Dear Claimant:

The purpose of this letter is to give you our understanding of the status of the processing and payment of claims submitted in connection with the Swiss Banks settlement and the German Foundation.  We have heard from many of you that you have been confused and frustrated about not hearing any information regarding your claims.  Unfortunately, the number of claims is so large that it would be difficult for the people working on the claims to respond to everyone’s inquiry.  While we lawyers have a little more weight in trying to find out this information, it has been frustrating for us as well.  In any event, we finally were able to learn some specific information and we wanted to communicate it to you.  The information in this letter, and any updates, will be posted on our website:   www.bergermontague.com

I.  The Swiss Banks Settlement

The settlement fund in this case will be used primarily to pay the claims of owners (or their heirs) of Swiss banks accounts, the claims of Jewish slave laborers and the claims of those who successfully or not tried to seek refuge in Switzerland..

The time to file bank account claims has just expired as of December 31, 2001.  The claims are being reviewed by an international committee chaired by Paul Volcker and Michael Bradfield, who were also involved in the audit of the Swiss Banks.  The results of the audit indicate that there are over 20,000 accounts which may belong to Holocaust survivors.  In November, Judge Korman approved the first group of 24 awards recommended by Mr. Volcker and Mr. Bradfield.  The average of these awards is $144,000, but only 35% is being paid at this time to ensure that there is enough money to pay all the awards.  We are trying to determine what the timetable is for the rest of the bank account claims.

The plan approved by the Judge provided for the payment of $1,000 each to class members with slave labor claims.  These claims are being processed and paid by the Claims Conference.  As of November, the Claims Conference reports have issued Swiss Bank slave labor payments to over 46,000 individuals.  They anticipate another 25,000 payments to be made

by the end of January, for a total of over 70,000.  The Claims Conference anticipates that 180,000 people will eventually receive Swiss Banks slave labor payments.   This will probably take all of 2002 to complete.

To approve these payments, as well as the German Foundation slave labor payments discussed later in this letter, the Claims Conference must document, where possible, the individual’s history of persecution.  Therefore, they decided to issue payments first to people already included under certain German pension programs.  They are also trying to prioritize applications by age, individual hardship, and date of submission.

The refugee claims are being handled individually.  At this point, we have received no information as to a timetable for their payment.