in the united states district court for the district of ... v. rockwell international corporation ....

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 90-cv-00181-JLK

MERILYN COOK, et al.,

Plaintiffs, v. ROCKWELL INTERNATIONAL CORPORATION and THE DOW CHEMICAL COMPANY,

Defendants.

PLAINTIFFS’ AND CLASS COUNSEL’S

UNOPPOSED MOTION FOR AN INITIAL DISTRIBUTION OF THE NET SETTLEMENT FUNDS

For the reasons set forth in the accompanying memorandum in support and related

materials, Class Counsel and Class Representatives Merilyn Cook, Richard and Sally Bartlett,

and William and Delores Schierkolk1 respectfully request that the Court enter the proposed

Order providing that (1) late, otherwise valid claims accepted as of October 6, 2017 should be

approved; (2) ineligible claims should be rejected; (3) an Initial Distribution should be

distributed to approved Claimants; and (4) claims received after December 31, 2017 against the

Settlement Fund shall be barred.

1 Delores Schierkolk is deceased, but William Schierkolk is her heir and representative.

Case 1:90-cv-00181-JLK Document 2494 Filed 10/13/17 USDC Colorado of 3

2

Dated: October 13, 2017 Respectfully submitted,

/s/ Merrill G. Davidoff Merrill G. Davidoff David F. Sorensen Caitlin G. Coslett BERGER & MONTAGUE, P.C. 1622 Locust Street Philadelphia, PA 19103 (215) 875-3000 Gary B. Blum Steven W. Kelly SILVER & DeBOSKEY, P.C. 1801 York Street Denver, CO 80206 (303) 399-3000

Attorneys for Plaintiffs and the Class


CERTIFICATE OF SERVICE

The undersigned certifies that on this 13th day of October, 2017, he caused the foregoing

submission to be served via the Court’s ECF system on all participating counsel.

/s/ Merrill G. Davidoff Merrill G. Davidoff BERGER & MONTAGUE, P.C. 1622 Locust Street Philadelphia, PA 19103 (215) 875-3000


1





Defendants.

[PROPOSED] ORDER GRANTING PLAINTIFFS’ AND CLASS

COUNSEL’S UNOPPOSED MOTION FOR INITIAL DISTRIBUTION

This matter comes before the Court on Plaintiffs’ and Class Counsel’s Motion for an

Initial Distribution of the Net Settlement Funds, made pursuant to Paragraph 12 of the Plan of

Allocation of the Settlement Fund (“Plan of Allocation”), ECF No. 2407-2, approved by this

Court on April 28, 2017, ECF No. 2471, which provides that the Court shall establish

appropriate procedures for approval of the Proposed Allocation prior to disbursement of any

funds to members of the Class.

Pursuant to this Court’s Order granting Final Approval of the Settlement and Plan of

Allocation, ECF No. 2471, and in accordance with the terms of the Settlement Agreement

between Merilyn Cook, Richard and Sally Bartlett, and William and Delores Schierkolk1

(collectively the “Plaintiffs” or “Class Plaintiffs”) and on behalf of the Class, and Defendants

1 Delores Schierkolk is deceased, but William Schierkolk is her heir and representative.

Case 1:90-cv-00181-JLK Document 2494-1 Filed 10/13/17 USDC Colorado Page 1 of 3

2

Rockwell International Corporation (“Rockwell”) and The Dow Chemical Company (“Dow”)

(collectively, “Defendants”), dated May 18, 2016,

NOW, THEREFORE, upon review of Plaintiffs’ and Class Counsel’s Unopposed Motion

for Initial Distribution of the Net Settlement Funds, the accompanying Declaration of Edward

Radetich Jr. (“Radetich Declaration”) and Declaration of Wayne Hunsperger (“Hunsperger

Declaration”), and all other briefing and materials filed in connection with Plaintiffs’ and Class

Counsel’s Unopposed Motion for Initial Distribution of the Net Settlement Funds, it is

ORDERED, ADJUDGED AND DECREED as follows:

1. The Court approves the Initial Distribution from the Net Settlement Fund as

proposed by Class Counsel, and directs the Heffler Claims Group, the Settlement and Claims

Administrator, to distribute the Initial Distribution awards in accordance with the Plan of

Allocation.

2. The administrative determinations of the Claims Administrator accepting Claims

submitted and verified as of October 6, 2017 are approved, and all such Claims are accepted.

3. The administrative determinations of the Claims Administrator rejecting Claims

are approved, and these Claims are rejected.

4. Class Counsel shall submit a separate application requesting Court approval for

any additional, subsequent disbursements to Class members of Net Settlement Funds.

5. This Court retains jurisdiction over any further application or matter that may

arise in connection with this Action.

6. No Claim submitted after December 31, 2017 may be included in the initial

distribution or any subsequent distribution(s) for any reason whatsoever. Claims received after

December 31, 2017 against the Settlement Fund shall be barred.


3

7. Any further Claims against the Net Settlement Funds and all persons involved in

the review, verification, calculation, or any other aspect of the processing of the Claims

submitted herein, or otherwise involved in the administration or taxation of the Net Settlement

Funds, are released and discharged from any and all claims arising out of such involvement

beyond the amount allocated to them.

8. The Court retains exclusive jurisdiction over the Settlement and the Settlement

Agreement, including the administration and consummation of the Settlement.

IT IS SO ORDERED.

BY THE COURT: _____________________________________ John L. Kane, Senior District Judge United States District Court






Defendants.

MEMORANDUM IN SUPPORT OF PLAINTIFFS’ AND CLASS COUNSEL’S

UNOPPOSED MOTION FOR AN INITIAL DISTRIBUTION OF THE NET SETTLEMENT FUNDS

Case 1:90-cv-00181-JLK Document 2495 Filed 10/13/17 USDC Colorado Page 1 of 13

i

TABLE OF CONTENTS

BACKGROUND ............................................................................................................................ 1

I. Settlement Agreement .......................................................................................................... 1

II. Claims Administration ......................................................................................................... 3

DISTRIBUTION OF SETTLEMENT FUNDS ............................................................................. 5

I. Late, Yet Otherwise Eligible Claims Should Be Accepted ................................................ 5

II. Ineligible Claims Should Be Rejected ................................................................................. 6

III. Initial Distribution ................................................................................................................ 6

A. Calculation Methodology for the Initial Distribution ................................................... 7

B. Future Distributions ...................................................................................................... 8

CONCLUSION ............................................................................................................................... 9


1

Pursuant to the “Order for Final Approval of Proposed Class Action Settlement and

Approval of Proposed Plan of Allocation of the Settlement Fund,” ECF No. 2471, and the Plan

of Allocation approved therein (see ECF No. 2407-2), Plaintiffs and Class Counsel respectfully

move for an Order (1) approving awards to Claimants who submitted late, otherwise eligible

claims that were approved by the Settlement and Claims Administrator (“Claims Administrator”)

as of October 6, 2017; (2) approving the administrative determinations of the Claims

Administrator rejecting ineligible claims; (3) approving an initial distribution from the Net

Settlement Fund to Class members whose Claims have been approved as of October 6, 2017; and

(4) barring further claims against the Settlement Fund unless a claimant has a reasonable

explanation for lateness. In any event, Plaintiffs and Class Counsel respectfully submit that all

claims received after December 31, 2017 should be barred.

Pursuant to Local Rule 7.1A, Class Counsel has conferred with counsel for Defendants,

who stated they do not oppose the motion.

BACKGROUND

I. Settlement Agreement

On May 18, 2016, Plaintiffs1 and Defendants2 entered into a Settlement Agreement (the

“Settlement Agreement”), which was filed at ECF No. 2401. The Settlement Agreement

provided for settlement of the above-captioned action on behalf of a Settlement Class defined as:

[A]ll persons and entities who have not previously opted out or who do not timely opt out of the class and who owned, as of June 7, 1989, an interest (other than mortgagee and other security interests) in real property situated within the Property Class Area . . . exclusive of governmental entities, Defendants, and Defendants’ affiliates, parents, and subsidiaries.

1 The “Plaintiffs” or “Class Representatives” are Merilyn Cook, Richard and Sally Bartlett, and William and Delores Schierkolk. Delores Schierkolk is deceased, but William Schierkolk is her heir and representative. 2 Defendants are The Dow Chemical Company (“Dow”), and The Boeing Company as successor-in-interest to defendant Rockwell International Corporation (“Rockwell”).


2

Id. at 4.

The Court certified the Settlement Class for purposes of settlement on May 19, 2016.

