1 II. IMPORTANT MEDICAL NOTICE To Plant Workers, Formulators,

1 II. IMPORTANT MEDICAL NOTICE To Plant Workers, Formulators, Applicators and Other Covered Workers (as defined above):

You may have an increased risk of developing bladder cancer if you had on-!he-job exposure to Galecron®. Workers'exposed to Galecroh® should participate in a medical monitoring program because early detection of bladder cancer can result in more effective treatment. As part of the Settlcl ment. Ciba-Geigy has agreed to establish a medical monitoring program for the detection of bladder cancer for those individuals who do not exclude themselves from the lawsuit. Within six months, this program should be available free of charge to all Exposed Persons who do not exclude themselves from the lawsuit. I

If you had on-the-job exposure to Galecron®. it is recommended that you or your doctor call 1-800-565-3126 to learn how you can obtain further medical information or enroll in the medical monitoring program.

III. , BRIEF SUMMARY OF LITIGATION

On February 8. 1994. a class action lawsuit was filed against defendant. Ciba-Geigy Corporation (“Ciba-Geigy"). in Alabama State Court, which lawsuit was later removed to the United States District Court for the Southern District of Alabama. The Complaint, as amended, alleges that the Settlement Class as defined above is entitled to damages for medical monitoring and other compensation as a result of Exposed Persons' exposure to Galecron®.

Ciba-Geigy has filed an Answer denying all essential allegations of the Complaint, and asserting affirmative legal defenses. The Court has decided that the case can proceed as a class action for purposes of settlement only. This does not mean that the Class Representatives would have been successful had the case gone to trial. The Court has made no such determination. and the proposed Settlement is not to be construed as an expression of any opinion by the Court as to the merits of any of the claims asserted against Ciba-Geigy.