IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ...polyetherpolyolsettlement.com/docs/Motion...

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

____________________________________ ) IN RE: URETHANE ANTITRUST ) MDL 1616 LITIGATION ) ____________________________________) ) Civil No. 04-md-1616-JWL-JPO This Document Relates To: ) The Polyether Polyol Cases ) ____________________________________)

CLASS PLAINTIFFS’ MOTION TO APPROVE DISTRIBUTIONS FROM THE DOW SETTLEMENT FUND

I. INTRODUCTION

1. The claims process is now complete. By any measure, the process has been a

success. Claims were submitted by every one of the top 75 class members and 149 out of the top

150 class members. Indeed, claims were submitted by class members reflecting more than 95%

of the Recognized Losses estimated by Plaintiffs’ damages expert, a remarkably high percentage.

The high claims participation makes all the more impressive that participating Class Members

will recover more than 100% of their Recognized Loss, as described more fully below.

2. Now that the claims process is complete, Class Plaintiffs (“Plaintiffs”), by their

undersigned counsel, hereby respectfully move this Court to approve: (a) the procedures used,

the actions taken, and the determinations made by the Settlement Administrator, Garden City

Group, LLC (“GCG”), and by the undersigned Class Counsel relating to the administration of,

and proposed distributions from, the settlement fund established in accordance with the

Settlement Agreement with The Dow Chemical Company as approved by this Court (the “Dow

Settlement Fund”), including the administrative determinations of the Settlement Administrator

and Class Counsel in accepting, revising, and rejecting claims in connection therewith; (b) the

Case 2:04-md-01616-JWL Document 3281 Filed 11/06/17 Page 1 of 18

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payments of certain invoices associated with claims administration; and (c) distribution of

settlement funds to approved claimants.

II. BACKGROUND

3. On July 29, 2016, the District Court granted final approval to the Dow Settlement

(Dkt. No. 3274), and also approved Plaintiffs’ proposed Plan of Allocation for the Dow

Settlement Fund (Dkt. No. 3275).

4. The Notice and Claims process, described in detail below, is now complete, and

the Settlement Administrator is prepared to distribute the net Dow Settlement Fund to the Class,

on approval by the Court.

5. The current total available balance of the Dow Settlement Fund is $556,980,141

as of the September 30, 2017 Summary of Accounts. Declaration of Angela Ferrante, attached

hereto as Exhibit 1 (“Ferrante Decl.”), ¶ 46.

6. For the reasons set forth below, Class Counsel recommend distributing the

Settlement Fund in two installments: (i) 85% to be distributed as soon as practicable after court

approval and the running of the applicable appeal period; and (ii) the remaining approximately

15% at an appropriate and prudent future date. Based thereon, Class Counsel recommend

transferring $473,433,120.57 into a new Distribution Account for purposes of making the first

installment of payments. The monies in the Distribution Account will be distributed to claimants

pro rata based on their Recognized Loss Amounts as described below and in accordance with

the Estimated Recommended Schedule of Distribution, attached as Exhibit D-1 to the Ferrante

Declaration.

7. The Estimated Recommended Schedule of Distribution is “estimated” because

percentages and distribution amounts could change before the actual distributions. For example,


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Court-ordered changes to the treatment of specific claims or the acceptance of any additional

claims could affect percentages and distribution amounts. Should percentages or distribution

amounts change, Plaintiffs will submit a revised recommended schedule of distribution to the

Court, as they did in the Bayer and the BASF and Huntsman Settlement distribution processes

(Dkt. Nos. 1853-1; 2546-1).

III. CLAIMS ADMINISTRATION PROCESS

8. With the Court's approval, Class Counsel engaged Garden City Group (“GCG”)

to act as the Settlement Administrator, under the supervision of Class Counsel. GCG is

experienced in handling class action settlement notice programs and claims administration.

9. In its capacity as Settlement Administrator, GCG was authorized to: prepare and

mail proof of claim forms to Class Members; receive, review and enter data regarding the claim

forms that were filed; audit claims when appropriate and necessary; recommend the dollar

volume of eligible (and, where appropriate, ineligible) purchases as to each claim filed; and

otherwise assist Class Counsel in the claims administration process. GCG’s efforts are

summarized in the Ferrante Declaration.

10. The Plan of Allocation (the “Plan”) called for sending Class Members

individualized Proof of Claim Forms that showed the following:

Direct Purchase Amounts: The Class Member’s total net purchases of Polyether Polyol

Products between November 24, 2000 and December 31, 2003 (the “Damages Period”) in

dollars, directly from all of the Defendants. Direct Purchase Amounts were reported by

product category (i.e., MDI, TDI, polyols, and systems), as derived from sales data

provided by the Defendants.


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Overcharge Percentage: The Class Member’s overcharge percentage for each product

category, as determined by Plaintiffs’ expert on damages.1 See Plan § 1 & Claim Form

Part 1.

Each Class Member’s Recognized Loss Amount is calculated by multiplying its Direct Purchase

Amounts by its Overcharge Percentage in each product category and then adding together the

resulting amounts, the total being that Class Member’s Recognized Loss Amount.2 As explained

in the Plan, claimants’ awards are to be based on their Recognized Loss Amounts. See Plan § 3.

11. The Defendants’ sales data identified nearly 2,000 Class Members with positive

purchase data during the Damages Period. For each such Class Member, InfoTech obtained by

product category (i) the Class Member’s Direct Purchase Amounts from the database of class

member purchases constructed from Defendants’ sales records and (ii) the Overcharge

Percentage from the damages model constructed by Dr. McClave for presentation at trial.

12. InfoTech then prepared a database consisting of (i) Class Member names; (ii)

most current or best street addresses as derived from Defendants’ sales data, the work performed

during the Bayer and BASF/Huntsman settlement distributions, and the settlement notice

programs; (iii) Direct Purchase Amounts for each Class Member for each product category

during the Damages Period; and (iv) Overcharge Percentages for each Class Member for each

product category.

1 The overcharge percentage is bounded by the Interquartile Range (“IQR”) for each modeled product

overcharge applicable to that customer so as to compensate claimants based on their estimated damages while eliminating outlier estimates and excessive variability among claimants. See Memorandum in Support of Class Plaintiffs’ Motion for Approval of Their Plan of Allocation and Distribution of the Dow Settlement Fund at 5-6 (Dkt. No. 3249).

2 Plaintiffs’ expert estimated each Class Member’s overcharge percentage to between 14 and 16 decimal points, but the claim forms were simplified to identify overcharge percentages to two decimal points. Total Recognized Loss herein is being calculated based on Plaintiffs’ expert’s more precise estimates. Therefore, the Recognized Loss amounts listed on the Schedule differ slightly from the calculations based on the figures in the claim forms.


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13. GCG, in consultation with Class Counsel and InfoTech, created and sent

personalized, pre-printed proof of claim forms to the members of the Class identified in

Defendants’ purchase data. Ferrante Decl. ¶ 6. The personalized proof of claim forms specified

the Direct Purchase Amounts and Overcharge Percentages for each product category.

14. The proof of claim forms instructed claimants that they had two options: (a) they

could accept the pre-printed Direct Purchase Amounts appearing on the claim form, in which

case claimants did not have to provide any additional proof of their purchases, or (b) they could

claim different purchase amounts, in which case claimants were instructed to submit adequate

proof that they had purchased the claimed amount of Eligible Products directly from the

Defendants in the United States or its territories during the Damages Period. Ferrante Decl. ¶ 6.

The Claim Form explained that although a claimant’s Direct Purchase Amounts may be

contested and adjusted if supported by adequate documentation, the customer-specific

Overcharge Percentage could not be challenged. See Plan § 1 & Claim Form Part 5, Instructions

4, 6 & 7. A sample proof of claim form is attached as Exhibit A to the Ferrante Declaration.

15. GCG sent personalized claim forms showing no eligible purchases to entities that

had Recognized Loss Amounts in connection with the Bayer and/or BASF/Huntsman settlement

distributions but did not have Eligible Purchases for purposes of the Dow settlement distribution,

either because of changes in the list of Eligible Products or the duration of the period of

eligibility. GCG also sent blank claim forms to anyone who requested one during the course of

the litigation. This ensured that such Class Members had notice of the claims process and could

submit a claim with corrected amounts if they had, in fact, purchased Eligible Products during

the Damages Period. Ferrante Decl. ¶ 7.


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16. The proof of claim form instructed all claimants to return their claim forms by

February 27, 2017.3 Ferrante Decl. ¶ 6; see Claim Form, Part 1 and Part 5, Instruction 1.

17. The Ferrante Declaration, to which Plaintiffs respectfully refer the Court, provides

a detailed description of the claims administration process. Specifically, Ms. Ferrante describes

the procedures and criteria by which GCG reviewed and evaluated claim forms; GCG’s

communications with claimants and Class Counsel to evaluate and audit claims; GCG’s

procedures for, and efforts in, identifying deficiencies in submitted claim forms, notifying

claimants of the deficiencies, and allowing claimants to correct and cure the identified

deficiencies; the process by which GCG and Class Counsel determined whether to recommend

accepting, rejecting, or modifying each claim; GCG’s written notifications to claimants whose

claims are being recommended for rejection or reduction and the process and deadline for

objecting to that recommendation; and how GCG calculated the Recognized Loss Amount for

each claim and the resulting Estimated Recommended Schedule of Distribution.

18. More than 1,500 claim forms were submitted. After eliminating duplicative,

ineligible, and deficient claims, GCG and Class Counsel recommend that 865 claims be

approved for payment. Ferrante Decl. ¶¶ 20, 43.

19. The Defendants’ Purchase Data as listed on the preprinted claim forms (the

“Undisputed Claims”) was accepted by 783 Claimants. Class Counsel and GCG treated the

Undisputed Claims as presumptively approved for payment. Ferrante Decl. ¶ 22.

20. A number of Claimants returned claim forms that did not specify the amount of

claimed purchases. Many of these were “placeholder” claims, which are claims filed before the

claimant or someone acting on behalf of the claimant has determined the extent – or perhaps

3 In accordance with the Plan of Allocation (Dkt. No. 3248-1), Class Counsel instructed GCG to accept late

claims if doing so would not delay the claims administration process. Class Counsel is not recommending that any claims be denied on the basis that they were not submitted by February 27, 2017.


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even the existence – of Eligible Purchases. GCG sent a Notice of Claim Deficiency (“Deficiency

Notice”) to all claimants who did not specify purchase amounts, informing them that if they

failed to submit purchase numbers and supporting documentation, their claims would be rejected.

The majority of the placeholder claims were withdrawn or abandoned. The claims that

responded with purchase numbers were reviewed as disputed claims as set forth below. Ferrante

Decl. ¶ 23.

21. GCG received more than one hundred claim forms disputing the purchase

information reflected in the Defendants’ sales records, claiming either that (i) the claimant had

made more purchases than the positive purchase numbers on the claim form they received or the

products on their claim form were misclassified (e.g., listed as systems instead of MDI); or (ii)

they had made eligible purchases though the Defendants’ data showed no Eligible Purchases

during the Damages Period (“Disputed Claims”). Ferrante Decl. ¶ 24.

22. The Disputed Claims were first reviewed for completeness. Disputed Claims that

did not provide documents to support claimed purchase amounts were sent a Deficiency Notice

requiring that documentation be submitted to justify the additional claimed amounts. Many of

these Disputed Claims failed to supplement their claim with supporting documents or were

affirmatively withdrawn by the Claimants after they received Deficiency Notices, and as a result,

are recommended for rejection. Claims that provided supporting documentation were considered

for further review to determine eligibility. Ferrante Decl. ¶ 25.

23. All remaining Disputed Claims were then reviewed and evaluated individually to

determine whether the Claimant had sufficiently proven qualifying purchases in the amounts

claimed. In making this determination, GCG and Class Counsel considered, inter alia, the

following factors: (i) whether the Claimant had demonstrated that it purchased products within


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the Damages Period; (ii) whether the purchases were foreign or U.S. purchases; (iii) whether the

Claimant had demonstrated that the products were purchased directly from the Defendants; (iv)

whether the Claimant had demonstrated that the products purchased were Eligible Products

within the Class definition; and (v) the extent to which the Claimant had documented the

amounts of purchases. In many instances, GCG and Class Counsel searched Defendants’

Purchase Data, often asked InfoTech to perform additional research, and often conducted

independent research into the reasons for discrepancies between the amounts in Defendants’

Purchase Data and the amounts claimed by Claimants. Ferrante Decl. ¶ 26.

24. Class Counsel and GCG tried to resolve as many of the issues relating to Disputed

Claims as possible through phone calls and e-mails with Claimants. This approach was

extremely effective in streamlining the claims review process, and numerous Disputed Claims

were resolved in this manner. Ferrante Decl. ¶ 27.

25. Where the informal process was not successful or was deemed unlikely to be

successful, GCG sent a personalized letter to the Disputed Claimant whose claimed purchase

amounts were to be reduced or rejected, explaining the basis for reduction or rejection and

providing the Claimant with another opportunity to submit supplemental proof or argument. Id.

Some of the Claimants did not respond with any supplemental proof or argument, or

affirmatively withdrew their claims and, as a result, are recommended for rejection.

26. Many Disputed Claimants responded to the Deficiency Letters with more

information. All responding Claimants’ files, including the new information, were re-reviewed.

Where Claimants were able to produce sufficient proof of the amounts claimed, their Claims are

being recommended for approval. Id.


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27. A further aspect of the claims review process involved the submission of

duplicative claim forms filed by the same Claimant. GCG notified these Claimants of the

duplication and informed them that only one Claim Form could be approved for payment. GCG

and Class Counsel designated one of the submitted Claim Forms as the primary claim and

provided the Claimant with an opportunity to respond with additional information, including

with respect to the preferred address for communications and receipt of the settlement proceeds.

Ferrante Decl. ¶ 31.

28. In some instances, GCG received competing claim forms from two or more

different Claimants with respect to a particular claim, causing a potential duplication of

recoveries. In each such instance, GCG and Class Counsel communicated with the competing

claimants and suggested that the claimants agree between themselves as to which claimant is the

rightful owner of the claim or as to an appropriate allocation of the claim. Class Counsel and

GCG tried to resolve as many of these conflicts as possible through phone calls and e-mails with

the competing claimants. In some instances, they provided the claimants with additional

information as to the purchases at issue in order to clarify who made the purchases. In other

instances, they requested from the claimants the legal and factual bases for their claims. This

approach was extremely effective in resolving conflicts, and in almost all of these instances, the

competing claimants have successfully resolved ownership and/or allocation of the claim.

Ferrante Decl. ¶ 35.

29. In only one instance (Reference # 50), the claimants have not resolved fully the

ownership and/or allocation issues. With respect to this claim, the competing claimants have

agreed that a part of the claim properly is attributed to one of the claimants and so only the

remaining portion of the claim is in dispute. GCG and Class Counsel will continue to work


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towards resolving this conflict through the date of the Distribution Hearing. To the extent that

this claim remains unresolved at the time of the Hearing, Class Counsel will recommend to the

Court that the claim be approved based on the full amount in Defendants’ Data; that the amounts

that are not in dispute be paid as agreed; and that the amounts that continue to be in dispute be

retained in the Distribution Fund until such time as the dispute is resolved, either by negotiation,

mediation or court process. Class Counsel has informed the affected claimants of this proposal,

and they are both agreeable to this recommended approach. Ferrante Decl. ¶ 36.

30. Among the claims received by GCG were five claims submitted by companies

that were not related to any defendant during the Damages Period when their purchases of

eligible products were made but that are currently subsidiaries of defendants.4 For the reasons

stated below, Class Counsel and GCG recommend that these claims be accepted. Ferrante Decl.

¶ 37. The class herein is defined to include all persons and entities who purchased Polyether

Polyol Products directly from a defendant at any time from November 24, 2000 through

December 31, 2003 in the United States and its territories, “excluding all governmental entities,

any defendants, their employees, and their respective parents, subsidiaries and affiliates." While

the class definition excludes defendants and their subsidiaries, it is not clear whether the

exclusion applies to a claimant's current corporate status or to its status at the time the purchases

in question were made. In resolving this ambiguity, Class Counsel placed considerable weight

on the fact that (i) the purchases were impacted by the conspiracy and thus the companies were

overcharged; and (ii) the purchases made by these companies were included in plaintiffs'

damages model and therefore were reflected in the jury's verdict and the settlement with

Dow. Class Counsel recognize, however, that others may weigh factors differently and at least

4 These claims are identified on the Accepted Claims spreadsheet as Reference #11/Claim #692; Reference #16/Claim # 1002764; Reference #17/Claim # 1001266; Reference #35/Claim #1010006; and Reference #67/Claim #1008190.


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one class member has expressed to Class Counsel that any such purchases should be considered

ineligible. Given these circumstances, GCG and Class Counsel concluded that the best course

was to lay out the relevant facts in this motion, allowing any interested parties to submit

argument and enabling the Court to make a final determination as to the eligibility of these

purchases.

31. GCG and Class Counsel recommend that a total of 71 of the Disputed Claims be

approved as follows: 26 for the full amount requested by the Claimant, 8 for an amount greater

than that contained in Defendants’ Purchase Data but less than the full amount requested by the

Claimant, and 37 for the amount contained in Defendants’ Purchase Data (i.e., rejecting just the

additional claimed amount). Ferrante Decl. ¶ 29.

32. In addition, GCG and Class Counsel recommend that 56 Disputed Claims be

rejected in full. Ferrante Decl. ¶ 30.

IV. DISTRIBUTION PROCESS

33. Attached as Exhibit D to the Ferrante Declaration is a list of all the Claims filed.

34. Exhibit D-1 lists the 865 Claims that GCG and Class Counsel recommend be

approved, in whole or in part. Exhibit D-1 lists, for each claim, the Claim Number; the

Reference Number; the Total Recognized Loss Amounts; the Total Estimated Payment Amount

(100%); the Estimated Initial Payment Amount (85%); and a short description of the

circumstances relating to the claim.

35. As stated above, the results of the claims process were extraordinary. Every one

of the Top 75 Class Members (by Recognized Loss Amount) submitted a claim, and 149 of the

Top 150 Class Members submitted claims. Indeed, claims were submitted by Class Members

reflecting 95% of the Recognized Losses estimated by plaintiffs’ damages expert.


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36. Class Counsel is not aware of any claims process that comes anywhere close to

matching the results achieved here.

37. Exhibit D-2 lists 677 claims that GCG and Class Counsel recommend be rejected

in full. Exhibit D-2 lists, for each such claim, the Claim Number; the Reference Number; and a

short description of the circumstances relating to the claim.

38. For privacy reasons, these lists identify Claimants only by Claim Number and

Reference Number. No names, addresses or Taxpayer I.D. numbers are disclosed.

39. All told, GCG and Class Counsel recommend approval of 865 claims representing

a Total Recognized Loss Amount of $519,257,220.68. The September 2017 statement for the

Dow Settlement escrow account shows a total available balance of $556,980,141. According to

the Plan of Allocation, each Approved Claimant shall be allocated a pro rata share of the

Settlement Fund based on its percentage of the Total Recognized Loss Amount, after deduction

of reasonable, anticipated further expenses.

