Supplemental submission in support of motion for default
Pursuant to Rule 55(b) of the Federal Rules of Civil Procedure and Rule 55.2 of the Local Civil Rules for the United States District Courts for the Southern and Eastern District of New York (“Local Rules”) Lead Plaintiffs and the Class moved for entry of default against defendants Puda Coal, Inc. (“Puda”) and Ming Zhao (“Zhao”). (Dkt. Nos. 395-397) (“Default Judgment Motion”). Plaintiffs’ Default Judgment Motion seeks judgment against Puda and Ming Zhao for monetary damages in the amount of $236.7 million. The monetary damages amount sought by Plaintiffs’ Default Judgment Motion is based upon the Declaration of Peter W. Lert Ph.D., CFA (“Lert Report”) as to the damages incurred by investors included in the Defaulted Defendants’ Class Period as defined by the Court’s Order of October 1, 2013. (Dkt. No. 263).