FREQUENTLY ASKED QUESTIONS 31910

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					                    FREQUENTLY ASKED QUESTIONS

   1. WHO IS INCLUDED IN THE CLASS?
       The class consists of all current and former 3M Cordova non-exempt, hourly
employees who work, or have worked, at the Cordova, Illinois 3M facility at any time
from December 1, 1997 to November 23, 2009, and who allegedly were not paid either
their regular or overtime pay for engaging in any of the following activities: (1) donning
and doffing on 3M premises protective clothing and other Personal Protective
Equipment required by 3M or the nature of the work; (2) showering on 3M premises; (3)
walking to and from their locker rooms and work stations in protective clothing; and (4)
reporting to work stations prior to the official start of their shift and/or remaining at their
work stations after the official end of their shifts and performing off the clock work.
       You are a member of the Class if you are/were an hourly (8 or 12 hour shift) in
any of the following “departments:” 1) Internals; 2) Electronics; 3) Maintenance; 4)
Engineering; 5) Heating; 6) Oxide; 7) Specialty Manufacturing; 8) Packaging; or 9)
Warehouse AND you are/were assigned to any of the following “business titles:” a)
Chemical Processor; b) Oxide Processor; c) Process Specialist; d) Material Handler; e)
Finished Goods Handler; f) Environmental Material Handler; g) Mechanic; h)Electrician;
i) Utility Service Person; j) Apprentice; or k) Helper.
       A list of all identified Class Members is available for review.


   2. WHAT IF I FIT THE CRITERIA FOR A CLASS MEMBER BUT I AM NOT
       LISTED ON THE CLASS MEMBER LIST?
       Unfortunately, the time for being added to the Class Member List has passed.
You may still have a private right of action. You should contact an attorney.


   3. HOW MUCH CAN EACH CLASS MEMBER EXPECT TO RECEIVE?
       The Settlement Awards have been calculated based on each individual
employee’s payroll records.
       For the 2002 to present Class Members we know each shift the employee
actually worked (i.e.: excluding vacation, sick or personal days taken) and what his/her

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rate of pay was for that shift. Class Members will be paid for 14.57415 minutes per 12
hour shift worked from December 6, 2002 to June 7, 2009 and for 4.164042 minutes per
8 hour shift worked for that same time period at their then overtime rate of pay.
       For the 1997 -2002 class members, we know how many pay periods each
employee worked during those years. Class Members will be paid $5.00 per pay period
worked between December 6, 1997 and December 7, 2002.


   4. WHY THE TWO SUBCLASSES? WHY AREN’T ALL CLASS MEMBERS
       GETTING PAID BASED ON THE SAME FORMULA?
       The statute of limitations on overtime wages is typically 2 years (or 3 years if
intent is proven). We brought suit in December 2007 and therefore would only have
been allowed to recover from December 2004 at best under the overtime statutes. But,
since employees were not paid at all for this time, in addition to the overtime statutes,
we were able to sue under the Illinois Wage Payment and Collection Act as well, which
has a 5 year statute of limitations. As a result of suing under Illinois law, we were
allowed to seek recovery of back wages (at the promised daily overtime rate as
opposed to only time and a half for all hours over 40 in a work week) from December
2002. We amended the complaint in an attempt to expand the class time period to 10
years under the novel theory of breach of written contract. 3M strenuously objected to
this move on both a factual and legal basis. 3M would have vigorously defended against
a recovery of back wages going back 10 years had a settlement not been reached. In
addition, the outcome of this claim was far from certain. The tenuous nature of the claim
was considered when determining how to include employees from that time period in
the settlement. In addition, 3M was unable to produce time records for that entire period
so we could not base their award on shifts worked or do any verification of time on
premises as we were able to do with the post-2002 employees.


   5. WHY ARE WE ONLY BEING PAID THROUGH JUNE 7, 2009?
       3M has only provided us with payroll records through the time our settlement
discussions ended and early June is when we first came to an agreement in principal on
terms. Although not part of the settlement, it should be noted that 3M has, subsequent


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to our initial settlement, changed its timekeeping and payroll practices and now pays
employees for time spent in the work related activities that were the subject of our
lawsuit.


   6. WHEN WILL PAYMENT BE MADE?
       3M has agreed to transmit all checks to the Settlement Administrator for
distribution on March 26, 2010. Class Members will be paid as soon as practicable after
receipt of the checks.


   7. WHO ARE THE ATTORNEYS REPRESENTING THE CLASS MEMBERS?
Colleen McLaughlin                              Robin Potter
Elissa J. Hobfoll                               Jennifer Purcell
LAW OFFICES OF COLLEEN M.                       ROBIN POTTER & ASSOCIATES, P.C.
McLAUGHLIN                                      111 East Wacker Drive - Suite 2600
1751 S. Naperville Road - Suite 209             Chicago, Illinois 60601
Wheaton, IL 60189                               Telephone: (312) 861-1800
Telephone: (630) 221-0305

   8. WHO PAYS ATTORNEYS’ FEES?
       The attorneys’ fees and expenses for Class Counsel will be paid from the Class
settlement Amount.


