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In re Schering-Plough Corporation Securities Litigation

Master File No. 01-CV-0829(KSH/MF) In The United States District Court for the District of New Jersey

The Schering Plough Securities Litigation settlement provides a $165,000,000 cash settlement fund for the benefit of investors who purchased shares of Schering-Plough Corporation common stock from May 9, 2000, through February 15, 2001. Heffler Claims Administration received in excess of 71,000 Proofs of Claim (over 57,500 of which were filed electronically by large institutions or nominees). The matter involves a complex Plan of Allocation and Proof of Claim form processes, where Recognized Claim amounts were calculated for common stock purchased during the class period. It includes using a formula and algorithm that requires a separate calculation and comparison for each transaction matched on a first-in, first-out basis, whether a claimant held or sold their shares, and the date they purchased (and, if applicable, sold) their shares. Extensive audits of institutional and other high-end claims were conducted to verify that each claim was calculated properly.

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