40. GCG and Class Counsel recommend that the Settlement Fund be distributed in

two installments: (i) 85% of the Settlement Fund to be distributed as soon as practicable after the

Court enters a distribution order and the applicable appeal period has run; and (ii) the remaining

approximately 15% of the Settlement Fund to be distributed at an appropriate and prudent future

date.5 The purpose of this approach is to retain flexibility in the event that legitimate corrections

or adjustments need to be made after the initial settlements payments are distributed or any

presently unforeseen claims issues arise. GCG and Class Counsel believe that this approach

5 To the extent that any Claimants appeal the treatment of their claims, GCG and Class Counsel propose

that instead of delaying the distribution to other Class members pending resolution of such appeals, GCG would hold back from the distribution an amount sufficient to pay all such claims in the amounts claimed, in the event that that becomes necessary or appropriate. GCG and Class Counsel will submit an amended Recommended Schedule of Distribution to the Court in that event. If the appealing claimants ultimately do not prevail in full, the extra monies held back would revert to the general Distribution Fund to be allocated to all approved claimants on a pro rata basis.


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provides sufficient back-up to ensure the integrity of the distribution process. Class Counsel

request that the Court authorize a hold back here with the understanding that at an appropriate

and prudent future date, Class Counsel will petition the Court for leave to distribute the

remaining settlement proceeds to valid claimants on the same pro rata basis used for the initial

distribution requested in this Motion.

41. GCG calculated the Estimated Initial Payment Amount for each Approved

Claimant listed on Exhibit D-1 in accordance with the Court-approved Plan of Allocation, and

using an initial Distribution amount of $473,433,120.57. That amount is 85% of the available

balance of the Dow Settlement Fund.6

Ferrante Decl. ¶¶ 45-46.

42. GCG calculated the Total Estimated Payout Amount using a total distribution

amount of $556,980,141, which is the balance in the Dow Settlement Fund as of September 30,

2017. This amount will change as of the time of the final distribution. For example, the amount

will increase based on additional interest earned in the fund, as well as any uncashed Class

Member checks. In addition, GCG has incurred fees and expenses of $76,224.71 between

August 1 and October 15, 2017 that have not yet been billed, and estimates that approximately

$164,000 will be expended in reasonable, anticipated further expenses. These include further

work on the claims and distribution process, including conducting the initial and supplemental

distributions, re-issuing checks as necessary, and other administrative tasks. These expenses also

include expenditures associated with preparing tax forms, paying any taxes due on interest

earned by the Dow Settlement Fund, and funding any unanticipated costs. Ferrante Decl. ¶ 46.

Rather than requesting that the Court set aside a reserve to cover these expenses, Class Counsel

6 The recommended Approved Payment Amounts for Claimants for whom GCG’s initial calculations

returned a pro rata share of less than $500 have been adjusted upward to $500. Class Counsel and GCG recommend that the Court approve $500 as the minimum payment for each Approved Claim.


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recommends that they be paid out of the funds remaining in the Escrow Account and they be

accounted for at the time Class Counsel seeks the Court’s leave for the final distribution.

43. GCG and Class Counsel recommend that the Court approve GCG’s

determinations as set forth above and in Exhibit D. After approval by the Court and expiration

of the appeal period,7 GCG will prepare and mail checks to all Approved Claimants for their pro

rata shares of the Settlement Fund as set forth in Exhibit D-1 to the Ferrante Declaration. For

details of the mechanics of the Distribution, see Ferrante Decl. ¶¶ 50-56.

44. A significant number of claims were filed on behalf of Class Members by Third

Party Filers. Now that we are approaching the distribution stage of the settlement process, an

issue has arisen as to how the settlement checks should be made out and where they should be

sent: whether GCG should (i) make the settlement checks payable to the Class Member and mail

the check directly to the Class Member; or (ii) make the settlement checks payable to the Third

Party Filer “For the Benefit of” (“FBO”) the Class Member and mail the check directly to the

Third Party Filer. GCG and Class Counsel recommend that all settlement checks be made

payable to and mailed to the Class Member, rather than the Third Party Filer. Ferrante Decl. ¶

53. The magnitude of the payments in this case are enormous, more than ten times as much as

they were in the earlier settlements in this case. Indeed, some of the Dow Settlement claims

submitted through Third Party Filers involve recoveries in the many millions of dollars. Under

these circumstances, sending negotiable checks to third-party entities rather than the Class

Members to whom we have our direct obligation is not the prudent course. The protections

7 As described above, if any claimants appeal the treatment of their specific claims, Class Counsel propose

withholding sufficient funds from the initial distribution to pay such claims in full, proceeding with the distribution to all other claimants, and making any necessary payment adjustments in the supplemental distribution.


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available for the Class Members are not sufficient to justify any risk that the settlement monies

never make it to their intended beneficiary, the Class Member.8

45. In order to encourage Claimants to promptly negotiate their distributions, and to

avoid or reduce future expenses relating to unpaid distributions, GCG and Class Counsel

recommend that the distribution checks bear the notation, “CASH PROMPTLY. VOID AND

SUBJECT TO RE-DISTRIBUTION IF NOT NEGOTIATED WITHIN 90 DAYS AFTER

ISSUE DATE.” Ferrante Decl. ¶ 56.

46. GCG agreed to be the Settlement Administrator in exchange for payment of its

fees and expenses. Class Counsel have been billed and received reports of all of the work GCG

performed with respect to the administration of the Settlement, and authorized all of the claims

administration work GCG performed. Since settlement approval, GCG has been paid a total of

$320,658.64 out of the Dow Settlement Fund for the work it reasonably performed through July

31, 2017. Ferrante Decl. ¶ 57. For a summary of that work, see Ferrante Decl., passim & Exh.

E. Plaintiffs request that the Court find that those expenses were reasonable.

47. During the claims administration process, InfoTech consulted with Class Counsel

as to the eligibility of products listed in Class Members’ claims. InfoTech also provided

information on the billing and shipping locations of class member purchases which were used in

resolving disputes between competing claimants. Since settlement approval, InfoTech has been

paid a total $32,675.00 out of the Settlement Fund for the work it reasonably performed through

August 31, 2017. Plaintiffs request that the Court find that those expenses were reasonable.

48. As contemplated by § 4 of the Plan of Allocation, at least 21 days before the date

of the hearing on this Motion (“Distribution Hearing”), GCG will mail letters to claimants whose

8 Mailing checks to Class Members is not and should not be interpreted as a resolution by GCG or Class

Counsel, in form or substance, of any claims between the Class Member and Third Party Filer. It is simply a protocol to complete the claims distribution process in a timely and efficient manner.


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claims were rejected in toto and to those whose claims were reduced in the review and audit

process. The letters will inform the claimants of the rejection or modification of their claims, the

procedures for disputing those determinations, the deadline for doing so, and the time and date of

the Distribution Hearing. See Ferrante Decl. ¶ 48.

49. Class Counsel and GCG will continue to work closely with claimants until the

Distribution Hearing to eliminate or reduce the number of potential disputes relating to

claimants’ recommended Recognized Loss Amount. See Ferrante Decl. ¶ 49.

V. CONCLUSION

50. For the foregoing reasons, Plaintiffs respectfully request that the Court enter the

proposed Order authorizing the distributions from the Dow Settlement Fund as requested in this

Motion.

DATED: November 6, 2017 Respectfully submitted,

/s/ Robert W. Coykendall Robert W. Coykendall, No.10137 Robert N. Walter, No.08620 Morris, Laing, Evans, Brock & Kennedy, Chartered Old Town Square 300 North Mead – Suite 200 Wichita, KS 67202 Tel: (316) 262-2671 Fax: (316) 262-5991 Plaintiffs’ Liaison Counsel


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Donald L. Perelman Roberta D. Liebenberg Gerard A. Dever Paul Costa Matthew Duncan Mary Russell FINE, KAPLAN AND BLACK, R.P.C. One South Broad Street, 23rd Floor Philadelphia, PA 19103 Tel: (215) 567-6565 Fax: (215) 568-5872

Richard A. Koffman Kit A. Pierson Christopher J. Cormier Sharon K. Robertson Laura Alexander COHEN MILSTEIN SELLERS & TOLL PLLC 1100 New York Avenue, N. W., Suite 500 Washington, DC 20005 Tel: (202) 408-4600 Fax: (202) 408-4699

Plaintiffs’ Co-Lead Counsel


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CERTIFICATE OF SERVICE

I hereby certify that on this 6th day of November, 2017, I caused the foregoing Class

Plaintiffs’ Motion to Approve Distributions from the Dow Settlement Fund to be electronically

filed with the Clerk of the Court by using the CM/ECF system which will send a notice of

electronic filing to all counsel who have registered for receipt of documents filed in this matter.

/s/ Robert W. Coykendall Robert W. Coykendall


EXHIBIT 1

Case 2:04-md-01616-JWL Document 3281-1 Filed 11/06/17 Page 1 of 87

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

____________________________________ ) IN RE: URETHANE ANTITRUST ) MDL 1616 LITIGATION ) ____________________________________) ) Civil No. 04-md-1616-JWL-JPO This Document Relates To: ) The Polyether Polyol Cases ) ____________________________________)

DECLARATION OF ANGELA FERRANTE IN SUPPORT OF CLASS PLAINTIFFS' MOTION TO

APPROVE DISTRIBUTIONS FROM THE DOW SETTLEMENT FUND

I, Angela Ferrante, hereby declare as follows:

1. I am a Senior Vice President, Operations of Garden City Group, LLC (“GCG”).

Pursuant to this Court’s April 27, 2016 Order Authorizing Dissemination of Notice to the Class

of the Dow Settlement Agreement and Establishing Procedures and a Hearing on Final

Settlement Approval, the Proposed Plan of Allocation and Class Counsel’s Fee Petition Dkt.

3243 (the “Order Authorizing Dissemination”), GCG was appointed as the Settlement

Administrator in connection with the proposed settlement between Defendant The Dow

Chemical Company (“Dow”) and Class Plaintiffs (the “Dow Settlement”).1 The following

statements are based on personal knowledge and/or information provided to me by other

experienced GCG employees working under my supervision.

MAILING OF THE NOTICE OF THE DOW SETTLEMENT

2. As set forth in the Declaration of Jose C. Fraga Regarding Mailing of Notice of

Dow Settlement (the “Mailing Declaration”), GCG received from Class Counsel updated lists of

Class Members provided by the prior administrator, who had disseminated notices and claim 1 All capitalized terms not otherwise defined in this document shall have the meaning ascribed to them in the Settlement Agreement dated February 25, 2016. Dkt. 3238-1.


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forms in connection with prior settlements and other developments in the Urethane Antitrust

Litigation. Pursuant to the Order Authorizing Dissemination, on May 16, 2016, GCG mailed the

Notice, by first-class mail, postage prepaid, to 9,437 Class Member addresses. For those Notices

that were returned as undeliverable by the USPS with forwarding addresses, GCG re-mailed the

Notice to the forwarding addresses. For those Notices that were returned as undeliverable

without a forwarding address, GCG performed an NCOA search to locate new addresses and re-

mailed Notices to any updated addresses that were obtained.

3. In the aggregate, as of July 15, 2016, GCG mailed 9,474 Notices to potential

Class Members by first-class mail, postage prepaid. Included in this are 10 Notices that were

mailed to potential Class Members upon request.

MAILING OF PROOF OF CLAIM FORMS

4. During the course of the litigation, Class Counsel’s expert, InfoTech, processed

and compiled comprehensive data from the Defendants showing Class Members’ purchases of

qualifying products (“Defendants’ Purchase Data”).2 In 2016, at the request of Class Counsel,

InfoTech prepared a database containing the following information: (i) Class Member names; (ii)

most current or best street addresses as derived from Defendants’ Purchase Data and the work

performed during the Bayer and BASF/Huntsman settlement distributions; (iii) Direct Purchase

Amounts3 for each Class Member for each product category during the Damages Period; and (iv)

2 We understand that this data compilation was done as part of the expert damages analysis in the case under the supervision of InfoTech’s President, Dr. James T. McClave, who is Plaintiffs’ damages expert. 3 Direct Purchase Amounts are the Class Member’s total net purchases of Polyether Polyol Products (net

of freight charges, returns, discounts, credits, rebates, or other price adjustments) between November 24, 2000 and December 31, 2003 (the “Damages Period”) in dollars, directly from all of the Defendants: BASF, Bayer, Dow, Huntsman and Lyondell.


3

Overcharge Percentages4 for each Class Member for each product category.

5. InfoTech provided this database to GCG and worked with GCG and Class

Counsel to integrate the information with GCG’s database and systems for preparation of

personalized claim forms for Class Members who had not timely excluded themselves from the

Litigation Class. GCG worked with InfoTech and Class Counsel to ensure the accuracy and

completeness of the data used to prepare the personalized claim forms for Class Members.

6. Once GCG completed its analysis of the data, GCG created unique Proof of Claim

Forms (the “Claim Form”) for each Class Member. Each Claim Form included a unique Claim

Number, the corresponding Class Member’s Reference Number, and the Class Member’s Direct

Purchase Amounts and Overcharge Percentages for each product category. The Claim Form

instructed claimants that they had two options: (a) they could accept the pre-printed Direct

Purchase Amounts on the Claim Form, in which case they did not have to provide any additional

proof of their purchases, or (b) they could claim different purchase amounts, in which case they

were instructed to submit adequate proof that they had purchased the claimed amount of Eligible

Products directly from the Defendants in the United States or its territories during the Damages

Period. The Claim Form explained that although a claimant’s Direct Purchase Amounts may be

contested and adjusted if supported by adequate documentation, the customer-specific

Overcharge Percentage could not be challenged. The Claim Form instructed all claimants to

return their Claim Forms by February 27, 2017.5 A copy of a sample Claim Form is attached

hereto as Exhibit A.

4 The Overcharge Percentage included the Class Members’ overcharge percentage for each product

category, as determined by Plaintiffs’ expert on damages. 5 Although the deadline for Claim submission was February 27, 2017, Class Counsel instructed GCG to

accept late claims if doing so would not delay the claims administration process. GCG received and processed all claims through November 1, 2017. GCG is not recommending that any claims be denied on the basis that they were not submitted by February 27, 2017.


4

7. In order to ensure that Class Members had notice of the claims process and could

submit a claim with corrected amounts, GCG sent blank Claim Forms showing no eligible

purchases to entities that had Recognized Loss Amounts in connection with the Bayer and/or

BASF/Huntsman settlement distributions but did not have Eligible Purchases for purposes of the

Dow Settlement, either because of changes in the list of Eligible Products or the duration of the

period of eligibility. GCG also sent blank Claim Forms to anyone who requested one during the

course of the administration.

8. To the extent that GCG had multiple addresses for a Class Member, GCG sent a

Claim Form to each address, with each Claim Form having a unique Claim Number. Class

Members were directed that, to the extent they received multiple Claim Forms with different

Claim Numbers but the same Reference Number, they should only return one Claim Form. The

unique Reference Number was assigned based on each Class Members’ total Recognized Loss,

with Reference Number 1 assigned to the Class Member with the largest Recognized Loss.

9. On January 13, 2017, GCG mailed 10,204 Claim Forms, 3,705 pre-populated and

6,499 blank, to potential Class Members.

10. In addition, as mentioned above, when GCG received requests for Claim Forms

from entities for which purchase amounts were not provided in Defendants’ Purchase Data, GCG

sent blank Claim Forms to those entities. In the aggregate, as of November 1, 2017, GCG

mailed 10,458 Claim Forms.

TELEPHONE HOTLINE

11. As more fully described in the Mailing Declaration, on or about April 6, 2016,

GCG took control of the toll-free number (1-877-741-1226) that had been established in

connection with prior Urethane Antitrust Litigation settlements. GCG continues to maintain the


5

telephone hotline to accommodate inquiries from Class Members and to respond to frequently

asked questions. The telephone hotline is accessible 24 hours a day, 7 days a week.

WEBSITE

12. In addition, on or about March 30, 2016, GCG took ownership of the URL

www.polyetherpolyolsettlement.com, which was established in connection with prior settlements in the

Urethane Antitrust Litigation (the “Settlement Website”). GCG updated the Settlement Website to

provide information about the Dow Settlement, and continues to maintain the website. On November 6,

2017, GCG updated the homepage of the website to inform the Class that the Court will hear the Motion

for Distribution on December 19, 2017. Upon filing of Class Plaintiffs’ Motion to Approve Distributions

from the Down Settlement Fund, all documents associated with that motion, including this Declaration,

will be posted to the website, as well as the date of the Distribution Hearing.

13. GCG also established a dedicated email address

([email protected]) to assist Class Members with questions regarding the Dow

Settlement.

PROCEDURES FOLLOWED IN PROCESSING CLAIMS

14. As mentioned above, each Class Member who wished to receive a distribution

from the Dow Settlement was required to complete and submit a properly executed Claim Form.

Class Members were directed to submit their Claim Forms to:

Urethane Antitrust Litigation c/o GCG

P.O. Box 10223 Dublin, OH 43017-5723

15. Before claims processing commenced, GCG created a database dedicated to the

Litigation by customizing its proprietary database management software to accommodate the

specifics of the Litigation and the Dow Settlement as well as the data provided by InfoTech.

This included developing various computer programs and screens for entry of Class Members’


6

identifying and purchase information and calculating each Class Member’s pro rata share of the

Dow Settlement Fund pursuant to the Court-approved Plan of Allocation. In addition, GCG

trained its staff in the specifics of the Dow Settlement so that Claim Forms were properly

processed, and formulated a system so that telephone inquiries were properly handled.

16. GCG sorted incoming mail into Claim Forms and administrative mail.6 Claim

Forms that were returned by the Post Office as undeliverable were reviewed for updated

addresses on a rolling basis using the NCOA database and, where available, new addresses were

entered into the database and Claim Forms were mailed to the updated addresses.

Administrative mail was reviewed and, where necessary, appropriate responses were provided to

the senders.

17. As described above, each Class Member’s Claim Form included Direct Purchase

Amounts and customer specific Overcharge Percentages for each product category. In order to

participate in the Dow Settlement, Class Members who agreed with the amounts printed on the

Claim Form simply had to sign the Claim Form and return it to GCG at the address noted above

(“Undisputed Claims”). Class Members who disagreed with the Direct Purchase Amounts

printed on the Claim Form were required to fill in the amounts they believed to be accurate in

Part 4 of the Claim Form and submit documentation to support those amounts (“Disputed

Claims”).

18. Once received, mail including Claim Forms was opened and prepared for

scanning. This process included unfolding documents, removing staples, copying non-

conforming sized documents, sorting documents, and, where Claimant identification information

was not provided on the Claim Form, copying and attaching the envelope with the return address 6 Administrative mail includes all mail other than Claim Forms and supporting documentation and responses to deficiency (e.g., requests for Claim Forms, notification of change of address, questions regarding the administration process or the status of the administration).


7

to the file. This manual task of preparing the paper Claim Forms is laborious and time-intensive.

Once prepared, paper Claim Forms were scanned into the Settlement Database together with all

submitted documentation. Subsequently, each Claim Form was assigned a unique Claim

Number and Reference Number if it did not already have a pre-assigned Claim Number and

Reference Number. Once scanned, the information from each Claim Form was entered into the

Settlement Database.

19. GCG utilized internal codes to identify and classify claims and any deficient or

ineligible conditions that existed within those claims. The appropriate codes were assigned to

the claim as they were processed. For example, where a Claim Form was submitted by a

claimant who disputed the amounts on their Claim Form but who did not include amounts of

their own or supporting documentation, that claim received a message code that denoted

ineligibility. Similar ineligible codes were used to denote other ineligible conditions, such as

duplicate Claim Forms. These codes indicated to GCG that the claimant was not eligible to

receive any payment from the Dow Settlement with respect to that Claim Form unless the

deficiency was cured.

