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(Collectively "Woodward Settlement Class Members”). Note: If you are an NOR-AM Exposed Person or a Ciba Exposed Person, you are a Woodward Settlement Class Member whether or not you have been diagnosed with an illness. Spouses, parents, children, other relatives, and legal representatives are Woodward Settlement Class Members hut the claims they are settling are limited to those arising from a NOR-AM Exposed Person or Ciba Exposed Person's exposure.
II. IMPORTANT MEDICAL NOTICE To NOR-AM Exposed Persons and Ciba Exposed Persons (as defined above):
You may have an increased risk of developing bladder cancer if you had on-the-job exposure to Fundal® and/or Galecron*. Workers exposed to Fundal® and/or Galecron®1 should participate in a medical monitoring program because early detection of bladder cancer can result in more effective treatment.
If you had on-the-job exposure to Fundal* and/or Galecron®, it is recommended that you or your doctor call 1-800-211 -6913 lo learn how you can obtain further medical information or enroll in medical monitoring.
III. PROPOSED SETTLEMENT
The Woodward Settlement provides for the establishment by NOR-AM of two funds to provide medical benefits and compensation to eligible Woodward Settlement Class Members or their legal representatives. This settlement is intended, where applicable, to work as a complement to the Price Settlement
The total package of benefits potentially available to a NOR-AM Exposed Person is the same as the total package of benefits potentially available to a Ciba Exposed Person. Thus. Woodward Settlement Class Members may be eligible for the same benefits whether they were occupationally exposed to Fundal* only, or to Fundal* and Galecron*. or to Galecron* only.
(l) Tht NOR-AM Medical Monitoring and IffiUmcnt Fund ( The NOR-AM MMT Fund”) If the Woodward Settlement is approved, NOR-AM will make an initial deposit of $3,500,000 into the NOR-AM MMT Fund, and will thereafter make additional deposits on an as-needed basis. There is no limit to the amount of money NOR-AM can be required to contribute over the life of the NOR-AM MMT Fund, which will last a minimum of 20 years.
NOR-AM Exposed Persons will be entitled to participate in the NOR-AM medical monitoring and treatment program; Ciba Exposed Persons may receive medical monitoring and treatment benefits only through the Price Settlement. The NOR-AM medical monitoring and treatment program and the medical monitoring and treatment program provided through the Price Settlement are identical. The NOR- AM MMT Fund will pay for a medical monitoring program designed to detect at an early stage the lorm of bladder lancer alleged to he associated with exposure to Fundal*: specifically, primary urothelial carcinoma of the urinary collecting system. i.e, renal pelvis, ureter, bladder and urethra. The NOR-AM MMT Fund also will pay for all medically necessary treatment for NOR-AM Exposed Persons
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