ECF No. 2396. On August 5, 2016, the Court granted preliminary approval of the Settlement

Agreement. ECF No. 2416. In the same Order, the Court granted preliminary approval of

Plaintiffs’ Proposed Plan of Allocation of the Settlement Fund, and approval of Plaintiffs’

Proposed Forms and Manner of Notice to the Class (“Notice”), and Plaintiffs’ Proposed Claim

Form. Id. The Court also appointed The Huntington National Bank as Escrow Agent for the

Settlement Agreement (ECF No. 2418), and appointed Heffler Claims Group as Settlement and

Claims Administrator, (ECF No. 2417). Not one Class member objected to the fairness of the

proposed Settlement following a comprehensive notice program that included 28,179

individually mailed long form notices, plus an extensive publication notice campaign that

included: (1) an informational settlement website (www.RockyFlatsSettlement.com) on which

the notices and other important Court documents are posted; (2) a toll-free information phone

line for Class members to call 24 hours a day, 7 days a week for more information about the

Settlement, including but not limited to requesting copies of the long form notice and Claim

Form; (3) publication of the Court-approved short-form notice in nationally circulated consumer

magazines; (4) publication of the Court-approved Summary Notice in Denver and Colorado

newspapers; (5) television commercials aired nationwide on cable networks; (6) television and

radio commercials aired on network affiliate and cable networks in the Denver DMA; (7) online

display banner advertising with a nationwide reach; (8) online video advertising with a

nationwide reach; (9) advertising on mobile websites and applications specifically targeted to

reach potential Class members; (10) social media advertising through Facebook and Twitter with

a nationwide reach; (11) native advertising on premium internet properties with a nationwide


3

reach; (12) third party outreach to a community action group, Downwinders, and medical

providers asking them to share and distribute the Summary Notice; and (13) a multimedia press

release issued nationwide. See Declaration of Jeanne C. Finegan, APR Concerning

Implementation and Adequacy of Class Member Notification (ECF. No. 2432), at e.g., ¶ 6.

Following the final fairness hearing on April 28, 2017, the Court granted final approval of the

Settlement Agreement and the Plan of Allocation on April 28, 2017. See ECF No. 2471. No

appeals were taken from that final approval.

II. Claims Administration

Pursuant to the terms of the Settlement Agreement and Plan of Allocation, a Net

Settlement Fund of $207,125,136.35 was established for the payment of valid claims to

Claimants.3 As provided by the Plan of Allocation, 3.196% of the Net Settlement Fund is

allocable to commercial property claims; 81.537% is allocable to residential property claims; and

15.267% is allocable to vacant land claims. See ECF No. 2407-2. Pursuant to the Court-

approved Notice and Plan of Allocation, all Class members were required to submit Proofs of

Claim by mail or through the official settlement website.

As set forth in the accompanying Declaration of Edward J. Radetich Jr., CPA (“Radetich

Declaration”), the Claims Administrator receives and reviews all submitted Claims and mails a

letter to each Claimant to confirm receipt and provide an assigned claim number. Radetich

Declaration ¶ 4. An example of the confirmation letter is attached as Exhibit A to the Radetich

Declaration. As of October 6, 2017, the Claims Administrator has received a total of 10,316

claims as follows: 8,079 paper claims were received by mail, and 2,237 claims were submitted

3 This is equal to the $375,000,000 gross settlement fund less attorney fees of $150,000,000, reimbursed litigation expenses of $7,094,833.65, service payments to the Class Representatives totaling $780,000, and a set aside for claims administration expenses of $10,000,000 (which money is not all spent, and any money not spent will be returned to the Net Settlement Fund at a later date).


4

electronically through the official settlement website. Id. ¶ 3. Each claim is reviewed by a

Claims Administrator analyst and entered into a claims database. The Claims Administrator

reviews all claims and accompanying documentation and compares each claimed property to the

list of Class properties provided to the Claims Administrator by Plaintiffs’ property expert,

Wayne Hunsperger, who worked with Dr. Mark McNulty of Pacey Economics, Inc., on the

claims administration process.4 The list of Class properties was obtained from Jefferson County,

Colorado, by Wayne Hunsperger and Dr. McNulty. See Declaration of Wayne Hunsperger

(“Hunsperger Declaration”), at ¶ 4.

After reviewing each claim, the Claims Administrator mails deficiency letters to each

Claimant who submitted a claim that lacks certain required information and/or supporting

documentation but is otherwise valid. Radetich Declaration ¶ 6. As of October 6, 2017, the

Claims Administrator has mailed deficiency letters to 2,366 Claimants. Id. Also as of October

6, 2017, the Claims Administrator has received 2,117 written responses to deficiency letters. Id.

Examples of the deficiency letters are attached as Exhibit B to the Radetich Declaration. In

addition, the Claims Administrator will mail a second deficiency letter to Claimants who still

have not resolved the deficiencies associated with their Claims. Id. ¶ 7. A copy of this second

deficiency letter is attached as Exhibit C to the Radetich Declaration.

The Claims Administrator mailed rejection letters to all Claimants who filed claims

related to property not located in the Class area, and to Claimants who filed claims related to

properties that they did not own on June 7, 1989 (or to Claimants who were not the heirs or

successors to persons that owned the relevant property on June 7, 1989).5 As of October 6,

4 Dr. McNulty’s biography is available at https://www.paceyecon.com/mark-mcnulty-phd. 5 In other words, for example, the Claims Administrator would have denied a claim submitted by someone who bought a property located in the Class Area on January 1, 1992 if the claimant did not own that Class property as of June 7, 1989.


5

2017, the Claims Administrator had mailed rejection letters to 2,413 Claimants. Id. ¶ 8.

Examples of the rejection letters are attached as Exhibit D to the Radetich Declaration.

As of October 6, 2017, the Claims Administrator has received and confirmed 7,503 valid

claims. Id. ¶ 5. Of those valid claims, 7,371 were received on or prior to June 1, 2017 (the

deadline provided in the Notice), and 132 were received after June 1, 2017. Id.

DISTRIBUTION OF SETTLEMENT FUNDS

I. Late, Yet Otherwise Eligible Claims Should Be Accepted

Approximately 132 otherwise eligible Claims were received after the June 1, 2017

submission deadline. Id. ¶¶ 5, 9. No Claim has been rejected thus far because it was received

after the initial submission deadline.

Plaintiffs and Class Counsel respectfully submit that it would be unfair to prevent a

Claimant submitting a late but otherwise valid Claim from participating in the Net Settlement

Funds solely because the Claim was submitted after the cut-off date, even as the Claims

Administrator was continuing to process other Claims. Most of these claims have reasonable

explanations for lateness. Accordingly, Plaintiffs and Class Counsel respectfully request that this

Court approve Plaintiffs’ and Class Counsel’s proposal to accept otherwise valid Claims

submitted after the June 1, 2017 deadline.

However, there must be a final cut-off date after which no more Claims may be accepted

so that Class Counsel and the Claims Administrator can calculate and distribute the expected

subsequent distributions. Acceptance of any Claim with no final cut-off date would necessarily

require a delay in the distribution of all Settlement funds. Accordingly, Plaintiffs and Class

Counsel also respectfully request that this Court enter an order directing that no Claim submitted

after December 31, 2017 be included in the distributions for any reason whatsoever. See In re

Orthopedic Bone Screw Prods. Liab. Litig., 246 F.3d 315, 329 (3d Cir. 2001) (“There is no


6

question that in the distribution of a large class settlement fund, ‘a cutoff date is essential and at

some point the matter must be terminated.’”) (citations omitted).

II. Ineligible Claims Should Be Rejected

As detailed above, approximately 2,413 Claims were rejected because the subject

property was located outside of the Class Area, the property was not owned by the Claimant as

of June 7, 1989; the Claimant was not an heir or successor to the June 7, 1989 owner of a

property located in the Class Area; or the Claim was duplicative of another Claim. As of

October 6, 2017, the Claims Administrator had mailed rejection letters to 2,413 Claimants.

Radetich Declaration ¶ 8. The rejection letters provide that rejected Claimants may contest the

determination of the Claims Administrator by notifying the Claims Administrator and providing

a statement of the Claimant’s reasons for contesting, along with supporting documentation,

within thirty days of receiving the rejection letter. See Radetich Declaration Ex. D. All appeals

that have been filed by Claimants are being reviewed by the Claims Administrator with the help

of the Plaintiffs’ property expert, Wayne Hunsperger and Dr. McNulty. Radetich Declaration ¶

11. Unresolved appeals may go to the Court or a special master.

Plaintiffs and Class Counsel respectfully request that the Court enter an order approving

the administrative determinations of the Claims Administrator rejecting ineligible Claims where

(a) the Claimant was mailed a rejection letter and did not respond within thirty days, or (b) the

Claimant responded to a rejection letter but the Claims Administrator confirmed upon re-review

that the Claim was ineligible.

