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2 3 4 5 6 7 8 9 10 11 1 2 13 14 15 1 6 17 18 19 20 21 22 23 24 25 26 27 28 LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LL P WILLIAM S . LERACH ( 68581) SPENCER A. BURKHOLZ (147029) DANIEL S . DROSMAN (200643) JONAH H . GOLDSTEIN (193777) MATTHEW P . MONTGOMERY ( 180196) JESSICA T . SHINNEFIELD (234432) 655 West Broadway , Suite 1900 San Diego , CA 92101 Telephone : 619/231-1058 619/231-7423 (fax) Bi11L@lerachlaw .com SpenceB@Ierachlaw.com DanD @ lerachlaw.com JonahG@Ierachlaw .com Matt M @ lerachlaw .com JessicaS @lerachlaw .com - and - PATRICK J . COUGHLIN (111070) LESLEY E . WEAVER (191305) 100 Pine Street , Suite 2600 S an Francisco , CA 94111 Telephone : 415/288-4545 415/288-4534 (fax) PatC@ lerachlaw .com LesleyW@lerachlaw .com Co-Lead Counsel for Plaintiffs LEVIN, PAPANTONIO, THOMAS, MITCHELL, ECHSNER & PROCTOR, P .A. TIMOTHY M . O'BRIEN (pro hac vice) 316 South Baylen Street , Suite 600 Pensacola , FL 3250 1 Telephone : 850/435-7000 850/497-7057 (fax ) UNITED STATES DISTRICT COUR T NORTHERN DISTRICT OF CALIFORNI A SAN JOSE DIVISIO N In re CISCO SYSTEMS , INC . SECURITIES ) Master File No .C-01-20418 -JW(PVT) LITIGATION ) . CLASS ACTION DECLARATION OF JOSEPH S . KRAEMER, This Document Relates To : Ph .D . IN SUPPORT OF MOTION FOR ALL ACTIONS . FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND PLAN O F ALLOCATION OF SETTLEMENT PROCEEDS, AND AWARD OF ATTORNEYS FEES AND REIMBURSEMENT OF EXPENSE S DATE : December 5, 2006 TIME : 9 :00 a .m . CTRM : The Honorable James Ware

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Page 1: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

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LERACH COUGHLIN STOIA GELLERRUDMAN & ROBBINS LLP

WILLIAM S . LERACH (68581)SPENCER A. BURKHOLZ (147029)DANIEL S. DROSMAN (200643)JONAH H. GOLDSTEIN (193777)MATTHEW P. MONTGOMERY ( 180196)JESSICA T. SHINNEFIELD (234432)655 West Broadway , Suite 1900San Diego , CA 92101Telephone : 619/231-1058619/231-7423 (fax)Bi11L@lerachlaw [email protected]@ [email protected]@ lerachlaw [email protected]

- and -PATRICK J. COUGHLIN (111070)LESLEY E . WEAVER (191305)100 Pine Street , Suite 2600San Francisco , CA 94111Telephone : 415/288-4545415/288-4534 (fax)PatC@ lerachlaw [email protected]

Co-Lead Counsel for Plaintiffs

LEVIN, PAPANTONIO, THOMAS, MITCHELL,ECHSNER & PROCTOR, P .A.

TIMOTHY M. O'BRIEN (pro hac vice)316 South Baylen Street , Suite 600Pensacola , FL 3250 1Telephone : 850/435-7000850/497-7057 (fax)

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNI A

SAN JOSE DIVISION

In re CISCO SYSTEMS , INC. SECURITIES ) Master File No .C-01-20418-JW(PVT)LITIGATION ) .

CLASS ACTION

DECLARATION OF JOSEPH S . KRAEMER,This Document Relates To :Ph.D. IN SUPPORT OF MOTION FOR

ALL ACTIONS. FINAL APPROVAL OF CLASS ACTIONSETTLEMENT AND PLAN O FALLOCATION OF SETTLEMENTPROCEEDS, AND AWARD OFATTORNEYS FEES ANDREIMBURSEMENT OF EXPENSE S

DATE : December 5, 2006TIME: 9:00 a.m .CTRM: The Honorable James Ware

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I, Joseph S. Kraemer, Ph .D ., declare as follows :

INTRODUCTION

1 . I submit this declaration to set forth the basis for the charges incurred by

plaintiffs ' counsel for my work in connection with the action entitled In re Cisco Systems, Inc.

Securities Litigation , No. C-01-20418 -JW(PVT ) . I performed all work in connection with the

Cisco litigation on an assignment basis .

2. The purpose of this declaration is to summarize my professional qualifications

I and the services I rendered in connection with the Cisco litigation .

QUALIFICATIONS

3 . I am currently a Director at the firm of Law & Economics Consulting Group

("LECG") where I work in the Washington, DC office. I am a member of th e

telecommunications industry practice group .

4. I have consulted in the telecommunications and high technology industries since

1975 . My areas of expertise include business strategy , regulation , market analysis , new product

development and rollout , revenue/cost forecasting and operational improvement. I have

provided consulting services to a range of telecommunications service providers including :

incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

interexchange carriers, wireless carriers and satellite carriers . I have also consulted with network

equipment and high technology manufacturers , as well as with television and radio

broadcasters/content providers . At various times, financial institutions have engaged me to

perform due diligence on potential investments in telecommunications companies /ventures . The

range of clients served includes both start-up companies and well established service providers .

My clients have included companies in North America, Europe and Asia.

5 . I began my consulting career at, and was a partner with, Touche Ross (which later

merged with Deloitte, Haskins & Sells to form Deloitte & Touche) where I led the Globa l

Telecommunications and Electronic Service practice. In 1994, after retiring from Deloitte &

DECLARATION OF JOSEPH S . KRAEMER, Ph.D . IN SUPPORT OF MOTION FO RFINAL APPROVAL OF CLASS ACTION SETTLEMENT - C-01-20418-JW(PVT) - 1 -

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Touche, I joined EDS where I led a consulting practice focused on the telecommunications, hig h

technology and media industries .

6. In 1999, I left EDS and joined PHB Hagler Bailley ("PHB"), an economic and

I management consultancy, where I led the firm's telecommunications practice . When PHB was

I sold, I left and joined LECG where I continue to provide consulting services to

telecommunications service providers .

7 . I am a Certified Public Accountant (Virginia) and a Certified Managemen t

Consultant . My education includes a Ph .D. and Masters degree (University of Michigan), a

Masters of Business Administration (George Washington University), and a Bachelor's degre e

(Georgetown University) . I currently serve as an adjunct professor at both Georgetown

University's McDonough School of Business and at American University's Kogod Business

School where I teach courses related to electronic commerce and Internet-based business strateg y

and practice .

8 . I have appeared as an expert witness in multiple regulatory proceedings and in

disputes involving mediation, arbitration and litigation. I have also testified before state and

federal legislative committees on competition and other public policy issues in the

telecommunications and television industries .

9 . My curriculum vitae is attached hereto as Exhibit A .

10 . I was compensated for my work on this case at my usual and customary billin g

I rate of $425 per hour. My compensation was not dependent on the outcome of this matter or on

the opinions I expressed.

DESCRIPTION OF WORK PERFORMED

11 . The law firm of Lerach Coughlin Stoia Geller Rudman & Robbins LLP retaine d

me in this case as a telecommunications industry expert . In that role I was engaged to express an

opinion as to : (1) whether reports filed by defendants' experts, James H . Vander Weide ("Vander

Weide") and Jeffrey P . Williams ("Williams"), accurately described industry conditions ; (2) the

DECLARATION OF JOSEPH S. KRAEMER , Ph.D. IN SUPPORT OF MOTION FORFINAL APPROVAL OF CLASS ACTION SETTLEMENT - C-01-20418-JW(PVT) -2-

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impact of those conditions on Cisco System, Inc .'s ("Cisco") business plans; and (3) what was

known and disclosed by Cisco's management with respect to that impact .

12 . If there were defects in reports filed by Vander Weide and Williams, then I was

asked to correct such errors, supply additional information and/or provide the necessary industry

context on an as required basis so as to correct defects in the expert reports of Vander Weide an d

I Williams .

13 . In preparing my report, I reviewed the relevant sections of the Vander Weide and

Williams Reports, as well as the documents listed in Exhibit B attached hereto . Those

documents included :

(a) The First Amended Consolidated Complaint for Violation of the Federal

Securities Laws;

(b) The Expert Report of D . Paul Regan;

(c) More than a dozen transcripts of depositions taken in the litigation;

(d) A book about Cisco ;

(e) Numerous internal documents produced by Cisco in discovery ;

(f) Economic data; and

(g) SEC filings for Cisco and several other companies within the

telecommunications or network provider industry .

14 . While the Vander Weide report suffered from a multitude of errors and omissions ,

I identified the core defects as follows :

(a) Vander Weide's "Summary of Opinions" contains five opinions of which

the fourth ("[t]he rapid decline in industry revenues in the spring of 2001 was unexpected") and

fifth ("Cisco's vendor financing and inventory practices were a rational and necessary response

to industry and competitive conditions") were the most relevant and significant to the issues

raised in the case .

(b) Although the relevant period in this case included the full calendar year

2000, Vander Weide emphasized industry conditions in the spring of 2001 in his fourth summar y

DECLARATION OF JOSEPH S . KRAEMER , Ph.D. IN SUPPORT OF MOTION FO RFINAL APPROVAL OF CLASS ACTION SETTLEMENT - C-01-20418-JW(PVT) - 3 -

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opinion while largely ignoring conditions during 2000 . After analyzing Cisco's internal

documents, deposition testimony from Cisco's management and publicly-available documents

such as SEC filings, scholarly articles and books, and economic data, I concluded that by mid-

2000, the external market conditions had become adverse and put the successful attainment of

Cisco's FY 2001 (beginning August 2000) business plan goals at risk . The record showed that

the information necessary to understand the market situation was in the possession of Cisco

management . However, Cisco's management chose to ignore information that was contrary to

the attainment of the company's FY 2001 plan . Consequently, Cisco's management failed to

disclose information in a timely way that would have been of value to investors .

(c) I also concluded that Cisco seemed to have viewed vendor financing as a

sales channel or as a sales channel complement . Vendor financing was focused primarily on the

Service Provider ("SP") markets , especially in Cisco 's FY 2001 . The CY 2000 surge in the

demand for vendor financing should have served as a warning of deteriorating financial

conditions among customers and prospects in the SP industry . The information required to

update the financial information in the lease/loan files (had Cisco bothered to collect it) would

have provided even more confirmation that the new entrants in the SP industry (e.g., CLECs)

were at risk of insolvency .

15. My analysis led me to conclude that Vander Weide missed or failed to describe

the basic situation as it existed in the time frame addressed by his report . For example, Cisco's

FY 2001 (August 2000-July 2001) plan was dependent upon a significant increase both in

bookings and revenues in the SP line of business . Furthermore, within the SP industry, the plan

targeted primarily the U .S . SP industry, in particular, Network Service Providers ("NSPs") and

buyers of optical equipment . Beginning in the first quarter of FY 2001, Cisco failed to execute

against its FY 2001 U .S. SP plan .

16 . I discovered that Cisco was positioned ideally to understand its customers and th e

I markets, including and especially the SP market, in which Cisco competed . The critica l

I components of this information engine included an Executive Information System ("EIS") tha t

DECLARATION OF JOSEPH S . KRAEMER, Ph.D. IN SUPPORT OF MOTION FORFINAL APPROVAL OF CLASS ACTION SETTLEMENT - C-01-20418-JW(PVT) -4-

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facilitated the "virtual close" on any given day or hour, 14,000 sales personnel in daily contact

with customers, and a forecasting process that was designed to facilitate the attainment of

"stretch" goals. Although Cisco's management chose to disregard the information received

about market conditions, such information was available on a near real-time basis . For Cisco to

claim ignorance of market conditions until late December 2000 or early January 2001 meant tha t

Cisco's management chose recklessly to disregard information that contradicted what

management wanted to hear, even when such information was available from systems and

processes that management had put in place .

17. Accordingly, I concluded that in its communications with investors, Cisco's

management recklessly disregarded information and signals received from the SP market -

including customers, its own sales people, competitors, industry analysts, and its own forecastin g

system/EIS .

18 . I also concluded that the analysis and conclusions of Williams were flawed .

Many of the errors and omissions in the Williams report overlapped with those identified in the

Vander Weide report, including :

(a) Williams disregarded the economic linkages between the dot .coms and the

NSP sector ;

(b) Williams ignored both the timing and the significance of the closure of the

public capital markets to new entrants, such as CLECs and ISPs ;

(c) Williams used revenue as his primary indicator of economic conditio n

I rather than other more relevant indicators including, and especially, cash flow;

(d) Williams failed to acknowledge the significant deterioration of ke y

inventory metrics, such as inventory turns and growth rates in excess of revenues ; and

(e) Williams failed to identify the undisclosed risks and the implications of

the expansion of Cisco' s vendor financing program in early CY 2000.

DECLARATION OF JOSEPH S . KRAEMER, Ph.D . IN SUPPORT OF MOTION FORFINAL APPROVAL OF CLASS ACTION SETTLEMENT - C-01-20418-JW(PVT) - 5 -

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19. Finally, both Williams and Vander Weide failed to focus on the core issue of what

Cisco's management knew, but failed to disclose and/or recklessly ignored in mid-to-late CY

2000.

