out of this Agreement shall be governed by the laws of California, and shall be brought and maintained in the San Diego Superior Court, which shall have exclusive jurisdiction thereof.
C. This agreement, along with the signed Certification and Authorization of Named Plaintiff, sets forth the entire Agreement between the parties, and supersedes all other oral or written provisions.

Notice of Opportunity: 

Bottini & Bottini, Inc., a law firm specializing in securities class action litigation, announces that it has filed a class action lawsuit on behalf of all persons who purchased the common stock of LOAN DEPOT, Inc. (NYSE: “LDI”) pursuant to the Registration Statement issued in connection with the Company’s February 16, 2021 initial public offering (“IPO”). The lawsuit—pending in the United States District Court for the Central District of California —seeks to recover damages under the federal securities laws for those who purchased LOAN DEPOT stock.
If you purchased shares of LOAN DEPOT Holdings, Inc. and would like to assist with the case as a lead plaintiff, you must, no later than November 6, 2021, request that the Court appoint you a lead plaintiff of the proposed class.

join now

Class Period: 
Press Release: 

IMPORTANT LOAN DEPOT INC. INVESTOR ALERT: Bottini & Bottini, Inc. Has Filed a Securities Class Action Lawsuit on Behalf of LOAN DEPOT Investors (NYSE: “LDI”)

San Diego, California, September 7, 2021. Bottini & Bottini, Inc., a law firm specializing in securities class action litigation, announces that it has filed a class action lawsuit on behalf of all persons who purchased the common stock of LOAN DEPOT, Inc. (NYSE: “LDI”) pursuant to the Registration Statement issued in connection with the Company’s February 16, 2021 initial public offering (“IPO”). The lawsuit—pending in the United States District Court for the Central District of California —seeks to recover damages under the federal securities laws for those who purchased LOAN DEPOT stock.

Investors who have purchased Loan Depot stock at any time between February 16, 2021 and September 3, 2021 and incurred losses are urged to contact the firm immediately at fab@bottinilaw.com or (858) 914-2001. Bottini & Bottini is representing clients on a contingency fee basis. You may obtain additional information concerning the action on our website, www.bottinilaw.com.

If you purchased shares of LOAN DEPOT Holdings, Inc. and would like to assist with the case as a lead plaintiff, you must, no later than November 6, 2021, request that the Court appoint you a lead plaintiff of the proposed class.

The lawsuit charges that Loan Depot violated the Securities Act of 1933 because the Registration Statement failed to disclose that: (1) the Company’s loan originations had already declined substantially at the time of the IPO due to industry over-capacity and increased competition;
(2) that the Company’s gain-on-sale margins had already declined substantially at the time of the IPO; (3) that, as a result, the Company’s revenue and growth would be negatively impacted;
(4) that the Company had already been forced to embark on a significant expense reduction plan due to the significantly lower growth and refinance originations that the Company was experiencing; and (5) that, as a result of the foregoing, Defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.

Subsequent to the IPO, Loan Depot’s stock declined immediately, declining below $8 per share less than six months after the IPO -- a decline of over 42% from the IPO price.

If you wish to join the litigation or discuss your interests in this lawsuit, contact Frank A. Bottini of Bottini & Bottini at (858) 914-2001 or fab@bottinilaw.com.

Contact:
Bottini & Bottini, Inc.
Frank A. Bottini, Esq.
Email: fab@bottinilaw.com
Tel: (858) 914-2001
SOURCE: Bottini & Bottini, Inc.

Allergan Inc.

Motion Deadline: 
Tuesday, February 17, 2015
Summary: 

