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Estate of Hoover E. Ensor; David and Carol Goss; Sandra Cornwell, as the Personal<br />
Representative of the Estate of Mack Hartman; Joseph Edward Hawkins, Jr., Individually and<br />
as the Personal Representative for the Estate of Joseph Edward Hawkins, Sr.; Shirley Ellen<br />
Koehne, Individually and as the Personal Representative of the Estate of John D. Koehne;<br />
Vivian Mountney, Individually and as the Personal Representative of the Estate of George<br />
Mountney; Roger S. Weinberg and Cheryl A. Schattall, as Personal Representatives of the<br />
Estate of James P. Olszewski; Antonina Parisi, Individually and as the Personal Representative<br />
of the Estate of Carmclo Parisi; Willis Henderson Pope and Dorothy Louise Pope; George S.<br />
Cantler, Jr, as the Personal Representative of the Estate of Clinton Purner; Carol Tezyk,<br />
Individually and as the Personal Representative of the Estate of Stanley Tezyk; Rosemarie<br />
Carroll, Individually and as the Personal Representative of the Estate of Donald Charles<br />
Carroll; Melvin Hauer; Doris Hayes, Individually and as the Personal Representative of the<br />
Estate of Clifton E. Hayes, Jr.; Mary Tarkir, Individually and as the Personal Representative of<br />
the Estate of Richard Anthony Tarkir; Gary Thompson and Ilka Thompson; and Teresa Weisz,<br />
Individually and as the Personal Representative of Mark Weisz (collectively, the `Kilnoise<br />
Claimants"), have asserted, among other claims, direct, non-derivative claims against Pfizer<br />
arising from their exposure to an acoustic plaster known as Kilnoise and resultant personal<br />
injuries (the "Kilnoise Claims'); and<br />
WHEREAS, on or about October 6, 2005, Quigley filed its Third Amended Plan Of<br />
Reorganization Under Chapter I I Of The Bankruptcy Code (the "Plan'"); and<br />
WHEREAS, under the terms of the Plan direct claims against Pfizer (such as the Pfizer<br />
Settlement Agreement and the Kilnoise Claims) are not channeled to the section 524(g) trust to<br />
be established pursuant to the Plan (the "Plan Trust') and are not subject to treatment under the<br />
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