FEES AND EXPENSE S

20. Pursuant to a non-contingent agreement with plaintiffs' counsel, I spent 574 .5 hours

working on this matter at a rate of $425 per hour. My case associate, Charlotte Brown, spent 65 .5

hours assisting me in this matter at a rate of $125 per hour . Another principal at LECG, Richard

Levine, spent 8 .5 hours assisting me in this matter at a rate of $350 per hour . The fee for my

firm's expert services totaled $244,162.50. Plaintiffs' counsel has paid my firm's fees and

expenses related to this matter .

21 . In addition, I incurred $4,949.12 in expenses directly related to my work as an

expert in this matter.

22. Attached hereto as Exhibit C is a summary further detailing my fees and

expenses .

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

foregoing is true and correct. Executed this ILeday of November, 2006, at Washington, DC.

JOSEPH S . KRAEMER, Ph.D.

II DECLARATION OF JOSEPH S . KRAEMER, Ph .D . IN SUPPORT OF MOTION FO RFINAL APPROVAL OF CLASS ACTION SETTLEMENT -C-01-20418-JW(PVT) -6-

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CERTIFICATE OF SERVICE

I hereby certify that on November 20, 2006, I electronically filed the foregoing with th e

Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mai l

addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I hav e

mailed the foregoing document or paper via the United States Postal Service to the non -CM/EC F

participants indicated on the attached Manual Notice List .

s/Spencer A. Burkholz

SPENCER A . BURKHOL Z

LERACH COUGHLIN STOIA GELLERRUDMAN & ROBBINS LLP

655 West Broadway, Suite 1900San Diego, CA 92101Telephone: 619/231-1058619/231-7423 (fax)E-mail : SpenceB(a%lerachlaw. com

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Mailing Information for a Case 5 :01-cv-20418-JW

Electronic Mail Notice Lis t

The following are those who are currently on the list to receive e-mail notices for this case .

• George E. Barrett

[email protected]

• Eric J. Belfi

[email protected] ElectronicCaseFiling@labaton .com

• Stuart L . [email protected]

• Ronald S Betmanrbetman@winston .com

• Patrice L. Bishopservice@ssbla .com

• Norman J. [email protected] susan .griffin-preston@hellerehrman .com;yvonne. somek@hellerehrman .com;victor .gonzales@hellerehrman .com

• Ruth Marian Bond, Es qruth .bond@sfgov .org blanca .martin@sfgov .org

• Jennifer Corinne Bretanjbretan@fenwick .com

• George H. Brow ngbrown@hewm .com nsims@hewm .com ;rsazegari@hewm .com

• Spencer A. Burkhol zSpenceB@lerachlaw .com e_file_sd@lerachlaw .com;[email protected]

• Connie M. Cheungconniec@lerachlaw .come_file_sd@lerachlaw .com;e_file_sf@lerachlaw .com ;KiyokoH@lerachlaw .com

• James Nixon [email protected]

• Daniel S . Drosma nDanD@lerachlaw .com e_file_sd@lerachlaw .com;[email protected]

• Krista M. Ennskenns@winston .com hhammon@winston .com

• Kathryn [email protected]

• Donald P . [email protected] [email protected]

• Bruce C. Gibneybgibney@hewm .com

• Daniel C. Girardgirardgibbs@girardgibbs .com cma@girardgibbs .com

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• Lionel Z. Glancyinfo@glancylaw .com

• Jonah [email protected]

• Mark Gordon• John Halebian

jhalebian@lshilp .com Ishscanner@lshllp .com• Thomas J . Harrison• Alice L. Jense n

ajensen@fenwick .com vadelman@fenwick .com• Robert A. Jigarjian

CAND .USCOURTS@CLASSCOUNSEL .COM

• Willem F. Jonckhee rwjonckheer@schubert-reed .com

• Dean S. [email protected]

• Felix [email protected]

• William S. Lerache_file_sd@lerachlaw .com

• Robert L . Michelsrmichels@winston .com

• Matthew Paul [email protected] e_file_sd@lerachlaw .com ;[email protected]

• Kevin P. Muckkmuck@fenwick .com cprocida@fenwick .com

• Lucas OltsLukeO@Lerachlaw .com

• Troy Alan Raffertytrafferty@levinlaw .com balverson@levinlaw .com

• Brian J . [email protected]@ruflaw .com;[email protected];[email protected]

• Darren J. Robbins• Daniel T . Rockey

[email protected] nsims@hewm .com;rsazegari@hewm .com• Michael L. Rugen

mrugen @hewm :com• Robert Yale Sperling

rsperling@winston .com• James G. Stranch, III

jgs@branstetterlaw .com [email protected]

• Jessica TallyJessicaT@lerachlaw .com

• Carol Lynn ThompsonCTHOMPSON@HEWM .COM

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• Lesley E. [email protected] e_file_sf@lerachlaw .com

• Dan Keith Web bdwebb@winston .com

• Ethan Richard [email protected] ECF_CH@winston .com

Manual Notice Lis t

The following is the list of attorneys who are not on the list to receive e-mail notices for this case

(who therefore require manual noticing) . You may wish to use your mouse to select and copythis list into your word processing program in order to create notices or labels for these

recipients .

J. Erik Connolly

Winston & Strawn LLP

West Wacker Drive

Chicago, IL 60601-9703

Christopher Alan Garcia

Attorney at Law

Dell, Inc

1 Dell Way-Legal

Round Rock, TX 78682

Frederick W . Gerkens, II I

Wechsler Harwood Halebian & Feffer, LLP

488 Madison Avenue, 8th Floo r

New York_ NY 10022

Corey D . Holzer

Holzer Holzer & Cannon LLC

1117 Perimeter Center West

Suite E-107

Atlanta, GA 30338

Peter Lawrence Kaufma n

Levin Papantonio Thomas Mitchell Echsner

316 South Baylen Street, Suite 600

Pensacola, FL 3250 2

Frederick T . Kuykendall

Levin Papantonio Thomas Mitchell Echsner316 South Baylen Street, Suite 600

Pensacola, Fl 3250 1

Christopher R . Leclerc

Heller Ehrman LL P

275 Middlefield Road

Menlo Park, Ca 94025-3506

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Fredric G . Levin

Levin PapantonioThomas Mitchell Echsner

316 South Baylen Street, Suite 600

Pensacola, fL 3250 1

Timothy M . O'Brien

Levin Papantonio Thomas Mitcgell Echsner

316 South Baylen Street, Suite 600

Pensacola, Fl 3250 1

J. Papantonio Papantonio

Levin, Papantonio, Thomas, Mitchell, Ech

316 South Gaylen Street, Suite 600

Pensacola_ Fl 3250 1

Joe Scarborough

Levin, Papantonio, Thomas, Mitchell, Ech

316 South Baylen Street, Suite 600

Pensacola_ Fl 3250 1

Robert E . Smith, JR

Levin Papantonio thomas Mitchell Echsner316 South Baylen St ., Ste 40 0

Pensacola, FL 32502

Melvyn I . Weiss

Attorney at Law

One Pennsylvania Plaza

New York, NY 10119-1063

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Manual Service List (cont . )In re Cisco Systems, Inc . Sec. Litig.Master File No. C-01-20418-JW(PVT)

Stephen B . Morris, APCMORRIS and ASSOCIATES401 West "A" Street, Suite 2200San Diego, CA 92101Telephone: 619/239-1300

Wayne Schneider, General Counse lNEW YORK STATE TEACHERS' RETIREMENT SYSTEM10 Corporate Woods Driv eAlbany, NY 12211-2395Telephone : 800/356-312 8

Richard P . Bosson2703 Montague Court EastClearwater , FL 3376 1

Charles W. Morgan2220 Calle Opal oSan Clemente , CA 92673Telephone: 949/498-8296

John P. DillmanTara L. Grundemeier1301 Travis, Suite 300Houston, TX 77002Telephone : 713/844-343 6

John R. Ihms19149 Sierra Estates DriveNewhall , CA 91321-227 2

Lee M. Cassidy1503 North Colonial CourtArlington, VA 22209

Steven L. Moldane3309 142nd Place NEBellevue, WA 98007-3249Telephone : 425/376-2830

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EXHIBIT A

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e

Joseph Kraemer, Director, LECG

1725 Eye Street, NW, Suite 800Washington, DC 20006direct: 202.973.9384mobile : 703 .501 .1270fax: 202.466.4487email : jkraemer@lecg .com

BIO/SUMMARY

Dr. Kraemer holds the title of director at the Washington DC office of LECG . For over .25 years, hehas worked with, and served as counselor to, senior management at communications, media, andhigh-tech companies in Asia, Europe, and the Americas . He teaches electronic commerce andbusiness strategy courses at both the Georgetown University McDonough School of Business andthe Kogod Business School at American University . The Progress & Freedom Foundation(Washington, D .C.) has designated him an Adjunct Fellow.

EDUCATION

Ph .D ., University of Michiga nM .B .A., George Washington UniversityM .A., University of Michiga nB.S ., Georgetown University

PRESENT POSITIONSLECG, Director, 2000 to presentAmerican University, Adjunct Professor, 1998 - presentGeorgetown University, Adjunct Professor, 1999 - presen t

TEACHING EXPERIENC E

Dr. Kraemer serves as an Adjunct Professor and guest lecturer at Georgetown University'sMcDonough School of Business in Washington, D.C. where he teaches "Electronic CommerceStrategy & Policy." Dr. Kraemer is also an Adjunct Professor at the Kogod School of Business atAmerican University where he teaches the "Fundamentals of Electronic Commerce," a requiredcourse for upper classmen .

OTHER POSITIONS HELD

PUTNAM, HAYES & BARTLETT/HAGLER BAILLY, Senior Vice President, 1999-2000EDS/A.T.KEARNEY, Vice President , 1994-199 9DELOITTE & TOUCHE, Partner (Retired), 1989-1994TOUCHE ROSS & CO ., Partner ( Retired), 1974-1989MERRILL LYNCH, Investment Research and Advisor, 1972-1974U.S. ARMY, Captain , 1966-197 2

2/25/2005 www.lecg .com Page 1 of 13

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BOARD MEMBERSHIPS

Exigent , Inc. (Melbourne , FL) : public company in the software business ; member of Audit &Investment Committees ; chaired Outside Director Committee that presided over sale of company toHarris Corporation (2000-2001) .

Center for Telecommunications Management (Los Angeles ) : University of Southern California(1998-2001) .Linguatek, Inc. (McLean, VA): start-up company in software industry ; sold to Sonus ; member ofAdvisory Board (1997-2001) .

Wintergreen Partners , Inc . (Charlottesville , VA) : Resort Operator ; Chairman Finance Committee,and member Executive Committee (2004-Present) .Wintergreen Hospitality LLC (Charlottesville , VA): Resort Investment Fund ; member of the Board(2005-present) .

PROFESSIONAL

Certified Public Accountant (CPA)Certified Management Consultant (CMC )

SELECTED BUSINESS & CONSULTING EXPERIENCE : Strategy and Financin g

• Wireless Broadband Business and Market Plan . Prepared a plan for a national wirelessbroadband business; compiled secondary sources for purposes of market research andanalysis ; assessed both communications and entertainment services with priority assigned tosupplying access and connectivity for business customers ; included P&L and balance sheetpro formas .

• Diversification and Investment Strategy . Directed a case team that analyzed investmentoptions in the United States; the scope included local, long distance, wireless, competitiveaccess, entertainment, business information services and Internet-related opportunities ; thecore issue was how to leverage investments to become a full service provider in the UnitedStates ; performed for a major European carrier .

• Fiber Optics Demand Study . Forecasted the demand for fiber optics over a five-yearperiod ; °study involved interviews with current and potential customers, data analysis, and aregression model to forecast levels of demand given different economic and marketassumptions .

• Broadband Consumer and Business Market Assessment . Conducted primary marketresearch to identify addressable markets for cable TV, Internet access, and telephony ; clientarchitecture was hybrid fiber-coax (HFC) ; developed penetration strategies for each segmentand for the total market, including optimal service packaging and pricing ; developed strategyto achieve market share, cash flow and EBITDA targets set by the Board of Directors andpotential JV partners .

• Telecommunications Market Entry by Power Companies . Led several analyses of theoptimal strategy for power companies to enter telecommunications markets ; scope includedall options including, facilities-based, resale, and leasing towers and rights-of-way; includedbundling telecommunications and energy at the retail level ; involved primary and secondarymarket research .

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e• Dark Fiber Business Strategy. Directed a case team to evaluate the options available to a

natural gas pipeline company that wanted to deploy and sell fiber optic cables along its inter-city rights-of-way ; evaluated demand for, and supply of, fiber along specific routes ; identifiedcosts and benefits of entry; utilized primary and secondary sources for market analysis ;recommended potential partners for our client among cable and telephone companies .

• Strategic Assessment of the Future of the Broadcast Television Industry . Reviewedhistoric trends (1993-2002) and projected the probable future economics of broadcasting(2003-2007) ; scope included all stages of the industry supply chain (programming, networks,local distribution, and syndication) ; stress was placed on the relative economics of cable vs .broadcasting ; participants included broadcast networks and station groups ; conductedinterviews that included senior executives, as well as station-level managers in multiplemarkets .

