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T he P ortland O bserver • M ay 24, 1995
---------------------- —------------ ----------------------- ---------------------------------------------------------------------------
be used to further their intended purpose, subject to the Court's
may have against Woodmen I f you wish to exclude yourself
from the Settlement Class, you may use the form provided
by Woodmen and Class Counsel which w ill make use o f the
below in this Notice or you may submit your own request for
information and investigation they have expended in bring
exclusion You must mail any Request for Exclusion to the
following:
ing the Class Action and the State Court Actions
Woodmen has also agreed to contribute $2,500.000 over
a fisc year period (in an amount o f $500,000 per year) to
UNITED STATES DISTRICT COURT FOR THE SOUTHERN
DISTRICT OF MISSISSIPPI JACKSON DIVISION
The Woodmen Litigation
c/o Clerk o f the Court
United States District Court for the
enhance and improve its youth programs. This contribution
is intended to improve the opportunities for and the partici
LORENE NEALY, et al. vs. Woodmen of the World Life Insurance Society
Southern District o f Mississippi
245 E. Capitol St.
pation in Woodmen's youth programs by African-American
youths who arc Woodmen certificate holders. Determination
of how these funds w ill best be used to furdici their intended
Jackson, Mississippi 39201
purpose w ill be made in the same manner as the determina
tion on use o f die funds for the enhancement and improve
NO. 3:93-CV-536 BN
Your exclusion request must set forth your full name and cur
rent address Your written request for exclusion must be post
marked no later than July 15, 1995. I f any other method of
ment of Woodmen's Equal Access Plan
AFRICAN-AMERICAN CERTIFICATE HOLDERS
OF WOODMEN OF THE WORLD/OMAHA WOODMEN
LIFE INSURANCE SOCIETY
S
du « R?
In addition, the following amounts w ill also be distrib
§ c LM
^
' g
!
W
S
M
-
o r ju d g m rn t(s) entered in connection w ith the Settlement
and expenses, any indiv idual awards to Class Representatives,
E R Q Q E Q F C L A IM P R O C E D U R E
If you do not exclude yourself form the Settlement Class
and payments of fees, costs, and expenses incurred in calcu
lating. administering and distributing Settlement benefits); and
(2) any interest or other income earned by the Cash Settle-
,NSURANCE PREMIUMS' A™
i
quest, the dale o f receipt shall govern Class M em bers who
do nut tim ely seek exclusion shall be bound bv any order)»)
maining from the Cash Settlement Fund (after distributions
to the Settling Class Members, any awards o f attorneys' fees
mem Fund after the Funding Date, net o f income taxes, if
NOTE. THE WOODMEN OF THE WORLD/OMAHA WOODMEN LIFE INSURANCE SOCIFTY IN V O l V F H
S I K
delivery than United States M ail is used for an exclusion re
uted to the United Negro College Fund: ( I ) any amount re
’ ' 0 0 D U E N 0 F ™ E'
PLEASE READ THIS NOTICE CAREFULLY SINCE IT MAY AFFECT YOUR LE G A L R IG H T S y h ii mav re cw
TITLED TO SHARE IN THE PROCEEDS OF THIS PROPOSED CLASS ACTION SETTLEMENT THIS N O T IC F
TELLS Y° U
COVERED BY THE SETTLEMENT AND GENERALLY DESCRIBES THE LITIGATION THE
POTENTIAL BENEFITS OF THE PROPOSED SETTLEMENT AND YOUR LEGAL RIGHTS
UTIGATI0N' ™ E
as set forth above, and you wish to share in the proceeds of
the Cash Settlement Fund and receive other benefits as set
any A ll contributions and distributions o f U N C F under these
forth above, you must submit a completed and timely Proof
provisions shall be subject, at UNCF, to the condition that
a t Claim Form no later than July 15. 1995.
these funds shall be made available by U N C F on a first prior
you have filed and served any objections pursuant to this N o
ity basis to Settling Class Members, on their own behalf and
tice, you w ill be barred from sharing in the distribution o f
proceeds of the Settlement Fund if you have not requested
or heir at law, to assist such persons in attending the college
exclusion from the Class and you fail to submit a properly
o f their choice. I f no such persons apply, or if the funds are
completed and timely Proof o f Claim form.