III. Initial Distribution

Plaintiffs and Class Counsel respectfully request that the Court enter an order directing

and authorizing an initial distribution to all Claimants whose claims have been accepted as of

October 6, 2017, using the methodology described in the Plan of Allocation and below.


7

In order to allow the Claims Administrator to work toward the full distribution of the Net

Settlement Funds, it is necessary to bar any further Claims against the Net Settlement Funds and

to provide that all persons involved in the review, verification, calculation, or any other aspect of

the processing of the Claims submitted herein, or otherwise involved in the administration or

taxation of the Net Settlement Funds, be released and discharged from any and all claims arising

out of such involvement beyond the amount allocated to them. Accordingly, it is respectfully

requested that the Court enter an order allowing for these terms.

A sample of the letter that the Claims Administrator proposes to send with each initial

distribution award is attached as Exhibit E to the Radetich Declaration. The letter makes clear

that the initial distribution award is “only the first part of [the] total award related to this case”

for each Claimant, and that Class Counsel and the Claims Administrator expect to make an

additional payment or payments in future distributions. See Radetich Declaration Ex. E.

A. Calculation Methodology for the Initial Distribution Pursuant to the terms of the Settlement Agreement and Plan of Allocation, a Net

Settlement Fund was established for the payment of valid claims to Claimants. As provided by

the Plan of Allocation, 3.196% of the Net Settlement Fund is allocable to commercial property

claims; 81.537% is allocable to residential property claims; and 15.267% is allocable to vacant

land claims.

As provided in the Plan of Allocation and in the Proposed Order accompanying this

motion, for purposes of calculating award amounts in the initial distribution, the Claims

Administrator, working with Plaintiffs’ property expert Wayne Hunsperger, determined, for each

Claimant property, the property’s assessed value, expressed as a fraction of the total assessed

value of all Class Properties within the same property category (the property’s “Fractional


8

Allocable Share”). The Claims Administrator, again with Wayne Hunsperger, then computed a

Claim award value for approved Claimant, based on the Class member’s property’s Fractional

Allocable Share of the Net Settlement Fund apportioned to that category of properties, and based

on whether the Claimant was due 100% of the total value awarded to a particular property or

some lesser percentage.6 For example, for a claim associated with a residential property, the

proposed initial distribution will present an award based on the property’s Fractional Allocable

Share multiplied by the Net Residential Property Settlement Fund (equal to 81.537% of the Net

Settlement Fund). The process used for this determination is set forth in the accompanying

Hunsperger Declaration and Radetich Declaration.

The Claims Administrator estimates that the first distribution will result in approximately

ninety-five to one hundred million dollars being paid to claimants who have filed valid claims.

See Radetich Declaration ¶ 10. The remainder of the Fund will be distributed in a second or

subsequent distribution. All Class members with approved claims will also share in the second

distribution.

B. Future Distributions As contemplated by the Plan of Allocation, there will be unclaimed or residual funds

following the initial distribution. Class Counsel and the Claims Administrator anticipate that the

amount of unclaimed or residual funds following the initial distribution will be more than

sufficient to provide awards to Claimants whose claims were submitted on or prior to October 6,

2017, but have not yet been verified and approved by the Claims Administrator. Plaintiffs and

Class Counsel propose that Claimants who submitted claims on or prior to October 6, 2017 but

6 For example, if a property was owned by a now-divorced husband and wife, ordinarily the husband (or his heirs) would be entitled to 50% of the total claim value associated with that property and the wife (or her heirs) would be entitled to the other 50% of the total claim value associated with that property.


9

which claims have not yet been verified receive payments at a later date, with the payment

amounts computed using the same formula used for those claims receiving distributions as part

of the initial distribution. Plaintiffs and Class Counsel will request Court approval for any such

distributions to these Claimants at a later date.

Class Counsel also anticipate that the unclaimed or residual funds will be sufficient to

provide additional awards to all Claimants included in the initial distribution. As provided in the

Plan of Allocation, and subject to Court approval, in any such second or subsequent distribution

Plaintiffs and Class Counsel will likely request that the properties closest to the former Rocky

Flats plant be given an extra weighting and so will receive relatively higher payments in such

subsequent distributions.

CONCLUSION

Plaintiffs and Class Counsel submit that the work performed, as explained above, was

conducted fairly and in accordance with the terms and provisions of the Court-approved

Settlement Agreement and Plan of Allocation. Accordingly, Plaintiffs and Class Counsel

respectfully request that the Court enter the Proposed Order accompanying this motion providing

that (1) late, otherwise valid claims accepted as of October 6, 2017 should be approved; (2)

ineligible claims should be rejected; (3) an Initial Distribution should be distributed to approved

Claimants; and (4) claims received after December 31, 2017 against the Settlement Fund shall be

barred.


10

Dated: October 13, 2017 Respectfully submitted,

/s/ Merrill G. Davidoff Merrill G. Davidoff David F. Sorensen Caitlin G. Coslett BERGER & MONTAGUE, P.C. 1622 Locust Street Philadelphia, PA 19103 (215) 875-3000 Gary B. Blum Steven W. Kelly SILVER & DeBOSKEY, P.C. 1801 York Street Denver, CO 80206 (303) 399-3000 Attorneys for Plaintiffs and the Class


CERTIFICATE OF SERVICE

The undersigned certifies that on this 13th day of October, 2017 he caused the foregoing

submission to be served via the Court’s ECF system on all participating counsel.

/s/ Merrill G. Davidoff Merrill G. Davidoff BERGER & MONTAGUE, P.C. 1622 Locust Street Philadelphia, PA 19103 (215) 875-3000


IN THE UNITED ST ATES DISTRICT COURT FOR THE DISTRICT OF COLORADO



Plaintiffs,

V.

ROCKWELL INTERNATIONAL CORPORATION and THE DOW CHEMICAL COMP ANY,

Defendants.

DECLARATION OF EDWARD J. RADETICH JR., CPA, HEFFLER CLAIMS GROUP, IN SUPPORT OF PLAINTIFFS' AND CLASS COUNSEL'S UNOPPOSED MOTION FOR AN

INITIAL DISTRIBUTION OF THE NET SETTLEMENT FUNDS


I, Edward J. Radetich Jr., CPA, declare as follows:

1. I am a partner of Heffler Claims Group LLC ("Heffler"), the Court-approved

Settlement and Claims Administrator. (See the Court's Order Appointing the Heffler Claims

Group as Settlement and Claims Administrator, Doc. No. 2417.) I am over 21 years of age and

not a party to this action. I have personal knowledge of the facts set forth herein and, if called as

a witness, could and would testify competently thereto.

2. I submit this declaration in connection with Plaintiffs' and Class Counsel's

Unopposed Motion for an Initial Distribution of the Net Settlement Funds.

3. As of October 6, 2017, Heffler has received l 0,316 claims in this matter. Of those

claims, 8,079 paper claims were received by mail, and 2,237 claims were submitted

electronically through the official settlement website, www.rockyflatssettlement.com.

4. Heffler mailed letters to all Claimants. Each letter confirmed Heffler's receipt of

the Claim, provided the assigned claim number, and provided Heffler's contact information for

any questions or assistance with the claims process. A sample confirmation letter is attached as

Exhibit A.

5. As of October 6, 2017, Heffler has received and determined that 7,503 claims are

valid. Of those valid claims, 7,371 were submitted on or prior to June 1, 2017 (the deadline

provided in the Court-approved Notice), and 132 were submitted after June 1, 2017.

6. Of the 10,316 Claims received as of October 6, 2017, Heffler determined that

2,366 Claims lacked certain required information and/or supporting documentation but are

otherwise valid. For each of those Claims, Heffler mailed a deficiency letter stating that the

Claim lacked ce1tain required information (e.g., a required signature, proof that the Claimant is

an heir of the Class member, etc.), and that the Claimant must provide a written response with


the requested information, including any supporting documentation, within thirty (30) days from

the date of the deficiency letter. As of October 6, 2017, the Claims Administrator has mailed

deficiency letters to 2,366 Claimants. Examples of the deficiency letters are attached as Exhibit

B. From those Claimants who received deficiency letters, Heffler has received 2,117 written

responses.

