IV. PROPOSED SETTLEMENT

IV. PROPOSED SETTLEMENT

A Settlement has been entered into between the Class Representatives. Class Counsel and Ciba-Geigy, which will resolve all past, present and future claims against Ciba-Geigy arising out of Exposed Persons' exposure to Galecron®. The Settlement provides for the establishment by Ciba-Geigy of two funds to provide medical benefits and compensation to Exposed Persons or their legal representatives.

ID The Medical Monitoring and Treatment Fund (“The MMT Fund”). If the Settlement is approved. Ciba-Geigy will make an initial deposit of $5,000,000 into the MMT Fund, and will thereafter make additional deposits on an as-needed basis. There is no limit to the amount of money Ciba-Geigy can be required to contribute over the life of this Fund.

The MMT Fund will pay for a medical monitoring program designed to detect at an early stage the form of bladder cancer alleged to be associated with Galecron®: specifically, primary urothelial carcinoma of the urinary collecting system, i.e., renal pelvis, ureter, bladder and urethra. The MMT Fund also will pay for all medically necessary treatment not paid for by Medicare or Medicaid if the Exposed Person has been or in the future is diagnosed with such bladder cancer.

The MMT Fund will pay for medical monitoring to Exposed Persons for a period of 20 years, and will pay for medical treatment until one full year passes with no claims for treatment being filed but.in no event less than 20 years. Ciba-Geigy will have no obligation to continue the medical monitoring and treatment program if the Settlement is not approved. Only Exposed Persons, i.e., eligible Plant Workers, Formulators, Applicators and Other Covered Workers, as defined in this Notice, will be entitled to medical monitoring and treatment.

(2) The Disease Compensation and Administration Fund (“The DCA Fund”). If the Settlement is approved, CibaGeigy will also make an initial deposit of $30,000,000 into the DCA Fund. In addition to medical treatment paid for by the MMT Fund, the DCA Fund will make cash payments of up to $410,000, as set forth in more detail below, on behalf of an Exposed Person who, after exposure to Galecron®, has developed or in the future develops the form of bladder cancer alleged to be associated with Galecron®: specifically, primary urothelial carcinoma of the urinary collecting system, i.e., renal pelvis, ureter, bladder and urethra. Cash payments will vary depending upon the Exposed Person’s age, smoking status and participation in the health screening program. For Exposed Persons who are nonsmokers and participants in the health screening program, the cash payments will be as follows: (a) $10,000 in the event of treatment involving an invasive procedure (this is a one-time payment regardless of the number of procedures); (b) up to $150,000 in the event of a radical cystectomy (bladder removal) with diversion of the urinary tract, which amount will decrease with a person's age to a minimum of $10,000 if the Exposed Person is 85 years or older; and (c) up to $250,000 in the event an Exposed Person’s death is found to be caused by bladder can