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  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview 
						
                                
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SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
JOHN T. JASNOCH
707 Broadway, Suite 1000

San Diego, CA 92101 ELECTRONICALLY
Telephone: 619/233-4565 FILED
619/233-0508 (FAX) Superior Court of California,
jjasnoch@scott-scott.com County of San Francisco
05/05/2016
-and- Clerk of the Court
BY-MAURA RAMIREZ
Deputy Clerk

GEOFFREY M. JOHNSON (pro hac vice)
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
12434 Cedar Road, Suite 12

Cleveland Heights, OH 44106

Telephone: 216/229-6088
gjohnson@scott-scott.com

Attorneys for Plaintiffs
[Additional Counsel in Signature Blocks]

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO

IN RE KING DIGITAL ENTERTAINMENT Lead Case No.: CGC-15-544770
ple SHAREHOLDER LITIGATION
CLASS ACTION

PLAINTIFFS’ UNOPPOSED
SUPPLEMENTAL FILING IN SUPPORT

OF REVISED STIPULATION AND

This Document Relates To: [PROPOSED] ORDER CERTIFYING
ALL ACTIONS. SECTION 11 CLASS AND DISMISSING
SECTION 12 CLAIM

EXHIBIT C

Assigned for All Purposes to the
Honorable Curtis E.A. Karnow

PLAINTIFFS’ UNOPPOSED SUPPLEMENTAL LEAD CASE NO.: CGC-15-544770

FILING IN SUPPORT OF REVISED STIP. AND
[PROPOSED] ORDERw

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EXHIBIT C

PLAINTIFFS’ UNOPPOSED SUPPLEMENTAL 1
FILING IN SUPPORT OF REVISED STIP. AND
[PROPOSED] ORDER

CASE NO.: CGC-15-544770SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
John T. Jasnoch

707 Broadway, Suite 1000

San Diego, California 92101

Telephone: (619) 233-4565

Facsimile: (619) 233-0508

E-mail: —_jjasnoch@scott-scott.com

[Additional counsel listed on signature page.]

Attorneys for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA.
COUNTY OF SAN FRANCISCO

In re KING DIGITAL ENTERTAINMENT
PLC SHAREHOLDER LITIGATION

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This Document Relates To: ;
ALL ACTIONS. ;

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DECLARATION OF SEAN DEBOTTE
IN SUPPORT OF MTN. FOR CLASS CERTIFICATION

Lead Case No. CGC-15-544770

CLASS ACTION

DECLARATION OF SEAN DEBOTTE IN
SUPPORT OF PLAINTIFFS’ MOTION FOR
CLASS CERTIFICATION

Assigned for All Purposes to the
Honorable Curtis E.A. Karnow

No. CGC-15-544770DECLARATION OF SEAN DEBOTTE

I, SEAN DEBOTTE, declare as follows:

1. I am one of the named Plaintiffs in this consolidated action. I make this declaration in
support of Plaintiffs’ Motion for Class Certification. I have personal knowledge of the facts stated in this
declaration. I could and would competently testify to these facts if called upon to do so.

2. I purchased 500 shares of King Digital Entertainment PLC (“King Digital”) common shares
on or about April 3, 2014 at a price of approximately $19.5234 per share.

3. Iam committed to continue to vigorously prosecute this litigation should I be appointed as a
class representative. I intend to obtain the largest recovery for the class, consistent with good faith and
sound judgment. Additionally, I believe that I have the ability to adequately and effectively represent the
interests of all investors who purchased or acquired King Digital common stock pursuant or traceable to
King Digital’s initial public offering. I am not aware of any conflicts between myself and other Class
Members.

4. I have supervised and monitored the progress of this litigation. For example, I have: (a)
received regular status reports from my counsel; (b) participated in discussions with counsel concerning
significant developments in this litigation and case strategy; (c) reviewed pleadings and orders in this matter;
and (d) searched for and produced documents pursuant to Defendants’ discovery requests. I intend to
continue to provide fair and adequate representation by, among other things, working with proposed co-lead
class counsel, Scott+Scott, Attorneys at Law, LLP (“Scott+Scott”).

5. I selected Scott+Scott as proposed co-lead class counsel based on the firm’s substantial
experience and expertise in prosecuting securities class actions. I believe Scott+Scott possesses the
necessary financial and human resources to prosecute this case effectively.

6. I will continue to keep myself fully informed at all times concerning the status and progress
of this action, the strengths and weaknesses of the case, and the prospects for settlement. I will consult with
counsel in advance with respect to each major litigation event, such as important motions, settlement

discussions, trial preparation, and trial.

DECLARATION OF SEAN DEBOTTE
IN SUPPORT OF MTN. FOR CLASS CERTIFICATION No. CGC-15-5447707 I recognize that I owe a fiduciary duty to the proposed class and, if appointed as class
representative, I will take all steps necessary to vigorously fulfill that duty.
T declare under penalty of perjury that the foregoing is true and correct, pursuant to the laws of the

State of California. Executed this 25 day of January, 2016, at_5:00pmEST__.

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Sean Debotte

DECLARATION OF SEAN DEBOTTE
IN SUPPORT OF MTN. FOR CLASS CERTIFICATION No. CGC-15-544770