IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION

PENELOPE BAIM BLOCK, BRIJ M.  SHARMA, CHARANJIT SINGH,

LISA M. BERTINI, VANDANA   MAKKER, BALA M. KRISHNA,                

TY C. GERHARDT, JEFFREY  ZIMMERMAN, MUKESH                        

MITTAL, SANJAY AGARWAL, and SAVITA REDDY,                                

Plaintiffs,

v.                                                                      01 CH 9137

McDONALD’S CORPORATION,

Defendant.

NOTICE OF PROPOSED SETTLEMENT

Notice to all persons resident in the United States (including the District of Columbia, territories and possessions [hereinafter the “United States”]) including, but not limited to, vegetarians and Hindus, who:  (i) have consumed french fries or hash browns from or at McDonald’s restaurants in the United States  since July 23, 1990; and (ii) have concerns, objections or dietary restrictions, whether ethical, moral, religious, philosophical or health-related, with respect to the consumption of beef or meat

This notice may affect your rights.

Please read it carefully.

The Litigation.

On June 6, 2001, a proposed class action lawsuit was commenced against McDonald’s Corporation (“McDonald’s”), entitled Block v. McDonald’s Corporation, (Circuit Court of Cook County Case No. 01 CH 9137) (the “Action”).  The Second Amended Complaint in the Action asserts claims for violations of the consumer fraud laws and common law principles of all 50 states.  The Action alleges that McDonald’s provided false and misleading nutritional information to consumers by failing to disclose that its french fries and hash browns contain a small amount of beef flavoring and thus are not vegetarian.

The Class Members.

For purposes of settlement, the Court has certified  a class consisting of all persons resident in the United States including, but not limited to, vegetarians and Hindus, who:  (i) have consumed french fries or hash browns from or at McDonald’s Restaurants in the United States since July 23, 1990; and (ii) have concerns, objections, or dietary restrictions, whether ethical, moral, religious, philosophical, or health-related, with respect to the consumption of beef or meat (the “Plaintiff Settlement Class”).  If you fit within this definition, you will be considered a member of the class unless you request to be excluded.  YOU NEED NOT DO ANYTHING IF YOU WISH TO BE INCLUDED IN THE SETTLEMENT.

Description of the Settlement.

McDonald’s denies the allegations made in the Action, and denies any and all liability with respect to the facts alleged therein.  Further, McDonald’s denies that plaintiffs are entitled to any relief whatsoever.  The Court has not decided in favor of either plaintiffs or McDonald’s.  However, McDonald’s has reached a settlement with the plaintiffs.

As part of the settlement, McDonald’s has agreed to:  (i)  donate $10 million to charitable organizations in the following percentages:  vegetarianism (60 percent); Hinduism and/or Sikhism (20 percent); children’s nutrition and/or children’s hunger relief (10 percent); and promotion of the understanding of Jewish law, standards and practices with respect to Kosher foods and dietary practices (10 percent); (ii) issue an apology; and (iii) establish an advisory board to make reports and recommendations to McDonald’s about dietary restrictions that apply to various types of vegetarians, as well as guidelines for companies who market to vegetarians.  The apology is to be published concurrently with this notice.

Plaintiffs’ counsel may apply to the Court for an award of attorneys’ fees, costs and expenses not to exceed $2.452 million, which is separate from and in addition to the $10 million donation to charitable organizations.  The settlement also provides for incentive awards of up to $4,000 each for the eleven named plaintiffs who are part of the settlement, which amounts are separate from and in addition to the $10 million donation to charitable organizations.

All members of the class who have not excluded themselves will be bound by any final judgment entered by the Court.  All claims of the Plaintiff Settlement Class members which were or could have been asserted in the Action will be released as provided in the Settlement Agreement (and the reference to “food products” in paragraph 1.11 of the Settlement Agreement shall mean french fries and hash browns), and class members will be forever barred from seeking other or further relief on such claims.

Right to Object

Any class member who objects to the settlement and who has not opted out (see procedure below), may file a written objection with the Court.  ANY SUCH OBJECTION MUST BE MAILED TO THE CLERK OF THE COURT AND SERVED ON THE ATTORNEYS FOR THE CLASS AND ATTORNEYS FOR McDONALD’S, AT THE ADDRESSES SET OUT BELOW, POSTMARKED ON OR BEFORE JULY 8, 2002.  ANY OBJECTIONS TO THE SETTLEMENT SHOULD BEGIN WITH THE FOLLOWING STATEMENT:  “I OBJECT TO THE PROPOSED SETTLEMENT IN Block v. McDonald’s Corporation, (Circuit Court of Cook County, Case No. 01 CH 9137).”  All objections must state the objector’s name and address and all grounds for the objection in writing.  Objections should be sent to:  (1) Daniel A. Edelman, Edelman, Combs, Latturner & Goodwin, LLC, 20 South Clark Street, Suite 1500, Chicago, IL 60603, and (2) Alan H. Silberman, Sonnenschein, Nath & Rosenthal, 8000 Sears Tower, 233 South Wacker Drive, Chicago, IL 60606.

Right to Opt Out

If you do not wish to be a member of the class, you may exclude yourself by mailing a written request to be excluded postmarked no later than July 8, 2002, and addressed to:  (1) Daniel A. Edelman, Edelman, Combs, Latturner & Goodwin, LLC, 20 South Clark Street, Suite 1500, Chicago, IL 60603; and (2) Alan H. Silberman, Sonnenschein, Nath & Rosenthal, 8000 Sears Tower, 233 South Wacker Drive, Chicago, IL 60606.  The request should state your name and address, and reference the name of this case.  If you choose to exclude yourself from the class, you will not be affected by the Action, and will not be able to participate in or object to this settlement, but you will not release any rights.

Court Hearing and Final Approval

The proposed Settlement must be finally approved by the Court.  On August 22, 2002, at 2:00 p.m., in the Circuit Court of Cook County, Courtroom 2305, located at Richard J. Daley Center, Chicago, IL 60602, a hearing will be held on whether the proposed settlement should be approved as fair, reasonable and adequate.

If you file a timely written objection and have not opted out of the class, you may appear at the hearing in person or through an attorney retained at your own expense.  IF YOU WISH TO APPEAR AT THE HEARING TO OBJECT TO THE SETTLEMENT, YOU MUST NOTIFY COUNSEL IN WRITING, AS SET FORTH ABOVE, OF YOUR INTENTION TO DO SO, WITH YOUR WRITTEN OBJECTION AS DESCRIBED ABOVE.  DO NOT CALL OR PERSONALLY CONTACT THE COURT OR McDONALD’S ABOUT MATTERS SET FORTH IN THIS NOTICE.

Examination of Papers.

You may inspect the complete Settlement Agreement, the Addendum to Settlement Agreement, the Complaint, and the file in this lawsuit during the hours of 8:00 a.m. to 4:30 p.m., Monday through Friday (excluding holidays) at the office of the Clerk of the Court, Circuit Court of Cook County, Richard J. Daley Center, Room 802, Chicago, IL 60602.  Copies of the Settlement Agreement, including exhibits, and the Addendum to Settlement Agreement are available at plaintiffs’ counsel’s websites, located at <www.edcombs.com>, <www.hbharti.com>, <www.hagens-berman.com>, <www.caddellchapman.com>, and <www.bergermontague.com>.

Additional Information

DO NOT CONTACT THE COURT OR McDONALD’S CONCERNING THIS NOTICE OR THE LAWSUIT.  If you have questions or if you would like more information about this notice or this case, contact your own attorney or you may contact us.