7. Heffler will mail before the end of October 2017 a second deficiency letter to

each Claimant who did not respond to the first deficiency letter, or who provided a written

response to their first deficiency letter that was insufficient to cure the deficiencies associated

with their claims. The second deficiency letters specify the reasons for deficiency, and provide

an additional thirty (30) days from the date of the letter for the Claimant to respond by providing

the requested information and documentation. A copy of this second deficiency letter is attached

as Exhibit C.

8. Heffler has mailed rejection letters to aJI Claimants who filed claims related to

properties not located in the Class area, and to Claimants who filed claims related to properties

that they did not own on June 7, 1989 (or were not the heirs or successors to persons that owned

the relevant property on June 7, 1989). As of October 6, 2017, Hefiler has mailed rejection

letters to 2,413 Claimants. Examples of the rejection letters are attached as Exhibit D.

9. Heffler received approximately 270 Claims after the June 1, 2017 submission

deadline, but prior to October 6, 2017. Thus far, Heffler has confirmed that 132 of these 270

Claims are val id.

10. Heffler has worked with Wayne L. Hunsperger and Dr. Mark McNulty to

calculate the claim amounts payable to each claimant who submitted a valid claim. We expect

that the first distribution will result in a payment of approxim ately ninety-five to one hundred


million dollars. A sample of the letter that the Heffler plans to send with each initial distribution

award is attached as Exhibit E to the Radetich Declaration.

11. Heffler is continuing to review received claims and correspond with Claimants

regarding deficiencies, and expects that some of the received claims will be determined to be

valid after further review and correspondence with the Claimants. In addition, Heffler is

reviewing all appeals that we have received from Claimants whose claims have been denied with

the help of Wayne Hunsperger and Dr. Mark McNulty.

Dated: October 13, 2017

f ,,t.,-,, ,d ;_ 12..tz ~,th C' l'A

Edward J. Racl'etich, Jr., CPA


Exhibit “A”


Rocky Flats Settlement c/o Heffler Claims Group Settlement and Claims Administrator P.O. Box 58459 Philadelphia, PA 19102-8459 [Date of Letter] Class Member ID: 30281XXXXXXXX

Re: Cook, et al. v. Rockwell International Corp. and The Dow Chemical Co.

(D. Colo.) No. 90-cv-00181-JLK

CONFIRMATION OF RECEIPT OF CLAIM

Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have received your Proof of Claim Form for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX, and have assigned it claim number XXXXXXX. Please note that if you filed more than one Proof of Claim Form, you should receive a separate letter with a unique claim number for each claim filed.

At this time, we continue to receive and process claims. If in the course of reviewing your claim it is determined that additional information and/or documentation is required, you will be notified by mail.

Important note: If your address or contact information has changed since submitting your Proof of Claim Form, or changes at any time in the future, you must contact us with the new information at your earliest convenience. Please be sure to include your claim number in any correspondence or communications with us.

Additionally, if you have any questions or need assistance with anything for your claim, please contact us: (a) in writing at the address on this letterhead; (b) by telephone at 1-844-528-0187; or (c) through the “Contact” section of the official, Court-approved settlement website: www.RockyFlatsSettlement.com. Thank you.

Sincerely,

Heffler Claims Group Settlement and Claims Administrator


Exhibit “B”


30281 DL

Rocky Flats Settlementc/o Heffler Claims GroupSettlement and Claims AdministratorP.O. Box 58459Philadelphia, PA 19102-8459

[Date of Letter]

Class Member ID: 30281XXXXXXXX

Re: Cook, et al. v. Rockwell International Corp. and The Dow Chemical Co.,No. 90-cv-00181-JLK (D. Colo.)

NOTIFICATION OF DEFICIENT CLAIMAND DESCRIPTION OF CORRECTIVE MEASURES

Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

You have filed a Claim Form as an heir to a Property Owner on June 7, 1989 who has since died. We have reviewed your Claim Form and determined that you need to submit additional documentation in order for your claim to be processed. (By “heir,” we mean that you have stated that you are legally entitled to the assets upon the death of someone who owned the property in the Property Class Area on June 7, 1989.) You have further indicated to us that the now deceased Property Owner (of whom you are an heir) passed away without a will or estate proceeding. In order to show that you are entitled to recover any monies that would have gone to the Property Owner who is now deceased, you must complete, sign, have notarized and return the sworn statement enclosed with this letter.

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days fromthe date of this letter. Remember to attach only copies of acceptable supporting documentation.Do not send original deeds, wills, or other original documents as these items cannot be returnedto you by the Settlement and Claims Administrator. Only send copies of documents. PLEASEKEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.


Claim No. XXXXXXX[Date of Letter] Page 2

30281 DL

We strongly suggest that you send your response to this letter by certified mail, return receipt requested (or any other delivery method that provides you with proof of mailing and of our receipt).

Important note: If your address or contact information has changed since submitting your Claim Form, or changes at any time in the future, you must contact us with the new information at your earliest convenience. Please be sure to include your claim number in any correspondence or communications with us.

Additionally, if you have any questions about your claim or this letter, or need assistance with anything related to your claim, please contact us: (a) in writing at the address on this letterhead; (b) by telephone at 1-844-528-0187; or (c) through the “Contact” section of the official, Court-approved settlement website: www.RockyFlatsSettlement.com. Thank you.

Sincerely,

Heffler Claims GroupSettlement and Claims Administrator


Class Member ID: 30281XXXXXXXX Claim No. XXXXXXX

1

S W O R N S T A T E M E N T

TO BE COMPLETED BY AN HEIR OF A CLASS MEMBER

1. Name of person completing this form: ____________________________________________

2. Address of Property or Other Legal Description of Property (as of June 7, 1989): _________

___________________________________________________________________________

3. Names of Owners on June 7, 1989:

Owner No. 1: ________________________________________

Owner No. 2: ________________________________________

If more than two owners, list other owners here and provide additional pages with the information about the other owners.

___________________________________________________________________________

___________________________________________________________________________

4. State your relationship to Owner No. 1: _______________________________________

5. State your relationship to Owner No. 2: _______________________________________

6. Are either of the above-named Owners deceased? _____Yes _____ No

Date of death of Owner No. 1, if applicable: ____________________________________

Date of death of Owner No. 2, if applicable: ____________________________________

INFORMATION ABOUT DECEASED OWNER NO. 1

1. At the time of Owner No. 1’s death, was he/she married? _____Yes _____ No

2. If Owner No. 1 was married at the time of his/her death, was Owner No. 1 married to Owner No. 2 at the time of Owner No. 1’s death?

_____Yes _____ No



2

3. If you answered the previous question (No. 2) “No,” state the name of Owner No. 1’s spouse

on the date of Owner No. 1’s death and provide the current address of the spouse if known.

___________________________________________________________________________

___________________________________________________________________________

4. Did Owner No. 1 have children? _____Yes _____ No

5. If you answered the previous question (No. 4) “Yes,” please list the following according to the following instructions:

List the name and address of ALL of Owner No. 1’s children, whether alive or deceased as of the date of death of Owner No. 1.

Indicate in Column c whether the child died before Owner No. 1.

Indicate in Column d whether the child’s other parent was Owner No. 2.

a. Name of Child b. Address c. Child died before Owner No. 1?

d. Was the other parent Owner No. 2?

IF NO, please provide the name and address of the child’s other parent.

6. If any of the children listed in response to the previous question (No. 5) died before Owner No. 1, did these children leave surviving children of their own?

_____Yes _____ No



3

7. If you answered the previous question (No. 6) “Yes,” please list the names of the deceased

child’s children (attach additional sheets if necessary):

Owner No. 1’s Children Who Died Before Owner No. 1

Name of his/her Children Address

1. a.

b.

c.

2. a.

b.

c.

8. State the total approximate value of Owner No. 1’s Estate: __________________________

INFORMATION ABOUT OWNER NO. 2

1. At the time of Owner No. 2’s death, was he/she married? _____Yes _____ No

2. If you answered the previous question (No. 1) “Yes,” was Owner No. 2 married to Owner No. 1 on the date of death?

_____Yes _____ No

3. If you answered the previous question (No. 2) “No,” state the name of Owner No. 2’s spouse on the date of Owner No. 2’s death and current address if known.

Name: __________________________________________

Current Address: _________________________________________________________



4

4. Did Owner No. 2 have children? _____Yes _____ No

5. If you answered the previous question (No. 4) “Yes,” please list the following according to the following instructions:

List the name and address of ALL of Owner No. 2’s children, whether alive or deceased as of the date of death of Owner No. 2.

