IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ALEX VOLKOV, Plaintiff,                                       Case Number:   01 C 4038

v.                                                                   Judge Rebecca R. Pallmeyer

ALLIED INTERSTATE, INC. and                              Magistrate Judge Ian H. Levin

ALLIED INTERSTATE WEST, INC.,

Defendants.

NOTICE OF CLASS ACTION SETTLEMENT

         PLEASE READ THIS NOTICE CAREFULLY.

THIS IS NOT A NOTICE OF A LAWSUIT AGAINST YOU.

YOU MAY BENEFIT FROM READING THIS NOTICE.

I.          WHY ARE YOU RECEIVING THIS NOTICE?

This Notice informs you, pursuant to Rule 23(c)(2) of the Federal Rules of Civil

Procedure, that there is a settlement in a consolidated class action lawsuit, entitled Alex Volkov v. Allied Interstate, Inc. and Allied Interstate West, Inc., Case Number 01 C 4038, in the United States District Court for the Northern District of Illinois Eastern Division.  You have been identified as a member of this class.

II.            WHAT IS THIS LAWSUIT ABOUT?

Plaintiff, Alex Volkov, filed this class action lawsuit against Allied Interstate, Inc. and Allied Interstate West, Inc.. (defendants), alleging that the defendant violated the Fair Debt Collection Practices Act, 15 U.S.C. ‘1692 et al. (AFDCPA@).

Defendants deny that they violated the FDCPA and therefore maintains that it is not liable to the plaintiff or any class member.

III.       WHO IS IN THE CLASS?

On January17, 2002, the Court certified a class for the purposes of settlement.  The class consists of (i) all individuals with Illinois addresses (ii) who were sent a letter in the form represented by Exhibit A of the complaint, (iii) on or after January 1, 2001, (iv) which was not returned as undeliverable by the Postal Service.

IV.            WHAT ARE THE POTENTIAL BENEFITS?

The Court has preliminarily approved a settlement in this action.  According to the terms of the settlement, defendants agree to pay $39,7500.00 to the class, divided equally among each class member who submits a valid claim form.  The claim may be made by returning the claim form enclosed with this notice to defendants= attorneys on or before May 15, 2002.

Plaintiff, will be paid $1,500 in satisfaction of his individual claims and may share in the class recovery.

Counsel for the class, subject to court approval, will be paid $13,750.00 for attorney=s fees and costs.

The defendants are to make all payments within thirty (30) days after the Court grants final approval of the settlement, unless there is an appeal of the approval.  The hearing on final approval will be held at a Fairness Hearing on May 30, 2002 at 9:00 a.m.  You need not attend this hearing to participate in this settlement.

V.             RELEASE.

Under this settlement, you are giving the defendants a release, whether or not you submit a claim form, unless you opt-out of the class. You are releasing defendants from all claims for statutory damages arising from the allegations in the complaint.  This settlement does not release any claims for actual damages.

VI.            WHAT CAN YOU DO?

1. Participate in the class settlement.  For you to participate in this settlement, you must make a claim.  You may make a claim by using the claim form enclosed with this notice.  You must submit your claim form by May 15, 2002 in order to get the benefits of the settlement described above.

2. Opt-Out.  If you object to the settlement, you must submit your objection in writing to the Clerk of the United States District Court for the Northern District of Illinois, 219 South Dearborn Street, Suite 2722, Chicago IL 60604.  The objection must be received by the Clerk of the Court by May 15, 2002.  By the same date, you must also serve copies on the attorneys listed under “Who Represents the Class?,” below, and on Scott Thomas, Raymond Persin of Thomas & Persin, 500 West Madison, Suite 2790, Chicago, Illinois 60610 (attorney for defendants).  Any objection must include the name and number of the case and a statement of the reasons why you believe that the Court should find that the proposed settlement is not in the best interests of the class.  If you do file an objection and wish to be heard, you may also appear at the Fairness Hearing before Judge Pallmeyer on May 30, 3002 at 9:00 a.m. Please note that it is not sufficient to simply state that you object.  You must state reasons why the settlement should not be approved.