   9. HOW MUCH ARE THE ATTORNEYS RECEIVING?
       Class Counsel will receive 1/3 of the total Class Settlement Amount of 4.95
million plus 2.5% interest from December 3, 2009 to the date of distribution, March 26,
2010, to compensate Class Counsel for the work performed by Class Counsel in
bringing this Litigation. Class Counsel will also be reimbursed their costs and expenses.


   10. WHY AREN’T THE ATTORNEYS BEING PAID SEPARATELY BY 3M
       INSTEAD OF TAKING THEIR PAY OUT OF THE SETTLEMENT FUND?
       There are many ways to structure settlements. The laws under which we sued
3M provide for the employer to pay the attorneys’ fees and we always take fees into
account when discussing settlement, whether in a lump sum or as a separate


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component of the settlement. In this case, 3M offered a lump sum settlement inclusive
of all costs, fees and damages. Typically, because of the risks involved in Class Action
lawsuits and the substantial out of pocket expenses and time advanced by Class
Counsel, class attorneys receive up to 40% or more of the Settlement Fund plus their
expenses. Class Counsel in this case agreed to accept 1/3 of the Settlement Fund.


   11. WHAT WILL THE CLASS REPRESENTATIVES RECEIVE?
       Class Representatives will each receive an additional award of between $25,000
and $4,000 based on their level of participation in the Litigation and release of claims.
The total distribution from the settlement fund will be $105,000.


   12. WHAT CLAIMS ARE BEING RELEASED BY THE PROPOSED
       SETTLEMENT?
       All Class Members who have not opted out of the settlement, will be bound by
the terms of the Settlement Agreement with regard to the state law claims asserted in
the lawsuit and will have released and forever discharged 3M for any related state law
claim that stems from the time period 1997 to the date of the Final Approval Order. In
accepting the Settlement Award, all Class Members also agree to release claims that
could have been brought against 3M under the federal Fair Labor Standards Act
(“FLSA”), 29 USC §201, et. seq.
       In addition to the above release, upon the final approval by the Court, each
Settlement Class Representative must also execute a General Waiver and Release as
to 3M, which means they are releasing not only their overtime wage claims but any
claim, known or unknown, that they may have against 3M, for the time period 1997 to
the date of the Final Approval Order.


   13. WILL THE COMPANY RETALIATE AGAINST ME IF I RECEIVE A
       SETTLEMENT AWARD?
       No. Retaliation by 3M against Class Members is unlawful and is strictly
prohibited.



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   14. THE PERSON TO WHOM THE CHECK WAS SENT IS DECEASED OR
      INCAPABLE OF ACTING. CAN I RECEIVE THE AWARD ON THEIR BEHALF?
      Deceased Response: Settlement Awards will go to the deceased Class
Members estate. Heirs and executors should contact an attorney if they have difficulties
cashing the check. You may need to provide a death certificate or other legal
documents and/or sign an affidavit of heirship.
      Incapable of Acting Response: If you have a Power of Attorney for the Class
Member, you should be able to cash the check. If you have difficulties, please contact
an attorney.


   15. WILL I RECEIVE A W-2 FORM FROM 3M EVEN THOUGH I AM NO LONGER
      AN EMPLOYEE THERE?
      Yes. All Final Settlement Class Members will receive a W-2 form from 3M in the
normal course of business in January 2011.


   16. WHAT HAPPENS IF MY ADDRESS HAS CHANGED OR CHANGES?
      Please contact Class Counsel and/or the Settlement Administrator with any
change to your contact information. We will inform 3M of any change of addresses
received so that 3M can send you your W-2 at the end of the year. We will also keep the
Community Foundation for the Great River Bend informed so that you will receive any
information on the scholarship process it may send out in the future.


  17. HOW DO I CONTACT THE SETTLEMENT ADMINISTRATOR:
      The Settlement Administrator is:
      Administar Services Group, Inc.
      Lueders Settlement
      P.O. Box 56798
      Jacksonville, Florida 32241-6798
      Fax: 904-807-3030
      Telephone: 1-866-778-0475
      luedersettlement@administarllc.com

   18. HOW CAN I APPLY FOR A SCHOLARSHIP


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   Scholarship information is available on this website. You may also contact the
                     Community Foundation of the Great River Bend
                                 Attn: Scholarship
                            852 Middle Road, Suite 100
                               Bettendorf, Iowa 52722
                             Telephone: (563) 326-2840

                                By email to: info@crgrb.org
                                 By fax to: 563.326.2870


   19. HOW DO I GET MORE INFORMATION?
       More information is available in the court documents, You may contact the Clerk
of the Federal District Court for the Central District of Illinois or the Settlement
Administrator toll free at 1-866-778-0475 or leudersettlement@administarllc.com.
Alternatively you may contact Class Counsel.




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