• Market Entry and Diversification Strategy. Assisted a major multistate electric utility todevelop an entry strategy into various segments of the telecommunications industry toinclude wireless, broadband, and switched voice with both a wholesale and retail componentto the strategy ; used primary and secondary sources ; included partnership options at the lineof business level .

• Cable Television . Directed support for a county government that was reviewing the transferof its cable franchise from one MSO to another ; scope included financial condition andoperating efficiency .

• Analysis of Fundamental Changes in the Global Network Services Industry . Our client,an information technology services company and network services reseller, engaged LECGto analyze'the nature and extent of the changes to the telecommunications industry in the1998-2002 period with projections for 2003-2005 ; our client used the analysis both to : (a)change business strategies ; and (b) restructure its carrier contracts .

• Analyses of Voice, Data, and IP Market Competition . LECG was engaged by a regionalbell operating company (RBOC) to assess the nature and extent of competition in multiplestates within its service territories ; our analysis covered : (a) the types of competitors ; (b) thecontested markets by service line and geographic area ; (c) competitive strategies, especiallythose targeted at business customers ; (d) competition from mobile wireless, cable televisiondigital systems, and IP-based instant messaging ; and (e) critical business trends (2002-2005) ; used secondary sources for market and competitive information .

• Post-Acquisition Integration Strategy for Two Telephone Companies . Defined a courseof action by which the two parties to the transaction could integrate business strategies andconsolidate operating functions but leave the acquired company sufficient autonomy so as topreserve minority shareholder value ; reviewed organizational models from several industries ;scope also included dispute resolution and HR policies .

• Market Entry Strategy . Developed 'a U.S. market entry strategy for a Canadian carrier;used secondary sources to identify trends in U .S. markets for underserved opportunities ;scope included voice, data, and IP services, as well as prepaid calling cards, dial around, andresale .

• Due Diligence . For a London-based bank consortium, directed a due diligence assessmentof a mobile satellite services company; capital at risk exceeded $1 .0 billion ; conducted fullreview of operating systems, business systems, space, handset, and ground systems as wellas program management processes and capabilities ; identified risks to cost, budget, and

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market-based performance specifications ; prepared capital draw down schedule tied to keymilestones ; provided support for IPO, high-yield debt, and bank structured financing .

• Customer Retention Strategy. Led a joint consultant-client team that developed aCustomer Relationship Management strategy for a national wireless carrier ; scope was end-to-end from lead generation and initial sale through customer care, add-on sales, credit, andcollections; included identifying required changes to culture, processes, and systems .

• Market Study of Alternative Access Services . Directed a study for an ILEC of the marketfor metropolitan area fiber optic-based networks ; utilized primary and secondary sources ;scope included an analysis of the competitive implications for pricing, service, and networkconfiguration ; developed a range of potential competitive responses .

• Analysis of the Market for Small Satellites . Directed a study of the civilian market forsmall space satellites ; scope included a worldwide supply-demand analysis of transponders,as well as a comparison of the economics of small versus traditional satellites to providedomestic and/or international communications services .

• International Partnership Negotiations . Assisted three carriers (one each from the U .S .,Europe, and South Asia ) to define the benefi ts of forming a new partnership to provide globalend-to-end provisioning to multinational corporations ; conducted primary and seconda ryresearch ; analyzed the potential market , evaluated management structures for the newentity, and valued the partnership contributions of each carrier .

• Global Strategy . Directed a study for an overseas carrier to analyze the internationalstrategies of major U .S . and foreign carriers ; developed criteria for success and forecastedthe "winners " over a ten-year period , study was used by our client to develop a competitiveinternational strategy .

• International Service Contracting Suppo rt . Supported an agent representing multiplelesser-developed country PTTs ; assisted to assess an existing contract and providedrecommendations for a to - be-negotiated extension with emphasis on price adjustments undera most- favored-customer arrangement with mark-to - market provisions .

• Market Ent ry by a Second Korean Carrier. Directed a study of the market for long-distance domestic and international voice and data services ; scope included design of a fiberoptic backbone network and an analysis of the economic , operational , and marketimplications of entry by the second carrier ; prepared a business plan including capitalrequirements , adoption cu rves , penetration strategies , and financial projections .

• National Digital Multicasting Television Business Feasibility Study . Assisted to forecastthe costs and revenues over an eight -year period; included all aspects of the business suchas market analysis using prima ry research , program acquisition , technical feasibility , set topbox development and distribution, operations , sales, marketing , and billing ; also included theaction-reaction cycle of competitors .

• Nationwide Multipoint Distribution System (MDS) Feasibility Study and Cost Analysis .Managed a study to estimate the feasibility and cost of developing a two-channel MDS in thetop 100 television markets ; included capital expenditures for equipment, towers, andsoftware, as well as ten-year operating pro formas showing revenue and operating costs .

• Feasibility Study of Using Microwave for Home Delivery of Multichannel Video .Directed an analysis of the technology and cost of a nationwide MDS system in the UnitedKingdom ; client was the U .K. government ; scope included market adoption scenarios,financial forecasts, and an overall feasibility assessment .

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• Residential Video Market Analysis . Analyzed the fundamentals of the entertainment videomarket using secondary sources ; emphasized advertising vs . subscription support, wired vs .wireless delivery, and analog vs. digital media ; provided in-depth comparison of cable, DBS,LMDS, MMDS, and standard over-the-air systems .

• Milestone Study of the Effects of Competition and the AT&T Divestiture . Performed fora foreign dominant carrier confronted with potential divestiture by its government ; scopeincluded price effects, social effects, impact on R&D, public opinion, labor impacts, andeffects on business and residential users ; used secondary sources in combination withprimary research .

• Regional Bell Operating Companies Market Research . Directed multiple market surveysfor RBOCs to quantify the existing nature and extent of competition in their service territoriesand forecast future losses of market share, lines, and profitability ; survey results used asbasis for new business plans, new product development, modification of competitivestrategies, and regulatory testimony .

• Delphi Panel. Directed a study utilizing a panel of North American, Japanese, and Europeanexperts on the subject of global competition among international carriers ; objective was toforecast potential winners and their strategies ; used iterative survey rounds as a forecastingtechnique .

• Spectrum Licensing and Availability . Participated in a spectrum study that compared U .S .licensing and assignment practices to specific proposals by the U .K. government .

• Fiber Optics Feasibility and Due Diligence . Reviewed the feasibility of a fiber opticsnetwork in a major Pennsylvania city ; client was a financial institution; scope includedinterviews with potential customers and review of city-specific market data .

• Private Satellite Network Study . Directed a market study of the use of private satellitenetworks for voice, data, and video traffic ; analyzed trade-offs between fiber optics andsatellites for long-haul transmission .

• Aerospace Market Opportunity and Competitive Analysis . Assessed the market forsatellite-based communications services and the activities of competitors in the servicesbusiness for an aerospace manufacturer of satellites and launch vehicles ; objective was toevaluate potential entry into the services business .

• New Telecommunications Venture Evaluation for a Bank. Conducted due diligence onthe business plan of a venture proposing to deploy fiber optic cable in the Washington, D .C .area ; client was a major bank that was considering financing the venture ; scope includedinterviews with potential customers and an analysis of the competition, as well as review offinancial forecasts .

• Satellite Communication System Feasibility and Implementation . Supported the PublicBroadcasting Service (PBS) and National Public Radio (NPR) in their successful effort tomove their programming to satellites; scope included feasibility study, RFP preparation,vendor negotiation, program management, and earth station site acquisition ; total earthstations exceeded 300 .

• Retail Business Entry . Assisted an international carrier's carrier to initiate a retail business ;scope included channel design, avoidance of channel conflict with existing resellers, pricing,cost allocation, profitability measurement, and automated systems support.

• Due Diligence. For equity investors, directed due diligence on a Russian-French satelliteventure ; scope covered manufacturing, systems engineering, testing, and launch for a four-

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satellite GEO system; also included program management and contractual risk mitigationactivities; identified risks, their probability of occurrence, and the potential impact on cost,schedule, and performance .

• Data Services Joint Venture . Supported a joint venture between an IT services companyand a RBOC; negotiations and structuring the venture ; used primary and secondary market,research; subsequently assisted to structure go-to-market strategy in terms of products,pricing, and distribution channels .

• Competitive Local Exchange Carrier Strategy, Processes, and Business Launch .Supported the rollout of a CLEC, including market definition and penetration strategies,organizational structure, partner and agent relationships, operating support systems, andoutsourcing tactics .

• Digital Television (DTV). Conducted senior management roundtables on DTV technologyand rollout ; prepared a book for publication by the National Association of Broadcasters(NAB) on use of DTV spectrum to transmit revenue-generating data carriers .

• Economic Value Creation (EVC). Supported an assessment of the EVC generated by theworld's largest telecommunications companies ; rank ordered the carriers; identified at thecarrier level specific levers that could increase EVC .

• Segmentation Analysis and Divestiture Options . For a leading book publisher, analyzedthe business interdependencies (e .g ., cross selling, market reputation impact) of the varioussegments -- journals, education, professional, and trade ; strategic issue was the potential forselling off one or more segments to focus on the remaining segment(s) without damaging theoverall market position of the company .

• Market Entry Acceleration . Supported market entry by a new carrier, including marketentry tactics, operating processes, and support system requirements ; included retail andwholesale markets ; accelerated market entry and cashflow .

• Corporate Restructuring and Market Assessment - Satellite Communications . Directeda market-based analysis of five global businesses : (1) international public switched service ;(2) direct-to-home video ; (3) video contribution and distribution ; (4) very small apertureterminal services; and (5) consumer multimedia/Internet services ; based on the concept thatthe market drives strategy which then drives structure ; recommended a partial spin-off of aglobal telecommunications business unit .

• Merger & Acquisition Analysis . Led a strategic assessment for an interexchange carrier ;potential candidates were information services/ technology companies ; focus was uponsynergies of a carrier with an IT company ; scope included niche markets and dominant ITfirms .

• Teaming and Joint Venture Opportunities. Directed a strategic market study to identifyteaming opportunities and joint ventures between RBOCs and facilities-based long distancecarriers ; scope included joint marketing, industry-specific network services, networkmanagement, billing, and database services .

• International Partnership Negotiations. Assisted three carriers (one each from the U .S .,Europe, and Asia) to define the benefits of forming a new partnership to provide global end-to-end provisioning to multinational corporations ; researched the potential market usingprimary and secondary research methods ; evaluated management structures for the newentity, and valued the partnership contributions of each carrier .

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• Global Strategy. Directed an analysis of the international strategies of major U .S. andforeign carriers ; developed criteria for success and forecasted the "winners" over the nextfive to seven years ; study was used by our client to develop a competitive internationalstrategy .

• Forecast of Satellite Transponder Demand and Supply . Directed an analysis of themarkets for transponders and various supply scenarios ; scope included both C and Ku bandtransponders ; forecast covered a ten year period .

• Market Study of Long-Distance Satellite Telecommunications Services . Managed amarket survey for a resale common carrier that covered 16 major markets for long-distancevoice and data traffic ; compiled relevant raw statistics to forecast point-to-point voice anddata traffic.

• Digital Television Strategy (DTV) . In an effort to accelerate the rollout of DTV in the UnitedStates, conducted single and group interviews with broadcasters, consumer electronicscompanies, networks, and FCC staff; analyzed enhanced capabilities of DTV over analog ;developed multiple rollout scenarios ; assessed relative significance of critical factors affectingrollout ; developed business case for 8VSB broadcast modulation standard .

• Study of the Five-Year Demand for Satellite Earth Stations by Common Carriers andBroadcasters . Directed a market analysis for an earth station antenna manufacturer ;developed forecast using secondary sources and client's proprietary market data .

• Financial Analysis of a Nationwide Satellite System . Directed a financial analysis ofseveral options available for deployment of a second generation system of 300 earthstations ; scope included ground and space segment cost projections .

• Feasibility Study of the Direct Broadcast Satellite (DBS) Market. Directed a study of thecompetitive, regulatory, and technical risks of the DBS market .

• Pricing Study for a Cable Television Program Service . Conducted a market analysis todetermine the price elasticity of demand ; assisted the service to implement a successful priceincrease ; utilized primary market research as basis to compute subscriber willingness-to-pay .

SELECTED BUSINESS & CONSULTING EXPERIENCE : Operations and System s

• Margin Improvement at Wireless Company . Directed an analysis of the performance of acarrier's HR, Finance, Tax, and Supply Chain organization; goal was to scale supportfunctions in order to allow revenue and profit growth without an increase in G&A costs ; scopeincluded benchmarking over 100 metrics against industry standards and other third partysources ; developed . an organizational process model ; allocated labor among processes;identified inefficient practices and over-staffing ; facilitated cultural change and organizationalredesign .

• Operational Performance Measurement and Repo rt ing . Identified key performanceindicators for a national wireless carrier, including corporate reports of record for inclusion ina company-wide scorecard system that focused on financial measures, customersatisfaction, and internal operating performance assessment ; designated metrics and reportsavailable from a newly-implemented ERP system .