Indicate in Column c whether the child died before Owner No. 2.

Indicate in Column d whether the child’s other parent was Owner No. 1.

a. Name of Child b. Address c. Child died before Owner No. 2?

d. Was the other parent Owner No. 1?

IF NO, please provide the name and address of the child’s other parent.

6. If any of the children listed in the previous question (No. 5) died before Owner No. 2, did that child leave surviving children?

_____Yes _____ No


Class Member ID: 30281XXXXXXX Claim No. XXXXXXX

5

7. If you answered the previous question (No. 6) “Yes,” please list each deceased child’s

children (attach additional sheets if necessary):


Name of his/her Children Address

1. a.

b.

c.

2. a.

b.

c.




6

COUNTY OF _______________________ ) ) ss. STATE OF _______________________ )

I do swear or affirm under penalty of perjury that the answers contained in this form are true and correct.

__________________________________ Signature of Claimant

Subscribed and sworn to before me this _____ day of __________________, 2017, by

____________________________, the Claimant.

My commission expires: _____________________.

____________________________________ Notary Public


30281 DL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

You have filed a Claim Form as the spouse of a Property Owner on June 7, 1989 who has since died. We have reviewed your Claim Form and determined that you need to submit additional documentation in order for your claim to be processed. You have further indicated to us that your spouse passed away without a will or estate proceeding. In order to show that you are entitled to recover any monies that would have gone to your spouse who is now deceased, you must complete, sign, have notarized and return the sworn statement enclosed with this letter.

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter. Remember to attach only copies of acceptable supporting documentation.Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents.PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.



Claim No. XXXXXXX[Date of Letter]Page 2

30281 DL



Sincerely,



Class Member ID: 30281XXXXXXXXClaim No. XXXXXXX

1


TO BE COMPLETED BY SURVIVING SPOUSE

I, ____________________________________________________________ (Claimant),

was Co-Owner of the Property at ___________________________________________ (address

or legal description), on June 7, 1989 with

____________________________________________ (Co-Owner).

1. The Co-Owner of the property on June 7, 1989 died on _________________________. (The

Co-Owner who is deceased is referred to as the “Decedent” throughout this sworn statement.)

The Decedent and I were married at the time of his/her death. I am the Decedent’s surviving

spouse.

2. The Decedent:

____ left a Will, a copy of which is attached.

____ left a Will that cannot presently be located.

____ did not leave a Will.

3. Was an Estate Proceeding opened for the Decedent?

____ Yes. If Yes, please state the County and State in which the proceeding was

commenced and the Probate Case Number if available: _________________________________

______________________________________________________________________________

____ No



2

4. If the Decedent did not leave a Will, please state the following:

a. Did the Decedent have children? ______ Yes ______ No

b. If the Decedent had no children, did any parent of the Decedent survive the

Decedent (i.e., were any of the Decedent’s parents alive at the time of the

Decedent’s death)? ______ Yes ______ No

c. If the Decedent had children, are all of the Decedent’s children also children

of yours? ______ Yes ______ No

If the Decedent had children, please list all of the Decedent’s children by name and

address and state whether they are alive or deceased:

Name Address Alive or Deceased?

Were you also the biological or adoptive parent of this child (with the Decedent)?


Class Member ID: 30281XXXXXXXXClaim No. XXXXXXX

3

If any children listed above are deceased, did they leave children or grandchildren

surviving them (i.e., did they have children or grandchildren who were alive at the time of the

child’s death)? For each child listed above who is deceased but who was survived by children or

grandchildren, list the name and address of his or her surviving child or grandchild and state the

relationship:

Name Address Relationship to Deceased Child and Name of Deceased Child

d. If all of the Decedent’s surviving children or grandchildren were also children

or grandchildren (or great-grandchildren) of yours, do you have children alive

today who are not children of the Decedent? ______ Yes ______ No

5. What was the total approximate value of the Decedent’s Estate? ______________________.



4

COUNTY OF _____________________ ) ) ss. STATE OF ______________________ )

I do swear or affirm under penalty of perjury that the above Answers are true and correct.

___________________________________ Claimant


____________________________, the Claimant.

My commission expires: ________________________________.

___________________________________ Notary Public


30281 DL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

You have filed the Claim Form as an heir or corporate successor to the Property Owner on June 7, 1989. However, the documents you submitted to support that position are insufficient (if they were submitted at all). You must send sufficient documentation to support the fact that you are entitled as an heir or corporate successor to make the claim and share in the settlement proceeds. This may include copies of wills, estates, probate documents, liquidation or corporate dissolution documents, etc. (By “heir,” we mean that you were legally entitled to the property and assets upon the death of someone who owned the property in the Property Class Area.)

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days fromthe date of this letter. Remember to attach only copies of acceptable supporting documentation.Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents.PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.



30281 DL




Sincerely,



30281 DL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

The Claim Form was not properly signed by all claimants (if the claim is made for joint claimants, each must sign). Part III of the Claim Form is reproduced below. The claimant (and joint claimant, if applicable) must complete and sign in the appropriate places and return the completed section to us at the address on this letterhead.



30281 DL

PART III - CERTIFICATION AND SIGNATURE

UNDER THE PENALTIES OF PERJURY, I (OR WE) CERTIFY THAT ALL OF THE INFORMATION PROVIDED BY ME (US) ON THE CLAIM FORM IS TRUE, CORRECT, AND COMPLETE, AND THAT THE DOCUMENTS SUBMITTED THEREWITH ARE TRUE AND CORRECT COPIES OF WHAT THEY PURPORT TO BE.

PLEASE NOTE: You should be aware that it will take a significant amount of time to fully process all of the Claim Forms. We cannot estimate when claims will be fully processed. In addition, net settlement funds will not be paid unless and until the settlement receives final Court approval. Please notify the Settlement and Claims Administrator of any name change, change of address, phone number or email. Please also note that the Settlement and Claims Administrator and/or Class Counsel may contact you with questions, or with requests for more documentation and the like. By signing below and submitting this claim, you agree to cooperate with such requests in a timely manner. Failure to do so may result in the rejection of your claim.

__________________________________________________________________________________________Signature of Claimant (or Person Authorized to Sign on behalf of claimant, if applicable.)

______________________________________________________ ____________________________Print Name of Claimant Date(or Person Authorized to Sign on behalf of claimant, if applicable.)

__________________________________________________________________________________________If not the Claimant, explain the reason why you are submitting this form on behalf of the Claimant and submit documentation showing you are authorized to sign on Claimant’s behalf

______________________________________________________ ____________________________Print Name of Joint Claimant Date

__________________________________________________________________________________________Signature of Joint Claimant (or Person Authorized to Sign on behalf of Joint Claimant, if applicable.)

__________________________________________________________________________________________If you are not the Joint Claimant, explain why you are submitting this form on behalf of the Claimant and submit documentation showing you are authorized to sign on Claimant’s behalfNOTE: If there are more than 2 joint Claimants, please attach a page with information about additional Joint Claimants.



30281 DL

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days fromthe date of this letter. Remember to attach only copies of acceptable supporting documentation.Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents.PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.




Sincerely,



30281 DL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim numberXXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

The Claim Form was not properly filled out for the Social Security Number or Employer Identification Number for the claimant(s) (if the claim is made for joint claimants, each SSN is required). Part I, Sections 1 and 2 of the Claim Form are reproduced below. The claimant (and joint claimant, if applicable) must complete in the appropriate places and return the completed section to us at the address on this letterhead.



30281 DL

PART I - NAME OF INDIVIDUAL OR CORPORATION MAKING A CLAIM

1) INDIVIDUALComplete here if you are an individual(s) making the claim (whether on your own behalf or as an heir of someone who owned property in the Property Class Area on June 7, 1989):

Last Name (Claimant) MI First Name (Claimant)

Social Security Number __ __ __ - __ __ - __ __ __ __

Last Name (Joint Owner, if applicable) MI First Name (Joint Owner, if applicable)


2) CORPORATION OR OTHER ENTITYComplete here if you are making a claim on behalf of a corporation, trust, estate, or other type of entity (whether on your own behalf or as the successor to the entity which owned the property on June 7, 1989):

Entity Name

Name of Representative (executor, administrator, trustee, corporate officer, etc.)

Employer Identification Number (for estates, trusts, corporations, etc.) __ __ -__ __ __ __ __ __ __



30281 DL

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter. Remember to attach only copies of acceptable supporting documentation.Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents.PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.




