Myroslaw Smorodsky, P.A.
Petro R. Stawnychy, P.A.

Berlin, March 23, 2000. After thirteen months of intense negotiations in Washington DC, in Bonn and Berlin, Germany, German industry and representatives of slave and forced laborers and other Nazi victims reached an agreement on the distribution and allocation of the settlement amount that had been previously agreed to as the total amount of compensation to be paid to victims of the Nazi era. On December 17, 1999, representatives of five Central and East European countries (Belarus, The Czech Republic, Poland, Russia, and Ukraine), Israel, the Jewish Claims Conference, German industry and government, and the United States government had agreed to the overall amount of 10 BILLION Deutsche marks that would be paid as the total compensation package to Holocaust victims. Throughout the negotiations, the attorney for the Ukrainian class of forced and slave labor victims and for the Ukrainian delegation was Myroslaw Smorodsky of Rutherford, New Jersey.

However, after the December accord, extensive issues remained to be agreed upon including the allocation of the settlement amount between forced and slave laborers, the amount to be allocated to property losses, insurance claims and other wrongs, and the amount that would be set-aside for the "Future Fund". This latter fund was a project which German industry and government insisted upon as a condition of settlement. Germany wished to set aside a very large part of the settlement, which would be held in perpetuity to fund future projects aimed at preventing the recurrence of the horrors of the Nazi Era. The representatives of the victims argued that the emphasis should be placed on compensation of living victims rather than on humanitarian and educational projects, which, although laudatory, would not give direct benefit to living victims of the Holocaust. The allocation issues were complicated even further by the fact that the settlement amount of 10 BILLION Deutsche marks was in and of itself inadequate to even partially compensate for the suffering of the victims of World War II.

The allocation that was agreed to is as follows:

• Forced & Slave Labor, 8.1 BILLION Deutsche marks augmented by a contribution from the Swiss Bank litigation case and earned interest for a total of 8.250 BILLION Deutsche marks.
• Other Wrongs, 50,000,000 Deutsche marks.
• Banking claims and other property claims, 200,000,000 Deutsche marks.
• Banking humanitarian fund, 300,000,000 Deutsche marks for humanitarian projects.
• Direct Insurance claims, 150,000,000 Deutsche marks of which 50 million is from earned interest.
• Insurance humanitarian, 350,000,000 Deutsche marks for humanitarian projects.
• Reserve for insurance claims, 100,000,000 Deutsche marks.
• Future Fund, 700,000,000 Deutsche marks
• Administration costs, 200,000,000 Deutsche marks.

The programs for humanitarian projects will be established by a Foundation to be established under German law consisting of representatives from each of the victim groups and participating countries and German industry and Government.

Based upon information received from the victim representative groups and the Central & East European delegations, it is estimated that there are approximately 242,000 living slave laborers. In addition, there are approximately 82,000 slaves who were incarcerated in camps other than concentration camps. Known statistics indicate that approximately 575,000 individuals who worked as forced laborers for German industry are still alive. In addition, 666,000 farm laborers who were compelled to work on German farms are also survivors. Slave laborers will receive up to 15,000 Deutsche marks each. Forced laborers in industrial establishments and the other camps will receive up to 5,000 Deutsche marks each and farm workers will receive up to 1,000 Deutsche marks each. Victims who reside in the Central and East European countries will receive the proceeds of the settlement from existing Reconciliation Foundations that presently exist in each country. Jewish victims that reside in the west will be paid through the Jewish Material Claims Conference.

The distribution between the various representative groups is as follows:
 

Belarus	0.694 BL DM
The Czech Republic	0.423 BL DM
Poland	1.812 BL DM
Russia	0.835 BL DM
Ukraine	1.724 BL DM
The Jewish Claims Conference	1.812 BL DM

After the war, many forced laborers, especially from Poland and Ukraine, remained in the West and emigrated to the United States, Canada and other parts of the free world settling in major metropolitan areas such as New York and New Jersey. Presently, the number of such survivors is not known. As such, a reserve of 800,000,000 Deutsche marks has been set-aside for these forced and slave labor victims.

However, before payments to victims can begin, the German Parliament must adopt the appropriate legislation to monetarily fund the settlement. In addition, a procedure for registration and verification of claims, especially in the West, must be developed and implemented. It is anticipated that there will be an official worldwide notification and registration process during which forced and slave victims must register their claims. Optimistically, payments can begin late this year or in early 2001.

Please note that because of the fluctuating currency exchange rates, all sums referred to in this press release are given in German Deutsche marks. At present, the exchange ratio between Deutsche marks to United States dollar is approximately 2:1. Two (2) Deutsche marks for every dollar.

For further information, please call Myroslaw Smorodsky at the number listed above.