20. As of November 1, 2017, GCG has received 1,543 Claim Forms from 1,293

unique claimants. All but one of the Class Members with the 150 largest Recognized Loss

Amounts filed a Claim Form. In addition, claims were submitted by Class Members reflecting

approximately 96.8% of the total Recognized Loss Amounts.

21. Of the 1,543 Claim Forms GCG received, 190 Claim Forms were duplicative of

other Claim Forms filed by the same Claimant with the same Reference Number. Those

duplicate Claim Forms are recommended for rejection and Claimants were notified that only one

claim would be approved for payment.


8

22. Of the 1,543 Claim Forms, 786 Claim Forms accepted the pre-printed Direct

Purchase Amounts (“Undisputed Claims”). The Undisputed Claims were presumptively

approved for payment, subject to change only if new information came to our attention during

the claims process.

23. Of the 1,543 Claim Forms, 395 Claim Forms were blank Claim Forms (i.e., Claim

Forms without pre-populated data) that did not provide Corrected Purchase Data in Part 4 of the

Claim Form. Many of these were “placeholder” claims, which are claims filed before the

claimant or someone acting on behalf of the claimant has determined the extent – or perhaps

even the existence – of Eligible Purchases. GCG sent a Notice of Claim Deficiency (“Deficiency

Notice”) to all claimants who did not specify purchase amounts, informing them that if they

failed to submit purchase numbers and supporting documentation, their claims would be rejected.

A sample of the Deficiency Notice sent regarding placeholder claims is attached hereto as

Exhibit B. In response to the Deficiency Notice, the majority of the placeholder claims were

withdrawn or abandoned.

24. Of the 1,543 Claim Forms, 127 Claim Forms were submitted disputing the Direct

Purchase Amounts pre-printed on the Claim Form, claiming either that (i) the claimant had made

more purchases than the amounts pre-printed on the Claim Form or the products on their Claim

Forms were misclassified (e.g., listed as Systems instead of MDI); or (ii) they had made eligible

purchases though the Defendants’ data showed no Eligible Purchases during the Damages

Period. (“Disputed Claims”).

REVIEW OF DISPUTED CLAIMS

25. The Disputed Claims were first reviewed for completeness. Disputed Claims that

did not provide documents to support claimed purchase amounts received a Deficiency Notice


9

requiring that documentation be submitted to justify the additional claimed amounts. Many of

these claimants failed to supplement their claim with supporting documents or were affirmatively

withdrawn by the claimants after they received Deficiency Notices and, as a result, are

recommended for rejection. Claims that provided supporting documentation were considered for

further review to determine eligibility.

26. All remaining Disputed Claims were then reviewed and evaluated individually to

determine whether the claimant had sufficiently proven Eligible Purchases in the amounts

claimed. In making this determination, GCG and Class Counsel considered, among other things,

the following factors: (i) whether the claimant had demonstrated that it purchased products

within the Damages Period; (ii) whether the purchases were foreign or U.S. purchases; (iii)

whether the claimant had demonstrated that the products were purchased directly from the

Defendants; (iv) whether the claimant had demonstrated that the products purchased were

Eligible Products within the Class definition; and (v) the extent to which the claimant

documented the purchase amounts they claimed. In many instances, GCG and Class Counsel

searched Defendants’ Purchase Data, asked InfoTech to perform additional research, and often

conducted independent research into the reasons for discrepancies between the amounts in

Defendants’ Purchase Data and the amounts claimed by claimants.

27. Class Counsel and GCG worked with claimants via phone calls and emails to try

to resolve as many of the Disputed Claims as possible. In those instances where these phone

calls and emails were not successful or were deemed unlikely to be successful, GCG sent a

personalized Deficiency Notice to the Disputed Claimant whose claimed purchase amounts were

to be reduced or rejected, explaining the basis for rejection or reduction and providing the


10

Claimant with another opportunity to submit supplemental proof or argument. A sample of these

personalized Deficiency Notices is attached hereto as Exhibit C.

28. Many Disputed Claimants responded to the Deficiency Notice with additional

information. All responding Claimants’ files, including the new information, were re-reviewed.

Where Claimants were able to produce sufficient proof of the amounts claimed, their Claims are

being recommended for approval.

29. Ultimately, of the 127 Disputed Claims that were submitted, GCG and Class

Counsel recommend that a total of 71 be approved as follows: 26 for the full amount requested

by the Claimant, 8 for an amount greater than that contained in Defendants’ Purchase Data but

less than the full amount requested by the Claimant, and 37 for the amount contained in

Defendants’ Purchase Data (i.e., rejecting just the additional claimed amount).

30. In addition, GCG and Class Counsel recommend that 56 Disputed Claims be

rejected in full.

REVIEW OF DUPLICATE CLAIMS

31. As mentioned above, GCG received multiple Claim Forms filed by the same

claimant for the same Reference Number. GCG notified these claimants of the duplication and

informed them that only one Claim Form could be approved for payment. GCG and Class

Counsel designated one of the submitted Claim Forms as the primary claim and provided the

claimant with an opportunity to respond with additional information, including with respect to

the preferred address for communications and receipt of the settlement proceeds.

32. GCG also received duplicate Claim Forms submitted by Class Members on their

own behalf as well as by a third party on behalf of the Class Member (a “Third Party Filer”). In

most instances, both Claim Forms accepted the pre-populated Direct Purchase Amounts and only


11

required completion of the Certification section of the Claim Form and providing taxpayer

identification number, contact information and any change of address.

33. GCG and Class Counsel determined that, so long as the Claim Form submitted

by the Third Party Filer was signed by the Class Member, both the claim filed by the Class

Member and the claim filed by the Third Party Filer would be recommended for approval,

however, only one payment would be issued. Accordingly, upon approval of the Court, payment

will be sent directly to the Class Member at the address provided on the Claim Form. Neither

GCG nor Class Counsel consider this determination to constitute a resolution, in form or

substance, of any claims between the Class Member and Third Party Filer but, instead, simply

reflects a protocol for purposes of completing the claims administration process in a timely and

efficient manner.

34. To ensure that checks are sent to the correct address, GCG and Class Counsel

have requested that all Third Party Filers provide contact information with respect to the Class

Members on whose behalf they have submitted claims. GCG and Class Counsel expect the

Third Party Filers to update this information, as needed.7 GCG and Class Counsel will inform

the Third Party Filers via email of the filing of this Motion and direct them to the settlement

website where Class Counsel’s motion papers and this declaration will be posted.

35. GCG also received competing Claim Forms from two or more different claimants

with respect to the same Reference Number (“Competing Claimants”). GCG and Class Counsel

communicated with the Competing Claimants and suggested that they agree between themselves

as to who was the rightful owner of the claim or as to an appropriate allocation of the

claim. Class Counsel and GCG worked with the Competing Claimants to try to resolve as many 7 As initially submitted, the majority of the claims submitted by Third Party Filers did not provide contact information for the Class Member but instead only provided contact information for the Third Party Filer.


12

of these conflicts as possible through phone calls and e-mails, and in some instances, provided

the claimants with additional information regarding the Eligible Purchases. In all but one

instance, the Competing Claimants have resolved ownership and/or allocation of the claim.

36. In only one instance (Reference No. 50), the Competing Claimants have not

resolved fully the ownership and/or allocation issues for this claim. The Competing Claimants

have agreed that a part of the claim is properly attributed to one of the claimants and so only a

portion of the claim remains in dispute. GCG and Class Counsel will continue to work with the

Competing Claimants to attempt to resolve this conflict through the date of the Distribution

Hearing. To the extent that this claim remains unresolved at the time of the Hearing, Class

Counsel will recommend to the Court that the claim be approved based on the full amount in

Defendants’ Data; that the amounts that are not in dispute be paid as agreed; and that the

amounts that remain in dispute be retained in the Distribution Fund until such time as the dispute

is resolved, either by negotiation, mediation or court process. Class Counsel has informed the

Competing Claimants of this approach, and they are both agreeable.

37. GCG has also received five claims submitted by companies that were not related

to any Defendant during the Damages Period when their purchases of Eligible Products were

made, but are currently subsidiaries of one of the Defendants.8 After consultation with Class

Counsel, GCG recommends that these claims be accepted.

QUALITY ASSURANCE, FRAUD PREVENTION AND REGULATORY COMPLIANCE

38. An integral part of all of GCG’s settlement administration projects is its Quality

Assurance review. GCG personnel worked throughout the entire administration process to

8 These claims are: Reference No. 11 (Claim No. 692); Reference No. 16 (Claim No. 1002764); Reference No. 17 (Claim # 1001266); Reference No. 35 (Claim No. 1010006); and Reference No. 67 (Claim No. 1008190).


13

ensure that Claim Forms were processed properly; that Deficiency Notices were mailed to the

appropriate Claimants; and that GCG’s computer programs were operating properly.

39. GCG performed a final project wrap-up on all of the claims that have been

reviewed as described in this Declaration. For example, GCG conducted a review of the

Deficiency Notices that were mailed along with the resulting responses to ensure proper

processing. The team also reviewed the claims filed to ensure the correctness and completeness

of all of the Claim Forms. Here, in connection with this Quality Assurance wrap-up, GCG

(i) confirmed that valid claims have no messages denoting ineligibility; (ii) confirmed that claims

that are ineligible have messages denoting ineligibility; (iii) confirmed that all claims requiring

Deficiency Notices were sent such Notices; and (iv) reviewed claims with large dollar amounts.

40. GCG also used a variety of fraud protection controls throughout the

administration process to identify potential fraudulent Claim Forms. Duplicate claim searches,

high value reviews, spot reviews, and other standard audit reports that examined the information

in a variety of ways, were used during the claim review.

41. GCG reviewed and compared the entire database for the Settlement against the

“watch list” of known potential fraudulent filers that GCG has developed throughout its over

thirty years of experience as a claims administrator. GCG works closely with the FBI to update

that watch list with the latest information available.

42. In accordance with the regulations of the Office of Foreign Asset Control

regulations and guidelines, known as OFAC, GCG will perform searches on payments to identify

potential payees whose names may appear on the federal government’s restricted persons list or

who reside in countries to which payments are prohibited. GCG regularly monitors changes to

OFAC regulations and guidelines in connection with its distributions.


14

DISPOSITION OF CLAIMS

43. As noted above, GCG received a total of 1,543 Claim Forms from 1,293 unique

claimants. Of these, 865 claims are recommended for acceptance and 678 are recommended for

rejection.

44. Submitted herewith as Exhibit D is a list of all claims filed. Exhibit D-1 lists the

8659 Approved Claims with each Class Member’s Total Approved Recognized Loss Amount,10

Estimated Total Recovery, Estimated Initial Payment Amount and a short description of the

circumstances of the claim. Exhibit D-2 lists the 678 Rejected Claims and the reason(s) for

rejection. For privacy reasons, these lists identify claimants only by Claim Number and

Reference Number. No names, addresses or Taxpayer I.D. numbers are disclosed.

45. In total, GCG has recommended for approval 86511 claims representing a Total

Loss Amount of $519,257,220.68. According to the Plan of Allocation, each Approved

Claimant shall be allocated a pro rata share of the Dow Settlement Fund Total Loss Amount.12

9 Although there are 865 Approved Claims listed on Exhibit D-1, there are only 830 claims that will be paid. As mentioned above, there are a number of Class Members for whom two claims were filed, however, only one claim will be paid, 10 Each Class Member’s Approved Recognized Loss Amount was calculated by multiplying the Direct Purchase Amounts by the Overcharge Percentage in each product category. The Approved Recognized Loss Amount for each product category was added together for the Total Approved Recognized Loss Amount. 11

GCG received duplicate Claim Forms submitted by Class Members on their own behalf as well as by a third party on behalf of the Class Member. GCG and Class Counsel determined that, so long as the Claim Form submitted by the Third Party Filer was signed by the Class Member, both the claim filed by the Class Member and the claim filed by the Third Party Filer would be recommended for approval, however, only one payment will be issued.

12 For Claims where the potential payment amount calculated to less than $500, upon direction from Class Counsel, GCG increased the payment amounts for these claims to $500 and re-calculated the potential payment amounts for the remaining claims.


15

Upon approval by the Court and expiration of the appeal period,13 GCG will prepare and mail

checks to all Approved Claimants for approximately 85% of their pro rata share of the Dow

Settlement Fund as set forth in Exhibits D-1.

46. GCG calculated the Estimated Payment for each Approved Claimant listed on

Exhibits D-1 in accordance with the Court-approved Plan of Allocation. GCG coordinated with

Class Counsel to determine the amount remaining in the Dow Settlement Fund after all

outstanding fees and expenses have been paid, and approximately 85% of that amount will be

distributed pro rata to Class Members in the initial distribution. Class Counsel has recommended

to the Court that approximately 15% of the Dow Settlement Fund be held in reserve to cover any

legitimate corrections or adjustments that need to made after the initial settlement payments are

made or any presently unforeseen claims issues arise as well as for administrative fees and

expenses and address contingencies such as paying any taxes due on interest earned by the Dow

Settlement Fund, and funding any unanticipated costs. The most recent statements for the

Settlement escrow accounts show a total balance of $556,980,141.85. Accordingly, the balance

of the Dow Settlement Fund available for distribution is $473,433,120.57.

47. GCG recommends that the Court approve GCG’s determinations as set forth

above and in Exhibit D.

48. Pursuant to page 6 of the Plan of Allocation, at least 21 days before the date of the

hearing on Plaintiffs’ Motion to Approve Distributions from the Dow Settlement Fund

(“Distribution Hearing”), GCG will mail letters to claimants whose claims were rejected and to

13 To the extent that any claimants appeal the administrative determination of their claim, GCG and Class Counsel propose that instead of delaying the distribution to other Class Members pending resolution of such appeals, GCG would hold back from the distribution an amount sufficient to pay all such claims in the amounts claimed, in the event that that becomes necessary or appropriate. GCG and Class Counsel will submit an amended Recommended Schedule of Distribution to the Court in that event. If the appealing claimants ultimately do not prevail in full, the extra monies held back would revert to the Dow Settlement Fund to be allocated to all Approved Claimants on a pro rata basis.


16

those whose claims were reduced in the review and audit process. The letters will inform the

claimants of the rejection or modification of their claims, the procedures for disputing those

determinations, the deadline for doing so, and the time and date of the Distribution Hearing.

49. Class Counsel and GCG will continue to work with claimants until the

Distribution Hearing to eliminate or reduce the number of potential disputes before the Court.

DISTRIBUTION OF THE SETTLEMENT FUNDS

50. Should the Court approve GCG’s recommendations and determinations, GCG

recommends the following Distribution Plan. As set forth in Exhibits D-1, GCG has calculated

the pro rata payment amounts from the Dow Settlement Fund for each of the Approved

Claimants.

51. GCG will conduct an immediate distribution (the “Initial Distribution”) of the

Dow Settlement Fund in the amounts listed, as described below.

52. GCG will prepare checks and check registers. Check files will be reviewed and

compared to the entitlement report prior to printing checks. All check files will have records that

indicate the total number of checks and the total dollar amount of the checks. The records will

be checked against the entitlement report totals and also against the sum of the detail record

check amounts in the actual file. GCG will compare the list of Approved Claimants to GCG’s

internal list of Claimants who have been identified as potentially fraudulent filers.

53. In consultation with Class Counsel, GCG recommends that all settlement checks

be made payable to and mailed to the Class Member.

54. Once all of these quality assurance tests are performed and confirmed, checks will

be printed and mailed by first class mail, postage prepaid.


17

55. GCG will issue replacement payments for distributions upon request by payee,

and will respond to inquiries about distribution amounts and Payment Amount calculations.

56. Based on our years of experience, we know that not all of the checks distributed

to Approved Claimants will be cashed promptly. In order to encourage Approved Claimants to

promptly cash their distributions and to avoid or reduce future expenses relating to unpaid

distributions, all of the distribution checks will bear a notation: “CASH PROMPTLY. VOID

AND SUBJECT TO RE-DISTRIBUTION IF NOT CASHED WITHIN 90 DAYS AFTER

ISSUE DATE.”

FEES AND DISBURSEMENTS

57. GCG agreed to be the Settlement Administrator in exchange for payment of its

fees and expenses. Class Counsel have been billed and received reports of all of the work GCG

performed with respect to the administration of the Dow Settlement, and authorized all of the

claims administration work performed herein. Since settlement approval, GCG has been paid a

total $320,658.64 from the Dow Settlement Fund for the work it has performed through July 31,

2017. GCG has also incurred fees and expenses of $76,224.71 between August 1 and October

15, 2017 and estimates that $163,331.47 will be expended to conduct the Initial

Distribution. Copies of GCG’s invoices for the work performed through July 31, 2017, GCG’s

fees and expenses incurred from August 1, 2017 through October 15, 2017 and its estimate to

conduct the Initial Distribution of the Dow Settlement Fund are attached hereto as Exhibit E.

CONCLUSION

58. GCG respectfully requests that the Court enter an order approving its

administrative determinations accepting and rejecting the Claim Forms received on or before


18

November 1, 2017 and approving the Distribution Plan. GCG also request that the Court

approved GCG’s fees and expenses as set forth in Exhibit E hereto as reasonable.

I declare under penalty of perjury under the laws of the United States that the foregoing is

true and correct.

Executed in Lake Success, New York on November 6, 2017.

_________________________________ Angela Ferrante


EXHIBIT A


*P-UTH-POC/1*Urethane Antitrust Litigation

c/o GCGP.O. Box 10223

Dublin, Ohio 43017-57231-877-741-1226

[email protected]

UTHIf mailed, must be postmarked no later than

February 27, 2017

Claim Number: Reference Number: Control Number:

IN RE: URETHANE ANTITRUST LITIGATIONUnited States District Court for the District of Kansas MDL No. 1616 – Civil No. 2:04-md-1616-JWL

PROOF OF CLAIM FORM ― SETTLEMENT WITH THE DOW CHEMICAL CO.

To view GCG’s Privacy Notice, please visit http://www.gardencitygroup.com/privacy

PART 1: CLAIMANT PURCHASE DATA

The Direct Purchase Amounts set forth below were obtained directly from Defendants’ sales records and summarize your net total payments for qualifying Polyether Polyol Products during the period November 24, 2000 through December 31, 2003.

POLYETHER POLYOL PRODUCT

DIRECT PURCHASE AMOUNT

CUSTOMER-SPECIFIC OVERCHARGE PERCENTAGE

POLYOLS N/A N/A

MDI N/A N/A

TDI N/A N/A

Submission Deadline: February 27, 2017

If you accept the Direct Purchase Amounts above, you do not need to attach any additional information to submit a claim. Complete the Certification and Claimant Identification information on the next page of this form and your share of the Net Settlement Fund will be calculated based on these amounts.

If you disagree with the Direct Purchase Amounts above, please complete Part 4 and complete the Certification and Claimant Identification information on the next page of this form. You MUST attach documentation in support of any correction.

The Customer-Specific Overcharge Percentage was calculated by Plaintiffs’ expert. You may not contest this figure.