IMPORTANT:  THE COURT REQUIRES THAT ANY OBJECTIONS BE RECEIVEDBY THE CLERK BY MAY 30, 2002.  IF YOU MAIL AN OBJECTION, YOU BEAR THE RISK OF ANY PROBLEM WITH THE MAILS.

If the settlement is not approved, the case will proceed as if no settlement has been attempted.  There can be no assurance that if the settlement is not approved, the class will recover more than is provided in this settlement, if indeed anything.

This description of the case is general and does not cover all of the issues and proceedings thus far.  In order to see the complete file, you should visit the office of the Clerk of the United States District Court for the Northern District of Illinois, 219 S. Dearborn St., 20th Floor, Chicago, IL 60604. The Clerk will make the files relating to this lawsuit available to you for inspection and copying at your own expense.

If you submit a claim form in timely fashion, defendant will send you a check within 30 days after final approval of the settlement, unless there is an appeal.  If you wish, you may consult with an attorney, or file objections, as described above, at your expense.  You also have the right to file an appearance in the case if you wish.

This notice is only a summary of the terms of the proposed settlement.

VII.     WHO REPRESENTS THE CLASS?

The Court has appointed the following attorneys as Class Counsel:

Daniel A. Edelman

Cathleen Combs

James O. Latturner

Adela C. Lucchesi

EC&L Number 7163

EDELMAN, COMBS, LATTURNER, & GOODWIN, LLC

120 South LaSalle Street, 18th Floor

Chicago, Illinois 60603

Class Counsel represents your interests in this lawsuit.  You will not be charged for their services. You may, however, hire your own attorneys at your own cost to advise you in this matter.

VIII.            WHAT IS THE OPINION OF CLASS COUNSEL CONCERNING

THE VALUE OF THE SETTLEMENT?

The attorneys for the class believe that this settlement is fair, reasonable, and in the best interests of all members of the class.

Plaintiff filed his Complaint on this class action lawsuit on May 31, 2001, alleging that defendant violated the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et seq. (AFDCPA@).

Class counsel believe that the payment provided for by this settlement is fair and reasonable and that the class members should accept this settlement.

IX.       WHO CAN HELP WITH ADDITIONAL INFORMATION?

Any further questions that you or your attorney may have concerning this Notice should be directed to Class Counsel, Edelman, Combs, Latturner & Goodwin, LLC (phone number and address given above).

DO NOT ADDRESS ANY QUESTIONS ABOUT THE CASE TO THE CLERK OF THE COURT OR TO THE JUDGE.  They are not permitted to answer your questions.

X.            FAIRNESS HEARING

You do not have to attend this hearing in order to receive the benefit of this settlement.  On May 30, 2002 at 9:00 a.m., a hearing will be held on the fairness of the proposed settlement.  At the hearing, the Court will be available to hear any objections and arguments concerning the fairness of the proposed settlement.  The hearing will take place before Judge Pallmeyer in Room 2119 of the United States District Court, Northern District of Illinois, 219 S. Dearborn Street, Chicago Illinois 60604.

Michael W. Dobbins,

Clerk of the Court

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ALEX VOLKOV, Plaintiff,                            Case Number:  01 C 4038

v.                                                         Judge Rebecca R. Pallmeyer

ALLIED INTERSTATE, INC. and                   Magistrate Judge Ian H. Levin

ALLIED INTERSTATE WEST, INC.,

Defendants.

CLAIM FORM

Please fill out this form and return to the following address:

Name:                                                                                  

Current Address:                                                                

Social Security Number:                                                    

Signature:                                                                           

Please return this claim to:

Scott Thomas

Raymond Persin

THOMAS & PERSIN

500 West Madison, Suite 2790

Chicago, Illinois 60610

By: May 15, 2002