Clarence D. Kightlinger - Page 6

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          and received the above-mentioned notice.  The notice of class               
          action summarized the underlying class action as follows:                   
               Plaintiffs allege in their complaint that Private                      
               Defendants, who in the course of a scheme reasonably                   
               calculated to deceive Plaintiffs and to evade state and                
               federal taxes, to avoid compliance with various other                  
               federal and Commonwealth laws and regulations, and to                  
               relocate jobs from a state of the United States * * * to               
               Guayama, Puerto Rico, and who acting in concert with its               
               corporate officers and agents of the Commonwealth of Puerto            
               Rico, did unlawfully and without justification violate                 
               federal Racketeering laws and intentionally interfere with             
               the protected rights of Plaintiffs, including the                      
               prospective economic advantages, enjoyed by the herein                 
               described class of former * * * employees.  Plaintiffs                 
               further allege that as a direct result of AHP's scheme to              
               relocate its production facilities to Guayama, Puerto Rico             
               to take advantage of tremendous tax savings, AHP caused                
               workers to lose jobs, to be downgraded in their employment             
               and/or to take early retirement, all of which caused                   
               substantial economic damages to members of the plaintiff               
               class.  Plaintiffs in this class action lawsuit seek to                
               recover, on behalf of themselves and all other similarly               
               situated workers, for the economic harm losses resulting               
               from AHP's relocation to Puerto Rico, and the related events           
               occurring thereafter. [Emphasis added.]                                
               The notice of class action further stated:                             
                    If you want to participate in this class action lawsuit           
               and thereby made a claim for economic loss resulting from              
               AHP's alleged wrongful relocation of pharmaceutical                    
               production jobs to Guayama, Puerto Rico, you need do                   
               nothing. [Emphasis added.]                                             
                        *     *     *     *     *     *     *                         
                    If you have any claims for damages arising out of AHP's           
               relocation of production to Guayama, Puerto Rico that [are]            
               not employment-related economic harms, these claims are not            
               included in this class action.  Examples of economic harm              
               included in this class action are lost wages or lost salary,           
               lost health care and/or retirement benefits.                           

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