New Mexico State Invest. Council, New Mexico Public Employees’ Ret. Assoc., and New Mexico Educ. Ret. Bd. v. Countrywide Fin. Corp. No. D‐0101‐C‐2008‐02289 (N.M. 1st Dist) In 2008, together with Co-Counsel, Pomerantz LLP identified a substantial opportunity for recovery of losses in Countrywide mortgage-backed securities ("MBS") for three large New Mexico funds (New Mexico State Investment Council, New Mexico Public Employees' Retirement Association, and New Mexico Educational Retirement Board), that had been overlooked by all of the firms then in their securities litigation pool. We then filed the first non-class lawsuit by a public institution with respect to Countrywide MBS. In this opt-out action, we advised our clients, which had suffered large losses in Countrywide mortgage‐backed securities (“MBS”), to bring suit in New Mexico state court to take advantage of the concurrent jurisdiction provisions of the Securities Act of 1933 (for litigating Section 11 claims), rather than to join a parallel class action in which their significant claims would have been diluted. We established important precedents for MBS investors, and developed overwhelming supportive evidence through a combination of aggressive formal discovery, private investigation, and the engagement of world‐class experts. As a result, we achieved for our clients an extremely favorable (but confidential) settlement, much more than they would have received in the class action.