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February 6, 2004

ShareClass Action Settlement Agreement in the United States District Court for the District of Montana Helena Division

Plaintiffs (Travis, D. et al.) filed a Class Action Complaint in the United States District Court of Montana on August 23, 1996, and eventually filed a Second Amended Class Action Complaint (Complaint) in November 2001. The Complaint alleged violations of the federal Medicaid Act, the Rehabilitation Act, the Americans With Disabilities Act, corresponding federal regulations, the Fourteenth Amendment to the United States Constitution (violations of the Due Process and Equal Protection clauses), including alleged deprivations of federal rights pursuant to 42 U.S.C. 1983, by the State of Montana and various officers, employees, and institutions of the State of Montana. The Complaint generally challenges the State of Montana's provision of services to certain persons with developmental disabilities, and in particular focused upon the State of Montana's provision of community services and "intermediate care facility" institutional services to persons with developmental disabilities.

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