Korean Claimants
  1. Joint Motion to Dismiss dated 2015-4-24

  2. Response by Mr. Kim dated 2015-5-03

  3. Response in Support of Suggested Mootness dated 2015-5-14

  4. Supplemental Response by Mr. Kim dated 2015-6-01

Consent Order to Establish Guidelines for Distributions from the Class 7 Silicone Material Claimants' Fund
  1. Consent Order filed May 22, 2015

    1. Exhibit A
    2. Exhibit B
    3. Exhibit C
    4. Exhibit D
    5. Exhibit E
    6. Exhibit F
    7. Exhibit G
    8. Exhibit H
    9. Exhibit I
    10. Exhibit J
    11. Exhibit K
    12. Exhibit L
    13. Exhibit M
    14. Exhibit N
    15. Exhibit O
    16. Exhibit P
    17. Exhibit Q
    18. Exhibit R
    19. Exhibit S
    20. Index of Exhibits

  2. Order Authorizing Distribution of Notice under Class 7

  3. Notice of Proposed Order Establishing Guidelines for Distribution from the Class 7 Fund

  4. 2015, July 29 Scheduling Order Regarding Consent Order to Establish Guidelines for Distributions from Class 7 Silicone Material Claimants' Fund

  5. 2015, September 15 Omnibus Response to Objections & Submissions Responding to Consent Order to Establish Guidelines for Distribution From Class 7 Silicone Materials Claimants Fund

Motion By Korean Claimants To Recategorize
  1. Motion by Mr. Kim to Recategorize filed April 7, 2014

    1. Exhibit 1
    2. Exhibit 2
    3. Exhibit 3
      Exhibit 4
    4. Exhibit 5
    5. Exhibit 6

  2. DCC Response to Mr. Kim's Motion for Recategorization filed April 24, 2014

  3. CAC Response to Mr. Kim's Motion for Recategorization filed April 24, 2014

Korean Claimants Motion To Extend Class 7 Deadline
  1. Motion by Mr. Kim for Extension of Deadline of Class 7 Claimants filed March 7, 2014

  2. DCC Motion to Dismiss and Response to Appeal filed by Korean Claimants filed March 7, 2014

  3. CAC Response in Opposition to Motion for Extension of Deadline for Class 7 Claimants filed March 7, 2014

Dow Corning's Motion Regarding Calculation of Time Value Credits
  1. Dow Corning's Motion Regarding Calculation of Time Value Credits, filed January 8, 2010

  2. CAC's Response to Dow Corning's Motion, filed February 12, 2010

  3. Joint Stipulation and Order Setting Briefing Schedule and Hearing Date on CAC Motion Regarding Treatment of Initial Payment filed 8-1-2013

  4. Motion of CAC for Order Resolving Dispute Regarding Treatment of Initial Payment filed 8-5-2013

  5. Opposition of Dow Corning to Motion of CAC for Order Resolving Dispute Regarding Treatment of Initial Payment dated 09-09-2013

  6. Reply in Further Support of Motion of CAC for Order Resolving Dispute Regarding Treatment of Initial Payment dated 09-27-2013

CAC Motion To Extend the June 1, 2006 Deadline For Certain Groups of Claimants.
  1. CAC Motion for Extension of the June 1, 2006 Deadline for Certain Groups of Claimants - Document #400

  2. Dow Corning's Response to CAC - Document #413

  3. Dow Corning's Supplemental Response to CAC - Document #415-1

  4. Reply of CAC to Dow Corning's Response - Document #418

  5. Index to Exhibits to CAC Reply

  6. Exhibits 1, 1A - 1H to CAC Reply

  7. Exhibits 2, 4, 5 to CAC Reply (Exhibit 3 not posted - Confidential)


Motion by Siegel Kelleher for Extension of the June 1, 2006 Deadline and Request to allow expert rupture reports
  1. Motion for Extension - Document #399