• Joint Process Improvement and Supplier Relationships . Assisted an aerospacecompany to redefine and restructure first and second tier vendor relationships to improve th e

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efficiency of its satellite manufacturing process ; objective was process improvement tofacilitate bidding on high volume LEO and MEO contracts .

• New Venture Business Launch . Assisted the management of a wireless subsidiary of amajor carrier to enter the market after license award ; developed core processes (e .g .,concept-to-market ; sales-to-service management ; usage-to-cash; customer contact-to-restoration) and support systems necessary to begin operations and accelerate entry into themarket for PCS services .

• Pre- and Post-Merger Integration . Adapted a template for use by an acquiring carrier tomanage pre-merger and post-merger activities ; the template covers 90 days before closingand 18 months after closing and allows management to control the process to improve theprobability of meeting the objectives of the transaction .

• Process and System Requirements for New Serv ice Rollouts . For a wireless carrier,defined the changes to existing order entry, activation, and fulfillment processes required bythe introduction of new wireless services such as worldwide roaming and packet data ; alsodeveloped functional IT requirements to support new services rollout .

• Process Improvement. For a national wireless telephony service company, directed aprocess improvement study of the order entry, customer activation, handset fulfillment, andnetwork provisioning functions ; additional objective was to identify metrics and standards bywhich certain strategic questions could be addressed such as outsourcing, centralization, andthe utility of over-the-air programming .

• Fiber Optic Urban Deployment. Structured the real estate penetration strategy for thenational rollout of a fiber optic-based Competitive Local Exchange Carrier (CLEC) ; focus wason negotiating with property managers and owners to accelerate penetration into targetbuildings across urban U .S . ; also included a wireless broadband strategy to supplement thefiber infrastructure .

• Local Exchange Order Entry Process and Systems . For an interexchange carrier,reengineered order entry process for the local service line of business ; reduced averageelapsed time per order by 50 percent .

• Rapid Rollout Product for New Carriers . Led the development of a packaged solution toaccelerate market entry for new carriers ; scope included market segmentation and businessplanning support, a full suite of core and support processes suitable for immediateimplementation (e.g ., order entry, trouble resolution, billing), and automated systemsrequirements ; objective was to put a carrier into business rapidly by leveraging pre-packagedcapabilities .

• Cost Reduction Through Sourcing Purchased Goods and Services . Participated in aproject to reduce a carrier's cost to purchase specific categories of goods (e.g ., outside plant)and services (e .g ., leased labor) ; significant annual savings on the order of 15 percentidentified .

• Productivity, Process Improvement, and Organizational Structure. Served as senioradvisor to a case team that was evaluating and improving internal processes at an Asiancarrier in anticipation of intensified competition ; recommended a new organizational model toreduce duplication of functions and facilitate reorganization into separate retail and wholesaleoperations .

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• Long -Distance Carrier Selection . Assisted multiple clients to : (a) identify their current andexpected future cost of service ; (b) formulate service requirements for voice, data, and video ;(c) issue an RFP ; (d) select a single vendor ; and (e) negotiate and implement a contract .

• Satellite Vendor Selection . Directed an analysis of proposals received by a client forpurchase of multiple transponders; required development of comparable costs for proposalswhich bundled different options into variable payment plans ; worked with the user to selectmost cost-effective proposal .

• State of California Centrex Study. Directed a major study for the State to determine thefeasibility of replacing Centrex with premise-based equipment at state offices ; scope includeddevelopment of a PC-based model to run site-specific PBX versus Centrex cost analyses .

• Telecommunications Study for a Major University. Directed a study of networkutilizations, cost reduction possibilities, purchase vs . lease equipment choices, and voice-data integration options for the university .

SELECTED RECENT SPEECHES AND PRESENTATION S

• Participated as a facilitator and commentator at management retreats focused uponthe impacts of competition , revenue growth , and new product development with theassociated requirements for rapid organizational change ; worked with Alcatel, Aliant,Ameritech, AT&T, Bell Atlantic, B .C. Tel, Bell Canada, Call Net, Canadian BroadcastingCorporation, Compaq, Edmonton Telephone, EDS, GTE, Hekimian, Kodak, Microsoft,National Association of Broadcasters (NAB), Nortel, Sprint (interexchange and localexchange), Telesystem, Telstra, Telus, Tribune Broadcasting, and Verizon .

• "The Impact of Broadband : It Has Only Just Begun ," Luncheon Speaker, America's TrustSponsor, Capitol Hill, Washington, DC (February 2005) .

• "The Myths and Realities of Universal Service ," The Progress & Freedom FoundationSponsor, Capitol Hill, Washington, DC (December 2004) .

• "Multicasting Power Panel : What's Hot, What's Not," Annual Convention of the NationalAssociation of Broadcasters, Las Vegas (April 2004) .

• "The Multicasting Business Oppo rtunity ," National Association of Broadcasters FuturesSummit 2004 ; also moderated two panels, Pebble Beach (March 2004) .

• "The Present and Future State of the Local Television Industry," Annual Convention ofthe National Association of Broadcasters, Las Vegas (April 2003) .

• "Small and Medium Business Market for High-Speed Data Se rvices," United StatesTelephone Association's SuperComm Conference, Atlanta (June 2002) ; also given at theTelecommunication's Industry Association Meeting , Washington, D .C. (April 2002) .

• "Summa ry of Strategic Trends in the U.S. Telecommunications Industry," NewMillennium Research Council, National Press Club, Washington (November 2001) .

• "Digital Television ' s Impact on Broadcast Television ," Annual Convention of the MaineAssociation of Broadcasters, Portland (October 2001) .

• "Competition Policy and the Local Telephone Indust ry," Commentator on the address ofDr. Michael Porter at the Canadian Competition Policy Conference, Toronto (June 2001) .

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• "Facing the Realities of the Digital Television Age," Panelist at the National Associationof Broadcasters (NAB) Annual Conference, Las Vegas, NV (April 2001) .

• "The Dawn of the Digital Television Era : What Is & What Could Be," to the StateLeadership Conference of Television Broadcasters, Washington, D .C. (March 2001) .

• "Telecommunications Indust ry Investment: The Importance of Due Diligence ;" at theSuperComm Conference, Atlanta (June 2000) .

• "Telephony, Television & The Internet: Convergence Trends and Realities ;" Sponsoredby the Board of the Canadian Broadcasting Corporation (CBC), Montreal (May 2000) .

• "The E-Commerce Revolution : Implications for the U.S. TelecommunicationsIndustry ;" keynote speaker at a conference on industry strategies for the 21St century ;hosted by the Ivey School of Business of the University of Western Ontario, Ottawa (April2000) .

• "E-Commerce : The Next Wave ;" at the Conference on Telecommunications andInformation Markets (COTIM '99) (September 1999) .

• "Technology Push & Marketing Pull: Migrating to a Data World ;" at the InternationalEngineering Consortium's Executive Institute , Jackson Hole (July 1999) .

• "The Business Case for High Bandwidth Satellites and Orbital Technology;" at theTelecom Conference organized by George Gilder and Forbes magazine, Lake Tahoe(September 1998) .

• "Digital Television in the United States : Long Fuse & Big Bang ;" served as co-chairmanof a workshop on the future of digital television given for Congressmen and their staffs at theRayburn House Office Building (July 1998) .

• "The Competitive Environment in the Telecommunications Industry : Circa 2003 -2005;"at a conference for clients and staff sponsored by Heidrich & Struggles, Dallas (June 1998) .

• "Retailing in the Emerging Digital Economy;" at a conference sponsored by Les Echos onEuropean retailing strategies, Paris (June 1998) .

PUBLICATION S

• The Myths and Realties of Universal Service, with Richard O . Levine and Randolph J . May(February 2005) .

• "Deregulation of Retail Local Services is both Appropriate and Inevitable ," with Richard0 . Levine and Randolph J . May, included in the International Engineering Consortium'sAnnual Review of Communications, (February 2005) .

• "The High -Speed Access Market for Small and Medium Businesses : Total andAddressable Markets with Penetration Scenarios ," included in the InternationalEngineering Consortium's Annual Review of Communications (Summer 2004) .

• Trends in the Competitiveness of Telecommunications Markets , with Richard O . Levineand Randolph J . May, published by the Progress and Freedom Foundation (December2003) .

• "The CLEC Experiment : Anatomy of a Meltdown ," with Larry F . Darby and Jeffrey A .Eisenach, published by the Progress & Freedom Foundation (September 2002) .

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• "Summa ry of Strategic Trends in the U .S. Telecommunications Indust ry," included inthe International Engineering Consortium's Annual Review of Communications (Summer2002) .

• "Local Exchange Competition : Progress in Ma ryland ," with Randolph J . May, publishedby the Progress & Freedom Foundation (May 2002) .

• Digital Television in a Digital Economy , for the National Association of Broadcasters, withRichard O . Levine (revised January 2002) .

• "Beyond the Network : The E -Commerce Oppo rtunity for the U .S. TelecommunicationsIndustry," included in the International Engineering Consortium's Annual Review ofCommunications (summer 2001) .

• "Local Exchange Competition : Progress in New Jersey," with Randolph J . May,published by the Progress & Freedom Foundation (July 2001) .

• "Global Telecom Trends : A U.S. Perspective," included in Strategies for the 21st Century,published by the Richard Ivey School of Business at the University of Western Ontario (May2001) .

• "Local Exchange Competition : Progress in Pennsylvania ," with Randolph J . May,published by the Progress & Freedom Foundation (October 2000) .

• "The Market -Driven Economics of Voice over Internet Protocol," included in Carrier IPTelephony 2000, published by the International Engineering Consortium (July 2000) .

• "The Convergence of Energy and Telecommunications ," Perspectives (4th Quarter1999) .

• "Tentative Steps Toward New Local Loop Technology ," included in adapting to NewRealities: The Canadian Telecommunications Industry, published by the Richard Ivey Schoolof Business at the University of Western Ontario (Fall 1998) .

• "Winners and Losers Emerge From Judicial Review of the FCC's Local ExchangeCompetition Order," with Richard O . Levine, A.T . Kearney (August 1997) .

• "Local Competition : The War of Many Against One (1997-2001)," A.T. Kearney IndustryWhite Paper Series (Summer 1997) .

• "A Primer on Technology Convergence : Causes & Effects," Annual Review ofCommunications 1997 by the International Engineering Consortium .

• "The Future of Digital TV : Market Rollout Scenarios and Prospects for a MoreUnified Technology ," participated in and edited the transcript of a managementroundtable (February 1997) .

• "Local Competition : The War of Many Against One (1996-2001 )," Annual Reviewof Communications 1996 by the International Engineering Consortium .

• "A Roundtable Review of the Future of Digital Television : The Implications forConsumers , Broadcasters , Cable Television , and Telephone Companies ," servedas organizer and transcript editor (Fall 1996) .

• "An Assessment of the Telecommunications Act of 1996 and Its Impact onCompetition and the Converging Communications , Information andEnte rtainment Industries ," with Richard O. Levine, A .T . Kearney (March 1996) .

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• "Local Competition : Changing Ground Rules for Network Access ," BusinessCommunications Review (Fall 1995) .

• "The Realities of Convergence : A Perspective on How To Avoid Becoming aRoad Kill on the Global Information Highway ," EDS 1994 Thought LeadershipSeries (December 1994) .

• "Changing Ground Rules : Local Competition ," special supplement to BusinessCommunications Review (September 1994) .

• "A New Perspective On the War of All Against All," Teletimes (Summer 1994),published by the United States Telephone Association .

• "Local Competition : The War of All Against All," Business CommunicationsReview (March 1993) .

• "Prepare for Rate Regulation Now," Multichannel News (March 1993) .

• "Outlook for Clinton Administration on Telecommunications and Cable Issues,"with Dwight Allen (December 1992) .

• "The Effects of Competition on Dominant Carriers : Common Patterns ofWorldwide Change ," Deloitte Touche Tohmatsu International Monograph (June1992) .

• "Global Telecommunications Leaders of the 1990s : A Delphi Analysis ," DeloitteTouche Tohmatsu International Monograph (March 1992) .

DISPUTE RESOLUTION AND EXPERT WITNESS EXPERIENC E

Qualified as an expert witness by courts, arbitration panels, mediators, and regulatory commissions .Scope of testimony has dealt with subject matter such as market analyses, valuation of businesses,and calculation of damages .

Also testified before legislative bodies on public policy matters, including the nature and extent ofcompetition in the telecommunications, broadcast, and high technology industries .Regulatory/legislative appearances and/or filings include :

• American Arbitration Associatio n

• Arkansas Public Service Commissio n

• California Commission on State Government Organization and Economy

• California Public Utilities Commission

• Florida: Committee of the State House of Representatives

• Federal Communications Commission (FCC )

• Florida Public Service Commission

• Illinois Commerce Commissio n

• Indiana Utility Regulatory Commission

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• Kansas State Corporation Commission

• Michigan Public Service Commission

• Missouri Public Service Commission

Montgomery County (MD) County Council

• New York Public Service Commissio n

• Ohio State: Legislative Committees (House and Senate)

• Oklahoma Corporation Commission

• Public Utilities Commission of Ohio

• Public Utility Commission of Texa s

• U.S. House of Representatives, Committee on Small Busines s

• U.S. Senate Commerce, Science and Transportation Committee

• Utah Public Service Commission

• Wisconsin Public Service Commission

Participated as an expert in multiple disputes including a class action shareholder suit involvingan interexchange carrier, two arbitrations involving pay phone contracts, a suit alleging theft ofhigh-technology trade secrets, two suits involving FCC license awards for IVDS service, adispute over the meaning of provisions in a senior executive's non-compete clause, anarbitration between an agent and an IXC over responsibility for order entry/billing errors, twosuits over disclosure adequacy by telecommunications companies that went bankrupt, adispute that alleged unfair negotiating practices on the part of an EMS radio equipment vendor,two contract disputes involving sales of cellular service at retail stores, and a shareholder suitconcerning management actions in the CLEC industry . Almost all commercial litigation casesinvolved calculation of damages based on case-specific facts and industry conditions .