SAN DIEGO – December 17, 2014. BOTTINI & BOTTINI, INC. today announced that a class action has been commenced in the United States District Court for the Central District of California on behalf of persons who sold Allergan, Inc. (NYSE: AGN) common stock between February 25, 2014 and April 21, 2014 (the “Class Period”).
If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from December 17, 2014. If you wish to discuss this action or have any questions concerning this notice or your rights or interests, please contact plaintiff’s counsel, Frank A. Bottini or Albert Y. Chang of Bottini & Bottini at (858) 914-2001, or via e-mail at fbottini@bottinilaw.com or achang@bottinilaw.com. If you are a member of this class, you can view a copy of the complaint on this website. Any member of the putative class may move the Court to serve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent class member.
The complaint charges defendants Valeant Pharmaceuticals International, Inc., Valeant Pharmaceuticals International, AGMS Inc., Pershing Square Asset Management L.P., William A. Ackman, PS Management GP, LLC, and PS Fund 1, LLC (“Defendants”) with violations of Sections 14(e) and 20A of the Securities Exchange Act of 1934.
Plaintiff alleges that Valeant unlawfully tipped Pershing Square about its plan to make a tender offer for Allergan, with Pershing Square then trading on such material, non-public information by buying an approximately 9.7% stake in Allergan during the Class Period without first disclosing Valeant’s plan to pursue a tender offer to acquire Allergan at a significant premium.
When Valeant first disclosed its desire to pursue an acquisition of Allergan to the stock market on April 22, 2014, Allergan’s stock price soared, rising from a closing price the previous day of $141.88 to close at $163.51 on April 22, 2014 on huge volume of over 32 million shares – ten times Allergan’s average daily trading volume during the Class Period.

Company Name:

Stock Symbol:

Date Filed: 
Tuesday, December 16, 2014
Retention Agreement: 

This Retention Agreement governs the retention of Bottini & Bottini, Inc. (the “Attorneys”) by those institutions or individuals (the “Client”) who have authorized the Attorneys to prosecute claims arising out of their purchase of Allergan Inc.'s stock.
WHEREAS the Client has authorized the Attorneys to prosecute claims relating to the securities of Allergan Inc. (the “Litigation”);
WHEREAS the Litigation entails numerous complex factual and legal issues and entails considerable risk;
WHEREAS the Litigation requires the expenditure of substantial resources by the Attorneys retained to prosecute the Litigation;
WHEREAS the Client seeks to maximize their recovery while limiting the expenditure of their own resources; and
NOW, THEREFORE, the Client and the Attorneys AGREE AS FOLLOWS:
I. SCOPE OF SERVICES/CASE HANDLING
A. Upon execution by Client, Attorneys are retained to provide legal services for the purpose of seeking damages and other relief in the Litigation. Client provides authorization to seek appointment as Lead Plaintiff in the class action, while the Attorneys will seek to be appointed Class Counsel. If this occurs, the Litigation will be prosecuted as a class action.
B. Attorneys are authorized to prosecute the Litigation. The appointed Lead Plaintiffs will monitor, review and participate with counsel in the prosecution of the Litigation. The Attorneys shall consult with the appointed Lead Plaintiffs concerning all major substantive matters related to the Litigation, including, but not limited to, the complaint, dispositive motions and settlement. Because of potential differences of opinion between Clients concerning, among other things, strategy, goals and objectives of the Litigation, the Attorneys shall consult with the appointed Lead Plaintiffs as to the courses of action to pursue. The Client agrees to abide by the decisions of the appointed Lead Plaintiffs, which shall be final and binding on all Clients.
C. The Attorneys shall provide sufficient resources, including attorney time and capital for payment of costs and expenses, to vigorously prosecute the Litigation.
D. Any recovery will be divided among Clients based on the recognized loss by each Client as calculated by a damage allocation plan which will be prepared by a financial expert, provided to the appointed Lead Plaintiffs, be subject to the Court's approval and will account for such factors as size of stock ownership, date of purchase, date of sale and continued holdings, if any.
II. CONTINGENT FEE AGREEMENT
A. The Attorneys shall advance all expenses in the Litigation. The Client is not liable to pay any of the expenses of the Litigation, whether attorneys' fees or costs. Recovery of costs and other expenses is contingent upon a recovery being obtained. If no recovery is obtained, Client will owe nothing for costs and other expenses. In the event that an order is entered awarding costs and expenses in favor of defendants, Attorneys will be responsible for such costs and expenses, not the Client.
B. If there is a recovery in the Litigation, whether by settlement or judgment, the Attorneys shall be compensated via payment of a reasonable percentage of any recovery as approved by the Court, which amount shall include attorneys’ fees plus reasonable disbursements in the Litigation. “Disbursements” shall include, but not be limited to, costs of travel, telephone, copying, fax transmission, depositions, investigators, messengers, mediation expenses, computer research fees, court fees, expert fees, other consultation fees and paralegal expenses. Any recovery in the Litigation shall first be used to reimburse disbursements.
C. In the event that the Litigation is resolved by settlement under terms involving any “in-kind” payment, such as stock, the contingent fee agreement shall apply to such “in-kind” payment.
III. GENERAL REQUIREMENTS
A. This Agreement may not be assigned by the Attorneys.
B. Client agrees to cooperate in the prosecution of the suit including providing documents to substantiate the Client's claim, and to cooperate in providing discovery information, including a deposition if necessary.
C. Client recognizes that the Attorneys are representing other Allergan Inc. investors in the Litigation. The Client agrees that any conflicts caused by such representation are waived.
IV. TERMINATION
A. Client may terminate this Agreement as to any Attorneys, with or without cause and without penalty, by providing the Attorneys with written notice of termination. Attorneys may terminate this agreement with or without cause and without penalty, by providing client with written notice of termination if the Client fails to cooperate in the prosecution of this action or such other reason as may be approved upon application to the Court.
B. If the Attorneys are terminated for any reason, Attorneys shall be entitled (a) to be reimbursed, pursuant to §II above, for reasonable out-of-pocket costs and expenses that they incurred, but only if and when recovery is obtained, and (b) to be paid such compensation as might be payable to them in accordance with this Agreement, but only if and to the extent and at the time compensation is payable to the Attorneys from any recovery in the Litigation pursuant to §II above.
V. NOTICE
A. All notices to be given by the parties hereto shall be in writing and served by depositing same in the United States Post Office, postage prepaid and registered as follows:
TO THE CLIENT
The address set out in the Authorization to File Allergan Inc. Claim form.
TO ATTORNEYS