  2. CAC Response to Siegel Kelleher Motion - Document #412

  3. CAC's Response to Siegel Kelleher and Exhibits 1-3

  4. CAC's Response to Siegel Kelleher and Exhibits 4-10

  5. CAC's Response to Siegel Kelleher and Exhibits 11-12

  6. Dow Corning's Response to Motion - Document #411

  7. Dow Corning's Response to CAC's Response to Siegel Kelleher and Exhibits A - M - Document #426
    Exhibit A
    Exhibit B
    Exhibit C
    Exhibit D
    Exhibit E
    Exhibit F
    Exhibit G
    Exhibit H
    Exhibit I
    Exhibit J
    Exhibit K
    Exhibit L
    Exhibit M

Notice of Hearing on Motion by Dow Corning To Authorize Disposition of Claim Records.
  1. Notice of Hearing on Motion

  2. Order Authorizing Daticon To Destroy Records


CAC Motion for Declaratory Judgment
  1. CAC Motion for Declaratory Judgment That The "Receipt and Release" Document Solicited By The Dow Corning Legal Department From Unrepresented Claimants From 1992 - 1995 As Part of the Removal Assistance Program (Or Represented As Part of Such Program) Is Not A General Release"

  2. Memorandum in Support of Motion of Claimant's Advisory Committee for Declaratory Relief that the "Receipt and Release" Document Solicited by the Dow Corning Legal Department from Unrepresented Claimants from 1992-1995 as Part of the Removal Assistance Program (or Represented as Part of Such Program) is Not a General Release
  3. Exhibit 1
    Exhibit 2A
    Exhibit 2B
    Exhibit 2C
    Exhibit 2D
    Exhibit 2E
    Exhibit 2F
    Exhibit 3
    Exhibit 4
    Exhibit 5
    Exhibit 6 Part 1
    Exhibit 6 Part 2
    Exhibit 6 Part 3
    Exhibit 6 Part 4
    Exhibit 6 Part 5
    Exhibit 6 Part 6
    Exhibit 6 Part 7
    Exhibit 6 Part 8
    Exhibit 7
    Exhibit 7A
    Exhibit 7B
    Exhibit 7C
    Exhibit 8
    Exhibit 9
    Exhibit 10
    Exhibit 11
    Exhibit 12
    Exhibit 13
    Exhibit 14
    Exhibit 15
    Exhibit 16
    Exhibit 17
    Exhibit 18
    Exhibit 19
    Exhibit 20
    Exhibit 21
    Exhibit 22
    Exhibit 23
    Exhibit 24
    Exhibit 25
    Exhibit 26
    Exhibit 27
    Exhibit 28
    Exhibit 29
    Exhibit 30
    Exhibit 31
    Exhibit 32
    Exhibit 33A
    Exhibit 33B
    Exhibit 34
    Index of Exhibits

  4. DCC Response to CAC Motion for Declaratory Judgment Regarding the Release & Receipt Document.
  5. Exhibit List
    Exhibit 1, Part 1
    Exhibit 1, Part 2
    Exhibit 2
    Exhibit 3
    Exhibit 4
    Exhibit 5

  6. Reply of CAC to Dow Corning's Response Regarding Validity of Releases
  7. Updated List of Exhibits
    Exhibits 35-44 (Exhibit 44 is filed under seal)
    Exhibits 45-54

Motion For Equitable Relief

Motion For Equitable Relief by Nancy Forehand w/exhibits

CAC Motion regarding eligibility of Dow Corning Tissue Expanders as Breast Implants
  1. CAC's Motion regarding the eligibility of tissue expanders implanted in the breast to be treated as breast implants, filed on July 19, 2004

  2. Dow Corning's Motion seeking to deny tissue expanders implanted in the breast from being treated as breast implants, filed July 19, 2004

  3. CAC's Response to Dow Corning's Motion regarding Tissue Expander Eligibility (with exhibits)
    Exhibit 1
    Exhibit 2

  4. *NEW* Dow Corning's Memorandum Regarding Extrinsic Evidence of the Meaning of "Breast Implant" and "Tissue Expander," filed on March 29, 2011