SYSTEMS N/A N/A


*P-UTH-POC/2*2

PART 3: CLAIMANT IDENTIFICATION (Please type or neatly print all information – use blue or black ink)

I certify that I am an owner, officer, or director of the Class Member submitting this Proof of Claim and that I have the authority to submit this claim on its behalf. I also certify that the Class Member/Claimant is the proper recipient of the funds sought. I further declare under the laws of the United States of America that all Corrections to Direct Purchase Amounts that I provided in Part 4 of this Proof of Claim are true and correct.

______________________________________________ ______________________________________________Name (please print) Capacity or Title

______________________________________________Company

______________________________________________ ________________________________Signature Date

PART 2: CERTIFICATION

Contact Person Last Name Contact Person First Name

Address Line 1

Address Line 2 (If Applicable)

City State Zip Code

- -Daytime phone number

Email Address

Federal Employer Tax ID Number (FEIN)

Business Name

If necessary, use the following box to correct your name and address information that appears on page 1.


*P-UTH-POC/3*3

PART 4: CLAIMANT’S CORRECTED PURCHASE DATA

1. To receive your share of the Dow Settlement Fund, you must complete and sign the Proof of Claim and return it to the Settlement Administrator, postmarked on or before February 27, 2017, to the following address: Urethane Antitrust Litigation, c/o GCG, P.O. Box 10223, Dublin, Ohio 43017-5723.

2. This Proof of Claim, even if prepared by a third party, must be completed and signed by the Class Member. You must submit the Proof of Claim Form to obtain your share of the Dow Settlement Fund even if you submitted a claim in connection with the earlier settlements with Bayer, BASF and/or Huntsman. If you have any questions concerning the Proof of Claim, or if you change your address, please contact the Settlement Administrator at the above address.

3. You are only entitled to a distribution if you are a Class member and purchased Polyether Polyol Products (Products) directly from a Defendant (defined below) at any time from November 24, 2000 through December 31, 2003 (the Claims Period) in the United States and its territories. Excluded from the Class are Defendants, their employees, and their respective parents, subsidiaries and affiliates; all who timely elected to exclude themselves from the Class; and all governmental entities. Polyether Polyol Products are: propylene oxide-based polyether polyols; monomeric or polymeric diphenylmethane diisocyanates (MMDI or PMDI – collectively, MDI); toluene diisocyanates (TDI); MDI-TDI blends; and propylene oxide-based polyether polyol systems (except those that also contain polyester polyols). Defendants are: Bayer AG, Bayer Corporation, Bayer MaterialScience LLC (f/k/a Bayer Polymers, LLC), BASF SE (f/k/a BASF AG), BASF Corporation, The Dow Chemical Company, Huntsman International LLC and Lyondell Chemical Company.

4. As stated in the Plan of Allocation, the Net Dow Settlement Fund will be distributed in proportion to the dollar amount of Claimant’s estimated customer-specific damages, as determined by Plaintiffs’ expert, for the period November 24, 2000 through December 31, 2003. The customer-specific damage amounts were estimated from each Claimant’s purchases of the relevant Products from all of the Defendants during the Claims Period. A list of the trade names of the eligible Products is available online at www.PolyetherPolyolSettlement.com.

5. The Direct Purchase Amounts set forth in the chart on page 1 of this form were taken from Defendants’ sales records and summarize your net payments for relevant Products during the Claims Period. If you accept the Direct Purchase Amounts pre-printed on page 1, you can submit a claim without collecting any documentation from your files. The stated amounts may differ from the purchase amounts that appeared on your claim forms for earlier settlements because the Claims Period for the Dow settlement (November 24, 2000 through December 31, 2003) is different than the Claims Period for earlier settlements.

6. If you believe that any of the pre-printed Direct Purchase Amounts on page 1 are incorrect, you may provide corrected purchase information in the space provided in Part 4 (“Corrections”). You must provide proof to support the corrected amount and identify the Defendant-supplier, product name and type, date of purchase, and net purchase amounts (in U.S. dollars). Electronic transaction summaries or similar records are preferred. You must have purchased directly from one of the Defendants and not through an intermediary such as a wholesaler or distributor. Provide net purchase amounts: total purchases net of freight charges, discounts, returns, rebates, chargebacks, and other debits, credits, or price

PART 5: INSTRUCTIONS

Polyether Polyol Product Corrections to Direct Purchase Amount

POLYOLS

MDI

TDI

SYSTEMS

(To be completed ONLY if you disagree with, and do not wish to accept, the totals presented in Part 1)

If you disagree with the pre-printed information contained in Part 1, please enter the corrected purchase amounts in the table below and complete the Certification and Claimant Identification information on page 2 of this form. You only need to complete this Part if you disagree with, and do not wish to accept, the amounts presented in Part 1. You MUST attach documentation in support of any corrected amounts. Further instructions are provided in Part 5.


*P-UTH-POC/4*4

adjustments. If you received multiple Proof of Claim forms, please provide supporting documentation and specify the Claim Number for each corrected form. Each form contains a discrete Claim Number in the address block on the first page. You should include that Claim Number in all correspondence and submissions to the Settlement Administrator. You may only submit Corrections to the total purchases for a particular Product category. Corrections must reflect a good-faith belief as to the accuracy of the purchase information; blank or “$0” claim forms and/or placeholder claim forms will not be accepted. You may not rely on submissions made in connection with earlier settlements because: (i) the Claims Period is different for this settlement; and (ii) you must designate the amounts purchased by Product category (e.g., polyols, MDI, TDI and/or systems).

7. The Customer-Specific Overcharge Percentage was calculated by Plaintiffs’ expert. You may not contest this figure.

8. If you appeared in Defendants’ records under other names or at different locations, you and related entities and locations may receive multiple but non-duplicative Proof of Claim Forms, each with a unique Reference Number. In those circumstances, you are encouraged to combine all of your claims into one Proof of Claim. To do so, you must mail all the Proof of Claim forms to the Settlement Administrator with a written request specifying which Claim Numbers to combine and designating one of them as the master claim. The Claim Number is on page 1, near the address.

9. The Settlement Administrator is authorized to request from persons or entities submitting proofs of claim any documentation necessary to verify all information appearing in the Proof of Claim and to prevent claim duplication. Failure to provide requested information may constitute grounds for rejection of the Claim.

10. The completed Proof of Claim and the information it contains will be treated as confidential and will be used solely for purposes of administering the settlement.

11. If you would like further information or have any questions, you may go to www.PolyetherPolyolSettlement.com. You may also contact the Settlement Administrator at 1-877-741-1226 or at [email protected]. You may also contact Don Perelman or Jerry Dever of Fine Kaplan and Black at 215-567-6565. Please do not contact the Court or the Judge.

12. By signing above and/or submitting a Proof of Claim, you are submitting to the jurisdiction of the United States District Court for the District of Kansas with respect to the claim you are making as a Class Member.

13. If you are a Class Member, whether or not you submit a Proof of Claim form, you already have released the specific claims against Dow and its affiliates as described in Paragraph 26 of the Settlement Agreement.


EXHIBIT B


***THIS IS THE ONLY NOTICE YOU WILL RECEIVE FOR THIS CLAIM***IF YOU HAVE ADDITIONAL QUESTIONS, PLEASE CALL US AT 1-877-741-1226

Urethane Antitrust Litigationc/o GCGP.O. Box 10223Dublin, Ohio 43017-5723

Date:Response Due Date:Claim Number:Reference Number:

NOTICE OF REJECTION

Dear Claimant:

We have received the Proof of Claim (“POC”) identified above that you submitted in connection withthe Dow Settlement of the Urethane Antitrust Litigation. The POC did not include pre-printedEligible Purchases, and you did not claim any Eligible Purchases or submit any documentation ofEligible Purchases with your POC. Therefore, your claim is ineligible. If you do not respond to thisletter, your claim will be denied.

If you disagree with this determination, you must submit a corrected Proof of Claim form tothe Settlement Administrator no later than June 12, 2017. You must provide a revised POC withthe amount of Eligible Purchases and documentation demonstrating the specific products purchased,the Defendant from which they were purchased, the dates, and the prices. In particular, your re-submission should include sufficient product, location, date, seller and other data to allow us tomeaningfully review the claim.

A blank claim form (with detailed instructions for filing a corrected claim) and a searchable list ofEligible Products are available on the settlement website at www.polyetherpolyolsettlement.com.

If you have any questions regarding this letter, please c o n t a c t t h e Settlement Administratortol l f ree at 1 - 877-741-1226 or by email at [email protected].

Sincerely,

The Settlement AdministratorUrethane Antitrust Litigation


EXHIBIT C


Urethane Antitrust Litigation

c/o GCG

P.O. Box 10223

Dublin, OH 43017-5723

Date:

Response Due Date:

Claim Number:

Reference Number:

Dear Claimant:

We have received the Proof of Claim (“POC”) identified above that you submitted in connection with the Dow

Settlement of the Urethane Antitrust Litigation. After careful review, we are unable to approve the “corrected”

purchase totals submitted with your claim because our review of the material you submitted shows insufficient

proof of qualifying purchases in the amounts you have claimed. In particular, we are unable to identify from the

documentation that you submitted what urethane products were purchased, from whom they were purchased

and the purchase prices that were paid for the products. Specifically, the only documentation submitted is a

vendor/product list with no purchase totals and a letter saying that you extrapolated based on 2006 and forward

purchases. Extrapolation is not an acceptable means of establishing purchase figures in a case like this, where

Defendants’ data on actual purchase figures is available. If you wish to establish “corrected” amounts, you

must provide more detailed information with respect to your purchases.

We are writing to provide you with a final opportunity to submit supplemental proof of your qualifying

purchase amounts. To do so, please return this letter along with documentation demonstrating the specific

products purchased, the Defendant from which they were purchased, the dates, and the prices. In particular,

your re-submission should (1) remove all non-urethane purchases, (2) remove all foreign purchases, and (3)

include sufficient product, location, date, seller and other data to allow us to meaningfully review the claims,

including transparency as to how you calculated your purchase figures. In considering what to include in your

supplemental submission, you may want to consult the list of eligible products on the Urethane settlement

website at www.polyetherpolyolsettlement.com.

Examples of acceptable documentation are invoices and purchase orders. Product purchase spreadsheets which

set forth the specific qualifying products purchased, the Defendant from which they were purchased, the dates,

and the prices may be submitted along with representative invoices and purchase orders, but summary

spreadsheets which merely aggregate purchases generally are insufficient. Generic product designations (e.g.,

$___ of MDI or $___ of urethane chemicals) will not be accepted. Purchase amounts based on extrapolation are

not acceptable.

Any supplemental submission must be made no later than May 30, 2017. If we do not hear from you by that

date, your claim will be denied.

Sincerely,

The Settlement Administrator

Urethane Antitrust Litigation

***THIS IS THE ONLY NOTICE YOU WILL RECEIVE FOR THIS CLAIM***

IF YOU HAVE ADDITIONAL QUESTIONS, PLEASE CALL US AT 1-877-741-1226

NOTICE OF CLAIM DEFICIENCY


EXHIBIT D


EXHIBIT D-1


EXHIBIT D-1 ACCEPTED CLAIMS REPORTThe Estimated Total Recovery and Estimated Payment Amounts listed below are the

current proposals of GCG and Class Counsel Only. They are subject of approval and/or change by the Court.

1 of 1411/6/2017 2:03 PM

Ref. No. Claim No.Total LossAmount

Estimated TotalRecovery

Estimated PaymentAmount (85%)

Comment

1 1006101 $81,886,702.20 $87,830,303.79 $74,655,758.22 Corrected Purchase Amount Approved in Part2 1007042 $18,750,511.84 $20,111,484.61 $17,094,761.92 Accepted Defendants Data3 1008262 $17,478,628.11 $18,747,283.45 $15,935,190.93 Accepted Defendants Data

41006423*1010029*

$12,759,409.04 $13,685,528.20 $11,632,698.97Corrected Purchase Amount Rejected/Claim Approved for Defendants Data/Class Member and Third Party Filer Claims Submitted

5 1005430 $14,373,657.72 $15,416,944.27 $13,104,402.63 Accepted Defendants Data

6342

1001760$11,173,759.47 $11,984,787.06 $10,187,069.00

Corrected Purchase Amount Rejected/Claim Approved for Defendants Data

7 1006842 $14,467,500.03 $15,517,597.96 $13,189,958.27 Corrected Purchase Amount Approved in Full8 1005072 $8,808,901.51 $9,448,280.06 $8,031,038.05 Accepted Defendants Data

9 1010030 $293,848.91 $315,177.41 $267,900.80Claim Divided Based on Defendants Data/Corrected Purchase Amount Approved in Part

9 1003727 $10,400,068.29 $11,154,938.87 $9,481,698.04Claim Divided Based on Defendants Data/Corrected Purchase Amount Approved in Full

10 1000991 $7,129,320.25 $7,646,789.36 $6,499,770.96 Accepted Defendants Data11 692 $6,852,486.64 $7,349,862.28 $6,247,382.94 Accepted Defendants Data12 1000312 $6,838,762.19 $7,335,141.66 $6,234,870.41 Corrected Purchase Amount Approved in Full13 1001360 $11,019,339.97 $11,819,159.29 $10,046,285.40 Corrected Purchase Amount Approved in Part14 1006670 $6,387,080.61 $6,850,675.57 $5,823,074.23 Accepted Defendants Data15 1002394 $6,464,298.28 $6,933,497.95 $5,893,473.26 Accepted Defendants Data16 1002764 $5,827,792.42 $6,250,792.44 $5,313,173.57 Accepted Defendants Data17 1001266 $5,806,967.76 $6,228,456.25 $5,294,187.81 Accepted Defendants Data18 1003690 $5,192,661.40 $5,569,561.55 $4,734,127.32 Accepted Defendants Data19 1000978 $5,134,688.19 $5,507,380.46 $4,681,273.39 Accepted Defendants Data20 1006059 $5,104,995.59 $5,475,532.67 $4,654,202.77 Accepted Defendants Data21 1000967 $4,808,676.54 $5,157,705.83 $4,384,049.96 Accepted Defendants Data22 74 $4,402,168.19 $4,721,691.79 $4,013,438.02 Accepted Defendants Data23 1006821 $4,268,636.33 $4,578,467.76 $3,891,697.60 Accepted Defendants Data24 1006764 $4,254,028.89 $4,562,800.06 $3,878,380.05 Accepted Defendants Data25 1007617 $4,230,404.75 $4,537,461.20 $3,856,842.02 Accepted Defendants Data26 1005503 $3,941,221.36 $4,227,287.95 $3,593,194.76 Accepted Defendants Data27 1006063 $3,809,179.82 $4,085,662.41 $3,472,813.05 Accepted Defendants Data28 1004176 $3,788,078.14 $4,063,029.10 $3,453,574.74 Accepted Defendants Data29 1006992 $3,635,574.96 $3,899,456.74 $3,314,538.23 Accepted Defendants Data30 1009437 $3,626,108.94 $3,889,303.65 $3,305,908.10 Accepted Defendants Data31 1006959 $3,557,575.92 $3,815,796.28 $3,243,426.84 Accepted Defendants Data

32 1005490 $3,565,529.56 $3,824,327.22 $3,250,678.14Corrected Purchase Amount Rejected/Claim Approved for Defendants Data

33 1008427 $3,312,182.89 $3,552,591.83 $3,019,703.06 Accepted Defendants Data34 1006414 $3,263,052.54 $3,499,895.44 $2,974,911.12 Accepted Defendants Data35 1010006 $173,585.31 $186,184.69 $158,256.99 Claim Divided Based on Defendants Data35 608 $921,342.71 $988,216.74 $839,984.23 Claim Divided Based on Defendants Data35 1004555 $2,316,172.84 $2,484,288.15 $2,111,644.93 Claim Divided Based on Defendants Data

36114*

1002170*$3,185,306.08 $3,416,505.89 $2,904,030.01

Accepted Defendants Data/Class Member and Third Party Filer Claims Submitted

37 1006656 $2,888,762.57 $3,098,438.30 $2,633,672.56 Accepted Defendants Data38 1003397 $2,682,643.75 $2,877,358.71 $2,445,754.90 Accepted Defendants Data39 1002406 $2,574,138.92 $2,760,978.25 $2,346,831.51 Accepted Defendants Data40 1003657 $2,467,216.60 $2,646,295.16 $2,249,350.89 Accepted Defendants Data41 1004489 $2,283,434.91 $2,449,174.00 $2,081,797.90 Accepted Defendants Data42 1002613 $2,228,149.10 $2,389,875.37 $2,031,394.06 Accepted Defendants Data43 266 $2,287,407.66 $2,453,435.10 $2,085,419.84 Accepted Defendants Data44 1000269 $2,183,323.72 $2,341,796.41 $1,990,526.95 Accepted Defendants Data45 1001281 $2,173,798.33 $2,331,579.64 $1,981,842.69 Accepted Defendants Data

461006445*1009850*

$2,097,782.21 $2,250,046.03 $1,912,539.13Accepted Defendants Data/Class Member and Third Party Filer Claims Submitted

47 1006053 $2,068,690.41 $2,218,842.65 $1,886,016.25 Accepted Defendants Data48 1001214 $2,063,115.42 $2,212,863.01 $1,880,933.56 Accepted Defendants Data


50131

1010009$790,142.20 $847,493.28 $720,369.29

Claim Divided Based on Defendants Data/Approved Subject to Determination of Ownership

50 1004751 $1,465,104.55 $1,571,446.58 $1,335,729.59Claim Divided Based on Defendants Data/Approved per Agreement Between Class Members

51 1000073 $2,261,615.31 $2,425,770.66 $2,061,905.06 Accepted Defendants Data




2 of 1411/6/2017 2:03 PM




Comment

52 1004047 $1,977,242.15 $2,120,756.78 $1,802,643.26 Accepted Defendants Data53 1007908 $1,936,794.05 $2,077,372.82 $1,765,766.90 Accepted Defendants Data54 1007987 $1,931,400.37 $2,071,587.65 $1,760,849.50 Accepted Defendants Data55 1001516 $1,809,318.93 $1,940,645.15 $1,649,548.38 Accepted Defendants Data56 1005870 $1,737,754.38 $1,863,886.21 $1,584,303.28 Accepted Defendants Data57 1003497 $1,643,103.01 $1,762,364.74 $1,498,010.03 Accepted Defendants Data58 1002342 $1,639,176.15 $1,758,152.85 $1,494,429.92 Accepted Defendants Data59 1000507 $1,638,321.03 $1,757,235.67 $1,493,650.32 Accepted Defendants Data60 1009451 $1,624,971.73 $1,742,917.43 $1,481,479.82 Accepted Defendants Data61 1008987 $1,612,161.34 $1,729,177.22 $1,469,800.64 Accepted Defendants Data


63 1005525 $1,564,030.38 $1,677,552.76 $1,425,919.85 Accepted Defendants Data64 1005462 $1,760,193.09 $1,887,953.60 $1,604,760.56 Accepted Defendants Data65 1006690 $1,512,022.90 $1,621,770.41 $1,378,504.85 Accepted Defendants Data66 1000284 $1,488,034.37 $1,596,040.72 $1,356,634.61 Accepted Defendants Data67 1008190 $1,457,385.16 $1,563,166.89 $1,328,691.86 Accepted Defendants Data68 1006431 $1,426,585.30 $1,530,131.47 $1,300,611.75 Accepted Defendants Data69 1009054 $1,569,779.46 $1,683,719.13 $1,431,161.26 Accepted Defendants Data70 1002358 $1,421,123.98 $1,524,273.75 $1,295,632.69 Accepted Defendants Data71 1000955 $1,422,460.97 $1,525,707.79 $1,296,851.62 Accepted Defendants Data


