Graña y Montero Securities Settlement
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Welcome to the Graña y Montero Securities Settlement Website

Pursuant to the Court’s Order, dated December 3, 2020, the Fairness Hearing scheduled for December 21, 2020, at 11:00 a.m. shall be conducted telephonically. The Order is available hereAll parties shall connect to the call through dial-in number 888-557-8511 with access code 3152145.

This website has been established to provide general information related to the proposed settlement of the case styled In re Graña y Montero S.A.A. Securities Litigation, No. 2:17-cv-01105-LDH-ST (the "Litigation"), pending before the United States District Court for the Eastern District of New York (the "Court"). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Stipulation and Agreement of Settlement (the "Stipulation") dated July 2, 2020, which can be found and downloaded by clicking on the Case Documents tab above. Your rights may be affected by the Settlement if you purchased or otherwise acquired American Depository Shares ("ADS") of Graña y Montero S.A.A. ("Graña y Montero" or the "Company") during the period from July 24, 2013 through February 24, 2017, inclusive, and are not otherwise excluded from the Settlement Class. 

The law firms of Robbins Geller Rudman & Dowd LLP and Holzer & Holzer, LLC represent you and other Settlement Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.


As more fully described in the Notice of Pendency and Proposed Settlement of Class Action (the "Notice"), the Consolidated Amended Class Action Complaint for Violations of the Federal Securities Laws was filed on May 29, 2018. 

On November 19, 2019, counsel for Graña y Montero, Monica Miloslavich Hart and Plaintiffs participated in an in-person mediation session with Gregory Lindstrom, Esq. of Phillips ADR Enterprises, an experienced mediator. The mediation was preceded by submission of mediation statements by the mediating parties. The Settling Parties engaged in arm’s-length negotiations during the mediation session, and reached an agreement-in-principle to resolve the Litigation, subject to insurer approval. The agreement included, among other things, the Settling Parties’ agreement to settle the Litigation in return for a cash payment of $20,000,000 for the benefit of the Settlement Class, subject to the negotiation of the terms of a Stipulation of Settlement and approval by the Court. The Stipulation (together with the Exhibits thereto) reflects the final and binding agreement between the Settling Parties.


The Settlement, if approved, will result in the creation of a cash settlement fund of $20,000,000.00 (the “Settlement Amount”). The Settlement Amount, plus accrued interest, is the Settlement Fund. The Settlement Fund minus the costs of the Notice and all costs associated with the administration of the Settlement, Taxes and Tax Expenses, attorneys’ fees and expenses, and any award to Plaintiffs in connection with their representation of the Settlement Class, as approved by the Court (the “Net Settlement Fund”), will be distributed to eligible Settlement Class Members pursuant to the Plan of Allocation that is described in the Notice.


Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully.


SUBMIT A PROOF OF CLAIM FORM The only way to be eligible to receive a payment from the Settlement. Proof of Claim forms must be postmarked or submitted online on or before January 13, 2021.
EXCLUDE YOURSELF Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against the Defendants or any other Released Persons about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Settlement Class you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Exclusions must be postmarked on or before November 10, 2020.
OBJECT Write to the Court about why you do not like the Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and expenses. You will still be a Member of the Settlement Class. Objections must be received by the Court and counsel on or before November 10, 2020. If you submit a written objection, you may (but do not have to) attend the hearing.
GO TO THE HEARING ON DECEMBER 21, 2020 AT 11:00 A.M. Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel on or before November 10, 2020.
DO NOTHING Receive no payment. You will, however, still be a Member of the Settlement Class, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.


Submit Proof of Claim: January 13, 2021
File Objection: November 10, 2020
Request Exclusion: November 10, 2020
File Notice of Intention to Appear: November 10, 2020
Court Hearing on Fairness of Settlement: December 21, 2020, at 11:00 a.m.