Witness Appearances (since 2001 )

Case

1 . MCI WorldCom Communications vs . ElectronicData Systems (2001 )

2. Siesta Telecom, Inc. vs . Qwest CommunicationsCorporation (2002)

Tribunal Deposition Trial

Arbitration No Yes

U.S. District Yes NoCourt

2/25/2005 www.lecg.com Page 13 of 13

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EXHIBIT B

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EXPERT REPORTOF

DR. JOSEPH S. KRAEMER

DOCUMENTS CONSIDERED

Deposition transcript and exhibits of Solectron Corp . /Michael Brooks, taken September 28,2005.

Deposition transcript and exhibits of Larry Carter, taken September 29-30, 2005 .

Deposition transcript and exhibits of John Chambers, taken September 21-22, 2005

Deposition transcript and exhibits of Douglas Dennerline, taken August 18, 2005 .

Deposition transcript and exhibits of Kevin DeNuccio, taken August 25, 2005 .

Deposition transcript and exhibits of Brian Fukuhara, taken April 28, 2005 .

Deposition transcript and exhibits of Rick Justice, taken May 5, 2005 .

Deposition transcript and exhibits of Kevin Kennedy, taken September 15-16, 2005 .

Deposition transcript and exhibits of Donald Listwin, taken August 4, 2005 .

Deposition transcript and exhibits of Carl Redfield, taken September 9, 2005 .

Deposition transcript and exhibits of Robert Slater, taken September 20, 2005 .

Deposition transcript and exhibits of Donald Valentine, taken August 18, 2005 .

Deposition transcript and exhibits of Michelangelo Volpi, taken September 27, 2005 .

Deposition exhibits 919, 920 & 931 of Michael Ashby, taken August 3, 2005.

Deposition exhibits 591 & 598 of Rebecca Jacoby, taken June 24, 2005 .

Deposition exhibits 4, 5 & 7 of Paul Johnson, taken January 12, 2005

Deposition exhibits 38 & 46 of Sue Perkins, taken December 13, 2004.

Deposition exhibit 349 of Randy Pond, taken March 30, 2005 .

Deposition exhibit 1246 of Bill Sherry, taken August 19,-2005 .

Cisco Systems Inc .'s Objections and Responses to Plaintiff Central States, Southeast and

Southwest Areas Pension Fund's Sixth Set of Interrogatories .

Transcripts of December 4-5, 2000 Worldwide Analyst Conference audio tapes CIS-PPNPF-HC180289-180298.

Confidential

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Communications Act of 1934, as amended, 47 U.S .C.S . §256, "Coordination forInterconnectivity . "

Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CCDocket 96-98, Third Report and Order and Fourth Further Notice of Proposed Rule Making(November 1999) .

SEC Form 10-K for Allegiance Telecom Inc . (1999 & 2000)

SEC Form 10-K for AT&T (2000 )

SEC Form 10-Ks for At Home Corp. (1999 & 2000)

SEC Form 10-Ks for Cisco Systems, Inc. (1999-2001)

SEC Form 10-Ks for Critical Path Inc. (1999 & 2000)

SEC Form 10-Ks for Digex Inc . (1999 & 2000 )

SEC Form 10-Ks for Digital Island Inc . (1999 & 2000)

SEC Form 10-K for Electric Lightwave Inc. (1999 & 2000 )

SEC Form 10-Ks for Exodus Communications Inc . (1999 & 2000)

SEC Form 10-K for Focal Communications Corp . (1999 & 2000)

SEC Form 10-K for Genuity Inc . (2000)

SEC Form 10-Ks for Globix Corp . (1999 & 2000 )

SEC Form 10-K for High Speed Access Corp . (1999 & 2000)

SEC Form 10-K for iBasis Inc . (1999 & 2000)

SEC Form 10-K for ICG Communications Inc . (1999 & 2000 )

SEC Form 10-Ks for Intermedia Communications Inc . (1999 & 2000)

SEC Form 10-Ks for Internap Network Services Corp. (1999 & 2000)

SEC Form 10-Ks for ITC Deltacom Inc . (1999 & 2000)

SEC Form 10-Ks for Juno Online Services Inc . (1999 & 2000)

SEC Form 10-Ks for Kana Communications Inc . (1999 & 2000)

SEC Form 10-Ks for Lucent Technologies, Inc . (1999-200 1)

SEC Form 10-Ks for McLeodUSA Inc . (1999 & 2000)

SEC Form 10-Ks for Metromedia Fiber Network Inc . a/k/a Abovenet Inc . (1999 & 2000)

SEC Form 10-K for Navisite Inc . (2000)

SEC Form 10-Ks for NetVoice Technologies Corp . (1999 & 2000)

2

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SEC Form 10-K for NextLink Communications Inc . (1999)

SEC Form 10-Ks for Nortel Networks Corp . (1999-2001)

SEC Form 10-Ks for OneMain.com Inc. (1999)

SEC Form 10-Ks for PSINet Inc . (1999 & 2000)

SEC Form 10-K for Rhythms NetConnections Inc . (1999 & 2000)

SEC Form 10-Ks for Savvis Communications Corp . (1999 & 2000)

SEC Form 10-K for Sprint (2000 )

SEC Form 10-Ks for Teligent Inc . (1999 & 2000)

SEC Form 10-Ks for Time Warner Telecom Inc . (1999 & 2000)

SEC Form 10-Ks for USlnternetworking Inc . (1999 & 2000)

SEC Form 10-K for Verio Inc . (1999)

SEC Form 10-K for Winstar Communications Inc . (1999)

SEC Form 10-K for XO Communications a/k/a NextLink Communications Inc . (2000)

SEC Form 10 -Qs for AboveNet Inc . a /k/a Metromedia Fiber Network (6/30/00)

SEC Form 10 -Qs for Allegiance Telecom (6/30/00)

SEC Form 10-Qs for AT&T (3/31/00, 6/30/00, 9/30/00)

SEC Form 10 -Qs for At Home Corp . (6/30/00)

SEC Form 10 -Qs for Critical Path Inc. (6/30/00)

SEC Form 10-Qs for Digex, Inc . (6 /30/00)

SEC Form 10-Qs for Digital Island, Inc. (12/31/99 , 3/31/00 & 6/30/00)

SEC Form 10-Qs for Electric Lightwave (6/30/00)

SEC Form 10-Qs for Exodus Communications, Inc. (6/30/00)

SEC Form 10 -Qs for Focal Communications Corp . (6/30/00)

SEC Form 10-Qs for Globix Corp . ( 12/31/99 , 3/31/00 & 6 /30/00)

SEC Form 10 -Qs for High Speed Access Corp . (6/30/00)

SEC Form 10 -Q for iBasis Inc . (6/30/00)

SEC Form 1OQs for ICG Communications, Inc . (6/30/00)

SEC Form 10 -Qs for Intermedia Communications , Inc. (6/30/00)

SEC Form 10 -Qs for Internap Network Services Corp . (6/30/00)

SEC Form 10 -Qs for ITC DeltaCom Inc . (6/30/00)

SEC Form 10 -Qs for Juno Online Services , Inc. (6 /30/00)

SEC Form 10 -Qs for Kana Communications (6/30/00)

Page 32: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

SEC Form 10-Qs for Lucent Technologies, Inc . (3/31/00, 6/30/00, 12/31/00)

SEC Form 10-Qs for McLeodUSA Inc . (6/30/00)

SEC Form 10-Qs for NaviSite Inc . (1/31/00, 4/30/00 & 7/31/00)

SEC Form 10-Q for NetVoice Technologies Corp . (6/30/00)

SEC Form 10-QSB for NetVoice Technologies (6/30/01 )

SEC Form 10-Qs for Nextlink (6/30/00)

SEC Form 10-Qs for Nortel Networks Corp . (6/30/00, 9/30/00)

SEC Form 10-Qs for OneMain.com, Inc. (6/30/00)

SEC Form 10-Qs for PSINet Inc . (6/30/00 )

SEC Form 10-Qs for Rhythms NetConnections (6/30/00)

SEC Form 10-Q for SAVVIS Inc . (6/30/00)

SEC Form 10-Qs for Sprint (3/31/00, 6/30/00 & 9/30/00)

SEC Form 10-Qs for Teligent, Inc . (6/30/00)

SEC Form 10-Qs for Time Warner Telecom Inc . (6/30/00)

SEC Form 10-Qs for USlnternetworking (6/30/00)

SEC Form 10-Qs for Verio, Inc . (3/31/00 & 6/30/00)

SEC Form 10-Qs for Winstar Communications, Inc . (6/30/00)

SEC Forom 8-K for High Speed Access Corp. (2/28/02 )

SEC Form 8-K/A for Nortel Networks Corp . (8/18/00)

SEC Form 8-K for Winstar Communications (11/11/00)

SEC Forms S-1 for Genuity (4/7/00 )

Expert report of D . Paul Regan .

James H . Vander Weide, Ph.D.'s Expert Report and back-up documents : US Trade Industry

Outlook '98, '99 & '00 (3 disks) ; articles : Dow Jones & Co ., Inc. "Ex-Fed Governor Gramley

Sees Soft Landing of US Economy" (11/9/00), "Fed's Ferguson Suggests Fed Will Shift toNeutral Bias" (12/6/00), Reuters News "U .S . Fed stands pat on rates, warns of risks" (11/15/00),

"Greenspan's blunt words leave economists puzzled" (1/28/01), Stanford University GraduateSchool of Business "Blue Chip Economic Indicators, Top Analysts' Forecasts of the U .S .

Economic Outlook for the Year Ahead" (Vol . 25, No. 12, 12/10/00), stock pricing & long-term

earnings growth estimates, GDP information ; 1 disk "Vander Weide Documents" ; The Insight

4

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Research Corporation "Gateways & the Telecom Carrier : Middleware & Mediation Platformsfor Next Generation Networks 2000-2004," "Telecom Services in Vertical Markets, Updated

Report 1998-2003," "Telecommunication Services in Vertical Markets, 2001-2006" ; Analyst

reports.

Jeffrey P . Williams' Expert Report and back-up documents : Business Week "Bad Loans RattleTelecom Vendors When upstart carriers default, their suppliers take a hit" (2/19/01) ; Telephony,

"The death of the CLEC has been greatly exaggerated" (Vol. 240, No. 11, 3/12/0 1) ; Moody'sInvestor Service Press Release, "Moody's Downgrades Lucent's Long Term Rating to A3 from

A2 and Short Term Rating to P-2 from P-1" (12/21/00) ; The McKinsey Quarterly, "Caveat

vendor" (6/22/01) ; Interactive Week from ZDWire, "The Inside Story of ICG's Collapse"

(6/7/01); Dow Jones News-Service, "Smartmoney .com: A Ticking Telecom Time Bomb?"

(1/25/01); CFO, The Magazine for Senior Financial Executives, "Road to Riches?" (8/1/00),FCC release "Federal Communications Commission Releases Latest Data on Local Telephone

Competition" (5/21/01) .

AT&T Group Earn ings Commentary , Fou rth Qua rter 2001, Appendix III - Historical SegmentData .

Sprint Corporation, Pro Forma Selected Operating Results for Quarters Ended December 31,

2000-March 31, 2001 .

"Allegiance Telecom . Announces Restructuring Plans and First Quarter 2003 Results," PR

Newswire (May 14, 2003) .

"Cable & Wireless completes acquisition of Digital Island," M2 Presswire (Aug . 31, 2001) .

"Cable and Wireless Wins Court Approval to Buy Exodus," The New York Times (Jan . 18,

2002) .

Chris Nolter, "More CLEC consolidation ahead," Daily Deal (May 17, 2004) .

"ClearBlue Technologies Acquires Majority Ownership Position in NaviSite ; Hewlett Packard

Financial Services Become Minority Shareholder in ClearBlue," PR Newswire (Sept . 11,

2002) .

"Compaq, CMGI throw $30M lifeline to NaviSite," The Boston Business Journal (Nov . 9, 2001) .

David Shabelman, "At Home-Excite : a failure on many fronts," Daily Deal (Nov . 13, 2001) .

David Shabelman, "Critical Path gets $15M lifeline," Daily Deal (Jan . 21, 2004) .

"EarthLink to acquire OneMain .com for 3 .72 times revenue," NVST.com, Inc. (June 19, 2000) .

Emily Burg, "At Home sells assets, goes bust," Daily Deal (Sept . 30, 2001) .

Eric Young, "Globix declares bankruptcy," Daily Deal (Mar . 4, 2002) .

