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C A N A D A
PROVINCE OF QUEBEC
DISTRICT OF HULL
No 550-06-000001-975 / (Class action)
S U P E R I O R C O U R T
______
ASSOCIATION FOR THE PROTECTION OF HENEY LACE
Plaintiff
v.

ATTORNEY GENERAL OF QUEBEC

Defendant

NOTICE TO MEMBERS

TO THE OWNERS OF TEMPORARY AND PERMANENT RESIDENCES BORDERING ON HENEY LAKE :

  1. TAKE NOTICE that a settlement has been reached with the Attorney General of Quebec in the present class action;
  1. The object of the agreement is to promote as much as possible the rehabilitation of the lake, without limiting the right of members of the class action to proceed against the Defendant for compensation for loss of property value if the rehabilitation objective is not reached within the time set in the present agreement;
  1. The Defendant undertakes to pay, as compensation measures, the amount of $4,940,000.00, from which will be deducted the extrajudicial fees and disbursements. This amount will serve entirely to defray the cost of rehabilitation measures of the lake and its watershed;
  1. To the extent that the lake should rehabilitate itself, without requiring the entirety of the amount, the balance of the capital and interest shall be invested in protection and conservation measures for the lake and its watershed;
  1. The Plaintiff undertakes to establish the Heney Lake Trust as a corporation, which will administer the whole of the amounts awarded in the present agreement;
  1. In consideration of the compensation measures provided for in this agreement, the Plaintiff and the members of the class action waive all claims in damages against the Defendant stipulated in the action, subject to the reservation, however, that, if the lake is not rehabilitated within five years, the Plaintiff and the members of the group shall be able to continue the present class action to obtain compensation for loss of property value, to the exclusion of any other damage;
  1. In order for the proposal to have force of law between the parties, the Superior Court of Quebec must approve the said proposal, which will then bind all members of the group;
  1. The Superior Court of Quebec will hold a hearing, to determine if it should approve the proposal, at the following place and time:

The 1st of June 2004, at 9:30 a.m., in room 1 of the Court House in Hull,

17 Laurier Street, Hull (Quebec) J8X 3Y9

  1. It is not necessary for you to participate at the hearing, however, if you are a member and wish to present your opinion on the said proposal, you have a right to participate at the hearing at the time and place above mentioned;
  1. If you wish to obtain further information relating to the terms of the agreement, please contact :

Mtre Michel Bélanger, attorney

Lauzon Bélanger, s.e.n.c.

511 Place d’Armes, suite 200

Montreal (Quebec) H2Y 2W7

Fax: (514) 844-7009

Telephone: (514) 844-3037

E-Mail:

  1. Copy of the settlement agreement is available on the following web site:

www. lauzonbelanger.qc.ca

THE PUBLICATION OF THIS NOTICE HAS BEEN AUTHORIZED BY THE SUPERIOR COURT OF QUEBEC

Lauzon Bélanger

Société en nom collectif