IMPORTANT
I f you received this notice in the m ail, a Proof o f Claim
tribute them as scholarship grants to other African-American
form is enclosed
Woodmen certificate holders
per or other publication, and you would like a Proof o f Claim
ALL SETTLING CLASS MEMBERS WHO DO NOT TIMELY EXCLUDE THEMSELVES FROM THE I AW^lllT wn I
BE BOUND BY THE PROPOSED SETTLEMENT IF IT IS APPROVED BY THE COURT
If you are reading (his notice in a newspa
C L A IM S ^ L ^ ^ A S F ^ Y Q L 0 0 NQT
form, you may obtain one by calling, toll-free. 1-800-927-
2987 or by written request addressed to Class Counsel You
FOR MORE INFORMATION CALL 1-800-927-2987.
ERUM TH E S E T T L E M E N T O F T H E CLASS A C T IO N
must mail your Proof of C laim form, or send written requests
for a Proof o f Claim form to:
This notice is given pursuant to an Order o f the United
States District Court for the Souihem District o f Mississippi
not request exclusion from the Settlement Class, then in re
turn for the settlement benefits outlined above vou w ill be
Class Counsel
II the Proposed Settlement is approved, and if you do
nation on the basis of race or any other protected status for
many years. In 1992 Woodmen supplemented that policy with
Jackson Division (the "Court” ), dated April 28, 1995, condi
Steven A. Martino, Esq.
One Shell Square
Box 46
a proactive plan to become a more diverse organization. An
Equal Access Plan was adopted to focus increased attention
giving Woodmen a General Release
On August 3, 1995, the Court w ill hold a Fairness Hear
ing at the Federal Courthouse located at 245 East Capitol
on m inority members and recruiting activity, particularly
within the African-American community. Woodmen asserts
thal this diversity initiative is achieving positive results and
against Woodmen, and against certain additional releasees as
defined in the Stipulation, involving, relating to. arising out
In your written request, you must include your name and your
o f or affecting the application for, underwriting of. purchase
current address
Street, Jackson, Mississippi, (the "Fairness Hearing") so the
Court can determine whether the Proposed Settlement is fair,
has the full support o f Woodmen's Board o f Directors and its
of, or the failure to receive or enjoy benefits under or in con
The Proof o f Claim form is designed so that you may
Executive Officers.
junction with, insurance issued by Woodmen. This General
tionally certifying a class action for settlement purposes on
behalf o f the Settling Class Members as defined above.
reasonable and adequate, and whether the Court should enter
final judgment approving the Settlement Agreement and dis
miss with prejudice the action against Woodmen. The Fair
ness Hearing w ill also provide the Court the opportunity to
neys fees and reimbursement o f expenses in connection with
the prosecution o f this action, and individual awards to Class
Release w ill include all kinds o f claims that you may have
against Woodmen relating to Woodmen insurance, including,
for example, a claim for alleged intentional and deliberate
tance. at no charge to you, by calling I -808-927-2987 If you
desire legal assistance, you are free to retain an attorney of
theft by any Woodmen employee, agent, independent con
your choice.
At the same time. Woodmen asserts thal it remains com
mitted to its diversity initiative among its members, consis
D E S C R IP T IO N O F T H E CLASS A C T IO N
A.
W hile Woodmen denies any wrongdoing or liability with
ment to come forward, provide information about such a l
leged conduct, and receive fair compensation.
ther notice.
D E F IN IT IO N O F T H E CLASS
tent with its Equal Access Policy, which is to seek qualified
For purposes o f settlement only, the Court has condi
members on a nondiscriminatory basis and to provide all
members with equal access to and allow their participation in
tionally certified a class action against Woodmen o f the World/
Omaha Woodmen Life Insurance Society ("Woodmen” ) on
Woodmen's lodge system, lodge events, fraternal benefits and
behalf o f the class defined as "all African-American/black
all other fraternal activities on a nondiscriminatory basis
persons who were issued insurance by Woodmen, paid
Woodmen insurance premiums, and/or paid Woodmen lodge
T H E PROPOSED S E T T L E M E N T
The detailed terms o f the Proposed Settlement are set
forth in detail in a Stipulation o f Settlement dated April 28.
dues on or before April 30, 1995, and who claim to or alleg
edly have been injured or have suffered damage as a result of
1995 (the "Stipulation"), which has been filed with the Court.
Woodmen's allegedly discriminatory practices or policies."
B.
The terms are summarized in this Notice.
