George and Kathleen Knevelbaard, et al. - Page 15

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                 To accomplish these goals, the settlement document did not                          
            require any specific allocation to specific plaintiffs but left                           
            allocation and distribution up to plaintiffs' counsel.  Paragraph                         
            2(c) of the settlement agreement provides as follows:                                     
                        (c)  Without reference to and without affecting                               
                  the allocation or distribution of the Settlement                                    
                  Payment among the various parties plaintiff, the                                    
                  Settlement Payment [$20 million] shall be attributed as                             
                  follows:                                                                            
                              (i)  Six Hundred Seventy-one Thousand                                   
                        Thirty-Four Dollars ($671,034.00) shall be                                    
                        attributed to the so-called "direct" cause of                                 
                        action in the Milk Producers Complaint for                                    
                        negligent interference with contractual                                       
                        relationship (the fourth cause of action);                                    
                        and                                                                           
                              (ii)  Nineteen Million Three Hundred                                    
                        Twenty-eight Thousand Nine Hundred Sixty-six                                  
                        Dollars ($19,328,966.00) shall be attributed                                  
                        to the so-called "direct" cause of action in                                  
                        the Milk Producers complaint for negligent                                    
                        infliction of emotional distress (the eighth                                  
                        cause of action);                                                             
                              (iii)  Nothing shall be attributed to                                   
                        any of the other causes of action in the Milk                                 
                        Producers Complaint or to any cause of action                                 
                        in the Danish Creamery complaint.                                             
            [Emphasis added.]                                                                         
                  Neither the Bank Defendants nor the milk producers wanted to                        
            settle on any basis relating to the contracts between Knudsen and                         
            the milk producers.  The banks consistently denied any liability                          
            on the contracts, and plaintiffs wanted to retain their direct                            
            claims for nonpayment of milk against the bankruptcy estate.                              
            Moreover, such a settlement would have required the bankruptcy                            




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