Sincerely,



30281 DL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX , for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on your Claim Form, we have determined that, for the reason(s) listed below, your claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund:

You have filed the Claim Form as the Property Owner on June 7, 1989. However, when compared to records provided by Jefferson County, Colorado, there is a slight difference in the name(s) of the owner and/or joint owner. This is not uncommon, and is usually due to marriage, divorce, or similar circumstances involving someone’s name changing. You must send sufficient documentation to support the fact that you are entitled, but have had a change of name, to make the claim and share in the settlement proceeds. This may include copies of marriage certificates, divorce decrees, etc.

In order to cure the deficiency or deficiencies listed above and receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. You must submit this information and/or supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter. Remember to attach only copies of acceptable supporting documentation. Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents. PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.




30281 DL



Sincerely,



Exhibit “C”


Rocky Flats Settlement c/o Heffler Claims Group Settlement and Claims Administrator P.O. Box 58459 Philadelphia, PA 19102-8459 October X, 2017 Class Member ID: «RefNum» «Company» «FirstName» «LastName» «coFirstName» «coLastName» «MailingAddress1» «MailingAddress2» «MailingCity», «MailingState» «MailingZip»

Re: Cook, et al. v. Rockwell International Corp. and The Dow Chemical Co., No. 90-cv-00181-JLK (D. Colo.)

SECOND NOTIFICATION OF DEFICIENT CLAIM AND DESCRIPTION OF CORRECTIVE MEASURES

Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing regarding your Proof of Claim Form, claim number «ClaimNum», for the property located at «PropAddress», «PropCrossStreet», «PropLegalDescription», «PropCity», «PropState» «PropZip». You were previously notified that, based upon our review of the information you provided on your claim form, claim is considered deficient, and at this point not eligible to share in the distribution of the Net Settlement Fund for the following reason(s):

< INSERT REASON(S) HERE >

THIS IS A SECOND NOTIFICATION THAT in order to cure the deficiency or deficiencies listed above and in order to receive your share of the Net Settlement Fund, you must: (i) notify us in writing that you are attempting to cure the deficiency in your claim, identified with the claim number listed above; and (ii) provide us with the information requested above, including with any supporting documentation. YOU MUST SUBMIT THIS INFORMATION AND/OR SUPPORTING DOCUMENTS TO US AT THE ADDRESS ON THIS LETTERHEAD, POSTMARKED ON OR BEFORE [DATE], WHICH IS THIRTY (30) DAYS FROM THE DATE OF THIS LETTER. Remember to attach only copies of acceptable supporting documentation. Do not send original deeds, wills, or other original documents as these items cannot be returned to you by the Settlement and Claims Administrator. Only send copies of documents. PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.



Claim No. «clmnum» October X, 2017 Page 2



Sincerely,



(DA) The Claim Form was not properly signed by all claimants (if the claim is made for joint claimants, each must sign). Part III of the Claim Form is reproduced below. The claimant (and joint claimant, if applicable) must complete and sign in the appropriate places and return the completed section to us at the address on this letterhead.

PART III - CERTIFICATION AND SIGNATURE

UNDER THE PENALTIES OF PERJURY, I (OR WE) CERTIFY THAT ALL OF THE INFORMATION PROVIDED BY ME (US) ON THE CLAIM FORM IS TRUE, CORRECT, AND COMPLETE, AND THAT THE DOCUMENTS SUBMITTED THEREWITH ARE TRUE AND CORRECT COPIES OF WHAT THEY PURPORT TO BE.

PLEASE NOTE: You should be aware that it will take a significant amount of time to fully process all of the Claim Forms. We cannot estimate when claims will be fully processed. In addition, net settlement funds will not be paid unless and until the settlement receives final Court approval. Please notify the Settlement and Claims Administrator of any name change, change of address, phone number or email. Please also note that the Settlement and Claims Administrator and/or Class Counsel may contact you with questions, or with requests for more documentation and the like. By signing below and submitting this claim, you agree to cooperate with such requests in a timely manner. Failure to do so may result in the rejection of your claim. __________________________________________________________________________________________ Signature of Claimant (or Person Authorized to Sign on behalf of claimant, if applicable.)

______________________________________________________ ___________________________ Print Name of Claimant Date (or Person Authorized to Sign on behalf of claimant, if applicable.)

__________________________________________________________________________________________ If not the Claimant, explain the reason why you are submitting this form on behalf of the Claimant and submit documentation showing you are authorized to sign on Claimant’s behalf ______________________________________________________ ___________________________ Print Name of Joint Claimant Date __________________________________________________________________________________________ Signature of Joint Claimant (or Person Authorized to Sign on behalf of Joint Claimant, if applicable.)

__________________________________________________________________________________________ If you are not the Joint Claimant, explain why you are submitting this form on behalf of the Claimant and submit documentation showing you are authorized to sign on Claimant’s behalf NOTE: If there are more than 2 joint Claimants, please attach a page with information about additional Joint Claimants.


(DS) The Claim Form was not properly filled out for the Social Security Number or Employer

Identification Number for the claimant(s) (if the claim is made for joint claimants, each SSN is required). Part I, Sections 1 and 2 of the Claim Form are reproduced below. The claimant (and joint claimant, if applicable) must complete in the appropriate places and return the completed section to us at the address on this letterhead. A valid Social Security Number or Employer Identification Number is required for each claimant.

PART I - NAME OF INDIVIDUAL OR CORPORATION MAKING A CLAIM

1) INDIVIDUAL Complete here if you are an individual(s) making the claim (whether on your own behalf or as an heir of someone who owned property in the Property Class Area on June 7, 1989): Last Name (Claimant) MI First Name (Claimant)


Last Name (Joint Owner, if applicable) MI First Name (Joint Owner, if applicable)


2) CORPORATION OR OTHER ENTITY Complete here if you are making a claim on behalf of a corporation, trust, estate, or other type of entity (whether on your own behalf or as the successor to the entity which owned the property on June 7, 1989): Entity Name Name of Representative (executor, administrator, trustee, corporate officer, etc.)

Employer Identification Number (for estates, trusts, corporations, etc.) __ __ -__ __ __ __ __ __ __

(DH) You have filed the Claim Form as an heir or corporate successor to the Property Owner on

June 7, 1989. However, the documents you submitted to show that you are an heir or corporate successor are insufficient (if they were submitted at all). You must send sufficient documentation to show that you are entitled as an heir or corporate successor to make the claim and share in the settlement proceeds. This may include copies of wills, estates, probate documents, liquidation or corporate dissolution documents, etc. (By “heir,” we mean that you were legally entitled to the property and assets upon the death of someone who owned the property in the Property Class Area.) If you have any questions about the required documentation, please contact us: (a) in writing at the address on this letterhead; (b) by telephone at 1-844-528-0187; or (c) through the “Contact” section of the official, Court-approved settlement website: www.RockyFlatsSettlement.com


(DN) You have filed the Claim Form as the Property Owner on June 7, 1989. However, when

compared to records provided by Jefferson County, Colorado, there is a slight difference in the name(s) of the owner and/or joint owner. This is not uncommon, and is usually due to marriage, divorce, or similar circumstances involving someone’s name changing. You must send sufficient documentation to support the fact that you are have had a change of name to complete your claim and share in the settlement proceeds. This may include copies of marriage certificates, divorce decrees, etc.

(DW) You have filed the Claim Form as the spouse of a Property Owner on June 7, 1989 who has

since died. We have reviewed your claim form and determined that you need to submit additional documentation in order for your claim to be processed. You have further indicated to us that your spouse passed away without a will or estate proceeding. In order to show that you are entitled to recover any monies that would have gone to your spouse who is now deceased, you must complete, sign, have notarized, and return the sworn statement enclosed with this letter.

(DX) You have filed the Claim Form as an heir to a Property Owner on June 7, 1989 who has

since died. We have reviewed your claim form and determined that you need to submit additional documentation in order for your claim to be processed. (By “heir,” we mean that you have stated that you are legally entitled to the assets upon the death of someone who owned property in the Property Class Area on June 7, 1989.) You have further indicated to us that the now deceased Property Owner (of whom you are an heir) passed away without a will or estate proceeding. In order to show that you are entitled to recover any monies that would have gone to the Property Owner who is now deceased, you must complete, sign, have notarized, and return the sworn statement enclosed with this letter.