T H E N ATUR E O F T H E A C T IO N
States District Court for the Southern District o f Mississippi
against Woodmen The class action plaintiffs ( “Class Repre
1-800-927-2987 if you have any further questions
sentatives"), Lorene Nealy and Pamela Mathews, are certifi
cate holders o f Woodmen. The Com plaint, as amended,
A.
CASH PAYM ENT
The Proposed Settlement, if approved by the Court, w ill
alleges that Woodmen engaged in wrongful conduct in refus
result in a cash payment for the benefit of the Class o f a total
ing to afford the Class Representatives and members o f the
class (lie full benefits o f the terms and conditions o f their con
tracts as certificate holders o f Woodmen on the basis o f race;
and that Woodmen intentionally refused to afford the Class
Representatives and members o f the class the same right to
age o f 18). incompetents (persons who are mentally or physi
bers, or their legal representatives or heirs, for payment of
cally incapacitated), or deceased Settling Class Members on
benefits ordinarily payable under any certificate o f insurance
whose behalf you are submitting a claim.
issued by Woodmen to such Settling Class Member, provided
all payment obligations have been met by that Settling Class
Proof o f Claim form must be signed by the claimant, or by
the claimant's parent, guardian or legal representative
Member.
F A IL U R E T O T I M E L Y F IL E A P R O O F O F C L A IM
F O R M W IL L R E S U L T IN Y O U R C L A I M B E IN G D IS
C L A S S R E P R E S E N T A T IV E S A N D C L A S S C O U N S E L
were afforded to white certificate holders o f Woodmen. The
Complaint also alleges that Woodmen committed fraud and
fraudulently concealed its wrongful conduct from its A fri
F R O M T H E C A S H S E T T L E M E N T F U N D AS W E L L AS
O T H E R N O N -C A S H B E N E F IT S . IF Y O U D O N O T R E
Michael G Crow; and Charles Victor McTeer
The Class Representatives and Class Counsel believe that
Class Representatives and Class Counsel have entered into
the Stipulation after weighing its substantial benefits against
the probabilities o f success or failure, and the long delays
that would be likely if the case proceeded to trial.
ing attorneys' fees. At the Fairness Hearing, Class Counsel
w ill request the Court to award attorneys' fees in an amount
F O R E V E R B A R R E D A N D C A N N E V E R A G A IN BE
be paid from the $18,000.000 Cash Settlement Fund
w ill be paid from the Cash Settlement Fund. The following
amounts w ill also be paid from the Cash Settlement Fund:
( I ) Each Settling Class Member shall be reimbursed from
purposes does not mean that the Class Representatives would
have been successful had the case gone to trial. The Court
the Cash Settlement Fund monthly dues at a rate o f $ I 00
has made no such determination, and the proposed Settlement
per month from the date o f certificate issuance until
is not to be construed as an expression o f any opinion by the
April 30, 1995, for each month that dues were paid to
Woodmen for membership in Woodmen's lodge and fra
Court as to the merits o f any o f the claims asserted as"nst
Woodmen.
R ELA TED A C T IO N S AND S IM IL A R C L A IM S
(2)
Several other actions were previously pending against
A N D D IS M IS S A L O F Y O U R C L A I M B Y T H E C O U R T .
T H IS M E A N S T H A T I F Y O U D O N O T F I L E A P R O P -
E R L Y F IL L E D O U T P R O O F O F C L A IM F O R M NO
available for distribution shall be the Cash Settlement Fund
o f $18,000,000, reduced by any award by the Court o f Class
B R O U G H T IN T H IS O R A N Y O T H E R C O U R T .