FCC release, "FCC Releases Local Telephone Competition Report" and attaching "LocalTelephone Competition at the New Millennium" (August 31, 2000) .

5

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FCC release, "Federal Communications Commission Releases Data on Local Telephone

Competition" and attaching "Local Telephone Competition : Status as of June 30, 2000"

(December 4, 2000) .

FCC release, "Federal Communications Commission Releases Latest Data on Local TelephoneCompetition" and attaching "Local Telephone Competition : Status as of December 31, 2000"

(5/21/01) .

Gregory Zuckerman & Deborah Solomon, "Telecom Debt Debacle Could Lead to Losses ofHistoric Proportions," The Wall Street Journal (May 11, 2001) .

Hilary Smith, "IDT picks up Winstar," RCR Wireless News (Dec . 24, 2001) .

Karen Kaplan, "Rivals Juno and NetZero Plan Merger ; Web: The $70.7-million deal wouldcreate the second-largest ISP, as free ISPs arrive to find ways to make money," Los Angeles

Times (June 8, 2001) .

Kris Hudson, "NTT Completes Verio Takeover," Denver Rocky Mountain News (Sept . 12,

2000) .

Larry Darby, Jeffrey Eisenach & Joseph Kraemer, "The CLEC Experiment : Anatomy of aMeltdown," September 2000, published by the Progress & Freedom Foundation (release

9.23) .

"Lessons from Lucent (Special Report) January 13, 2000," The Motley Fool,

http ://www.fool .com/specials/2000/spOO01 j3l ucent . htm .

Lisa Endlich, Optical Illusions: Lucent and the Crash of Telecom (Simon & Schuster 2004) .

"Lucent Technologies comments on expectations for first fiscal quarter 2000 earnings," LucentTechnologies press release, littp ://www.lucent.com/press/0100/000106 .cob .html (Jan. 6, 2000) .

"MCI completes tender offer for Digex," Epicom Business Intelligence (Nov . 18, 2003) .

"Metromedia Fiber to acquire AboveNet," CBS MarketWatch (June 23, 1999) .

"Nortel sparks sell-off," CNNMoney, http ://money .cnn .com/2000/10/24/news/earns nortel .index .htm (Oct .24, 2000) .

P. Solomon Banda, "ICG files for bankruptcy protection," The Associated Press State & LocalWire (Nov. 15, 2000) .

Robert Slater, The Eye of the Storm (HarperCollins 2003) .

Stephen Manning, "Annapolis Internet company files bankruptcy," The Associated Press State &Local Wire (Jan. 8, 2002) .

"Summary of Strategic Trends in the U.S. Telecommunications Industry," Joseph Kraemer(editor), January 2002, published by Law & Economics Consulting Group and included inthe International Engineering Consortium's Annual Review of Communications (Summer

2002) .

Telcordia Technologies Special Report, "Integrating Voice and Data Services in Next GenerationNetworks - An Architectural Framework" (Issue 1, March 2000) .

Telecom-Wireline, excerpt of Morgan Stanley Dean Witter report, pp . 15-23 (November 28,

2000) .

6

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Terence Chea, "PSINet Continues Selling Operations," The Washington Post (June 21, 2001) .

The Conference Board release, "U .S. Leading Economic Indicators and Related CompositeIndexes for October 2005" (November 21, 2005) .

The Conference Board, Composite Index of Ten Leading Indicators - U .S ., Monthly Data .

The Progress & Freedom Foundation, "The Local Telecommunications Marketplace : Are New

Policy Directions Needed?" (Release 8 .7, April 2001) .

Yuki Noguchi, "USlnternetworking Out of Bankruptcy ; Md. Company Gets $81 Million inFunding, Plans Merger with N.C. Firm," The Washington Post (May 22, 2002) .

CISCO SYS INC CIS-PPNPF-0005453-573 4Larry Carter, 8/10/99, 4Q FY 199 9Question and Answer TranscriptLetter from Brian Fukuhara to Jeff Cole ; January 23, 2001 CIS-PPNPF-006366 3Credit Scoring Model, ISP/SP/CLEC CIS-PPNPF-0070874-7087 6Email from Brian Fukuhara, To : drogan@cisco .com, CIS-PPNPF-0071522rdrobny@cisco .com, ablacklo@cisco .comCc : donichol@cisco .com, rcsnyder@cisco .com, Re : RiskProfile Slide sCisco Capital Worldwide Tie out to CIS-PPNPF-0077833-86 2Consolidated Balance Sheets - PDO1-02

Worldwide Financing Activity Program Description ; CIS-PPNPF-0078929-94 4November FY0 1Cisco FY01 January Month End Capital Leases Net CIS-PPNPF-0078939-7894 3ExposureWorldwide Financing Activity, Balance Sheet Net CIS-PPNPF-0079881-89 4Exposure Analysis, October FY0 1Chase Equity Research Industry Report, July 11, 2000 CIS-PPNPF-0081433-8145 3JPMorgan Equity Research Industry Report, December 7, CIS-PPNPF-0081454-8151 51999. "Beyond the Internet . . .The emergence of Broadban dand IP Data Services as the Prime Mover of a Technology-

Driven Economy . "Conference Call Transcripts, Ql& Q2 FY01 ; Q3 FY00 CIS-PPNPF-0084701-8476 7IssuesConference Call Transcripts, Q4 FY00-Q1 FY01 ; Q101 CIS-PPNPF-0084797-84874IssuesConference Call Transcripts, Q3 FY01 CIS-PPNPF-0084910-8494 3Issues/ Q&A Table of Contents, 3QFYO1 CIS-PPNPF-0084944-8496 9Cisco Transcript, Moderator Larry Carter, August 8, 2000 CIS-PPNPF-0088632-8864 9Report : "NextGen IP Optical" Is the Future CIS-PPNPF-0089329-8942 6Worldwide Analyst Conference 2001, "Master Project CIS-PPNPF-0090607-62 0Plan." December 4-5, 200 1Q4 FY00 Issues CIS-PPNPF-0091551-9155 6

7

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Conference Call Transcripts, Q3 FY00, May 9, 2000 CIS -PPNPF-009346 1Worldwide Financial Policies and Procedures Doc . CIS-PPNPF -0099406-99453Approved by Dennis Powell ; effective date : September 22 ,1998Email from KSlocum@witsoundview . com, to CIS-PPNPF -010131 7rdetata@cisco .com; cc : dzako@witsoundview . com; Re :Our Last Plea ; March 15 200 1E-mail from Ron Bernal re : Prep for conf. call, dated CIS -PPNPF-0101406-40 810/16/00 , to David Vellequette , Lawrence Lang, Gre gThomas , Roberta DeTata, Kevin Kennedy , Carl Redfield,Blaire Christie , [email protected] , acra@cisco .com ,braskamp rr. ,cisco .com , smarshal a , cisco .com ,a ierce c cisco .comMorgan Stanley Dean Witter , September 5, 2000 Equity CIS-PPNPF -0107461-10746 6Research report/Company Update on Cisco Systems ,"Squeaky Clean on Customer Financing"Larry Carter, 11/09/99 , 1Q FY 2000 CIS-PPNPF-0107572 - 10759 8Question and Answer TranscriptLarry Carter, 02/08/00, 2Q FY 2000 CIS-PPNPF-0107631-10765 1Question and Answer TranscriptWW Sales Operations Review, December 11, 2000 CIS-PPNPF -0110353-11043 2From : Cory Ellsworth <[email protected]> CIS-PPNPF-01 13729-11373 1Sent : Wed 23 Feb 2000To:paperry @cisco .com, [email protected],kgranade @oisco .com , [email protected],markande@cisco . com, wsherry @cisco.com ,[email protected] , cstoeppe @cisco.com ,[email protected] : Fwd: FW : FW: ICG UpdatePowerPoint Presentation , "Cisco Capital Update for CIS-PPNPF -0157879 - 15789 8Investment Commi ttee," Brian Fukuhara , January 8 , 2001 . "Americas Theater FY '01 Operation Level Base Booking CIS-PPNPF -0171832-17183 5Plan, Version 1 .0 - Updated on 07/20/0 0Enterprise-Federal, FY 01 Plan Book , Cisco Systems - US CIS -PPNPF-0480550-603US SP 6/26 Commit , FY01 Plan CIS -PPNPF-0486479-48648 4PSINet Shipping Error and Equipment Return Issues CIS -PPNPF -0494056PSINet Shipping Error and Equipment Return Issues CIS-PPNPF-0494056 -49405 7Spreadsheet, Loan Customers , FY00 thru 7/29/00 CIS -PPNPF-0498145 -498146Deloitte & Touche Doc - "Cisco Systems Capital CIS-PPNPF -0506642-50665 5Compliance Pro j ect, Phase 1, October 12, 2000 . "Morgan Stanley Dean Witter Equity Research Industry CIS-PPNPF -0519565-519656Report, Data Networking /Internet Infrastructure an dServices , December 7, 2000 .Worldwide Financial Policies and Procedures Doc . CIS -PPNPF-0523405 -523449Approved by Dennis Powell ; effective date : September 22 ,1998

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PowerPoint Presentation - Cisco Capital Update, September CIS-PPNPF-0523487-52352 720, 200 0Customer Financial Services Policies and Procedures ; CIS-PPNPF-0523569-523572Approved By John Della Marco/ Brian Fukuhara ; January19, 2001, Subject : New Account Credit Approval Policyand ProcedureUS SP 7/7 Plan Adjustment CIS-PPNPF-0528551-0528554Cisco Capital Corporation Leasing Reserve; P3FY01 CIS-PPNPF-0533836-53385 0Worldwide Sales Operations Review presentation, CIS-PPNPF-0538991-53904 1December 11, 2000Cisco Systems, Worldwide Sales FY00 Plan, September 16, CIS-PPNPF-0539633-6421999Cisco Capital Leasing Reserves, Q2 FY01 CIS-PPNPF-0541858-541976Cisco Worldwide Sales Operations, FY01 Plan, First Pass CIS-PPNPF-0545609-61 2April 20, 2000Operations Review, WW Field Operations presentation, CIS-PPNPF-0546640-54676 3June 19, 200 0US Service Provider Operations, FY01 Planning Meeting CIS-PPNPF-0547375-38 8May 18-19, 2000Product Bookings - Final, 8/14/2000 CIS-PPNPF-0563390-56339 5FY2001 Plan Book, sent to Jim Anderson, Michael Ashby, CIS-PPNPF-0568890-8946Larry Carter and John Chambers, August 14, 200 0Conference Call Transcript, Q4 FY99 CIS-PPNPF-0610010-61001 3DCR'S DLEC Industry Review CIS-PPNPF-0650379-65039 0Cisco Capital Lease Line Credit Review - PSI Net CIS-PPNPF-0655138-65514 0Requested Approval $50mm.Energy Communications Report, Vol . 3, No . 3 July 2000 . CIS-PPNPF-0699311-69931 8"Metro Carriers' Carrier Market : Understanding Supplyand Demand in the Top 20 MSAs ."

June Close Mt g . Q4 FY01 CIS-PPNPF-0700471-70073 9July Close Mt g . Q4 FY01 CIS-PPNPF-0700942-97 3Worldwide Financial Services, Leasing Reserve, P1 FY00 CIS-PPNPF-0769471-76947 3Cisco Capital, Leasing Reserve, P2 FY01 CIS-PPNPF-0769530-76953 1Cisco Capital, Leasing Reserve, P5 FY01 CIS-PPNPF-0769537-76954 2WW Sales Operations Fiscal Year 2001 Planning Calendar CIS-PPNPF-1067093-1067102C.E. Unterberg Industry Report, Service Provider Software, CIS-PPNPF-1074253-1074362"An Investment Opportunity Emerges," June 15, 200 0Merrill Lynch, Industry Report, Telecommunications CIS-PPNPF- 1074721-1074763Equipment, 2Q US Capex & July '00 Survey Teleco m

ManagersLehman Brothers, October 18, 2000 "The Dark Side of CIS-PPNPF-1074731-107479 1Leverage On the Impact of Telecom Credit Spreads . "Email from Nghia Tran, Fwd : Update Charts Please CIS-PPNPF-108963 5Cisco Capital Structured Finance Overview, November 10, CIS-PPNPF-1137807-113782 12000

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Service Provider Q1 FY01 Quarterly Business Summary, CIS-PPNPF-1 13917-11391 9October 31, 2000Cisco Capital Structured Finance Overview CIS-PPNPF-523621-523642PaineWebber Equity Research, April 2000, "Cisco CIS-PPNPF-HC 063772-86 1Systems, Are They Ready?"Cisco Worldwide Analyst Conference 2000 Slides CIS-PPNPF-HC 0011649-1166 7Cisco Worldwide Analyst Conference 2000 Slides - Kevin CIS-P?NPF-HC_0011690-1171 0KennedyCisco Worldwide Analyst Conference 2000 Slides - IP + CIS-PPNPF-HC_0011813-1184 5OpticalCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0011846-11860Enterprise Voice and Video Solutions, Martin DeBee rCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0011861-11876Service Provider Voice Update

Cisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0011877-11897Enterprise Security Solutions to Enable E-business .Cisco Worldwide Analyst Conference 2000 Slides - Mobile CIS-PPNPF-HC_0011898-1191 2Office Solutions for the Business Professiona l