73 1006142 $1,320,088.67 $1,415,904.97 $1,203,519.22 Accepted Defendants Data74 1006617 $1,472,611.74 $1,579,498.66 $1,342,573.86 Accepted Defendants Data75 1007058 $1,241,389.48 $1,331,493.54 $1,131,769.51 Accepted Defendants Data77 1004517 $1,201,446.74 $1,288,651.63 $1,095,353.89 Accepted Defendants Data78 1001288 $1,187,465.58 $1,273,655.67 $1,082,607.32 Accepted Defendants Data79 1005267 $1,151,538.00 $1,235,120.35 $1,049,852.30 Accepted Defendants Data80 1006042 $1,119,706.92 $1,200,978.87 $1,020,832.04 Accepted Defendants Data

81 1003531 $537,711.87 $576,740.74 $490,229.63Accepted Defendants Data/Claim Divided Based on Defendants Data

81 1000792 $537,711.88 $576,740.75 $490,229.64Accepted Defendants Data/Claim Divided Based on Defendants Data

82 1000066 $1,046,427.73 $1,122,380.84 $954,023.71 Accepted Defendants Data83 1002460 $1,040,626.08 $1,116,158.09 $948,734.38 Accepted Defendants Data84 1006134 $1,029,799.30 $1,104,545.46 $938,863.64 Accepted Defendants Data85 1005847 $1,011,944.02 $1,085,394.19 $922,585.06 Accepted Defendants Data86 1006060 $1,010,735.77 $1,084,098.24 $921,483.50 Accepted Defendants Data

871004360*1007681*

$1,006,941.20 $1,080,028.25 $918,024.01Corrected Purchase Amount Rejected/Claim Approved for Defendants Data/Two Third Party Filer Claims Submmitted

88 1004866 $990,693.08 $1,062,600.79 $903,210.67 Accepted Defendants Data89 1005461 $974,261.09 $1,044,976.11 $888,229.69 Accepted Defendants Data90 1004963 $974,177.02 $1,044,885.94 $888,153.05 Accepted Defendants Data91 1001523 $967,712.43 $1,037,952.13 $882,259.31 Accepted Defendants Data92 1007000 $964,436.82 $1,034,438.76 $879,272.95 Accepted Defendants Data93 2 $956,242.23 $1,025,649.38 $871,801.97 Accepted Defendants Data94 1003495 $932,850.87 $1,000,560.20 $850,476.17 Accepted Defendants Data95 1004210 $931,654.40 $999,276.89 $849,385.36 Accepted Defendants Data96 1004705 $915,314.47 $981,750.95 $834,488.31 Accepted Defendants Data97 1004690 $911,347.98 $977,496.56 $830,872.08 Accepted Defendants Data98 1005837 $895,570.19 $960,573.57 $816,487.53 Accepted Defendants Data99 1001637 $878,707.65 $942,487.09 $801,114.03 Accepted Defendants Data

100 1004694 $874,582.79 $938,062.84 $797,353.41 Accepted Defendants Data101 1000276 $858,515.62 $920,829.46 $782,705.04 Accepted Defendants Data102 1003447 $850,155.53 $911,862.57 $775,083.18 Accepted Defendants Data103 1005103 $848,110.65 $909,669.26 $773,218.87 Accepted Defendants Data104 1006667 $848,034.55 $909,587.64 $773,149.49 Accepted Defendants Data

105 1000809 $817,230.82 $876,548.08 $745,065.87Corrected Purchase Amount Rejected/Claim Approved for Defendants Data





3 of 1411/6/2017 2:03 PM




Comment

1111002236*1010043*

$762,387.85 $817,724.43 $695,065.77Accepted Defendants Data/Class Member and Third Party Filer Claims Submitted

112 1008169 $757,504.42 $812,486.54 $690,613.56 Accepted Defendants Data113 1007640 $743,643.27 $797,619.30 $677,976.41 Accepted Defendants Data114 1007059 $742,941.07 $796,866.13 $677,336.21 Accepted Defendants Data115 1005850 $739,234.44 $792,890.47 $673,956.90 Accepted Defendants Data116 1002135 $736,058.13 $789,483.61 $671,061.07 Accepted Defendants Data117 1005129 $732,779.24 $785,966.73 $668,071.72 Accepted Defendants Data118 1003594 $729,460.92 $782,407.55 $665,046.42 Accepted Defendants Data119 1009008 $727,309.08 $780,099.52 $663,084.59 Accepted Defendants Data120 1002404 $717,106.75 $769,156.68 $653,783.18 Accepted Defendants Data121 1000305 $712,971.35 $764,721.12 $650,012.95 Accepted Defendants Data


123 1006450 $693,187.51 $743,501.30 $631,976.11 Accepted Defendants Data

1241000992*1006589*1009139*

$753,611.38 $808,310.93 $687,064.29Accepted Defendants Data/Class Member and Two Third Party Filer Claims Submitted

125 1004432 $691,202.81 $741,372.54 $630,166.66 Accepted Defendants Data126 703 $675,247.98 $724,259.66 $615,620.71 Accepted Defendants Data127 1007586 $654,243.10 $701,730.18 $596,470.65 Accepted Defendants Data128 1002256 $650,411.14 $697,620.08 $592,977.07 Accepted Defendants Data129 1006168 $649,437.20 $696,575.45 $592,089.13 Accepted Defendants Data130 1002802 $653,267.78 $700,684.07 $595,581.46 Accepted Defendants Data131 1008090 $687,583.05 $737,490.05 $626,866.54 Corrected Purchase Amount Approved in Full132 1004506 $638,627.00 $684,980.61 $582,233.52 Accepted Defendants Data133 1002247 $637,660.03 $683,943.46 $581,351.94 Accepted Defendants Data

134517

1002249$631,963.19 $677,833.12 $576,158.15




141 1002786 $593,201.79 $636,258.29 $540,819.55 Accepted Defendants Data142 1000259 $574,373.83 $616,063.74 $523,654.18 Accepted Defendants Data143 1004454 $570,469.43 $611,875.95 $520,094.56 Accepted Defendants Data144 1002414 $568,653.02 $609,927.69 $518,438.54 Accepted Defendants Data145 1006086 $556,524.09 $596,918.41 $507,380.65 Accepted Defendants Data146 1004806 $556,330.06 $596,710.29 $507,203.75 Accepted Defendants Data147 1001362 $555,737.50 $596,074.72 $506,663.51 Accepted Defendants Data148 1006926 $546,538.14 $586,207.65 $498,276.50 Accepted Defendants Data149 1002410 $536,966.47 $575,941.23 $489,550.05 Accepted Defendants Data150 1007373 $525,844.31 $564,011.79 $479,410.02 Accepted Defendants Data151 1008990 $512,158.31 $549,332.42 $466,932.56 Accepted Defendants Data152 1001381 $511,834.18 $548,984.76 $466,637.05 Accepted Defendants Data153 1007759 $509,337.39 $546,306.74 $464,360.73 Accepted Defendants Data154 1002399 $506,141.40 $542,878.78 $461,446.96 Accepted Defendants Data155 1004387 $500,240.26 $536,549.32 $456,066.92 Accepted Defendants Data156 1003490 $494,056.35 $529,916.56 $450,429.08 Accepted Defendants Data157 1005469 $484,765.39 $519,951.23 $441,958.55 Accepted Defendants Data158 1004729 $465,207.01 $498,973.24 $424,127.25 Accepted Defendants Data159 1006606 $557,184.33 $597,626.57 $507,982.58 Accepted Defendants Data160 1005470 $453,044.33 $485,927.75 $413,038.59 Accepted Defendants Data161 1008980 $653,768.92 $701,221.58 $596,038.34 Accepted Defendants Data162 1000475 $449,301.55 $481,913.31 $409,626.31 Accepted Defendants Data163 1003361 $444,705.65 $476,983.82 $405,436.25 Accepted Defendants Data164 1006848 $433,652.87 $465,128.80 $395,359.48 Accepted Defendants Data

165171*

1007802*$433,457.42 $464,919.16 $395,181.29


166 699 $427,620.39 $458,658.46 $389,859.69 Accepted Defendants Data167 534 $743,331.66 $797,285.08 $677,692.32 Corrected Purchase Amount Approved in Full168 1007062 $414,650.02 $444,746.66 $378,034.66 Accepted Defendants Data169 1000812 $407,865.44 $437,469.63 $371,849.19 Accepted Defendants Data




4 of 1411/6/2017 2:03 PM




Comment

172 710 $451,776.57 $484,567.97 $411,882.77 Accepted Defendants Data173 1005619 $394,911.54 $423,575.50 $360,039.18 Accepted Defendants Data174 1007100 $389,503.86 $417,775.31 $355,109.01 Accepted Defendants Data175 1003488 $387,861.91 $416,014.18 $353,612.05 Accepted Defendants Data178 1001223 $382,994.16 $410,793.11 $349,174.14 Accepted Defendants Data179 1000214 $377,227.55 $404,607.95 $343,916.76 Accepted Defendants Data181 1006651 $362,990.73 $389,337.77 $330,937.10 Accepted Defendants Data182 1010056 $362,907.16 $389,248.13 $330,860.91 Accepted Defendants Data

1831009488*1009489*





2041003167*1010062*


206 1007226 $304,803.19 $326,926.79 $277,887.77 Accepted Defendants Data207 1006944 $302,066.28 $323,991.23 $275,392.55 Accepted Defendants Data209 294 $298,598.28 $320,271.51 $272,230.78 Accepted Defendants Data210 1002877 $294,535.61 $315,913.96 $268,526.87 Accepted Defendants Data211 1003633 $293,035.22 $314,304.66 $267,158.96 Accepted Defendants Data212 1003619 $292,344.48 $313,563.79 $266,529.22 Accepted Defendants Data213 1002152 $292,084.09 $313,284.50 $266,291.83 Accepted Defendants Data214 1005293 $288,127.68 $309,040.92 $262,684.78 Accepted Defendants Data215 1002044 $286,280.00 $307,059.13 $261,000.26 Accepted Defendants Data216 207 $280,227.76 $300,567.60 $255,482.46 Accepted Defendants Data217 1008904 $278,196.31 $298,388.70 $253,630.40 Accepted Defendants Data218 1008311 $273,532.82 $293,386.72 $249,378.71 Accepted Defendants Data220 1001483 $265,873.84 $285,171.82 $242,396.05 Accepted Defendants Data221 1000533 $265,756.42 $285,045.88 $242,289.00 Accepted Defendants Data223 1004802 $257,629.19 $276,328.75 $234,879.44 Accepted Defendants Data224 1003858 $253,066.92 $271,435.34 $230,720.04 Accepted Defendants Data225 1002409 $253,301.13 $271,686.54 $230,933.56 Accepted Defendants Data226 1000998 $303,284.44 $325,297.81 $276,503.14 Accepted Defendants Data227 1008182 $250,388.05 $268,562.02 $228,277.72 Accepted Defendants Data228 1002624 $250,108.18 $268,261.84 $228,022.56 Accepted Defendants Data229 1006678 $244,868.72 $262,642.08 $223,245.77 Accepted Defendants Data

230296

1004184$240,450.80 $257,903.50 $219,217.98


231 707 $284.40 $500.00 $425.00 Claim Divided Based on Defendants Data231 1003327 $237,507.16 $254,746.20 $216,534.27 Claim Divided Based on Defendants Data232 1006994 $235,655.74 $252,760.40 $214,846.34 Accepted Defendants Data234 1001013 $232,963.46 $249,872.70 $212,391.80 Accepted Defendants Data235 1004869 $231,996.86 $248,835.94 $211,510.55 Accepted Defendants Data237 1010063 $227,317.21 $243,816.63 $207,244.14 Accepted Defendants Data238 246 $221,581.03 $237,664.10 $202,014.49 Accepted Defendants Data


241 1002735 $218,719.16 $234,594.50 $199,405.33 Accepted Defendants Data242 1003335 $216,105.46 $231,791.09 $197,022.43 Accepted Defendants Data243 1004200 $212,402.46 $227,819.32 $193,646.42 Accepted Defendants Data245 1007048 $209,725.80 $224,948.38 $191,206.12 Accepted Defendants Data




5 of 1411/6/2017 2:03 PM




Comment

246 1007318 $209,176.09 $224,358.77 $190,704.95 Accepted Defendants Data247 1006650 $206,228.45 $221,197.18 $188,017.60 Accepted Defendants Data248 1005148 $204,840.71 $219,708.71 $186,752.40 Accepted Defendants Data250 1001369 $203,377.60 $218,139.40 $185,418.49 Accepted Defendants Data251 1002521 $199,413.08 $213,887.13 $181,804.06 Accepted Defendants Data252 1006209 $196,649.15 $210,922.58 $179,284.19 Accepted Defendants Data253 1002059 $196,314.41 $210,563.54 $178,979.01 Accepted Defendants Data254 1010067 $196,062.42 $210,293.26 $178,749.27 Accepted Defendants Data255 1000999 $191,369.32 $205,259.52 $174,470.59 Accepted Defendants Data

2561001524*1003134*


257 1009059 $187,399.34 $201,001.39 $170,851.18 Accepted Defendants Data258 1002758 $186,053.91 $199,558.30 $169,624.56 Accepted Defendants Data259 1003115 $185,887.37 $199,379.68 $169,472.73 Accepted Defendants Data260 1001308 $178,728.41 $191,701.10 $162,945.94 Accepted Defendants Data261 1000535 $177,452.70 $190,332.79 $161,782.87 Accepted Defendants Data262 329 $177,237.22 $190,101.67 $161,586.42 Accepted Defendants Data263 1001265 $172,201.42 $184,700.36 $156,995.31 Accepted Defendants Data264 1000996 $171,261.82 $183,692.56 $156,138.68 Accepted Defendants Data265 73 $170,471.19 $182,844.54 $155,417.86 Accepted Defendants Data266 1009822 $170,298.20 $182,658.99 $155,260.14 Accepted Defendants Data267 1005739 $168,510.63 $180,741.68 $153,630.43 Accepted Defendants Data268 247 $167,318.25 $179,462.75 $152,543.34 Accepted Defendants Data270 1003670 $165,491.24 $177,503.13 $150,877.66 Accepted Defendants Data271 1002198 $165,302.91 $177,301.13 $150,705.96 Accepted Defendants Data274 1010077 $158,578.37 $170,088.50 $144,575.23 Accepted Defendants Data276 1005145 $157,481.34 $168,911.84 $143,575.06 Accepted Defendants Data

277150*

1001039*$157,305.53 $168,723.27 $143,414.78



2841006634*1010078*

$150,894.81 $161,847.24 $137,570.15Accepted Defendants Data/Two Third Party Filer Claims Submitted




29067*

1006315*$139,472.72 $149,596.10 $127,156.69


291 1004914 $139,411.89 $149,530.86 $127,101.23 Accepted Defendants Data292 1007609 $139,194.99 $149,298.21 $126,903.48 Accepted Defendants Data293 1004721 $136,755.34 $146,681.48 $124,679.26 Accepted Defendants Data294 302 $134,295.68 $144,043.29 $122,436.80 Accepted Defendants Data295 1002478 $133,175.48 $142,841.79 $121,415.52 Accepted Defendants Data298 1003171 $129,911.91 $139,341.34 $118,440.14 Accepted Defendants Data299 1004554 $128,351.71 $137,667.89 $117,017.71 Accepted Defendants Data300 1001235 $128,257.52 $137,566.87 $116,931.84 Accepted Defendants Data301 303 $126,955.84 $136,170.71 $115,745.10 Accepted Defendants Data303 1004259 $123,059.95 $131,992.04 $112,193.23 Accepted Defendants Data

3041003852*1010081*


305 1002413 $121,842.16 $130,685.86 $111,082.98 Accepted Defendants Data306 1002302 $120,560.30 $129,310.96 $109,914.32 Accepted Defendants Data307 1006325 $119,690.59 $128,378.12 $109,121.40 Accepted Defendants Data308 1004930 $117,536.68 $126,067.87 $107,157.69 Accepted Defendants Data309 1000359 $115,767.75 $124,170.55 $105,544.97 Accepted Defendants Data311 1008968 $113,058.51 $121,264.66 $103,074.96 Accepted Defendants Data313 1004084 $110,148.38 $118,143.31 $100,421.81 Accepted Defendants Data314 1000157 $110,021.60 $118,007.32 $100,306.22 Accepted Defendants Data315 1001383 $109,449.37 $117,393.56 $99,784.53 Accepted Defendants Data318 1006439 $107,017.11 $114,784.76 $97,567.05 Accepted Defendants Data321 1006222 $103,678.01 $111,203.30 $94,522.81 Accepted Defendants Data322 1005128 $103,208.45 $110,699.65 $94,094.70 Accepted Defendants Data




6 of 1411/6/2017 2:03 PM




Comment

323 1006163 $102,845.31 $110,310.16 $93,763.64 Accepted Defendants Data324 1009812 $100,738.60 $108,050.53 $91,842.95 Accepted Defendants Data325 1003286 $100,495.86 $107,790.17 $91,621.64 Accepted Defendants Data327 1006140 $99,665.37 $106,899.40 $90,864.49 Accepted Defendants Data329 309 $193,053.01 $207,065.42 $176,005.61 Corrected Purchase Amount Approved in Full330 1003616 $98,636.52 $105,795.88 $89,926.50 Accepted Defendants Data333 1001619 $95,452.92 $102,381.20 $87,024.02 Accepted Defendants Data334 1006131 $95,051.39 $101,950.53 $86,657.95 Accepted Defendants Data338 1008352 $93,218.50 $99,984.60 $84,986.91 Accepted Defendants Data339 1008011 $93,163.02 $99,925.09 $84,936.33 Accepted Defendants Data340 1009433 $91,492.31 $98,133.12 $83,413.15 Accepted Defendants Data342 1002173 $90,201.08 $96,748.17 $82,235.94 Accepted Defendants Data343 1000309 $88,163.05 $94,562.21 $80,377.88 Accepted Defendants Data344 1004260 $88,016.92 $94,405.47 $80,244.65 Accepted Defendants Data345 1005574 $86,756.21 $93,053.26 $79,095.27 Accepted Defendants Data346 1004206 $86,411.48 $92,683.50 $78,780.98 Accepted Defendants Data347 1000884 $85,551.08 $91,760.65 $77,996.55 Accepted Defendants Data348 1007163 $84,965.94 $91,133.04 $77,463.08 Accepted Defendants Data349 1002471 $84,818.68 $90,975.09 $77,328.83 Accepted Defendants Data350 1004085 $84,220.05 $90,333.01 $76,783.06 Accepted Defendants Data351 1008494 $84,068.66 $90,170.64 $76,645.04 Accepted Defendants Data