  5. *NEW* Memorandum of CAC Regarding Extrinsic Evidence of the Parties Intended Meaning of "Breast Implant" filed April 11, 2011

CAC Motion regarding Tolling of 24 Month/5 Year Requirement for Disease Option 2 claims
  1. CAC's Motion regarding the tolling language in Disease Option 2 regarding the�"24 month / 5 year" provision, filed on July 19, 2004

  2. Dow Corning's Motion seeking to limit the tolling language in Disease Option 2 to just the 5 year part of the 24 month / 5 year requirement, filed July 19, 2004

  3. CAC's Response to Dow Corning's Motion on the Tolling Language Dispute (with exhibit)
    Exhibit 1


Motion by Korean Claimants to locate QMD in Korean
  1. Motion of Korean Claimants For The Settlement Facility To Locate Qualified Medical Doctor of Korea and Either Pay For That Qualified Medical Doctor To Travel To Korea And Conduct The Disease Evaluations Or Hire Qualified Medical Doctor In Korea To Conduct The Reviews At The Settlement Facility's Expense, filed December 14, 2004

  2. Response of Dow Corning to the Motion of Korean Claimants, filed December 28, 2004

  3. Response of Claimants' Advisory Committee to Motion of Korean Claimants to locate QMD (with exhibit)
    Exhibit 1


CAC Motion regarding Tolling Cure Deadlines in the Settlement Facility (and related individual motions)
  1. Motion of [Claimant Name Redacted] To Toll The Six Month Deadline For Curing Rupture Deficiencies

    1a. Motion to Withdraw Motion, filed August 16, 2005

  2. Response of�CAC to Motion To Toll The Six Month Deadline For Curing Rupture Deficiencies�and Motion of CAC To Toll The Cure Deadline For All Requests For Re-Review That Are Pending More Than 21 Days

  3. DCC Response to Motion to Toll The Six Month Deadline For Curing and Response to CAC Motion to Toll the Cure Deadline for All Requests For Re-Review That Are Pending More Than 21 Days

  4. Motion of Claimant DeSantos to Toll Cure Deadline

    4a. Notice of Withdrawal of Motion, filed July 15, 2005

  5. Motion of Claimant Vanlandingham to Toll Cure Deadline

    5a. Notice withdrawn verbally at hearing on July 29, 2005

  6. Motion by Motley Rice For Expedited Consideration For Tolling of Disease Deficiences and Request For Six Month Extension For Curing Past and Future Disease Deficiencies, filed May 27, 2005

    6a. Notice of Substitution of Plaintiffs' Exhibits 22 and 23

  7. Motion #1 by Doffermyre Shields To Toll The One Year Deadline For Curing Disease Claim Deficiencies For [Claimant Name Redacted]
    7a. Motion to Withdraw Motion

  8. Motion #2 by Doffermyre Shields To Toll The One Year Deadline For Curing Disease Claim Deficiencies For [Claimant Name Redacted]

    8a. Motion to Withdraw Motion

  9. Motion by Doffermyre Shields To Toll The Six Month Deadline For Curing Rupture Deficiencies For [Claimant Name Redacted]

    9a. Notice to Withdraw Motion, filed August 16, 2005

  10. Motion of Nita Baldwin To Toll The Six-Month Deadline For Curing Rupture Deficiency

    10a. Issue resolved by SF-DCT

  11. Motion of Claimant Susannah Breen In Support of To Toll The One Year Deadline For Curing Disease Deficiencies

    11a. Motion to Withdraw Motion

  12. Motion of Laura Ayon-Azzar To Toll The One Year Deadline For curing Disease Claim Deficiencies and Request For Six Month Extension For Curing Past and Future Disease Deficiencies

  13. Motion of Beth Bogert To Toll The One Year Deadline For curing Disease Claim Deficiencies and Request For Six Month Extension For Curing Past and Future Disease Deficiencies

