Plastic2Oil Inc (PTOI)

[scion]

09/26/2011 13 MEMORANDUM filed by Plaintiff Howard L. Howell re 12 MOTION Appointment as Lead Plaintiff and Approval of Lead Counsel. (OMara, David) (Entered: 09/26/2011)

Doc 13 PDF file
https://viewer.zoho.com/docs/gbYaadj

Extract -

2. Movant Has The Largest Financial Interest In This Action

The PSLRA requires a court to adopt the rebuttable presumption that “the most adequate plaintiff . . . is the person or group of persons that . . . has the largest financial interest in the relief sought by the class.” 15 U.S.C. §78u-4(a)(3)(B); Cavanaugh, 306 F.3d at 730.

Here, Movant purchased 25,300 shares of JBI during the Class Period, and has suffered financial losses of $37,067 as a result of his transactions. See Goldberg Declaration, Exhibit C. To the best of his knowledge, Movant believes he has the largest financial interest in this case among Class members who filed timely applications for appointment as lead plaintiff, and accordingly is presumed to be the “most adequate plaintiff.” See Cavanaugh, 306 F.3d at 730.