354 1007806 $83,461.40 $89,519.30 $76,091.41 Accepted Defendants Data356 1010017 $80,002.80 $85,809.66 $72,938.21 Accepted Defendants Data360 315 $77,099.34 $82,695.46 $70,291.14 Accepted Defendants Data362 1002134 $74,547.36 $79,958.25 $67,964.51 Accepted Defendants Data363 1009834 $74,210.89 $79,597.36 $67,657.76 Accepted Defendants Data364 1001511 $74,186.93 $79,571.66 $67,635.91 Accepted Defendants Data366 1000396 $73,792.54 $79,148.64 $67,276.34 Accepted Defendants Data367 1000364 $73,219.72 $78,534.24 $66,754.10 Accepted Defendants Data369 1005036 $71,347.65 $76,526.29 $65,047.35 Accepted Defendants Data370 316 $70,952.26 $76,102.20 $64,686.87 Accepted Defendants Data371 1005677 $70,539.46 $75,659.44 $64,310.52 Accepted Defendants Data372 1001084 $69,110.12 $74,126.36 $63,007.41 Accepted Defendants Data374 1002793 $68,364.39 $73,326.50 $62,327.53 Accepted Defendants Data375 1006413 $68,105.09 $73,048.38 $62,091.12 Accepted Defendants Data376 1002445 $67,988.66 $72,923.50 $61,984.98 Accepted Defendants Data

378606

1000201$66,961.95 $71,822.26 $61,048.92


379 1007635 $66,689.62 $71,530.17 $60,800.64 Accepted Defendants Data381 1004174 $66,390.53 $71,209.37 $60,527.96 Accepted Defendants Data386 1003597 $64,262.42 $68,926.79 $58,587.77 Accepted Defendants Data389 1002964 $62,895.85 $67,461.03 $57,341.88 Accepted Defendants Data391 1001208 $62,277.19 $66,797.47 $56,777.85 Accepted Defendants Data392 1008844 $61,739.35 $66,220.59 $56,287.50 Accepted Defendants Data395 1002156 $60,844.88 $65,261.20 $55,472.02 Accepted Defendants Data


397 1009503 $60,290.17 $64,666.23 $54,966.30 Accepted Defendants Data398 1008157 $59,258.99 $63,560.20 $54,026.17 Accepted Defendants Data399 1009048 $60,036.90 $64,394.57 $54,735.38 Accepted Defendants Data400 1004786 $59,052.34 $63,338.55 $53,837.77 Accepted Defendants Data403 1006219 $58,737.58 $63,000.94 $53,550.80 Accepted Defendants Data404 1001394 $57,896.55 $62,098.87 $52,784.04 Accepted Defendants Data405 1010094 $57,811.05 $62,007.16 $52,706.09 Accepted Defendants Data406 1010095 $57,659.71 $61,844.84 $52,568.11 Accepted Defendants Data407 1006891 $57,549.37 $61,726.49 $52,467.52 Accepted Defendants Data408 1005335 $56,547.14 $60,651.51 $51,553.78 Accepted Defendants Data411 1002799 $55,509.61 $59,538.68 $50,607.88 Accepted Defendants Data414 113 $54,290.00 $58,230.54 $49,495.96 Accepted Defendants Data415 1010099 $53,985.37 $57,903.80 $49,218.23 Accepted Defendants Data417 1001318 $53,693.64 $57,590.90 $48,952.27 Accepted Defendants Data418 1006159 $58,562.79 $62,813.47 $53,391.45 Corrected Purchase Amount Approved in Full419 1001985 $52,610.69 $56,429.34 $47,964.94 Accepted Defendants Data421 1006797 $52,218.78 $56,008.99 $47,607.64 Accepted Defendants Data




7 of 1411/6/2017 2:03 PM




Comment

422 1006563 $52,170.22 $55,956.90 $47,563.37 Accepted Defendants Data423 1003482 $51,874.64 $55,639.87 $47,293.89 Accepted Defendants Data427 1003513 $51,034.01 $54,738.22 $46,527.49 Accepted Defendants Data428 1008358 $50,526.17 $54,193.52 $46,064.49 Accepted Defendants Data429 1002926 $50,314.57 $53,966.56 $45,871.58 Accepted Defendants Data431 78 $49,948.22 $53,573.62 $45,537.58 Accepted Defendants Data

4321004514*1009473*



439701*

1004163*$54,357.81 $58,303.28 $49,557.79


440 1006169 $47,967.02 $51,448.62 $43,731.33 Accepted Defendants Data441 1002523 $47,943.43 $51,423.32 $43,709.82 Accepted Defendants Data443 1006401 $47,567.02 $51,019.59 $43,366.65 Accepted Defendants Data445 1002420 $98,510.49 $105,660.70 $89,811.60 Corrected Purchase Amount Approved in Full446 1003936 $45,449.47 $48,748.34 $41,436.09 Accepted Defendants Data450 1007991 $44,433.30 $47,658.41 $40,509.65 Accepted Defendants Data451 1004053 $44,431.97 $47,656.99 $40,508.44 Accepted Defendants Data453 1005002 $43,854.46 $47,037.56 $39,981.93 Accepted Defendants Data

4541002469*1010020*




462 1003108 $41,614.15 $44,634.64 $37,939.44 Accepted Defendants Data465 1007638 $40,486.53 $43,425.17 $36,911.39 Accepted Defendants Data467 1005766 $40,210.85 $43,129.48 $36,660.06 Accepted Defendants Data471 1006396 $39,606.75 $42,481.54 $36,109.31 Accepted Defendants Data472 1006047 $39,276.54 $42,127.36 $35,808.26 Accepted Defendants Data473 1005047 $46,962.26 $50,370.93 $42,815.29 Accepted Defendants Data474 1007594 $39,162.78 $42,005.34 $35,704.54 Accepted Defendants Data475 1003980 $39,108.40 $41,947.01 $35,654.96 Accepted Defendants Data478 1005581 $38,342.52 $41,125.54 $34,956.71 Accepted Defendants Data480 1004934 $38,158.58 $40,928.25 $34,789.01 Accepted Defendants Data481 1000829 $38,154.23 $40,923.59 $34,785.05 Accepted Defendants Data

4821000698*1010106*




490 1010016 $36,057.34 $38,674.50 $32,873.33 Accepted Defendants Data491 1002439 $35,926.98 $38,534.68 $32,754.48 Accepted Defendants Data492 1010108 $35,786.57 $38,384.07 $32,626.46 Accepted Defendants Data494 1004847 $35,452.46 $38,025.71 $32,321.85 Accepted Defendants Data499 1000273 $34,680.09 $37,197.28 $31,617.69 Accepted Defendants Data504 1004903 $33,347.83 $35,768.32 $30,403.07 Accepted Defendants Data505 1007934 $39,665.73 $42,544.80 $36,163.08 Corrected Purchase Amount Approved in Full507 1006725 $37,610.62 $40,340.52 $34,289.44 Corrected Purchase Amount Approved in Full509 1008007 $32,605.84 $34,972.48 $29,726.61 Accepted Defendants Data511 1007923 $32,392.24 $34,743.37 $29,531.86 Accepted Defendants Data514 1000307 $32,267.51 $34,609.59 $29,418.15 Accepted Defendants Data515 1004088 $32,053.78 $34,380.35 $29,223.30 Accepted Defendants Data516 1000836 $31,863.55 $34,176.31 $29,049.86 Accepted Defendants Data520 1003977 $31,343.14 $33,618.13 $28,575.41 Accepted Defendants Data521 1002418 $30,873.01 $33,113.87 $28,146.79 Accepted Defendants Data522 1001309 $30,660.85 $32,886.31 $27,953.36 Accepted Defendants Data523 1007111 $65,898.20 $70,681.30 $60,079.11 Corrected Purchase Amount Approved in Full

5241004778*1010114*






8 of 1411/6/2017 2:03 PM




Comment


5431004939*1009856*


544 1009804 $27,344.75 $29,329.52 $24,930.09 Accepted Defendants Data545 1002803 $27,173.35 $29,145.68 $24,773.83 Accepted Defendants Data547 1000869 $27,002.79 $28,962.74 $24,618.33 Accepted Defendants Data548 1001438 $26,982.26 $28,940.72 $24,599.61 Accepted Defendants Data553 1008528 $26,556.36 $28,483.91 $24,211.32 Accepted Defendants Data555 1008977 $26,474.34 $28,395.93 $24,136.54 Accepted Defendants Data557 1010126 $26,202.63 $28,104.50 $23,888.83 Accepted Defendants Data560 1002272 $27,170.25 $29,142.35 $24,771.00 Accepted Defendants Data561 1010129 $25,683.90 $27,548.12 $23,415.90 Accepted Defendants Data564 1007387 $24,925.44 $26,734.61 $22,724.42 Accepted Defendants Data565 1010130 $24,736.11 $26,531.54 $22,551.81 Accepted Defendants Data566 1000141 $24,550.22 $26,332.15 $22,382.33 Accepted Defendants Data571 1003144 $23,941.90 $25,679.68 $21,827.73 Accepted Defendants Data572 1001127 $23,551.67 $25,261.13 $21,471.96 Accepted Defendants Data573 129 $23,439.01 $25,140.29 $21,369.25 Accepted Defendants Data574 1004241 $23,375.35 $25,072.01 $21,311.21 Accepted Defendants Data576 1010134 $22,831.23 $24,488.39 $20,815.13 Accepted Defendants Data577 1000164 $22,375.31 $23,999.38 $20,399.47 Accepted Defendants Data

579217*

1006138*$22,253.41 $23,868.63 $20,288.34



596713

1010002$20,483.99 $21,970.78 $18,675.16


597 1002593 $20,314.81 $21,789.32 $18,520.92 Accepted Defendants Data598 1002965 $20,223.85 $21,691.76 $18,438.00 Accepted Defendants Data600 1000104 $20,192.98 $21,658.65 $18,409.85 Accepted Defendants Data601 1005111 $20,048.32 $21,503.49 $18,277.97 Accepted Defendants Data604 1004994 $19,935.64 $21,382.63 $18,175.24 Accepted Defendants Data605 1003419 $19,826.24 $21,265.29 $18,075.50 Accepted Defendants Data606 1000806 $19,805.78 $21,243.35 $18,056.85 Accepted Defendants Data607 1002911 $19,793.84 $21,230.54 $18,045.96 Accepted Defendants Data608 1004513 $19,671.16 $21,098.96 $17,934.12 Accepted Defendants Data610 1001030 $19,652.14 $21,078.56 $17,916.78 Accepted Defendants Data611 1000150 $19,617.95 $21,041.88 $17,885.60 Accepted Defendants Data612 1004065 $19,395.42 $20,803.20 $17,682.72 Accepted Defendants Data613 1007155 $19,123.00 $20,511.01 $17,434.36 Accepted Defendants Data614 1005305 $19,653.60 $21,080.12 $17,918.10 Accepted Defendants Data615 1000960 $18,753.84 $20,115.05 $17,097.79 Accepted Defendants Data616 1003537 $18,731.95 $20,091.58 $17,077.84 Accepted Defendants Data617 1000813 $18,717.72 $20,076.31 $17,064.86 Accepted Defendants Data619 1005188 $18,607.46 $19,958.05 $16,964.34 Accepted Defendants Data622 1001598 $18,018.27 $19,326.09 $16,427.18 Accepted Defendants Data623 1005198 $17,904.93 $19,204.53 $16,323.85 Accepted Defendants Data625 1007599 $17,840.99 $19,135.95 $16,265.56 Accepted Defendants Data626 1007399 $17,800.01 $19,091.99 $16,228.19 Accepted Defendants Data627 156 $17,782.99 $19,073.74 $16,212.68 Accepted Defendants Data628 1001759 $17,627.45 $18,906.91 $16,070.87 Accepted Defendants Data629 1007902 $16,889.92 $18,115.85 $15,398.47 Accepted Defendants Data631 1003894 $16,530.30 $17,730.12 $15,070.60 Accepted Defendants Data633 1001270 $16,338.46 $17,524.36 $14,895.71 Accepted Defendants Data634 1004190 $16,333.05 $17,518.56 $14,890.78 Accepted Defendants Data




9 of 1411/6/2017 2:03 PM




Comment

635 1003654 $16,283.25 $17,465.14 $14,845.37 Accepted Defendants Data636 1002531 $16,248.73 $17,428.12 $14,813.90 Accepted Defendants Data643 1007585 $15,878.89 $17,031.43 $14,476.72 Accepted Defendants Data644 1003561 $15,654.91 $16,791.19 $14,272.51 Accepted Defendants Data645 1003954 $15,578.02 $16,708.72 $14,202.41 Accepted Defendants Data646 1008543 $15,519.60 $16,646.06 $14,149.15 Accepted Defendants Data648 1006383 $15,487.93 $16,612.09 $14,120.28 Accepted Defendants Data652 1002254 $14,569.70 $15,627.22 $13,283.14 Accepted Defendants Data653 1005250 $14,565.13 $15,622.31 $13,278.96 Accepted Defendants Data659 1000952 $13,849.72 $14,854.98 $12,626.73 Accepted Defendants Data661 1008561 $13,698.89 $14,693.20 $12,489.22 Accepted Defendants Data662 1008941 $13,661.63 $14,653.24 $12,455.25 Accepted Defendants Data663 1001546 $13,555.07 $14,538.94 $12,358.10 Accepted Defendants Data664 1010151 $13,465.79 $14,443.18 $12,276.70 Accepted Defendants Data674 71 $12,727.04 $13,650.81 $11,603.19 Accepted Defendants Data675 1001446 $12,697.67 $13,619.31 $11,576.41 Accepted Defendants Data676 1008150 $301,230.80 $323,095.11 $274,630.84 Corrected Purchase Amount Approved in Part678 1002948 $12,218.44 $13,105.29 $11,139.50 Accepted Defendants Data679 1001170 $12,213.24 $13,099.72 $11,134.76 Accepted Defendants Data681 1001368 $12,139.01 $13,020.10 $11,067.09 Accepted Defendants Data682 1000330 $12,110.95 $12,990.00 $11,041.50 Accepted Defendants Data683 1001967 $12,084.11 $12,961.21 $11,017.03 Accepted Defendants Data685 1000726 $12,034.51 $12,908.01 $10,971.81 Accepted Defendants Data688 1006820 $11,779.52 $12,634.52 $10,739.34 Accepted Defendants Data

6891003686*1010023*



7191000907*1009846*


723 1000301 $9,767.11 $10,476.04 $8,904.63 Accepted Defendants Data724 1000003 $9,695.26 $10,398.97 $8,839.12 Accepted Defendants Data725 1008809 $9,634.85 $10,334.18 $8,784.05 Accepted Defendants Data729 1007328 $9,164.58 $9,829.77 $8,355.30 Accepted Defendants Data730 1004665 $9,149.97 $9,814.10 $8,341.99 Accepted Defendants Data736 1008874 $8,907.22 $9,553.73 $8,120.67 Accepted Defendants Data748 1001186 $8,609.71 $9,234.63 $7,849.44 Accepted Defendants Data751 1003982 $8,351.32 $8,957.49 $7,613.87 Accepted Defendants Data752 287 $8,347.49 $8,953.38 $7,610.37 Accepted Defendants Data754 1010169 $8,226.47 $8,823.57 $7,500.03 Accepted Defendants Data756 1009026 $8,080.15 $8,666.63 $7,366.64 Accepted Defendants Data761 1004103 $7,909.67 $8,483.78 $7,211.21 Accepted Defendants Data767 1002738 $7,492.66 $8,036.50 $6,831.03 Accepted Defendants Data768 1002150 $7,408.41 $7,946.14 $6,754.22 Accepted Defendants Data775 1010183 $7,285.08 $7,813.85 $6,641.77 Accepted Defendants Data778 1004428 $7,222.55 $7,746.79 $6,584.77 Accepted Defendants Data784 1008733 $7,023.36 $7,533.14 $6,403.17 Accepted Defendants Data785 1005623 $6,968.48 $7,474.27 $6,353.13 Accepted Defendants Data786 1005866 $6,957.68 $7,462.69 $6,343.29 Accepted Defendants Data787 1005327 $6,946.49 $7,450.69 $6,333.09 Accepted Defendants Data790 1008353 $6,882.20 $7,381.73 $6,274.47 Accepted Defendants Data791 1002467 $6,849.10 $7,346.23 $6,244.30 Accepted Defendants Data792 1003544 $6,835.47 $7,331.61 $6,231.87 Accepted Defendants Data794 1008791 $6,761.21 $7,251.96 $6,164.17 Accepted Defendants Data796 1005014 $6,725.75 $7,213.93 $6,131.84 Accepted Defendants Data798 1007453 $6,674.71 $7,159.18 $6,085.30 Accepted Defendants Data799 1008489 $6,669.98 $7,154.11 $6,080.99 Accepted Defendants Data800 1000982 $6,602.59 $7,081.83 $6,019.56 Accepted Defendants Data802 1005650 $6,512.94 $6,985.67 $5,937.82 Accepted Defendants Data803 1008008 $6,485.53 $6,956.27 $5,912.83 Accepted Defendants Data




10 of 1411/6/2017 2:03 PM




Comment


8101001015*1003433*


811 282 $6,202.79 $6,653.01 $5,655.06 Accepted Defendants Data812 1010187 $6,185.47 $6,634.43 $5,639.27 Accepted Defendants Data814 1005473 $6,120.06 $6,564.27 $5,579.63 Accepted Defendants Data

8231007793*1010189*


824 1010191 $5,752.81 $6,170.37 $5,244.81 Accepted Defendants Data826 1007432 $5,736.25 $6,152.61 $5,229.72 Accepted Defendants Data832 1004348 $5,415.56 $5,808.64 $4,937.34 Accepted Defendants Data836 262 $5,338.96 $5,726.48 $4,867.51 Accepted Defendants Data837 1010195 $5,329.15 $5,715.96 $4,858.57 Accepted Defendants Data839 1005423 $5,289.04 $5,672.94 $4,822.00 Accepted Defendants Data840 318 $5,259.64 $5,641.40 $4,795.19 Accepted Defendants Data845 1008490 $5,135.09 $5,507.81 $4,681.64 Accepted Defendants Data846 1001128 $5,101.67 $5,471.97 $4,651.17 Accepted Defendants Data847 1006801 $5,020.27 $5,384.66 $4,576.96 Accepted Defendants Data849 1003154 $4,975.73 $5,336.88 $4,536.35 Accepted Defendants Data850 1001217 $4,973.56 $5,334.56 $4,534.38 Accepted Defendants Data852 1000545 $4,917.14 $5,274.04 $4,482.93 Accepted Defendants Data859 1007614 $4,651.03 $4,988.62 $4,240.33 Accepted Defendants Data861 1007755 $4,648.68 $4,986.10 $4,238.19 Accepted Defendants Data865 1010203 $4,467.79 $4,792.08 $4,073.27 Accepted Defendants Data866 526 $4,444.27 $4,766.85 $4,051.82 Accepted Defendants Data868 1010205 $4,413.87 $4,734.24 $4,024.10 Accepted Defendants Data870 1010206 $4,375.38 $4,692.96 $3,989.02 Accepted Defendants Data873 1003126 $4,337.09 $4,651.89 $3,954.11 Accepted Defendants Data875 1008079 $4,312.80 $4,625.84 $3,931.96 Accepted Defendants Data877 1003022 $4,206.89 $4,512.24 $3,835.40 Accepted Defendants Data879 1009261 $4,144.78 $4,445.62 $3,778.78 Accepted Defendants Data881 1000749 $4,100.69 $4,398.33 $3,738.58 Accepted Defendants Data883 1005365 $4,088.11 $4,384.84 $3,727.11 Accepted Defendants Data886 1006341 $4,065.27 $4,360.34 $3,706.29 Accepted Defendants Data888 1010211 $3,941.88 $4,227.99 $3,593.79 Accepted Defendants Data889 1010212 $3,915.23 $4,199.41 $3,569.50 Accepted Defendants Data





