Subject IMPORTANT NOTICE ISSUED ABOUT THE VIOXX PRIVATE LIEN

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Subject: IMPORTANT NOTICE ISSUED ABOUT THE VIOXX PRIVATE LIEN RESOLUTION PROGRAM Judge Eldon E. Fallon, the federal judge overseeing the Vioxx Settlement, has authorized the Lien Resolution Administrator (Garretson Firm Resolution Group) to administer a program to assist with the resolution of Vioxx-related liens being asserted by Private Health Insurance Providers. On January 30, 2009, BrownGreer sent to all Primary Counsel an email informing them of the Program and how their clients can participate in it. The notice contained the following explanation. THE PROGRAM OFFERS SIGNIFICANT PRIVATE LIEN RESOLUTION BENEFITS TO VIOXX CLAIMANTS WHO WERE COVERED BY CERTAIN PRIVATE HEALTH INSURANCE PROVIDERS OR CERTAIN OTHER PRIVATE BENEFIT PLANS. The email included two PDF attachments, which now are posted on the general settlement website, www.browngreer.com/vioxxsettlement under a menu option for the Private Lien Resolution Program: Packet 1 entitled Notice to Vioxx Primary Counsel: This packet contains a document that provides a brief explanation of the Program and instructions for counsel. It does not need to be mailed to the clients of a Primary Counsel firm. Packet 2 entitled Vioxx Private Lien Program_Client Ed_Notice_Acceptance_HIPAA Auth: This packet contains four key documents that Primary Counsel should mail immediately to all their Vioxx clients: 1. Vioxx Private Lien Resolution Program Claimant Information: This document contains the Program s terms and conditions, including: benefits; costs; and participation deadline. 2. Exhibit 1: This document contains the list of Private Health Insurance Providers that currently are participating in the Program. 3. Private Lien Resolution Program Offer and Acceptance: This document must be completed, signed, and returned by your client(s) by March 20, 2009, in order to participate. 4. Authorization for Use and Disclosure of Protected Health Information (HIPAA Authorization): This document must be completed, signed, and returned by your client(s) by March 20, 2009, in order to participate. After review by Primary Counsel, the parties to the Program ask that Primary Counsel print and send all four documents included in the packet entitled Client Ed_Notice_Acceptance_HIPAA Auth to their clients. Each client who chooses to participate must then sign and return two of these documents in this packet to the Lien Resolution Administrator postmarked by March 20, 2009. (These must be mailed to the Lien Resolution Administrator in original hard copy (with signatures in ink by the March 20, 2009 deadline). Direct all questions to the Lien Resolution Administrator (Garretson Firm Resolution Group) at: (877) 774-1130, and not to BrownGreer, the Vioxx Claims Administrator.

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