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CLASS REPRESENTATIVES AND
CLASS COUNSEL
The Court has designated the following Settlement Class Members. Russell W. Price. Leslie E. Hoven, Grady W Brow n, Jennie Ropp Brown, Jack Harley Woodward. Alta Woodward. Joe H. Bowman and Martha Annie Bowman, as class representatives to represent till Settlement Class Members. The Court has also designated as Class Counsel the following individuals: Timothy E. Eble; J. Cecil Gardner; Joseph J. McKernan; S.C. Middlebrooks III: Charles W. Patrick. Jr.; and Patrick W. Pendley.
The Class Representatives and Class Counsel believe that the proposed Settlement is fair, reasonable and adequate. Class Representatives and Class Counsel have entered into (he proposed Settlement after weighing the substantial benefits against the probabilities ol success or failure, and the long delays that would be likely if the case proceeded to trial.
There has been no agreement between the parties regarding attorneys' fees. At the fairness hearing. Class Counsel will request the Court to award attorneys' fees and reimbursement of costs and expenses, to be paid from the DC A Fund. Class counsel will request a percentage fee award not to exceed 20ck of the benefit conferred on the class, half of which will be requested to be paid over a 4-year period while legal work continues.
VI. RIGHTS AND OPTIONS OF SETTLEMENT
CLASS MEMBERS
If you are a Settlement Class Member, you have the following options:
(1) Youmay do nothing and remain a Settlement Class Member. If you choose to take no action, your interests as a member of the Settlement Class will be represented by the Class Representatives and Class Counsel, at no cost to you individually. You will be bound by any judgment or final disposition of the litigation, and may participate in the benefits available as a member of the Settlement Class. It is important, however, to fill out the REQUEST FOR INFORMATION FORM in order to learn how to receive benefits.
(2) You may remain a Settlement Class Member and either represent yourself or hire your own attorney to represent you at your own cost. You or your attorney must file an Entry of Appearance with the Clerk of the Court and send a copy to Class Counsel and Ciba-Geigy, at the addresses set forth below. Such Entry of Appearance must be filed by December 16, 1994.
(3) You may remain a Settlement Class Member and object to the Settlement Any Settlement Class Member who does not elect exclusion from the Settlement Class and who objects to the proposed Settlement must mail such objections and any supporting papers to the Clerk of Court, at the address set forth below, on or before December 16. 1994. If the person filing the objection intends to appear personally at the January 30,
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