Bottini & Bottini, Inc.

7817 Ivanhoe Ave., Suite 102

La Jolla, California 92037

Attention: Francis A. Bottini, Jr.

B. Any actions arising out of this Agreement shall be governed by the laws of California, and shall be brought and maintained in the San Diego Superior Court, which shall have exclusive jurisdiction thereof.
C. This agreement, along with the signed Certification and Authorization of Named Plaintiff, sets forth the entire Agreement between the parties, and supersedes all other oral or written provisions.

Notice of Opportunity: 

BOTTINI & BOTTINI, INC. FILES CLASS ACTION LAWSUIT ON BEHALF OF PERSONS WHO SOLD ALLERGAN STOCK BETWEEN FEBRUARY 25, 2014 AND APRIL 21, 2014
SAN DIEGO – December 17, 2014. BOTTINI & BOTTINI, INC. (http://www.bottinilaw.com) today announced that a class action has been commenced in the United States District Court for the Central District of California on behalf of persons who sold Allergan, Inc. (NYSE: AGN) common stock between February 25, 2014 and April 21, 2014 (the “Class Period”).
If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from December 17, 2014. If you wish to discuss this action or have any questions concerning this notice or your rights or interests, please contact plaintiff’s counsel, Frank A. Bottini or Albert Y. Chang of Bottini & Bottini, at (858) 914-2001, or via e-mail at fbottini@bottinilaw.com or achang@bottinilaw.com. If you are a member of this class, you can view a copy of the complaint as filed or join this class action on this website. Any member of the putative class may move the Court to serve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent class member.
The complaint charges defendants Valeant Pharmaceuticals International, Inc., Valeant Pharmaceuticals International, AGMS, Inc., Pershing Square Capital Management L.P., William A. Ackman, PS Management GP, LLC, and PS Fund 1, LLC (“Defendants”) with violations of Sections 14(e) and 20A of the Securities Exchange Act of 1934, as amended.
Plaintiff alleges that Valeant unlawfully tipped Pershing Square about its plan to make a tender offer for Allergan, with Pershing Square then trading on such material, non-public information by buying an approximately 9.7% stake in Allergan during the Class Period without first disclosing Valeant’s plan to pursue a tender offer to acquire Allergan at a significant premium.
When Valeant first disclosed its desire to pursue an acquisition of Allergan to the stock market on April 22, 2014, Allergan’s stock price soared, rising from a closing price the previous day of $141.88 to close at $163.51 on April 22, 2014 on huge volume of over 32 million shares – ten times Allergan’s average daily trading volume during the Class Period.
Plaintiff seeks to recover damages on behalf of all persons who sold Allergan stock between February 25, 2014 and April 21, 2014, inclusive. Plaintiff alleges that class members were damaged by selling their Allergan stock during the Class Period at prices that did not reflect Valeant’s anticipated tender offer to acquire Allergan at a significant premium. The plaintiff is represented by Bottini & Bottini, which specializes in representing investors and has extensive experience in prosecuting securities class actions.
Located in San Diego, California, Bottini & Bottini represents shareholders across the country in contingency-based securities class action litigation. The firm has obtained many multi-million dollar recoveries for shareholders. Please visit http://www.bottinilaw.com for more information.
Contact:
BOTTINI & BOTTINI, INC.
Albert Y. Chang
Telephone: (858) 914-2001
E-mail: achang@bottinilaw.com