  14. Motion of Marcia Rathbun To Toll The One Year Deadline For curing Disease Claim Deficiencies and Request For Six Month Extension For Curing Past and Future Disease Deficiencies

  15. Out of time Motion and Memorandum in Support of Immediately Ordering The Dow Corning Settlement To Evaluate All Level A Disabilities According to the Language Found in the Settlement Document Which Allows A QMD To Apply The Definitions of Either Vocation or Self-Care; Tolling The One Year Deadline For curing Disease Claim Deficiencies For Helen Bolstorff Until The Decision Is Made (filed by Faris & Faris Law Office)

  16. Plaintiffs' Motion and Memorandum in Support of Expedited Consideration of Tolling of Deficiencies and Request for Six Month Extension For Curing Past and Future Deficiencies (filed by Gauthier, Houghtaling & Williams)

    17a. Notice of Withdrawal of Motion


CAC Omnibus Motion For Relief On Behalf Of All Settling Claimants Whose Cure Deadline(s) Have Already Run Or Are About To Run Within The Next Six Months
  1. Omnibus Response of CAC To Seven Additional Motions Seeking Relief in the Form of Tolling And/Or Extension of Cure Deadlines For Claim Submissions and CAC Omnibus Motion For Relief On Behalf Of All Settling Claimants Whose Cure Deadline(s) Have Already Run or Are About To Run Within The Next Six Months, filed June 27, 2005.

  2. Agreed Order To Indefinitely Defer The Deadline For Debtor's Representatives To Respond To The Omnibus Motion of CAC For Relief On Behalf of All Settling Claimants Whose Cure Deadline(s) Have Already Run or Are About to Run Within The Next Six Months


CAC Motion For Disclosure of Substantive Criteria
  1. CAC Motion For Disclosure of Substantive Criteria Created, Adopted And/Or Being Applied By The Settlement Facility And Request For Expedited Consideration

  2. Reply of CAC to Dow Corning's Response To The Motion For The Disclosure For Disclosure of Substantive Criteria Created, Adopted And/Or Being Applied By The Settlement Facility And Request For Expedited Consideration

  3. CAC Reply to DCC's Response

  4. Notice of Filing Supplemental Exhibit by CAC

  5. Response of Dow Corning to Filing of Supplemental Exhibit

  6. Objection of Dow Corning to Filing of Supplemental Exhibit

  7. Reply of CAC to Dow Corning's Response and Objection
  8. Index of Exhibits to CAC Reply
    Exhibits 13-17 to CAC Reply
    Exhibits 18-21 to CAC Reply
    Exhibits 22-25 to CAC Reply

  9. Dow Corning's Motion to Strike Certain Submissions and Arguments of the CAC and Plaintiffs' Counsel From The Record In Connection With The Disability Level A Proceedings
    DCC M to Strike Certain Exh.pdf
    Exh B - Austern Affidavit.pdf
    Exh C Under Seal Label
    Exh D Excerpts from Annex A.pdf
    Exh E1 Under Seal Label
    Exh E2 Under Seal Label
    Exhibit A - Nov 19.2001 Mem.pdf

CAC Motion re adding new Proof of Manufacturer Protocol
  1. Stipulation and Agreed Order Regarding Pre-1971 Breast Implant Identification Protocol

  2. Motion To Deem Pre-1971 Silicone Gel Breast Implants As Dow

  3. Response of CAC to Motion To Deem Pre-1971 Silicone Gel Breast Implants As Dow and Motion of CAC To Amend Annex A To The Settlement Facility and Fund Distribution Agreement To Adopt An Additional Proof of Manufacturer Protocol


Motion by Spitzfaden Claimants re Processing
  1. Motion of Spitzfaden Claimants

  2. Agreed Order Regarding Processing of Spitzfaden Claimants


Joint Motion to Establish Procedures To Determine Status of Late Claimants
  1. Joint Motion
For more information about orders and deadlines pertaining to Late Claim Requests, please click on the heading titled "Late Claims" on the upper left side of this page.



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