Cisco Worldwide Analyst Conference 2000 Slides - E- CIS-PPNPF-HC_0011913-1192 8Powering the Network Edge, Paulette AltmaierCisco Worldwide Analyst Conference 2000 Slides - ASPs : CIS-PPNPF-HC_0011930-11944Economies of Skills not Just Economies of Scale, Eugen eLeeCisco Worldwide Analyst Conference 2000 Slides - MPLS CIS-PPNPF-HC_0011945-11959Key Technology Enables by Cisco IOS Software

Cisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0011960-1197 3Internet Services Provisioning for AppliancesCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0011974-1198 6Content Networking for the Enterprise and Service ProviderCisco Worldwide Analyst Conference 2000 Slides - QoS CIS-PPNPF-HC_0012037-1205 3for IP Network s

Cisco Worldwide Analyst Conference 2000 Slides - IP CIS-PPNPF-HC_0012054-1206 2Telephony and the Call Center : A Platform for the FutureCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0012063-1207 5Broadband Business Solutions - SOHO to EnterpriseBranch Offic eCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0012076-1209 4Acceleration Customers Internet Business Transformation

in the Financial Services IndustryCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF- HC_0012095-1212 5Broadband Acces sCisco Worldwide Analyst Conference 2000 Slides - CIS-PPNPF-HC_0012127-1216 9Advances in IPCisco Worldwide Analyst Conference 2000 Slides - IP CIS-PPNPF-HC_0012141-1215 2Telephony and Unified Communications Revenue Driverfor the Service Provider Market

10

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Cisco Worldwide Analyst Conference 2000 Slides - VP NSolutions for the Enterprise and Service Provider

CIS-PPNPF-HC_0012170-1218 8

Cisco Worldwide Analyst Conference 2000 Slides - TheFuture of Ethernet

CIS-PPNPF-HC_0012189-1221 4

Cisco Worldwide Analyst Conference 2000 Slides - Ne wWorld Services

CIS-PPNPF-HC_0012758-1279 8

Cisco Worldwide Analyst Conference 2000 Slides -Cisco's Strategy for the Internet Economy BreakawayOpportunity, John Chambers

CIS-PPNPF-HC_0012861-1287 6

Cisco Worldwide Analyst Conference 2000 Slides - TheNew Customer Value Proposition

CIS-PPNPF-HC_0012877-1289 3

Cisco Worldwide Analyst Conference 2000 Slides -Telecoms?!? A World of Unlimited Bandwidth, Carl Russo

CIS-PPNPF-HC_0012907-1291 7

Cisco Worldwide Analyst Conference 2000 Slides - MPL SKey Technology Enabled by Cisco IOS Software

CIS-PPNPF-HC_0013056-1307 0

Cisco Worldwide Analyst Conference 2000 Slides - Cisc oMobile Wireless Overview

CIS-PPNPF-HC_0013098-1311 3

Cisco Capital, Highlights FY2000 -Aril Q3 M3 CIS-PPNPF-HC 0016147-15 2Cisco Capital, Highlights FY2000 - January Q2 M3 CIS-PPNPF-HC 0018334-33 8Cisco Capital, Highlights FY2000 - July Q4 M3 CIS-PPNPF-HC 0018866-87 3Cisco Capital, Highlights FY2000 - October Q1 M3 CIS-PPNPF-HC 0021481-48 5Cisco Capital Loan Administration Policy, 1/29/2000 CIS-PPNPF-HC 0054959-5502 9October FY 01 Close Meeting, November 1, 2000 CIS-PPNPF-HC 040718-75 5Cisco Worldwide Analyst Conference 2000 Slides -Internet Services Provisioning for Appliances

CIS-PPNPF-HC_090956-09096 9

Invoices CIS-PPNPF-HC 093303Email from Steve Darendinger, Fwd: Stretch Issues CIS-PPNPF-HCO6131 1Meeting Minutes, Board of Directors, January 12, 2000 CIS-PPNPF-HCO61555-67Meeting Minutes, Board of Directors, March 30, 2000 CIS-PPNPF-HCO61568-78Exhibit A : Merger with ArrowPoint Communications, Inc . CIS-PPNPF-HCO61581-8 4Meeting Minutes, Board of Directors, May 10, 2000 CIS-PPNPF-HCO61585-86Meeting Minutes, Board of Directors, July 27, 2000 CIS-PPNPF-HCO61587-600Meeting Minutes, Board of Directors, September 21, 2000 CIS-PPNPF-HCO61601-1 1Meeting Minutes, Board of Directors, November 14, 2000 CIS-PPNPF-HCO61612-2 1Meeting Minutes, Board of Directors, January 09, 2001 CIS-PPNPF-HCO61622-49Meeting Minutes, Board of Directors, March 15, 2001 CIS-PPNPF-HCO61650-57Meeting Minutes, Board of Directors, May 10, 2001 CIS-PPNPF-HCO61658-6 1Board of Directors Meeting, Board Package, January 12 ,2000

CIS-PPNPF-HCO63224-300

Board of Directors Meeting, Board Package, March 30 ,2000

CIS-PPNPF-HCO63371-58 3

Board of Directors Meeting, Board Package, January 12 ,2000

CIS-PPNPF-HCO63589-622

Board of Directors Meeting, Board Package, May 11, 2000 CIS-PPNPF-HCO63623-86 1Board of Directors Meeting, Board Package, July 27, 2000 CIS-PPNPF-HCO63862-93 9

11

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Meeting Minutes, Board of Directors , May 1, 2000 CIS-PPNPF-HCO63940-45Board Package, September 21, 2000 CIS-PPNPF-HCO63946-405 6Meeting Minutes, Board of Directors, July 27, 2000 CIS-PPNPF-HCO64057-7 8Board of Directors Meeting, Board Package, November 14,2000

CIS-PPNPF-HCO64079-64178

Meeting Minutes, Board of Directors, September 21, 2000 CIS-PPNPF-HCO64179-20 1Board of Directors Meeting , Board Package, January 9,2001

CIS-PPNPF-HCO64202-2 8

Board of Directors Meeting , Board Package, January 9,2001

CIS-PPNPF-HCO64229-34 0

Meeting Minutes, Board of Directors, November 14, 2000 CIS-PPNPF-HCO64341-8 3Board Meeting Agenda, March 15 , 2001 CIS-PPNPF-HCO64384-49 5Meeting Minutes, Board of Directors, January 9 , 2001 CIS-PPNPF-HCO64496-53 1Board of Directors Meeting, Board Package, May 10 , 2001 CIS-PPNPF-HCO64532-60 8PowerPoint Presentation , "FY02 Planning : Guidin gPrinciples"

CIS-PPNPF-HCO64609-24

PowerPoint Presentation , "eHub" CIS-PPNPF-HCO64625-50Meeting Minutes , Board of Directors, March 15, 2001 CIS-PPNPF-HCO64651-60Meeting Minutes , Special Meeting of the AcquisitionCommittee , January 12, 2000

CIS-PPNPF-HCO64730-3 9

Meeting Minutes, Special Meeting of the AcquisitionCommittee, February 9, 2000

CIS-PPNPF-HCO64740-44

Meeting Minutes, Special Meeting of the AcquisitionCommi ttee, March 10, 2000

CIS-PPNPF-HCO64745-49

Meeting Minutes , Special Meeting of the AcquisitionCommi ttee, March 13, 2000

CIS-PPNPF-HCO64750-54

Meeting Minutes , Meeting of the Acquisition Committee ,April 4, 2000

CIS-PPNPF-HCO64755-5 9

Meeting Minutes, Special Meeting of the Board of

Directors, May 1, 2000CIS-PPNPF-HCO64760-65

Meeting Minutes , Special Meeting of the AcquisitionCommi ttee, June 28, 2000

CIS-PPNPF-HCO64766-74

Meeting Minutes , Special Meeting of the AcquisitionCommi ttee , July 24, 2000

CIS-PPNPF-HCO64775-84

Meeting Minutes, Special Meeting of the Acquisitio nCommittee , August 22, 2000

CIS-PPNPF-HCO64785-89

Meeting Minutes, Special Meeting of the AcquisitionCommittee , March 15, 2000

CIS-PPNPF-HCO64821-29

Meeting Minutes, Special Meeting of the AcquisitionCommittee , May 5, 2000

CIS-PPNPF-HCO64830-3 5

Meeting Minutes, Special Meeting of the AcquisitionCommittee , October 6, 2000

CIS -PPNPF-HC06483 6-40

Meeting Minutes, Special Meeting of the Acquisition

Committee , October 13, 2000

CIS-PPNPF-HCO64841-5 0

Meeting Minutes of the Investment Finance Commi ttee of CIS-PPNPF-HCO64851-5 2

12

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the Board of Directors , January 12, 2000Meeting Minutes of the Investment Finance Committee of CIS-PPNPF-HCO64853-5 7the Board of Directors , May 9, 2001

Meeting Minutes of the Compensation/Stock Option CIS-PPNPF-HCO64858-91 4Commi tteeMeeting Minutes of the Investment Finance Committee of CIS-PPNPF-HCO64915-1 6the Board of Directors , May 10, 2000

Meeting Minutes of the Investment Finance Committee of CIS-PPNPF-HC064917-18the Board of Directors, January 21, 2000Meeting Minutes, Special Meeting of the Acquisition CIS-PPNPF-HCO64920-25Commi ttee , January 12, 2000Meeting Minutes of the Investment Finance Committee of CIS-PPNPF-HC064931-37the Board of Directors , September 20, 2000Dresdner Kleinwort , Benson Research, "Optical Switching : CIS-PPNPF-HC094401-9444 1Unleashing the Power ofLight." September 2000Worldwide Analyst Conference (December 4-5, 2000) CIS-PPNPF-HC 180289-18029 8audio tapesFaxed Doc from Katie Easterly to Kevin Kennedy, CIS-PPNPF-HC191763-19304 1November 20, 2000 , Contains email fromDvellequ@franklin . cisco . com to Kevin Kennedy; Re: MySummary of the BusinessPWC Audit : Assets, PP+E, Intangible Assets, Capital PWC 004950-5266Corporation, In Process R&DCapital Corp Balance Sheet Flux 7/26/2001 vs . 4/26/2001 PWC 005237-524 3Revenue and Reserves & Deferral Meeting Agenda, July PWC 007768-777 625, 200 0Cisco Capital Loan Reserves Doc PWC 016109-1611 3Cisco Lease Reserves Memo , 7/29/2000 PWC 017694-1769 6Cisco Capital - Note Receivable Analysis, 07/31/1999 PWC 025865-2586 9Email to John Hollenbeck from Michael A. Jerome, Re : PWC 037666-037670Cisco Loan Geography, 12/08/1998

13

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EXHIBIT C

Page 43: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

ry

Invoice #0101

e

XPRT Professional Services, Inc.

Tax ID #: 20-3861288

December 3, 2005

Daniel S. Drosman, Esq.Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego, CA 92101-3301

Project: In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional services and related out-of-pocket expenses for the periodOctober 26 - November 30 :

Professional Fees $ 56,762.50

Expenses 1,412.77

TOTAL DUE $ 58,175.27

Please make payment by check to XPRT Professional Services, Inc.

Remit to : Dr. Joseph S . KraemerXPRT Professional Services, Inc .1202 South Huntress. CourtMcLean , VA 22102

4 S. Kraemer

D' or

Page 44: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

ePROFESSIONAL SERVICES

Joseph S. Kraemer, Directo r

October 27October 28October 29October 31November 1November 2November 7November 8November 9November 10November 11November 13November 14November 15November 16November 17November 18November 20November 22November 23November 24November 25November 27November 28November 29November 30

2.5 hours4.0 hours3.5 hours3.5 hours

10.0 hours4.5 hours6.0 hours7.5 hours5.5 hours6.0 hours6.5 hours2.0 hours6.0 hours6.0 hours

$425 per hour

Review. depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentationReview depositions and related documentatio nReview case documentationReview case documentationReview case documentationReview case documentationReview case documentation

8.0 hours Prepare for meeting with counsel8.0 hours Meet with counsel; review case documentation5.0 hours Meet with counsel; review case documentation3.0 hours Review case documentation4.0 hours Review case documentation5.5 hours Review case documentation4.0 hours Review case documentation2.5 hours Review case documentation4.0 hours Review case documentation4.0 hours Review case documentation7.0 hours Review case documentation3.0 hours Review case documentation

TOTAL HOURS = 131.5 $55,887.50

Charlotte L. Brown, Case Associate $125 per hou r

October 27 1.5 hours Organized case materialNovember 7 1.5 hours Organized case materia lNovember 22 3.0 hours Organized case materia lNovember 30 1.0 hours Organized case materia l

TOTAL HOURS = 7.0 $ 875.00

TOTAL LABOR $56,762.50

Page 45: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

EXPENSES

Communications

Express Messenger

San Diego Travel(November 16 - 22)

Hotel (3 nights)

Meals

Taxicabs

Fax

Subtotal - Trip

Source

$ 85.89 LECG Accounting System

$ 360.98 LECG Accounting System

$ 659.70 Hyatt Hotel Receipt

$ 196.20 Lower of per diem or actual - seeattached

$ 96.00 No receipts - see attached

$ 14.00 Hyatt Hotel Receipt

$ 965.90

TOTAL EXPENSES $1412 .77

Page 46: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

e' cMEAL HISTORY

November 16 Dinner $35.00

November 17 Breakfast 15.00

Lunch NA

Dinner 31.20 (Hyatt receipt)

November 18 Breakfast 15.00

Lunch 25.00

Dinner 35.00

November 20 Breakfast 15.00

Lunch 25.00

TOTAL $196.20

Allowable meal expenses are the lower of actual or per diem.