join now

Class Period: 
Press Release: 

BOTTINI & BOTTINI, INC. FILES CLASS ACTION LAWSUIT ON BEHALF OF PERSONS WHO SOLD ALLERGAN STOCK BETWEEN FEBRUARY 25, 2014 AND APRIL 21, 2014
SAN DIEGO – December 17, 2014. BOTTINI & BOTTINI, INC. (http://www.bottinilaw.com) today announced that a class action has been commenced in the United States District Court for the Central District of California on behalf of persons who sold Allergan, Inc. (NYSE: AGN) common stock between February 25, 2014 and April 21, 2014 (the “Class Period”).
If you wish to serve as lead plaintiff, you must move the Court no later than 60 days from December 17, 2014. If you wish to discuss this action or have any questions concerning this notice or your rights or interests, please contact plaintiff’s counsel, Frank A. Bottini or Albert Y. Chang of Bottini & Bottini, at (858) 914-2001, or via e-mail at fbottini@bottinilaw.com or achang@bottinilaw.com. If you are a member of this class, you can view a copy of the complaint as filed or join this class action online at http://www.bottinilaw.com/cases/ valeant/. Any member of the putative class may move the Court to serve as lead plaintiff through counsel of their choice, or may choose to do nothing and remain an absent class member.
The complaint charges defendants Valeant Pharmaceuticals International, Inc., Valeant Pharmaceuticals International, AGMS, Inc., Pershing Square Capital Management L.P., William A. Ackman, PS Management GP, LLC, and PS Fund 1, LLC (“Defendants”) with violations of Sections 14(e) and 20A of the Securities Exchange Act of 1934, as amended.
Plaintiff alleges that Valeant unlawfully tipped Pershing Square about its plan to make a tender offer for Allergan, with Pershing Square then trading on such material, non-public information by buying an approximately 9.7% stake in Allergan during the Class Period without first disclosing Valeant’s plan to pursue a tender offer to acquire Allergan at a significant premium.
When Valeant first disclosed its desire to pursue an acquisition of Allergan to the stock market on April 22, 2014, Allergan’s stock price soared, rising from a closing price the previous day of $141.88 to close at $163.51 on April 22, 2014 on huge volume of over 32 million shares – ten times Allergan’s average daily trading volume during the Class Period.
Plaintiff seeks to recover damages on behalf of all persons who sold Allergan stock between February 25, 2014 and April 21, 2014, inclusive. Plaintiff alleges that class members were damaged by selling their Allergan stock during the Class Period at prices that did not reflect Valeant’s anticipated tender offer to acquire Allergan at a significant premium. The plaintiff is represented by Bottini & Bottini, which specializes in representing investors and has extensive experience in prosecuting securities class actions.
Located in San Diego, California, Bottini & Bottini represents shareholders across the country in contingency-based securities class action litigation. The firm has obtained many multi-million dollar recoveries for shareholders. Please visit http://www.bottinilaw.com for more information.
Contact:
BOTTINI & BOTTINI, INC.
Albert Y. Chang
Telephone: (858) 914-2001
E-mail: achang@bottinilaw.com

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