(DZ) You have filed the Claim Form as an heir or corporate successor to the Property Owner on

June 7, 1989 and the documents you submitted to support that position are sufficient. However, further documentation is required to establish the relative share of your portion of the estate. That is, we need additional documentation to show what percentage of the original Property Owner’s estate should be payable to you (i.e., whether you are entitled to 100% of the claim that would have been paid to the deceased original Property Owner, or 50%, or some other percentage). You must send sufficient documentation to support the extent to which you are entitled as an heir or corporate successor to make the claim and share in the settlement proceeds. This may include copies of wills, estates, probate documents, liquidation or corporate dissolution documents, etc. (By “heir,” we mean that you were legally entitled to the property and assets of someone who owned the property in the Property Class Area upon their death.)


1


TO BE COMPLETED BY AN HEIR OF A CLASS MEMBER

1. Name of person completing this form: ___________________________________________ 2. Address of Property or Other Legal Description of Property (as of June 7, 1989): _________

_____________________________________________________________________________

3. Names of Owners on June 7, 1989: Owner No. 1: ________________________________________ Owner No. 2: ________________________________________ If more than two owners, list other owners here and provide additional pages with the information about the other owners. ______________________________________________________________________________

______________________________________________________________________________

4. State your relationship to Owner No. 1: _______________________________________ 5. State your relationship to Owner No. 2: _______________________________________ 6. Are either of the above-named Owners deceased? _____Yes _____ No Date of death of Owner No. 1, if applicable: __________________________________ Date of death of Owner No. 2, if applicable: __________________________________

INFORMATION ABOUT DECEASED OWNER NO. 1

1. At the time of Owner No. 1’s death, was he/she married? _____Yes _____ No 2. If Owner No. 1 was married at the time of his/her death, was Owner No. 1 married to Owner

No. 2 at the time of Owner No. 1’s death? _____Yes _____ No


2

3. If you answered the previous question (No. 2) “No,” state the name of Owner No. 1’s spouse on the date of Owner No. 1’s death and provide the current address of the spouse if you know it. _____________________________________________________________________ __________________________________________________________________________

4. Did Owner No. 1 have children? _____Yes _____ No 5. If you answered the previous question (No. 4) “Yes,” please list the following according to the

following instructions:

• List the name and address of ALL of Owner No. 1’s children, whether alive or deceased as of the date of death of Owner No. 1.

• Indicate in Column c whether the child died before Owner No. 1.

• Indicate in Column d whether the child’s other parent was Owner No. 2.

a. Name of child b. Address c. Child

died before Owner No. 1?

d. Was the other parent Owner No. 2? IF NO, please provide the name and address of the child’s other parent.

6. If any of the children listed in response to the previous question (No. 5) died before Owner No.

1, did these children leave surviving children of their own?

_____Yes _____ No


3

7. If you answered the previous question (No. 6) “Yes,” please list the names of the deceased child’s children (attach additional sheets if necessary):


Name of his/her children Address

1. a.

b.

c.

2. a.

b.

c.


INFORMATION ABOUT OWNER NO. 2

1. At the time of Owner No. 2’s death, was he/she married? _____Yes _____ No 2. If you answered the previous question (No. 1) “Yes,” was Owner No. 2 married to Owner No. 1 on the date of death? _____Yes _____ No 3. If you answered the previous question (No. 2) “No,” state the name of Owner No. 2’s spouse

on the date of Owner No. 2’s death and current address if known. Name: __________________________________________ Current Address: __________________________________________________________


4

4. Did Owner No. 2 have children? _____Yes _____ No 5. If you answered the previous question (No. 4) “Yes,” please list the following according to the

following instructions:

• List the name and address of ALL of Owner No. 2’s children, whether alive or deceased as of the date of death of Owner No. 2.

• Indicate in Column c whether the child died before Owner No. 2.

• Indicate in Column d whether the child’s other parent was Owner No. 1.

a. Name of child b. Address c. Died

before Owner No. 2?

d. Was the other parent Owner No. 1? IF NO, please provide the name and address of the child’s other parent.

6. If any of the children listed in the previous question (No. 5) died before Owner No. 2, did that

child leave surviving children? _____Yes _____ No


5

7. If you answered the previous question (No. 6) “Yes,” please list each deceased child’s children (attach additional sheets if necessary):


Name of his/her children Address

1. a.

b.

c.

2. a.

b.

c.



6

COUNTY OF _______________________ ) ) ss. STATE OF _______________________ )

I do swear or affirm under penalty of perjury that the answers contained in this form are true and correct.

__________________________________ Signature of Claimant


____________________________, the Claimant.

My commission expires: _____________________. ____________________________________ Notary Public


1


TO BE COMPLETED BY SURVIVING SPOUSE

I, ____________________________________________________________ (Claimant),

was Co-Owner of the Property at ___________________________________________(address

or legal description), on June 7, 1989 with ____________________________________________

(Co-Owner).

1. The Co-Owner of the property on June 7, 1989 died on _________________________. (The

Co-Owner who is deceased is referred to as the “Decedent” throughout this sworn statement.) The

Decedent and I were married at the time of his/her death. I am the Decedent’s surviving spouse.

2. The Decedent:

____ left a Will, a copy of which is attached.

____ left a Will that cannot presently be located.

____ did not leave a Will.

3. Was an Estate Proceeding opened for the Decedent?

____ Yes. If Yes, please state the County and State in which the proceeding was

commenced and the Probate Case Number if available: _________________________________

_____________________________________________________________________________

____ No


2

4. If the Decedent did not leave a Will, please state the following:

a. Did the Decedent have children? ____ Yes ____ No

b. If the Decedent had no children, did any parent of the Decedent survive the

Decedent (i.e., were any of the Decedent’s parents alive at the time of the

Decedent’s death)? ______ Yes ______ No

c. If the Decedent had children, are all of the Decedent’s children also children of

yours? ____ Yes ____ No

If the Decedent had children, please list all of the Decedent’s children by name and address

and state whether they are alive or deceased:

Name Address Alive or Deceased?

Were you also the biological or adoptive parent of this child (with the Decedent)?


3

If any children listed above are deceased, did they leave children or grandchildren

surviving them (i.e., did they have children or grandchildren who were alive at the time of the

child’s death)? For each child listed above who is deceased but who was survived by children or

grandchildren, list the name and address of his or her surviving child or grandchild and state the

relationship:

Name Address Relationship to Deceased Child and Name of Deceased Child

d. If all of the Decedent’s surviving children or grandchildren were also children

or grandchildren (or great-grandchildren) of yours, do you have children alive

today who are not children of the Decedent?

____ Yes ____ No

5. What was the total approximate value of the Decedent’s Estate? _______________________.


4

COUNTY OF _____________________ ) ) ss. STATE OF ______________________ )

I do swear or affirm under penalty of perjury that the above Answers are true and correct.

__________________________________ Claimant Subscribed and sworn to before me this _____ day of __________________, 2017, by

____________________________, the Claimant.

My commission expires: ________________________________. ____________________________________ Notary Public


Exhibit “D”


30281 RL


[Date of Letter]



NOTIFICATION OF REJECTION OF CLAIMAND DESCRIPTION OF CORRECTIVE MEASURES

Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on and with your Claim Form, we have determined that your claim is invalid and thus not eligible to share in the distribution of the Net Settlement Fund, for the following reason(s):

After a detailed, careful review of the physical location of your property, it has been confirmed by the Property Expert for the Class that your property is not located within the Property Class Area. Therefore, you are not a member of the Settlement Class for this property, and are not entitled to participate in the distribution of the Settlement Funds for this property.

You may contest our determination and request further review by: (i) notifying us that you are contesting our determination of your claim, identified with the claim number listed above; and (ii) providing us with a statement of your reasons for your contesting, along with documentation to support your position. You must submit the notification, statement of reasons, and supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter.PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.


If we do not receive your response postmarked no later than [thirty (30) days from Date of Letter], we will determine your claim is invalid for the reason(s) described above.



30281 RL

This will be the final correspondence you receive from us UNLESS you contest our determination and request further review by the Settlement and Claims Administrator as described above.



Sincerely,


cc: Class Counsel:Berger & Montague, P.C.Silver & DeBoskey, P.C.


30281 RL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on and with your Claim Form, we have determined that your claim is invalid and thus not eligible to share in the distribution of the Net Settlement Fund, for the following reason(s):

After a detailed, careful review of the documents you provided and the records of Jefferson County, Colorado, we have determined that you are not the owner of the property on June 7, 1989, and are not an heir or successor to that owner. Therefore, you are not a member of the Settlement Class for this property, and are not entitled to participate in the distribution of the Settlement Funds for this property.

You may contest our determination and request further review by: (i) notifying us that you are contesting our determination of your claim, identified with the claim number listed above; and (ii) providing us with a statement of your reasons for your contesting, along with documentation to support your position. You must submit the notification, statement of reasons, and supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter. PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.





