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EXHIBIT F

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WHEREAS, on September 3, 2004 (the "Petition Date'), Quigley Company, Inc.<br />

("Quigley) filed a petition for relief under chapter 11 of the Bankruptcy Code, and on the<br />

Petition Date Quigley also filed a Motion for an Order Pursuant to Sections 105 (a) and 362<br />

(a) of the Bankruptcy Code and Bankruptcy Rule 7065 Confirming Application of the<br />

Automatic Stay and Granting a Preliminary Injunction and a Temporary Restraining Order<br />

(the "PI Motion ); and<br />

WHEREAS, pursuant to the PI Motion, the Court entered an Injunction Pursuant to I I<br />

U.S.C. §§ 105 (a) and 362 (a) and Federal Rules of Bankruptcy Procedure 7065 (the "Section<br />

105 Injunction"), which provides, among other things, that any party that demonstrates to the<br />

Court, and as to which the Court finds, that (1) the party holds a Pfizer-only Claim (as defined<br />

in the Section 105 Injunction); and (2) the Shared Insurance Policies or the funds in the<br />

Insurance Trust (each as defined in the Section 105 Injunction) could not be diminished or<br />

impaired in any way by the prosecution of the Pfizer-only Claim, may obtain relief from the<br />

order; and<br />

WHEREAS, prior to the Petition Date, William F. Geritz, 111, Patrick S. Geritz and<br />

Jocelyn Geritz Held, Individually and as the Personal Representatives of the Estate of William<br />

F. Geritz, Jr. ("Geritz') entered into separate settlement agreements, one with Quigley and one<br />

with Pfizer, pursuant to which (i) Pfizer agreed to pay to Geritz the sum of $285,000 to settle<br />

personal injury claims made by Geritz (the "Pfizer Settlement Agreement"), and (ii) Quigley<br />

agreed to pay to Geritz the sum of $665,000 to settle personal injury claims made by Geritz (the<br />

"Quigley Settlement Agreement"); and<br />

WHEREAS, .Kateri Ellison, Individually and as the Personal Representative of the<br />

Estate of Lary C. Ellison; Joan T. Ensor, Individually and as the Personal Representative of the<br />

2

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