F O R F U R T H E R I N F O R M A T IO N
T H IS N O T IC E IS O N L Y A S U M M A R Y . The alloca-
lion plan for cash and insurance benefits set forth above was
derived from the best information available to Class Counsel
ta N D IIW N iiU F T H L S L n L L M L N I
Under the Stipulation, Woodmen w ill have an opportu
nity to cancel the settlement if it is not approved without modi
fication by the Court or any appellate court. Woodmen w ill
also have the right to cancel the settlement if it concludes
that too great a number o f Class Members have requested
exclusion
their having served as Class Representatives, which awards
amended, and has asserted affirmative legal defenses. The
fact that the Court has certified a class action for settlement
Y O U R O N L Y O P P O R T U N IT Y T O M A K E A C L A I M ,
A N D F A IL U R E T O T IM E L Y F IL E A P R O O F O F C L A IM
F O R M W IL L R E S U L T IN F O R F E IT U R E O F R IG H T S
L A T E R T H A N J U L Y 15,1995 , Y O U R C L A I M W IL L BE
reimbursement of (he costs and expenses, all o f which would
tatives be awarded up to $50,000 each in connection with
Q U E S T E X C L U S IO N F R O M T H E S E T T L E M E N T O F
T H E C L A S S A C T I O N , T H I S S U IT R E P R E S E N T S
There has been no agreement between the parties regard
proval o f the Settlement. The "Net Cash Settlement Fund"
tionally, Class Counsel w ill request that the Class Represen
can-American/black certificate holders
Woodmen denies all allegations o f the Complaint, as
This is a standard provision to safeguard the set
at the time this Stipulation was entered into. Neither Class
Counsel nor Woodmen know how many Settling Class Mem
bers in categories (3), (4) and (5 ) w ill submit Proof o f Claim
forms. I f you would like further information in the form o f
estimated ranges o f cash and insurance benefits based on ac
tual and projected responses, you may call Class Counsel at
1-800-927-2987
tling company from settling one class action and then facing
the prospect o f another.
Furthermore, the complete terms o f the Settlement Agree
ment, and all other pleadings and relevant documents in this
litigation, are on file and may be examined or copied during
RI GHTS A j NDQFTlQfgQF l i E T l l I NG CLASS MEMBERS
1. You M ay Remain a Settling C la n Member, and
your interests as a member of the Settlement Class wUI be
represented by the Class Representatives and C la n Coun
sel, at no cost to you Individually. You w ill be bound by
regular business hours al the offices o f the Clerk o f Court.
United States District Court for the Southern District o f Mis
sissippi, 245 E. Capitol Street, Jackson. Mississippi 39201.
IF Y O U H A V E A N Y Q U E S T IO N S R E G A R D IN G T H IS
ternal system and for the benefits associated with thal
any judgment or final disposition o f the litigation, and may
N O T IC E , T H E P R O O F O F C L A I M F O R M O R A N Y
membership;
Each Settling Class Member whose certificate was is
participate in the benefits available as a member o f the Settle
M A T T E R S T H A T W I L L B E C O N S ID E R E D A T T H E
ment Class provided that you submit a Proof o f Claim Form
F A IR N E S S H E A R IN G , D O N O T C O N T A C T T H E
sued by Woodmen on or after June 1, 1992, and who was
as set forth below.
C L E R K O F T H E C O U R T . A D D R E S S A N Y Q U E S T IO N S
L
You May Remain a Settling Class Member and
Either Represent Yourself or Hire a Separate Attorney to
Represent You at Your Own Cost. I f you wish to represent
C A L L 1-800-927-2987.
Woodmen in state courts in Mississippi and Alabama ( “State
Court Actions"), which actions arose out o f the similar fac
not placed in a Holding Lodge, (i.e„ a “5200" series lodge
tual allegations as did this class action, but asserted claims
or any lodge to which a Settling Class M em ber was
for state law fraud as opposed to racial discrimination These
State Court actions were filed on behalf o f certain individual
wrongfully assigned on the basis o f race), shall receive
$300.00 from the Cash Settlement Fund;
plaintiffs who were represented by the same attorneys who
After these distributions, the Net Cash Settlement Fund will
are also Class Counsel in this case. Settlements in the State
Court Actions, as well as settlements o f similar claims by
ner:
certain other individuals represented by Class Counsel who
(3)
be allocated to Settling Class Members in the following man
T O CLASS C O U N SE L A T T H E ADDRESS B E LO W O R
Class Counsel
Steven A. Martino, Esq.
yourself or to hire a separate attorney, you or your attorney
must file an Entry o f Appearance with the Clerk o f Court and
One Shell Square
send a copy o f Class Counsel and counsel for Woodmen, al
Box 46
the addresses set forth below. Such Entry o f Appearance must
New Orleans. Louisiana 70139
Each Settling Class M ember whose certificate was is
be filed by July 15, 1995.
had no« yet filed suit, were negotiated by Class Counsel and
sued by Woodmen prior Io June I, 1992, and who was
placed in a Holding Lodge, as defined above, shall re
3. You May Remain a Settling Class Member and
Object to the Settlement. Any Settling Class Mem ber who
Jackson. Mississippi
Woodmen at the same lim e as the class settlement. In con
junction with the negotiation o f the settlement o f the class
ceive a per capita share o f 50% o f the Net Cash Settle
does not elect exclusion from the Settlement Class and who
By Order o f the Court
Judge W illiam H. Barbour. Jr
action and the State Court Actions, Woodmen and a partner
o f one o f the law firms that is Class Counsel also negotiated
(4)
separate settlements o f several other actions against Woodmen
in w hich the p la in tiffs alleged u n la w fu l treatm ent by
Woodmen, but not on the basis o f race.