919 1001646 $3,605.61 $3,867.32 $3,287.22 Accepted Defendants Data921 1008252 $3,556.72 $3,814.88 $3,242.65 Accepted Defendants Data927 1006899 $3,346.58 $3,589.49 $3,051.07 Accepted Defendants Data933 1003293 $118,500.00 $127,101.11 $108,035.94 Corrected Purchase Amount Approved in Part943 1005196 $3,054.77 $3,276.50 $2,785.03 Accepted Defendants Data948 1010239 $2,988.11 $3,205.00 $2,724.25 Accepted Defendants Data949 1010240 $2,987.71 $3,204.57 $2,723.88 Accepted Defendants Data954 1007867 $2,883.22 $3,092.49 $2,628.62 Accepted Defendants Data955 1005614 $2,860.59 $3,068.22 $2,607.99 Accepted Defendants Data958 1010244 $2,804.46 $3,008.02 $2,556.82 Accepted Defendants Data960 1003448 $2,768.32 $2,969.25 $2,523.86 Accepted Defendants Data963 1000981 $2,733.05 $2,931.42 $2,491.71 Accepted Defendants Data964 1001839 $2,728.66 $2,926.71 $2,487.70 Accepted Defendants Data






11 of 1411/6/2017 2:03 PM




Comment


1001 1010259 $2,369.34 $2,541.31 $2,160.11 Accepted Defendants Data1008 1010262 $2,225.12 $2,386.63 $2,028.64 Accepted Defendants Data

1009108*

1005588*$2,215.30 $2,376.09 $2,019.68


1012 1008698 $2,185.32 $2,343.94 $1,992.35 Accepted Defendants Data1013 1004645 $2,166.06 $2,323.28 $1,974.79 Accepted Defendants Data1018 1010264 $2,127.05 $2,281.44 $1,939.22 Accepted Defendants Data1023 1006894 $2,084.85 $2,236.18 $1,900.75 Accepted Defendants Data1029 1008648 $2,002.63 $2,147.99 $1,825.79 Accepted Defendants Data1032 1004162 $1,984.52 $2,128.56 $1,809.28 Accepted Defendants Data1033 1008911 $1,983.40 $2,127.36 $1,808.26 Accepted Defendants Data1034 1001146 $1,976.00 $2,119.42 $1,801.51 Accepted Defendants Data1040 1003703 $1,935.47 $2,075.95 $1,764.56 Accepted Defendants Data1041 1001752 $1,934.86 $2,075.30 $1,764.01 Accepted Defendants Data1042 1002164 $1,933.48 $2,073.82 $1,762.75 Accepted Defendants Data1046 289 $1,918.09 $2,057.31 $1,748.71 Accepted Defendants Data1048 1002387 $1,902.05 $2,040.11 $1,734.09 Accepted Defendants Data1049 1004329 $1,895.98 $2,033.60 $1,728.56 Accepted Defendants Data1052 1005561 $1,885.23 $2,022.07 $1,718.76 Accepted Defendants Data1054 1002424 $1,880.81 $2,017.33 $1,714.73 Accepted Defendants Data1055 1002607 $1,867.07 $2,002.59 $1,702.20 Accepted Defendants Data1060 1001181 $1,831.22 $1,964.14 $1,669.52 Accepted Defendants Data1061 1004460 $1,821.44 $1,953.65 $1,660.60 Accepted Defendants Data1063 1005761 $1,804.31 $1,935.27 $1,644.98 Accepted Defendants Data1067 1001245 $19,341.62 $20,745.50 $17,633.68 Corrected Purchase Amount Approved in Full1068 263 $1,748.60 $1,875.52 $1,594.19 Accepted Defendants Data1070 1001590 $1,742.64 $1,869.13 $1,588.76 Accepted Defendants Data1073 1002239 $1,720.42 $1,845.29 $1,568.50 Accepted Defendants Data1076 1005669 $1,688.75 $1,811.32 $1,539.62 Accepted Defendants Data1077 1005942 $1,672.44 $1,793.83 $1,524.76 Accepted Defendants Data1084 1010004 $1,569.21 $1,683.11 $1,430.64 Accepted Defendants Data1091 1010277 $1,485.26 $1,593.06 $1,354.10 Accepted Defendants Data1092 1008049 $1,484.32 $1,592.06 $1,353.25 Accepted Defendants Data1093 1005271 $1,483.11 $1,590.76 $1,352.15 Accepted Defendants Data1094 1007630 $1,480.35 $1,587.80 $1,349.63 Accepted Defendants Data1095 1003650 $1,478.19 $1,585.48 $1,347.66 Accepted Defendants Data1104 1003587 $1,397.29 $1,498.71 $1,273.90 Accepted Defendants Data1105 1008103 $1,385.27 $1,485.82 $1,262.95 Accepted Defendants Data1106 1010278 $1,379.40 $1,479.52 $1,257.59 Accepted Defendants Data1109 1008249 $1,372.00 $1,471.58 $1,250.84 Accepted Defendants Data1118 1001416 $1,304.29 $1,398.96 $1,189.12 Accepted Defendants Data1120 1006448 $1,279.33 $1,372.19 $1,166.36 Accepted Defendants Data1125 1002181 $1,257.24 $1,348.49 $1,146.22 Accepted Defendants Data1126 1002284 $1,245.21 $1,335.59 $1,135.25 Accepted Defendants Data1135 1005760 $1,209.92 $1,297.74 $1,103.08 Accepted Defendants Data1139 1005088 $1,185.70 $1,271.76 $1,081.00 Accepted Defendants Data1143 1004683 $1,160.34 $1,244.56 $1,057.88 Accepted Defendants Data1147 1010285 $1,141.57 $1,224.43 $1,040.77 Accepted Defendants Data1152 1010288 $1,089.95 $1,169.06 $993.70 Accepted Defendants Data

1153714

1004877$1,077.99 $1,156.23 $982.80


1157 276 $1,054.00 $1,130.50 $960.93 Accepted Defendants Data

1160 1007383 $1,037.10 $1,112.38 $945.52Corrected Purchase Amount Rejected/Claim Approved for Defendants Data

1163 1002888 $1,029.43 $1,104.15 $938.53 Accepted Defendants Data1166 1005400 $1,017.38 $1,091.22 $927.54 Accepted Defendants Data1172 1010297 $981.59 $1,052.84 $894.91 Accepted Defendants Data




12 of 1411/6/2017 2:03 PM




Comment

1174 1007438 $969.41 $1,039.77 $883.80 Accepted Defendants Data1176 1003778 $39,504.59 $42,371.96 $36,016.17 Corrected Purchase Amount Approved in Full1179 1000691 $927.69 $995.02 $845.77 Accepted Defendants Data1185 1001626 $892.06 $956.81 $813.29 Accepted Defendants Data1187 1000979 $882.71 $946.78 $804.76 Accepted Defendants Data1190 1008782 $867.27 $930.22 $790.69 Accepted Defendants Data1198 1000052 $836.31 $897.01 $762.46 Accepted Defendants Data1200 1007520 $829.48 $889.69 $756.24 Accepted Defendants Data1205 1008557 $826.30 $886.28 $753.34 Accepted Defendants Data1209 1004984 $811.38 $870.27 $739.73 Accepted Defendants Data1219 1002499 $783.87 $840.77 $714.65 Accepted Defendants Data1220 1003857 $774.79 $831.03 $706.38 Accepted Defendants Data1221 1002329 $771.16 $827.13 $703.06 Accepted Defendants Data1227 1010312 $760.85 $816.07 $693.66 Accepted Defendants Data1243 1010319 $696.01 $746.53 $634.55 Accepted Defendants Data1249 1003360 $676.15 $725.23 $616.45 Accepted Defendants Data1252 1010320 $669.53 $718.13 $610.41 Accepted Defendants Data1253 1010321 $667.15 $715.57 $608.23 Accepted Defendants Data1263 1007504 $656.21 $703.84 $598.26 Accepted Defendants Data1265 1007837 $644.63 $691.42 $587.71 Accepted Defendants Data1271 1001326 $610.55 $654.87 $556.64 Accepted Defendants Data1274 1006884 $607.13 $651.20 $553.52 Accepted Defendants Data1275 1007283 $604.82 $648.72 $551.41 Accepted Defendants Data1276 265 $604.34 $648.20 $550.97 Accepted Defendants Data1280 1006326 $591.66 $634.60 $539.41 Accepted Defendants Data1281 1008847 $588.28 $630.98 $536.33 Accepted Defendants Data1283 1010330 $583.20 $625.53 $531.70 Accepted Defendants Data1285 1010336 $579.12 $621.15 $527.98 Accepted Defendants Data1287 1010337 $574.47 $616.17 $523.74 Accepted Defendants Data1292 1005836 $560.50 $601.18 $511.00 Accepted Defendants Data1293 1007409 $547.46 $587.20 $499.12 Accepted Defendants Data1299 291 $522.09 $559.98 $475.98 Accepted Defendants Data1302 1007128 $510.68 $547.75 $465.59 Accepted Defendants Data1310 1001589 $489.16 $524.66 $445.96 Accepted Defendants Data1311 1010346 $487.34 $522.71 $444.30 Accepted Defendants Data1313 1010348 $474.23 $508.65 $432.35 Accepted Defendants Data1324 1001191 $447.36 $500.00 $425.00 Accepted Defendants Data1328 1006365 $431.43 $500.00 $425.00 Accepted Defendants Data1331 1010351 $425.17 $500.00 $425.00 Accepted Defendants Data1332 1001534 $422.71 $500.00 $425.00 Accepted Defendants Data1334 1000332 $409.67 $500.00 $425.00 Accepted Defendants Data1339 1007832 $405.08 $500.00 $425.00 Accepted Defendants Data1343 1002500 $399.43 $500.00 $425.00 Accepted Defendants Data1344 1000202 $398.87 $500.00 $425.00 Accepted Defendants Data1349 1003049 $394.17 $500.00 $425.00 Accepted Defendants Data1351 1000722 $390.49 $500.00 $425.00 Accepted Defendants Data1352 1003898 $384.66 $500.00 $425.00 Accepted Defendants Data1355 1010357 $374.98 $500.00 $425.00 Accepted Defendants Data1365 1006515 $360.24 $500.00 $425.00 Accepted Defendants Data1374 1008906 $348.53 $500.00 $425.00 Accepted Defendants Data1380 1005512 $340.82 $500.00 $425.00 Accepted Defendants Data1386 1003150 $325.76 $500.00 $425.00 Accepted Defendants Data1388 1000398 $322.02 $500.00 $425.00 Accepted Defendants Data1390 101 $316.72 $500.00 $425.00 Accepted Defendants Data1396 1000479 $310.23 $500.00 $425.00 Accepted Defendants Data1398 1000555 $306.20 $500.00 $425.00 Accepted Defendants Data1400 274 $299.80 $500.00 $425.00 Accepted Defendants Data1406 1002122 $293.71 $500.00 $425.00 Accepted Defendants Data

1416 1005006 $287.24 $500.00 $425.00Corrected Purchase Amount Rejected/Claim Approved for Defendants Data

1418 1003695 $284.68 $500.00 $425.00 Accepted Defendants Data1437 1001565 $265.68 $500.00 $425.00 Accepted Defendants Data1439 1008651 $264.77 $500.00 $425.00 Accepted Defendants Data1440 1009864 $264.68 $500.00 $425.00 Accepted Defendants Data1444 1004917 $261.63 $500.00 $425.00 Accepted Defendants Data1446 1003581 $260.03 $500.00 $425.00 Accepted Defendants Data




13 of 1411/6/2017 2:03 PM




Comment

1447 1000559 $259.99 $500.00 $425.00 Accepted Defendants Data1454 1005991 $249.16 $500.00 $425.00 Accepted Defendants Data1466 1005242 $237.06 $500.00 $425.00 Accepted Defendants Data1470 1001111 $234.72 $500.00 $425.00 Accepted Defendants Data1473 1005044 $233.05 $500.00 $425.00 Accepted Defendants Data1480 1000962 $224.88 $500.00 $425.00 Accepted Defendants Data1493 1005981 $214.10 $500.00 $425.00 Accepted Defendants Data1494 1006618 $212.89 $500.00 $425.00 Accepted Defendants Data1502 1010400 $204.08 $500.00 $425.00 Accepted Defendants Data1507 1006560 $198.28 $500.00 $425.00 Accepted Defendants Data1515 1008893 $187.47 $500.00 $425.00 Accepted Defendants Data1518 1000478 $184.38 $500.00 $425.00 Accepted Defendants Data1519 1010001 $184.10 $500.00 $425.00 Accepted Defendants Data1520 1008536 $183.95 $500.00 $425.00 Accepted Defendants Data1528 1000289 $178.34 $500.00 $425.00 Accepted Defendants Data1529 1006355 $177.75 $500.00 $425.00 Accepted Defendants Data1532 1002193 $175.84 $500.00 $425.00 Accepted Defendants Data1534 1010416 $173.18 $500.00 $425.00 Accepted Defendants Data1538 1006719 $169.95 $500.00 $425.00 Accepted Defendants Data1543 1010419 $165.71 $500.00 $425.00 Accepted Defendants Data1545 1008676 $163.13 $500.00 $425.00 Accepted Defendants Data1561 1001426 $147.46 $500.00 $425.00 Accepted Defendants Data1565 1004781 $144.09 $500.00 $425.00 Accepted Defendants Data1572 1004012 $138.55 $500.00 $425.00 Accepted Defendants Data1576 1006920 $136.13 $500.00 $425.00 Accepted Defendants Data1579 1003976 $133.29 $500.00 $425.00 Accepted Defendants Data1582 1000904 $130.56 $500.00 $425.00 Accepted Defendants Data1583 1010435 $129.80 $500.00 $425.00 Accepted Defendants Data1585 1008442 $128.03 $500.00 $425.00 Accepted Defendants Data1591 1006607 $123.28 $500.00 $425.00 Accepted Defendants Data1604 1007668 $114.23 $500.00 $425.00 Accepted Defendants Data1610 68 $111.06 $500.00 $425.00 Accepted Defendants Data1613 1005834 $109.49 $500.00 $425.00 Accepted Defendants Data1614 1004855 $109.21 $500.00 $425.00 Accepted Defendants Data1616 1000049 $107.59 $500.00 $425.00 Accepted Defendants Data1628 1008204 $101.97 $500.00 $425.00 Accepted Defendants Data1636 1004445 $195.86 $500.00 $425.00 Corrected Purchase Amount Approved in Full1657 1005842 $91.01 $500.00 $425.00 Accepted Defendants Data1661 1001734 $90.04 $500.00 $425.00 Accepted Defendants Data1665 1006704 $87.81 $500.00 $425.00 Accepted Defendants Data1669 1003410 $84.17 $500.00 $425.00 Accepted Defendants Data1678 1008538 $79.40 $500.00 $425.00 Accepted Defendants Data1680 1004724 $79.16 $500.00 $425.00 Accepted Defendants Data1683 1003897 $78.21 $500.00 $425.00 Accepted Defendants Data1691 1001467 $74.65 $500.00 $425.00 Accepted Defendants Data1693 1004097 $73.72 $500.00 $425.00 Accepted Defendants Data1697 1002860 $72.05 $500.00 $425.00 Accepted Defendants Data1698 1006294 $72.05 $500.00 $425.00 Accepted Defendants Data1706 1005872 $69.77 $500.00 $425.00 Accepted Defendants Data1713 1004045 $68.26 $500.00 $425.00 Accepted Defendants Data1714 1003395 $67.54 $500.00 $425.00 Accepted Defendants Data1721 1010456 $65.98 $500.00 $425.00 Accepted Defendants Data1726 1002862 $64.93 $500.00 $425.00 Accepted Defendants Data1734 1007405 $63.04 $500.00 $425.00 Accepted Defendants Data1743 1010460 $60.20 $500.00 $425.00 Accepted Defendants Data1745 1006901 $59.57 $500.00 $425.00 Accepted Defendants Data1761 1002128 $52.23 $500.00 $425.00 Accepted Defendants Data1763 1007148 $50.29 $500.00 $425.00 Accepted Defendants Data1768 1002902 $47.87 $500.00 $425.00 Accepted Defendants Data1770 1000501 $47.40 $500.00 $425.00 Accepted Defendants Data1776 1004166 $46.09 $500.00 $425.00 Accepted Defendants Data1784 1002785 $42.66 $500.00 $425.00 Accepted Defendants Data1789 1005432 $39.10 $500.00 $425.00 Accepted Defendants Data1793 1006312 $38.16 $500.00 $425.00 Accepted Defendants Data1804 1008109 $32.16 $500.00 $425.00 Accepted Defendants Data1825 1003862 $29.44 $500.00 $425.00 Accepted Defendants Data




14 of 1411/6/2017 2:03 PM




Comment

1826 1010472 $29.39 $500.00 $425.00 Accepted Defendants Data1828 1005765 $27.25 $500.00 $425.00 Accepted Defendants Data1832 1000537 $27.25 $500.00 $425.00 Accepted Defendants Data1839 1010475 $25.60 $500.00 $425.00 Accepted Defendants Data1857 1004713 $21.29 $500.00 $425.00 Accepted Defendants Data1860 1006586 $20.29 $500.00 $425.00 Accepted Defendants Data1862 1008922 $20.00 $500.00 $425.00 Accepted Defendants Data1864 1009858 $19.49 $500.00 $425.00 Accepted Defendants Data1865 1002245 $19.47 $500.00 $425.00 Accepted Defendants Data1901 1007661 $6.14 $500.00 $425.00 Accepted Defendants Data1935 1008517 $804,101.86 $862,466.17 $733,096.24 Corrected Purchase Amount Approved in Full2197 1009447 $5,317.63 $5,703.60 $4,848.06 Corrected Purchase Amount Approved in Part2324 1008516 $14,081.59 $15,103.68 $12,838.13 Corrected Purchase Amount Approved in Full2653 1008925 $4,735.02 $5,078.70 $4,316.90 Corrected Purchase Amount Approved in Full3284 1006726 $32,002.39 $34,325.23 $29,176.45 Corrected Purchase Amount Approved in Full3430 1000666 $880,533.64 $944,445.62 $802,778.78 Accepted Defendants Data3468 1007018 $4,106,536.20 $4,404,601.87 $3,743,911.59 Corrected Purchase Amount Approved in Full4407 1005258 $70,962.91 $76,113.63 $64,696.59 Accepted Defendants Data4408 1006988 $13,731.85 $14,728.55 $12,519.27 Accepted Defendants Data4416 1005254 $57,981.96 $62,190.48 $52,861.91 Accepted Defendants Data4686 1009049 $1,408.95 $1,511.22 $1,284.54 Accepted Defendants Data5134 1001222 $8,790.54 $9,428.59 $8,014.30 Corrected Purchase Amount Approved in Full5616 1004170 $921,655.08 $988,551.79 $840,269.02 Accepted Defendants Data5863 1010022 $44,949.50 $48,212.08 $40,980.27 Corrected Purchase Amount Approved in Full6651 1003084 $2,332.75 $2,502.07 $2,126.76 Corrected Purchase Amount Approved in Full6679 1009058 $414,951.99 $445,070.55 $378,309.97 Accepted Defendants Data6696 1000791 $4,607,137.72 $4,941,538.67 $4,200,307.87 Corrected Purchase Amount Approved in Full6862 1001548 $2,835.33 $3,041.13 $2,584.96 Corrected Purchase Amount Approved in Part7345 1007166 $125,193.92 $134,280.90 $114,138.77 Corrected Purchase Amount Approved in Part7363 497 $6,649.42 $7,132.06 $6,062.25 Corrected Purchase Amount Approved in Full7364 621 $6,083,570.16 $6,525,135.35 $5,546,365.05 Corrected Purchase Amount Approved in Full7366 1001391 $8,385.74 $8,994.40 $7,645.24 Accepted Defendants Data7367 1004404 $47,396.95 $50,837.17 $43,211.59 Corrected Purchase Amount Approved in Full

*GCG received duplicate Claim Forms submitted by Class Members on their own behalf as well as by a third party on behalf of the Class Member. GCG andClass Counsel determined that, so long as the Claim Form submitted by the Third Party Filer was signed by the Class Member, both the claim filed by theClass Member and the claim filed by the Third Party Filer would be recommended for approval, however, only one payment will be issued.


