EXHIBIT F

Plan. rather these claims will be unaffected by the confirmation of the Flan and will remain
viable to the extent they exist against Pfizer; and
WHEREAS, on or about December 16, 2005 Geritz and the Kilnoise Claimants moved
for relief from the Section 105 Injunction (Motion for Relief) in order to be allowed to pursue
and/or liquidate their respective claims against Pfizer; and
WHEREAS, Pfizer, Quigley, Geritz and the Kilnoise Claimants are now willing to
resolve their disputes regarding the Motion for Relief on the terms set forth below, provided
those terms are approved by the Court.
NOW, THEREFORE, in light of the recitals above and the consents of the parties
evidenced below, and for good cause shown, and the Court finding that the relief requested is in
the best interests of the Debtor, its creditors and its bankruptcy estate, it is by the United States
Bankruptcy Court for Southern District of New York, Agreed, Stipulated to and
ORDERED, that, within twenty (20) days of the date of the entry of this Order, Pfizer
shall pay to Geritz, in full satisfaction of all sums owed under the Pfizer Settlement Agreement,
the sum of $285,000, and it is further
ORDERED, that the claims of Geritz as liquidated pursuant to the terms of the Quigley
Settlement Agreement shall be channeled to the Plan Trust and treated and paid pursuant to the
terms of the plan of reorganization that is confirmed for Quigley by the Court, without the need
for further supporting documentation; and it is further
ORDERED, that that all requests for discovery served upon Pfizer and Quigley by the
Kilnoise Claimants shall be deemed withdrawn, and the motion by Pfizer and Quigley for a
protective order and for sanctions and the Motion for Relief shall be dismissed without
prejudice, subject to the right of the Kilnoise Claimants to seek relief from the Section 105
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