Upon request, the
objects to the Proposed Settlement must mail such objections,
along with all other papers or briefs he or she wishes the Court
sued by Woodmen prior to June I, 1992, and who was
to consider, to the Clerk o f Court at the address set forth be
low, on or before July 15, 1995. If the person filing the ob
receive a per capita share o f 377)% o f the Net Cash Settle
ment Fund;and
DATE: April 28, 1995
A form is provided below for you to use to opt-out or exclude
jection intends to appear personally at the August 3, 1995
yourself from this Settlement Class Action Please mail this
form to The Woodmen Litigation, c/o Clerk of the Court at
Fairness Hearing described above, he or she must file with
the address provided above.
Each Settling Class Member whose certificate was is
the Clerk o f Court, on or before July 15, 1995, a Notice of
sued by Woodmen on or after June 1, 1992, and who was
placed in a Holding Lodge, as defined above, shall re
Any Settling Class Member who does not
I f you wish to explain why you have decided to opt-out, please
S E T T L E M E N T N E G O T IA T IO N S A ND TH E
P O SITIO N S O F T H E PARTIES
file objections in the lime and manner described above is for
include your explanation in the space provided on the form
A ll o f the extensive settlement negotiations were con
ceive a per capita share o f 127:% o f the Net Cash Settle
ment Fund.
ing these settlements.
D.
ment Fund;
Each Settling Class Member whose certificate was is
not placed in a Holding Lodge, as defined above, shall
Court may permit disclosure o f additional information regard
BARRED FROM
S H A R IN G IN T H E D IS T R IB U T IO N O F P R O C E E D S
Nealy and Pamela Mathews, as Class Representatives to rep
of $ 18,000,000 ( the “Cash Settlement Fund” ), upon final ap
and expenses o f calculation, administration and distribution
of the cash and non-cash benefits o f the Settlement. Addi
Each claimant's
resent all Settling Class Members. The Court has also desig
nated as Class Counsel Steven A. M artino; Don Barrett;
not exceeding 28% of the total value o f the cash and non
cash benefits afforded to the class by the Stipulation, and for
curred in prosecution o f the class action, and the fees, costs
A L L O W E D A N D Y O U R B E IN G
The Court has designated the following Members, Lorene
Counsel's attorneys’ fees, reimbursement o f all expenses in
use real property, i.e„ to use the local Woodmen lodges, as
A separate Proof of C laim form must be completed for
each individual claimant, including minors (persons under the
tractor, or representative o f the premiums paid or cash value
accrued on a certificate o f Woodmen insurance This Re
lease, however, w ill not affect claims o f Settling Class M em
the Proposed Settlement is fair, reasonable and adequate
If the Proposed
Settlement is finally approved by the Court, these w ill be your
benefits if you do not request exclusion from the Settlement
Class. As this is only a summary, you are encouraged to call
In August 1993, a class action was filed in the United
New Orleans, Louisiana 70139
respect to the allegations made by (he Class Representatives
and the individuals in the Related Actions, it takes these alle
who feel that they have been subjected to discriminatory treat
Representatives This hearing may be continued without fur
This General Release
w ill release any and all claims you may have or have had
complete it yourself If you have any questions about the
Proof of Claim form or procedure, you may request assis
gations seriously and would like to correct any problems which
may exist. Entering into this Stipulation w ill enable those
consider Class Counsel's application for an award o f attor
C.
Whether or not
on behalf of their children and any other designated relative
not exhausted by scholarship grants to such persons within
30 years, then U N C F may make the funds available and dis
(5)
ever foreclosed from raising any objection to the Settlement.
below. You are not required to include any explanation, how
Any Settling Class Member whose objection is overruled w ill
ever, in order to opt-out and exclude yourself from the Settle
I f any Settling Class Mem ber falls into more than one of
still be bound by any judgment or final disposition o f the liti
ment Class Action.
categories (2), (3 ), (4 ) and (5) above, he or she w ill be con
gation. Copies o f all objections (including copies o f all other
ducted by Class Counsel and Woodmen at arm's length and
in good faith.