30281 RL




Sincerely,




30281 RL


[Date of Letter]




Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court, and are writing to advise you that we have reviewed your Proof of Claim Form, claim number XXXXXXX, for the property located at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Based upon our review of the information you provided on and with your Claim Form, we have determined that your claim is invalid and thus not eligible to share in the distribution of the Net Settlement Fund, for the following reason(s):

The claim number noted above is a duplicate of claim number XXXXXXX. Please be advised that claim number XXXXXXX is, with the exception of any deficiencies or rejections which were mailed under separate cover, a valid claim.

You may contest our determination and request further review by: (i) notifying us that you are contesting our determination of your claim, identified with the claim number listed above; and (ii) providing us with a statement of your reasons for your contesting, along with documentation to support your position. You must submit the notification, statement of reasons, and supporting documents to us at the address on this letterhead, postmarked on or before [thirty (30) days from Date of Letter], which is thirty (30) days from the date of this letter. PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS.






30281 RL



Sincerely,




Exhibit “E”


ON CHECK STUB: Class Member ID: 30281xxxxxxxx Claim Number: xxxxxxxxxx Check Number: xxxxxx Check Amount: $xx,xxx.xx Check Date: xx/xx/xxxx Payee: xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Property: xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Property Category: Residential / Commercial / Vacant Land Percentage: «Percent»%

PLEASE RETAIN THIS STUB FOR YOUR RECORDS.


Rocky Flats Settlement c/o Heffler Claims Group

Settlement and Claims Administrator P.O. Box 58459

Philadelphia, PA 19102-8459 1-844-528-0187

www.RockyFlatsSettlement.com

Month X, 2017 Re: Cook, et al. v. Rockwell International Corp. and The Dow Chemical Co.,

No. 90-cv-00181-JLK (D. Colo.)

Dear Claimant:

We are the Settlement and Claims Administrator appointed by the Court in the above-listed matter, and are writing to advise you that we have reviewed your Proof of Claim Form and supporting documentation for the “Property” listed on the enclosed check stub. Based upon our review of the information submitted in connection with your Proof of Claim Form, we have determined that your claim is valid and eligible for an award from the Net Settlement Fund. Additionally, we have determined that you, as the claimant, are entitled to the “Percentage” listed on the check stub of the award for the Property based on the circumstances of your claim and the Property. (This “Percentage” is equal to 100% if you are the only person who is entitled to file a claim in connection with the Property; if you are the only person who is entitled to file a claim in connection with the Property then you will receive 100% of the award associated with the Property. If the “Percentage” is, for example, 50%, then you will receive 50% of the award associated with the Property.)

We are pleased to provide you with the enclosed check representing the initial payment of your total award from the Net Settlement Fund. This is only the first part of your total award related to this case. We expect to make an additional payment or payments in connection with this case, but cannot yet calculate the amount of any additional payments to you because we are continuing to evaluate claims made by members of the Class. Special Note: Pursuant to the Court-approved Plan of Allocation of the Settlement Fund1 (“the Plan of Allocation”), this letter and enclosed check constitutes notification to you of the award, and of the process for Class members to seek adjustment of the amount of their awards under the Plan of Allocation. The calculation of this initial payment is based on the formula set forth in the Plan of Allocation, which utilizes various data including the 1989 assessed value of the Property, the 1989 assessed values of other properties in the Class area, and the amount of the Net Settlement Fund. To seek adjustment of the award, you must: (i) notify us in writing that you are seeking adjustment of the award, identified with the claim number listed above; (ii) provide us with a written explanation that includes the grounds for the sought adjustment, including any supporting documentation; and (iii) not cash or deposit this check in any manner. You must return this check and submit the required information and supporting documents to us at the address on this letterhead, postmarked on or before [Date], which is thirty (30) days from the date of this letter. Remember to attach only copies of acceptable supporting documentation. Do not send original deeds, wills, or other original documents as these items 1 The Plan of Allocation, and other important documents, can be found at the Settlement’s official website, www.RockyFlatsSettlement.com.


cannot be returned to you by the Settlement and Claims Administrator; send only copies of documents. PLEASE KEEP A COPY OF EVERYTHING YOU SEND TO US FOR YOUR RECORDS. We strongly suggest if you seek adjustment, that you send your response to this letter by certified mail, return receipt requested (or any other delivery method that provides you with proof of mailing and of our receipt).

Because the tax treatment of these award payments varies based on each Authorized Claimant’s tax status and circumstances, you should consult your tax advisor to determine the tax consequences, if any, of these award payments to you. Please note that the Internal Revenue Service has issued regulations under Internal Revenue Code §468B that may affect your tax treatment of these award payments.

IMPORTANT NOTE: IF YOUR ADDRESS OR CONTACT INFORMATION HAS CHANGED SINCE SUBMITTING YOUR CLAIM FORM, OR CHANGES AT ANY TIME IN THE FUTURE, YOU MUST CONTACT US WITH YOUR NEW ADDRESS OR CONTACT INFORMATION AT YOUR EARLIEST CONVENIENCE. PLEASE BE SURE TO INCLUDE YOUR CLAIM NUMBER IN ANY CORRESPONDENCE OR COMMUNICATIONS WITH US. MAKE SURE THAT YOU WRITE AND KEEP YOUR CLAIM NUMBER (LISTED ON THE CHECK STUB) BEFORE YOU CASH OR DEPOSIT YOUR CHECK SO THAT YOU WILL HAVE YOUR CLAIM NUMBER FOR FUTURE CORRESPONDENCE WITH US.

Additionally, if you have any questions about your claim or this letter or check, or need assistance with anything related to your claim, please contact us: (a) in writing at the address on this letterhead; (b) by telephone at 1-844-528-0187; or (c) through the “Contact” section of the official, Court-approved settlement website: www.RockyFlatsSettlement.com. Thank you.

Sincerely,





MERILYN COOK, et al. ,

Plaintiffs,

V.

ROCKWELL INTERNATIONAL CORPORATION and THE DOW CHEMICAL COMPANY,

Defendants.

DECLARATION OF WAYNE HUNSPERGER IN SUPPORT OF PLAINTIFFS' AND CLASS COUNSEL'S UNOPPOSED MOTION FOR AN INITIAL DISTRIBUTION OF THE

NET SETTLEMENT FUNDS


ccoslett

Text Box

I, Wayne L. Hunsperger, declare as follows :

1. I am the principal owner of Wayne L. Hunsperger, LLC. I have personal

knowledge of the facts set forth herein and, if called as a witness, could and would testify

competently thereto. I am over 21 years of age and not a party to this action.

2. I submit this declaration in connection with Plaintiffs' and Class Counsel's

Unopposed Motion for An Initial Distribution of the Net Settlement Funds.

3. I have been working on the claims administration related to the settlement of this

case. I have worked with Class Counsel, Dr. Mark McNulty of Pacey Economics, Inc. , 1 and

Heffler Claims Group ("Heffler"), the Court-approved Settlement and Claims Administrator.

4. At the request of Class Counsel, Dr. McNulty and I purchased data from Jefferson

County, Colorado, showing property information, property owner information, and the assessed

values as of 1989 for properties located in the Property Class Area.

5. Dr. McNulty and I used this data to calculate the total claim values for each

property located in the Property Class Area for which Heffler has received a valid or potentially

valid claim. We calculated the claim value associated with each property in accordance with the

Court-approved Plan of Allocation. In particular, as provided by the Plan of Allocation, 3.196%

of the Net Settlement Fund is allocable to commercial property claims; 81.537% is allocable to

residential property claims; and 15.267% is allocable to vacant land claims. See ECF No. 2407-

2. As provided in the Plan of Allocation, we determined, for each property for which a valid

claim was submitted, the property' s assessed value, expressed as a fraction of the total assessed

value of all Class Properties within the same property category (the property' s "Fractional

Allocable Share").

1 Dr. McNulty ' s biography is available at https://www.paceyecon.com/mark-mcnulty-phd.


6. In addition, I have worked with Heffler to address specific questions regarding

particular claims. For example, I have worked with Dr. McNulty to confirm that certain

properties are located outside of the Property Class Area following appeals filed by claimants

who wished to challenge the rejection of their claim.

7. My work with Heffler and on the claims administration process is ongoing. For

example, I expect to work to calculate the payment amounts to be distributed in any subsequent

distribution(s).

Dated: October 13, 2017


in the united states district court for the district of ... v. rockwell international corporation ....

Documents