EXHIBIT D-2


Reason Deemed IneligibleClaim # Ref. No

Rejected Claims

URETHANE

MC66N Page 1 of 14

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DUPLICATE1005384 8

DUPLICATE1002520 10

DUPLICATE1007332 13

DUPLICATE1003414 17

DUPLICATE1003411 17

DUPLICATE1006765 17

DUPLICATE1001273 17

DUPLICATE1001299 17

DUPLICATE1008118 17

DUPLICATE1003413 17

DUPLICATE1006646 17

DUPLICATE1008127 18

IMPROPER CLAIMANT/WITHDRAWN1008135 18

DUPLICATE1003499 19

DUPLICATE1000246 25

DUPLICATE1001012 27

DUPLICATE1006064 27

DUPLICATE1006609 27

DUPLICATE1006776 33

DUPLICATE1003398 38

DUPLICATE1005472 38


DUPLICATE/WITHDRAWN1000277 46


DUPLICATE1010013 50

DUPLICATE1010014 50

DUPLICATE1010012 50

DUPLICATE1010010 50

DUPLICATE1005648 52

DUPLICATE1003336 52

DUPLICATE1003060 54

DUPLICATE1001517 55

DUPLICATE1008186 56

DUPLICATE1007789 61

DUPLICATE1008988 61

DUPLICATE1007785 61

DUPLICATE1005292 70

DUPLICATE1004748 72

DUPLICATE1001987 75

DUPLICATE1010028 81

DUPLICATE1007808 81

DUPLICATE1009011 83

DUPLICATE1003136 83

DUPLICATE1005410 84

DUPLICATE1008496 86

DUPLICATE1001687 87

DUPLICATE205 87

DUPLICATE1006553 90

DUPLICATE1004701 93

DUPLICATE1005914 93

DUPLICATE1005527 93



Rejected Claims

URETHANE

MC66N Page 2 of 14

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DUPLICATE1005913 93

DUPLICATE1004512 93

DUPLICATE1003109 93

DUPLICATE1010042 105







IMPROPER CLAIMANT1004699 139


















DUPLICATE295 224





DUPLICATE297 247




DUPLICATE/NO CLASS MEMBER CONTACT INFO/SIGNATURE1003110 264
















Rejected Claims

URETHANE

MC66N Page 3 of 14

MC66N128 06-Nov-17 2:02 PM



DUPLICATE283 379

















DUPLICATE270 499


DUPLICATE396 505

















DUPLICATE94 604















Rejected Claims

URETHANE

MC66N Page 4 of 14

MC66N128 06-Nov-17 2:02 PM















DUPLICATE704 875


NO CLASS MEMBER CONTACT INFO/SIGNATURE/WITHDRAWN1009425 885











DUPLICATE82 1012


























Rejected Claims

URETHANE

MC66N Page 5 of 14

MC66N128 06-Nov-17 2:02 PM




DUPLICATE531 1561


NO CLASS MEMBER CONTACT INFO/SIGNATURE1002704 1598



DUPLICATE636 1789



NO PURCHASE DATA1009463 2003

NO PURCHASE DATA/WITHDRAWN1003909 2015












CORRECTED CLAIM REJECTED IN FULL1009449 2362

WITHDRAWN/RE-SUBMITTED1009030 2384

CORRECTED AMOUNT REJECTED IN FULL/WITHDRAWN1009896 2427



























Rejected Claims

URETHANE

MC66N Page 6 of 14

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Rejected Claims

URETHANE

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Rejected Claims

URETHANE

MC66N Page 8 of 14

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CORRECTED CLAIM REJECTED IN FULL/INSUFFICIENT DOC628 7365





















Rejected Claims

URETHANE

MC66N Page 9 of 14

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Rejected Claims

URETHANE

MC66N Page 10 of 14

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Rejected Claims

URETHANE

MC66N Page 11 of 14

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Rejected Claims

URETHANE

MC66N Page 12 of 14

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Rejected Claims

URETHANE

MC66N Page 13 of 14

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Rejected Claims

URETHANE

MC66N Page 14 of 14

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Claim Count: 678


EXHIBIT E


Paul Costa, Esq.Fine, Kaplan and Black, R.P.C.One South Broad Street, Suite 2300Philadelphia, PA 19107

Project Name: Urethane Antitrust Litigation

Description Quantity Rate Amount

Fees

Notice Dissemination

Enter name and address records into database (hard copy) 68 $0.45 $30.60

Imaging, Document Management & Storage

Sort Mail 289 $0.45 $130.05Prep Mail 9.9 Hrs. $544.50Scan Mail (per img.) 1,179 $0.09 $106.11Document Storage - Paper (per box/per month) 46 $1.50 $69.00Document Storage - Electronic (per img./record per month) 64,952 $0.008 $519.62

Claim Validation

Process Claims/deficiency responses 46 $6.95 $319.70Deficiency/rejection Claim notification 145 $1.50 $217.50

Contact Services

IVR (per minute) 531 $0.32 $169.92CSR/Live Operator including transcriptions of recorded messages (per minute)

246 $0.85 $209.10

Monthly maintenance charge 2 $100.00 $200.00Management of call center 1.4 Hrs. $136.00Handling of class member communications 84.9 Hrs. $7,692.00

Website Services

Monthly maintenance charge 2 $100.00 $200.00

Project Management 416.3 Hrs. $61,816.00

Systems Support 12.5 Hrs. $1,749.00

Quality Assurance 13.3 Hrs. $1,995.00

Total Fees $76,104.10

Total Project Expenses (See Exhibit A) $118.66

Sub Total $76,222.76

Estimate for Initial Distribution (See Exhibit B) $163,331.47

Grand Total $239,554.23

INVOICE DATE11/6/2017

8/1/2017

PERIOD START

INVOICE NUMBER23028

THROUGH DATE10/15/2017

INVOICE


Please Remit To :

Garden City Group, LLC1985 Marcus Avenue, Suite 200Lake Success, NY 11042

-Or-Garden City Group, LLCOperating A/CSignature Bank1225 Franklin AvenueGarden City, NY 11530

ABA # - 026013576A /C # - 1501168781Tax ID # - 58-0506554Swift Code - SIGNUS33


` Description Amount

Project Expenses

For the period: Aug 01, 2017 through Oct 15, 2017

Tax Consulting $40.00Postage $78.66

Total $118.66

EXHIBIT A


EXHIBIT B

URETHANE ANTITRUST LITIGATION

ESTIMATE OF FEES AND EXPENSES FOR INITIAL DISTRIBUTION

AS OF OCTOBER 16, 2017

I. Pre Distribution- Fees

Print 1 page final determination letters- 721 @ $1.50 $1,081.50

Project Management $40,000.00

Quality Assurance $20,000.00

Systems Support $5,000.00

Subtotal of Pre Distribution Fees $66,081.50

Pre Distribution- Expenses

Postage $353.29

Subtotal of Pre Distribution Expenses $353.29

Subtotal of Pre Distribution Fees & Expenses $66,434.79

II. Check Distribution- Fees

Print Checks- 824 @ $1.25 $1,030.00




Banking Services $1,250.00

Subtotal of Check Distribution Fees $23,280.00

Check Distribution- Expenses

Postage for 609 checks $298.41

FedEx charges for 215 checks $3,225.00

Subtotal of Check Distribution Expenses $3,523.41

Subtotal of Check Distribution Fees & Expenses $26,803.41

III. Post-Distribution Work- Fees (Assumes 12 months)

Reissue Checks 41 @ $1.95 $79.95

Handle Undeliverable checks 25 @ $5.00 $125.00

In-bound Claimant Correspondence

~IVR Minutes 2,500 minutes @ $0.32 per minute $800.00

~CSR/Live Operator Minutes 2,500 @ $0.85 per minute $2,125.00

~Monthly Maintenance Charge ($100 per month) $1,200.00

~Handling of class member communications $25,000.00

Website Monthly Maintenance Charge ($100 per month) $1,200.00




Banking Services $3,750.00

Subtotal of Post-Distribution Work Fees $59,779.95

Post-Distribution Work- Expenses

Postage $20.09

FedEx, Copies, Line Charges $300.00

Subtotal of Post-Distribution Work Expenses $320.09

Subtotal of Post-Distribution Work Fees & Expenses $60,100.04

IV. Ancillary Services- Fees

Prepare and file tax return [2017, 2018] $5,000.00

Paper Storage, 23 boxes @ $1.50 per box per month for 12 months $414.00

Electronic Storage- 32,781 @ $0.008 per image/record per month for 12 months $3,146.98

Subtotal of Ancillary Fees $8,560.98

Ancillary Services- Expenses

P.O. Box Renewal $1,300.00

Disposal of files $132.25

Subtotal of Ancillary Expenses $1,432.25

Subtotal of Ancillary Fees & Expenses $9,993.23

GRAND TOTAL FEES AND EXPENSES: $163,331.47





Fees


Enter name and address records into database (hard copy) 4 $0.45 $1.80Remails 2 $0.65 $1.30


Sort Mail 628 $0.45 $282.60Prep Mail 5.1 Hrs. $280.50Scan Mail (per img.) 1,137 $0.09 $102.33Document Storage - Paper (per box/per month) 23 $1.50 $34.50Document Storage - Electronic (per img./record per month) 31,655 $0.008 $253.24

Claim Validation

Process Claims/deficiency responses 39 $6.95 $271.05Deficiency/rejection Claim notification 16 $1.50 $24.00

Contact Services


96 $0.85 $81.60

Monthly maintenance charge 1 $100.00 $100.00Handling of class member communications 59.4 Hrs. $5,567.00

Website Services



Systems Support 34 Hrs. $6,215.00

Quality Assurance 3.9 Hrs. $582.50




Outstanding Balance Prior Invoice #22184 $61,085.68



7/1/2017

PERIOD START

INVOICE NUMBER22785


INVOICE




Fees


INVOICE


Please Remit To :






Project Expenses

For the period: Jul 01, 2017 through Jul 31, 2017

Tax Consulting $80.00Postage $7.82

Total $87.82

EXHIBIT A





Fees




Sort Mail 501 $0.45 $225.45Prep Mail 22.9 Hrs. $1,259.50Scan Mail (per img.) 3,391 $0.09 $305.19Document Storage - Paper (per box/per month) 46 $1.50 $69.00Document Storage - Electronic (per img./record per month) 59,945 $0.008 $479.56

Claim Validation

Process Claims/deficiency responses 241 $6.95 $1,674.95Deficiency/rejection Claim notification 823 $1.50 $1,234.50

Contact Services


924 $0.85 $785.40

Monthly maintenance charge 2 $100.00 $200.00Management of call center 1 Hrs. $100.00Handling of class member communications 122.4 Hrs. $11,077.00

Website Services




Quality Assurance 3 Hrs. $447.50


Total Project Expenses (See Exhibit A) $2,198.49




5/1/2017

PERIOD START

INVOICE NUMBER22584


INVOICE




Fees


INVOICE


Please Remit To :






Project Expenses

For the period: May 01, 2017 through Jun 30, 2017

Tax Consulting $520.00Postage $247.23FedEx, Messenger & Shipping $131.26P. O. Box Rental/Renewal $1,300.00

Total $2,198.49

EXHIBIT A





Fees




Sort Mail 1,256 $0.45 $565.20Prep Mail 38.3 Hrs. $2,106.50Scan Mail (per img.) 8,795 $0.09 $791.55Document Storage - Paper (per box/per month) 43 $1.50 $64.50Document Storage - Electronic (per img./record per month) 52,010 $0.008 $416.08

Claim Validation

Process Claims/deficiency responses 685 $6.95 $4,760.75

Contact Services

IVR (per minute) 1,137 $0.32 $363.84CSR/Live Operator including transcriptions of recorded messages (per minute)

1,320 $0.85 $1,122.00


Website Services


Distribution Services

Prepare and File Tax Returns (2016) 1 $2,500.00 $2,500.00








3/1/2017

PERIOD START

INVOICE NUMBER22184


INVOICE


Please Remit To :






Project Expenses

For the period: Mar 01, 2017 through Apr 30, 2017

Tax Consulting $640.00Postage $1,033.39Working Meals and Transportation $2.14Domain Registration $97.93

Total $1,773.46

EXHIBIT A





Fees




Sort Mail 1,157 $0.45 $520.65Prep Mail 31 Hrs. $1,705.00Scan Mail (per img.) 5,093 $0.09 $458.37Document Storage - Paper (per box/per month) 20 $1.50 $30.00Document Storage - Electronic (per img./record per month) 18,137 $0.008 $145.10

Claim Validation

Process Claims/deficiency responses 672 $6.95 $4,670.40

Contact Services


2,190 $0.85 $1,861.50


Website Services

Monthly maintenance charge 1 $100.00 $100.00Website updates 0.3 Hrs. $37.50










2/1/2017

PERIOD START

INVOICE NUMBER21800


INVOICE




Fees


INVOICE


Please Remit To :






Project Expenses

For the period: Feb 01, 2017 through Feb 28, 2017

Postage $22.08

Total $22.08

EXHIBIT A





Fees


Printing of Claim Form 10,204 $0.36 $3,673.44Enter name and address records into database (electronic) 462 $0.065 $30.03Enter name and address records into database (hard copy) 464 $0.45 $208.80Remails 71 $0.65 $46.15


Sort Mail 1,722 $0.45 $774.90Prep Mail 15 Hrs. $825.00Scan Mail (per img.) 1,816 $0.09 $163.44Document Storage - Paper (per box/per month) 46 $1.50 $69.00Document Storage - Electronic (per img./record per month) 34,561 $0.008 $276.49

Claim Validation

Process Claims/deficiency responses 74 $6.95 $514.30

Contact Services


1,500 $0.85 $1,275.00

Monthly maintenance charge 3 $100.00 $300.00Management of call center 21 Hrs. $2,480.00Handling of class member communications 56.3 Hrs. $6,167.00

Website Services


Project Management 175 Hrs. $22,505.00






11/1/2016

PERIOD START

INVOICEINVOICE DATE

3/10/2017

INVOICE NUMBER21759





FeesOutstanding Balance Prior Invoice #21270 $2,821.98


INVOICE


Please Remit To :






Project Expenses

For the period: Nov 01, 2016 through Jan 31, 2017

Tax Consulting $777.50Postage $5,441.41Stationery & Supplies $2.01FedEx, Messenger & Shipping $12.07PACER Charges $39.70Copy Charges $2.30Working Meals and Transportation $4.28

Total $6,279.27

EXHIBIT A





Fees


Enter name and address records into database (hard copy) 7 $0.45 $3.15


Sort Mail 2 $0.45 $0.90Prep Mail 0.2 Hrs. $11.00Scan Mail (per img.) 5 $0.09 $0.45Document Storage - Paper (per box/per month) 15 $1.50 $22.50Document Storage - Electronic (per img./record per month) 10,400 $0.008 $83.20

Contact Services


180 $0.85 $153.00

Monthly maintenance charge 1 $100.00 $100.00Handling of class member communications 3.4 Hrs. $425.00

Website Services


Project Management 7.2 Hrs. $908.50

Systems Support 2.1 Hrs. $330.00






10/1/2016

PERIOD START

INVOICE NUMBER21270


INVOICE


Please Remit To :






Project Expenses

For the period: Oct 01, 2016 through Oct 31, 2016

Tax Consulting $450.00

Total $450.00

EXHIBIT A





Fees


Enter name and address records into database (electronic) 30 $0.065 $1.95Enter name and address records into database (hard copy) 28 $0.45 $12.60



Contact Services


48 $0.85 $40.80

Monthly maintenance charge 1 $100.00 $100.00Management of call center 3.3 Hrs. $346.50Handling of class member communications 5.8 Hrs. $725.00

Website Services







Sub Total $4,321.99




9/1/2016

PERIOD START

INVOICE NUMBER21146


INVOICE


Please Remit To :






Project Expenses

For the period: Sep 01, 2016 through Sep 30, 2016

Postage $0.93

Total $0.93

EXHIBIT A





Fees


Enter name and address records into database (electronic) 156 $0.065 $10.14Enter name and address records into database (hard copy) 72 $0.45 $32.40



Contact Services


192 $0.85 $163.20


Website Services




Quality Assurance 3 Hrs. $450.00





8/1/2016

PERIOD START

INVOICE NUMBER20865


INVOICE


Please Remit To :






Project Expenses

For the period: Aug 01, 2016 through Aug 31, 2016

Tax Consulting $337.50Postage $0.47Domain Registration $132.05

Total $470.02

EXHIBIT A





Fees


Enter name and address records into database (electronic) 402 $0.065 $26.13Enter name and address records into database (hard copy) 21 $0.45 $9.45Remails 1 $0.65 $0.65



Contact Services


132 $0.85 $112.20

Monthly maintenance charge 2 $100.00 $200.00Handling of class member communications 4.2 Hrs. $519.00

Website Services









6/16/2016

PERIOD START

INVOICE NUMBER20764


INVOICE


Please Remit To :






Project Expenses

For the period: Jun 16, 2016 through Jul 31, 2016

Tax Consulting $337.50Postage $17.21FedEx, Messenger & Shipping $118.96

Total $473.67

EXHIBIT A





Fees


Printing of 6 pg. Notice 12,000 $0.37 $4,440.00Enter name and address records into database (electronic) 9,437 $0.065 $613.41Enter name and address records into database (hard copy) 91 $0.45 $40.95Remails 27 $0.65 $17.55


Sort Mail 1,444 $0.45 $649.80Prep Mail 0.9 Hrs. $49.50Scan Mail (per img.) 64 $0.09 $5.76Document Storage - Paper (per box/per month) 17 $1.50 $25.50Document Storage - Electronic (per img./record per month) 27,589 $0.008 $220.71

Contact Services

Standard set-up and design $2,500.00IVR (per minute) 685 $0.32 $219.20CSR/Live Operator including transcriptions of recorded messages (per minute)

450 $0.85 $382.50

Monthly maintenance charge 1 $100.00 $100.00Management of call center 2.1 Hrs. $226.00Handling of class member communications 3 Hrs. $384.00

Website Services

Standard set-up and design $2,500.00Monthly maintenance charge 1 $100.00 $100.00Website updates 2 Hrs. $250.00








5/29/2015

PERIOD START

INVOICE NUMBER20426


INVOICE


Please Remit To :






Project Expenses

For the period: May 29, 2015 through Jun 15, 2016

Postage $4,196.77P. O. Box Rental/Renewal $2,612.00Copy Charges $0.40

Total $6,809.17

EXHIBIT A


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