The Class Representatives contend that all
claims made by them in the Action have merit. Nevertheless,
the Class Representatives and Class Counsel recognize and
have taken into account the uncertainly and the risk of the
sidered to belong only to thal category that w ill result in the
papers or briefs the Settling Class Member wishes the Court
T h e re b y elect to exclude myself from the Woodmen S e t t l T
highest cash award to thal Settling Class Member.
to consider), and Notices o f Intent to Appear that are mailed
to the Cldrk of Court must also be mailed to Class Counsel
I ment Class Action:
outcome o f any litigation, especially complex litigation such
B.
as this; the difficulties and risks inherent in the trial o f such
The Proposed Settlement also provides that Woodmen
w ill pay $ 1,600,000 to fund the purchase of paid-up whole
an action; and the economic benefits to Class Members made
Intent to Appear
PAID-UP IN SURANCE
and to counsel for Woodmen at the following addresses:
Class Counsel
available through prompt implementation o f the Settlement
life insurance ( "Paid-Up Insurance Fund"). This insurance
Steven A, M artino, Esq
Agreement as explained below
w ill be ..sued only Io Settling Class Members falling within
One Shell Square
Subject to the approval of
the Court pursuant to Rule 23 o f the Federal Rules o f C ivil
categories (3), (4), and (5) above, and shall be distributed to
Box 46
Jackson, Mississippi
each category based on the percentages set forth above for
New Orleans, Louisiana
39225-2687
lieve that the terms o f the settlement w ill provide substantial
each category.
70139
benefits to the Class Members, and the Class Representatives
and Class Counsel deem the settlement to be fair, reasonable,
distributed equally among the Settling Class Members A ll
future disputes relating to or involving the Paid-Up Insur
adequate, and in the best interests o f the Class Members.
ance w ill be determined by binding arbitration under the Fed
Woodmen, while continuing to deny all allegations of
wrongdoing or liability whatsoever, but bearing in mind the
burden, inconvenience, risk and expense o f litigation, desires
to settle and terminate all claims against it, without in any
way acknowledging any fault or liability. Woodmen further
desires to pul to rest forever all claims which have or could
have been asserted against it by the Class Representatives, or
any member of the Class who has not tim ely excluded herself
or him self from the Class.
Woodmen asserts that it has had a policy o f nondiscnmi-
eral Arbitration Act. 9 U .S.C. f I . f l sfij.
MEASE nU N TLIC IILV :
NAME
ADDRESS:
I CITY:
I PHONE: ( ___
4. If You Choose to Remain a Settling Class Mem
ber (under Options 1,2, or 3 above). You Must Complete
a Proof of Claim Form to Receive Any Benefits. I f you
O T H E R BENEFITS T O T H E CLASS
In addition. Woodmen w ill establish a fund for the en
hancement and improvement o f its Equal Access Plan in the
amount of $1.000,000 over a five-year period ($200,000 per
year). This fund is intended for use in hiring staff, develop
any o f the benefits afforded by the Proposed Settlement, you
)
| CLASS M E M B E R :
__________
I S O C IA L S E C U R IT Y N U M B ER :
must complete the appropriate Proof o f C laim Form (see be
low) and execute an appropriate release, before any benefits
w ill be afforded to you or cash payments made.
5.
You May Request Exclusion From the Settlement
ing systems, conducting surveys, training Woodmen associ
Claas. I f you elect to be excluded from the Settlement Class,
ates and lodge officers in order to enhance the implementation
o f Woodmen's Equal Access Policy throughout its lodge and
you w ill not be bound by any judgment, disposition or settle
fraternal system. Determination o f how these funds w ill best
- S T A T E : ____ Z IP CODE:
I S IG N A T U R E O F
decide to remain a Settling Class Member, in order to receive
C.
DATE:
P.O. Box 22687
Procedure, the Class Representatives and Class Counsel be
Within each category, the insurance w ill be
I
Counsel for Woodmen
Lawrence J. Franck, Esq.
ment o f the class action, but you will also bave no right to
receive any cash or other benefits offered by this Settle-
' lOPTIONALl
I I have decided to opt-out o f the Settling Class because
I
*
P age B3
You w ill retain and be free to pursue any claims you
supervision, w ill be made by Woodmen with the advice o f
Class Counsel pursuant to an Agreement to be entered into
IMPORTANT NOTICE OF PROPOSED SETTLEMENT OF
CLASS ACTION AND FAIRNESS HEARING
*