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and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated
<br />claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to the facts
<br />and circumstances alleged in the Consolidated Proceedings ("Released Claims"), provided however, that nothing
<br />herein shall release claims involving any negligence, personal injury, breach of contract, bailment, failure to de-
<br />liver lost goods, damaged or delayed goods, product defect; securities or similar claim relating to Alum. During the
<br />period after the expiration of the deadline for submitting an opt -out notice, as determined by the Court, and prior
<br />to Final Judgment, all Releasing Parties shall be preliminarily enjoined and barred from asserting any Released
<br />Claims against the GEO Released Parties. The GEO Settling Parties further agree that they will not file any suit
<br />against the Releasing Parties and their current and former, direct and indirect, parents, subsidiaries, affiliates, di-
<br />rectors, officers, shareholders, and employees arising out of or relating to the Released Claims. The release of the
<br />Released Claims will become effective as to all Releasing Parties upon Final Judgment. Upon Final Judgment, the
<br />Releasing Parties further agree that they will not file any other suit against the GEO Released Parties arising out of
<br />or relating to the Released Claims.
<br />• Further Release: In addition to the provisions above (i.e.; Paragraph 15 of the Settlement Agreement), the Releas-
<br />ing Parties expressly waive and release, solely with respect to the Released Claims, upon Final Judgment, any and
<br />all provisions, rights, and benefits conferred by Section 1542 of the California Civil Code, which states:
<br />CERTAIN CLAIMS NOT AFFECTED BY GENERAL RELEASE. A GENERAL RELEASE DOES
<br />NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO
<br />EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF
<br />KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLE-
<br />MENT WITH THE DEBTOR;
<br />or by any law of any state or territory of the United States, or principle of common law, which is similar, compa-
<br />rable, or equivalent to Section 1542 of the California Civil Code. Each Releasing Party may hereafter discover
<br />facts other than or different from those which he, she, or it knows or believes to be true with respect to the claims
<br />which are released pursuant to the provisions above (i.e., Paragraph 15 of the Settlement Agreement), but each
<br />Releasing Party hereby expressly waives and fully, finally, and forever settles and releases, upon Final Judgment,
<br />any known or unknown, suspected or unsuspected, contingent or non -contingent claim that the Releasing Parties
<br />have agreed to release pursuant to the provisions above (i.e., Paragraph 15 of the Settlement Agreement), whether or
<br />not concealed or hidden, without regard to the subsequent discovery or existence of such different or,additional facts.
<br />Reservation of Claims. -The Parties intend by the Settlement Agreement to release only the GEO Released Parties
<br />-with respect to the Released Claims. The Parties specifically do not intend the Settlement Agreement, or any part
<br />thereof or any other aspect of the proposed Settlement, to compromise or otherwise affect in any way any rights the
<br />Releasing Parties have or may have against any other person, firm, association, or corporation whatsoever, includ-
<br />ing, but not limited to the Non -Settling Defendants. The release set forth in Paragraphs 15 and 16 of the Settlement
<br />Agreement is not intended to and shall not release any claims other than the Released Claims. The sales of Alum by
<br />GEO in the United States from January 1, 1997 through at least February 28, 2011 shall remain in the cases against
<br />the Non -Settling Defendants in the Consolidated Proceedings as a basis for damage claims and shall be part of any
<br />joint and several liability claims against Non -Settling Defendants in the Consolidated Proceedings or other persons
<br />or entities other than the GEO Released Parties.
<br />EXCLUDING YOURSELF FROM THE DIRECT PURCHASER SETTLEMENT CLASS
<br />If you want to keep the right to sue or continue to sue the GEO Settling Parties on your own about the legal issues being
<br />resolved by the Settlement, then you must take steps to get out of the Direct Purchaser Settlement Class. This is called
<br />excluding yourself - or sometimes referred to as "opting out." If you opt out of the Direct Purchaser Settlement Class, you
<br />will not receive any payment from the Net Settlement Fund.
<br />To exclude yourself, you must send a letter saying that you want to be excluded from the Direct Purchaser Settlement
<br />Class. The letter must include the following information: (i) a statement indicating that you want to be excluded from the
<br />Direct Purchaser Settlement Class 'in In Re: Liquid Aluminum Sulfate Antitrust Litigation, Civil Action No. 16-md-2687
<br />(JLL) (JAD); (ii) your name, address, telephone number, and your signature; and (iii) all trade names or business names
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