Page 47: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

TAXIS

November 16

Home to Airport $38.00

Airport to Hotel 10.00

November 20

Hotel to Airport 10.00

Airportto Home 38.00

TOTAL $96.00

Our firm does not require receipts for expenses of $50 or less .

Page 48: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Invoice #0102

XPRT Professional Services, Inc.

Tax ID #: 20-3861288

December 20, 2005

Daniel S. Drosman, Esq.Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego , CA 92101-330 1

Project: In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional services and related out-of-pocket expenses for the periodDecember 1 - December 15, 2005 :

Professional Fees $ 68,300.00

Expenses. 721.93

TOTAL DUE $ 69,021 .93

Please make payment by check to XPRT Professional Services, Inc .

Remit to : Dr. Joseph S . KraemerXPRT Professional Services, Inc .1202 South Huntress Cou rtMcLean , VA 22102

Joseph S. KraemerDirector

Page 49: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

PROFESSIONAL SERVICES

Joseph S. Kraemer, Director $425 per hour

C",

December 1 10.0 hours Review reports and related documentatio nDecember 2 10.0 hours Review reports and related documentationDecember 3 11.0 hours Review reports and related documentationDecember 4 10.0 hours Develop report outlin eDecember 5 13.0 hours Prepare reportDecember 6 8.0 hours Prepare reportDecember 7 14.0 hours Prepare reportDecember 8 10.0 hours Prepare reportDecember 9 6.0 hours Prepare repor tDecember 10 8.0 hours Prepare reportDecember 11 12.0 hours Meet with counsel ; prepare reportDecember 12 12.0 hours Meet with counsel ; prepare reportDecember 13 10.0 hours Meet with counsel ; prepare reportDecember 14 10.0 hours Meet with counsel ; prepare report

TOTAL HOURS = 144 .0 $61,200

Charlotte L. Brown, Case Associate $125 per hour

December 1 1.5 hours Organize case materialDecember 2 1.0 hours Organize case materialDecember 5 6.5 hours Type reportDecember 6 7.0 hours Type reportDecember 7 6.5 hours Type repor tDecember 8 7.0 hours Type reportDecember 9 2.5 hours Organize case materialDecember 12 1.0 hours Organize case material

TOTAL HOURS = 33 .0

Richard Levine, Principal

December 2 2.5 hoursDecember 5 2.0 hoursDecember 9 2.0 hoursDecember 11 2.0 hours

TOTAL HOURS = 8 .5

$4,125

$350 per hour

Perform researchPerform researchPerform researchPerform research

$2,975

TOTAL PROFESSIONAL FEE = $68,300

Page 50: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Communications

Express Messenger

Purchased Research

EXPENSES

C

Source

$ 157.49 LECG Accounting System

$ 439.44 Apple Courier

$ 25.00 LECG Accounting System

San Diego Travel - Air, Hotel, and Meals Direct Billed to Lerach Coughlin(December 11 - 14)

Taxicabs $ 100.00 No receipts - see attached

TOTAL EXPENSES $721 .93

Page 51: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

TAXIS

December 11

Home to Airport $35.00

Airport to Hotel $12.00

December 14

Hotel to Airport $15.00

December 15

Airport to Home $38.00

TOTAL $100.00

Our firm does not require receipts for expenses of $50 or less .

Page 52: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Invoice #0103

XPRT Professional Services, Inc.

Tax ID #: 20-3861288

January 9, 2006

Daniel S. Drosman, Esq .Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego , CA 92101-3301

Project : In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional services and related out-of-pocket expenses for the periodDecember 16 - December 31, 2005 :

Professional Fees

Expenses

$ 37,187.50

435.26

TOTAL DUE $ 37 ,622.76

Please make payment by check to XPRT Professional Services, Inc .

Remit to : Dr . Joseph S. KraemerXPRT Professional Services, Inc.1202 South Huntress CourtMcLean , VA 22102

Joseph S. KraemerDirector

Page 53: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

d-M

PROFESSIONAL. SERVICES

Joseph S. Kraemer, Director $425 per hour

December 16 6.0 hours Prepare reportDecember 20 6.0 hours Prepare reportDecember 21 13.0 hours Prepare reportDecember 22 7.0 hours Prepare reportDecember 23 9.5 hours Prepare reportDecember 26 9.0 hours Prepare reportDecember 27 5.5 hours Prepare reportDecember 28 8.0 hours Prepare reportDecember 29 6.0 hours Prepare reportDecember 30 10 .0 hours Prepare repor tDecember 31 5.0 hours Prepare report

TOTAL HOURS = 85.0 $36,125

Charlotte L. Brown, Case Associate $125 per hour

December 21 1.5 hours Organize case materia lDecember 22 2.5 hours Organize case materia lDecember 23 2.0 hours Organize case materia lDecember 27 2.5 hours Organize case materia l

TOTAL HOURS = 8.5 $1,062.50

r

TOTAL PROFESSIONAL FEE = $37,187 .50

Page 54: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

EXPENSES

Source

Communications $ 75.89 LECG Accounting System

Express Messenger 151.49 Apple Courier Receipts

FedEx Shipments 207.88 Kinkos Receipts

TOTAL EXPENSES $ 435.26

Page 55: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Fedex

1. December 3 $24.30

2. December 12 79.80 ✓

3. December 12 25.48

4. December 27 78.30 ✓

TOTAL $207.88

C-

C

Page 56: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Invoice #010 4

XPRT Professional Services, Inc .

Tax ID #: 20-3861288

February 3, 200 6

Daniel S. Drosman, Esq.Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego , CA 92101-3301

Project : In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional, services and related out-of-pocket expenses for the periodJanuary 1- 31, 2006:

Professional Fees $ 36,200.00

Expenses 224.64

TOTAL DUE $ 36,424.64

Please make payment by check to XPRT Professional Services, Inc .

Remit to : Dr. Joseph S. KraemerXPRT Professional Services, Inc .1202 South Huntress CourtMcLean , VA 22102

Joseph S. KraemerDirector

I

Page 57: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

PROFESSIONAL SERVICES

Joseph S. Kraemer, Director $425 per hour

January 1 7.0 hours Prepare reportJanuary 2 6.0 hours Prepare reportJanuary 3 3.0 hours Prepare reportJanuary 4 3.5 hours Prepare reportJanuary 6 2.0 hours Prepare reportJanuary 7 6.0 hours Prepare reportJanuary 8 8.0 hours Prepare reportJanuary 9 8.0 hours Prepare reportJanuary 10 2.0 hours Prepare reportJanuary 11 8.0 hours Prepare reportJanuary 16 3.5 hours Prepare for depositionJanuary 18 5.5 hours Prepare for depositionJanuary 19 8.0 hours Prepare for depositionJanuary 30 4.0 hours Prepare for depositionJanuary 31 9.5 hours Prepare for deposition

TOTAL HOURS = 84.0 $35,700

Charlo tte L. Brown, Case Associate $125 per hour

January 5 2.0 hoursJanuary 17. 1.0 hoursJanuary 18 1.0 hours

Organize case materialOrganize case materialOrganize case material

TOTAL HOURS = 3.0 $500

TOTAL PROFESSIONAL FEE = $ 36,200

2

Page 58: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

EXPENSES

Source

Communications $ 49.00 LECG Accounting System

Express Messenger 87.90 Apple Courier Receipts

FedEx Shipments 72.43 Kinko's Receipts

Duplication 15.31 Kinko's Receipt

TOTAL EXPENSES $ 224 .64

3

Page 59: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Messenger

1. January 5 $29.30

2. January 17 29.30

3. January 18 29.30

TOTAL $87.90

C

4

Page 60: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Invoice #010 5

XPRT Professional Services, Inc .

Tax ID #: 20-3861288

March 3, 2006

Daniel S. Drosman, Esq.Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego , CA 92101-3301

Project : In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional services and related out-of-pocket expenses for the periodFebruary 1 - 28, 2006:

Professional Fees $ 53,187.50

Expenses 2,047.38

TOTAL DUE $ 55,234.88

Please make payment by check to XPRT Professional Services, Inc .

Remit to : Dr. Joseph S . KraemerXPRT Professional Services, Inc .1202 South Huntress CourtMcLean , VA 22102

Joseph S. KraemerDirector

I

Page 61: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

PROFESSIONAL SERVICE S

Joseph S. Kraemer, Director $425 per hour

February1 8.0 hours Prepare for depositionFebruary 2 7.0 hours Prepare for depositionFebruary 3 7.5 hours Prepare for depositionFebruary 4 7.0 hours Prepare for depositionFebruary 5 7.0 hours Prepare for depositionFebruary 6 8.0 hours Prepare for depositionFebruary 7 13.0 hours Meet with counselFebruary8 9.0 hours DepositionFebruary 9 8.0 hours Deposition of defendant's expertFebruary 15 6.5 hours Prepare for depositionFebruary 21 7.5 hours Prepare for depositionFebruary 22 5.0 hours Prepare for depositionFebruary 23 8.0 hours Prepare for depositionFebruary 24 8.0 hours Meet with counse lFebruary 27 4.0 hours Prepare for depositionFebruary 28 9.0 hours Deposition of defendant's expert

TOTAL HOURS = 122.5 $52,062.50

Charlotte L. Brown , Case Associate $125 per hour

February1 1 .0 hours Prepare invoiceFebruary 22 2.0 hours Organize case materialFebruary 27 4.0 hours Archive case materia lFebruary 28. 2.0 hours Prepare invoice

TOTAL HOURS = 9.0 $1,125

TOTAL PROFESSIONAL FEE = $ 53,187.50

2

Page 62: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

EXPENSES

Category Amount Source

Communications $ 67.15 LECG Accounting System

Express Messenger 33.30 Apple Courier Receipts

FedEx Shipments 94.65 Kinko's Receipts

Travel - New York 1,531.28 See Enclosures

Travel - San Francisco 321.00 See Enclosures

TOTAL EXPENSES $ 2,047.38

3

Page 63: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Invoice #0106

XPRT Professional Services, Inc.

Tax ID #: 20-3861288

April 11, 2006

Daniel S. Drosman, Esq.Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego , CA 92101-3301

Project: In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional services and related out-of-pocket expenses for the periodMarch 1- 31, 2006:

Professional Fees $ 4,450.00

Expenses 107.14

TOTALDUE $ 4 ,557.14

Please make payment by check to XPRT Professional Services, Inc.

Remit to: Dr. Joseph S . KraemerXPRT Professional Services, Inc.1202 South Huntress Court

1

Director

Page 64: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

PROFESSIONAL SERVICES

Joseph S. Kraemer, Director $425 per hour

March 8 2.0 hours Review transcriptMarch 9 2.0 hours Review transcriptMarch 12 3.0 hours Prepare errata sheetMarch 27 2.0 hours Review errata sheet

TOTAL HOURS= 9 $ 3,825

Charlotte L. Brown, Case Associate $125 per hour

March 1 1.0 hours Organize . case materialMarch 13 2.5 hours Type errata sheetMarch 28 1.0 hours Type errata sheetMarch 30 .5 hours Perform billing reconciliation and . invoice preparation

TOTAL HOURS = 5.0 $ 625

TOTAL PROFESSIONAL FEE = $ 4,450

/

2

Page 65: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

Category

Communica tions

Express Messenger

TOTAL EXPENSES

C7

EXPENSES

Amount Source

S 48.55 LECG Accounting System

58.59 Apple Courier Receipts

S 107.14

3

Page 66: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

If,

Invoice #010 6

XPRT Professional Services, Inc .

Tax ID #: 20-3861288

August 1, 2006

Daniel S. Drosman, Esq .Lerach Coughlin Stoia Geller Rudman & Robbins LLPSuite 1900655 West BroadwaySan Diego, CA 92101-330 1

Project : In re Cisco Systems, Inc. Securities LitigationNo. C-01-20148-JW(PVT)

For professional se rvices and related out-of -pocket expenses for the periodJuly 1- 31, 2006 :

Professional Fees

Expenses

$ 3,187.50

0

TOTAL DUE $ 3,187.50

Please make payment by check to XPRT Professional Services, Inc .

Remit to : Dr. Joseph S. KraemerXPRT Professional Services, Inc .1202 South Huntress CourtMcLean , VA 22102

Joseph S. KraemerDirector

1

Page 67: LERACH COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLPsecurities.stanford.edu/filings-documents/1018/... · incumbent local exchange carriers, competitive local exchange carriers ("CLECs"),

PROFESSIONAL SERVICES

Joseph S. Kraemer, Director $425 per hour

July 10 2.0 hours Review defendants ' filingsJuly 11 5.5 hours Review documents ; participate in conference call with

counsel

TOTAL HOURS = 7.5

TOTAL PROFESSIONAL FEE = $ 3 ,187.50

2