On April 14, 2006, armed SGS agents allegedly confiscated plaintiffs’ access cards which permitted them freedom of movement into the “Green Zone” and other United States compounds.

Plaintiffs claim to have contacted Nagel and Treadwell who instructed them to barricade themselves in a room in the SGS compound until United States forces could come rescue them.

On April 22nd, Vance and Ertel allegedly each received a notice stating that they were “security internees.” The letter informed Plaintiffs they had the right to appeal by submitting a written statement to camp officials.

Evaluation of the private and public factors that comprise a Section 1404(a) analysis demonstrates that a transfer of this case to the District of Columbia will not make this litigation "clearly more convenient.”

In addition to consideration of the number of potential witnesses located in any one district, courts also consider the nature and quality of their testimony on the issues that are actually in dispute in the case.

PLEASE TAKE NOTICE, that, upon the annexed affidavits of Edward J. Sincavage, of Heffler, Radetich & Saitta, L.L.P., the Claims Administrator (“Heffler”), and Robin Switzenbaum of Berger & Montague, P.C., one of Plaintiffs’ Co-Lead Counsel, and the exhibits thereto and upon all prior proceedings herein, the undersigned hereby move this Court for an Order pursuant to Rule 23(e) of the Federal Rules of Civil Procedure (i) approving the administrative determinations of Heffler accepting and rejecting claims submitted herein; (ii) directing payment of $18,564.58 out of the Settlement Fund to Heffler for the balance of its fees and expenses in connection with giving notices to the Class, preparing the tax returns for the Settlement Fund, processing the Proofs of Claim, and distributing the Net Settlement Fund to the Authorized Claimants; (iii) directing of the payment of estimated quarterly income tax for the fourth quarter of 2005 in the sum of $8,500.00 to the Internal Revenue Service; (iv) directing distribution of the Net Settlement Fund, after deduction of the payments requested herein, to Class Members whose Proofs of Claim have been accepted; and (v) for such other and further relief as this Court deems appropriate.

WHEREFORE, Plaintiffs respectfully request that the Court enter an Order in the form of the proposed Order Re: Distribution of Class Settlement Fund annexed hereto as Exhibit A.

s/ Beth J. Kushner Beth J. Kushner, SBN 1008591 411 East Wisconsin Avenue, Suite 700 Milwaukee, WI 53202 Tel.

Sherrie R. Savett Robin Switzenbaum 1622 Locust Street Philadelphia, PA 19103-6365 Tel.

Richard Bemporad David C. Harrison Jeanne D’Esposito One North Lexington Avenue White Plains, NY 10601-1714 Tel.

PLEASE TAKE NOTICE, that, upon the annexed affidavits of Edward J. Sincavage, of Heffler, Radetich & Saitta, L.L.P., the Claims Administrator (“Heffler”), and Robin Switzenbaum of Berger & Montague, P.C., one of Plaintiffs’ Co-Lead Counsel, and the exhibits thereto and upon all prior proceedings herein, the undersigned hereby move this Court for an Order pursuant to Rule 23(e) of the Federal Rules of Civil Procedure (i) approving the administrative determinations of Heffler accepting and rejecting claims submitted herein; (ii) directing payment of $18,564.58 out of the Settlement Fund to Heffler for the balance of its fees and expenses in connection with giving notices to the Class, preparing the tax returns for the Settlement Fund, processing the Proofs of Claim, and distributing the Net Settlement Fund to the Authorized Claimants; (iii) directing of the payment of estimated quarterly income tax for the fourth quarter of 2005 in the sum of $8,500.00 to the Internal Revenue Service; (iv) directing distribution of the Net Settlement Fund, after deduction of the payments requested herein, to Class Members whose Proofs of Claim have been accepted; and (v) for such other and further relief as this Court deems appropriate.

WHEREFORE, Plaintiffs respectfully request that the Court enter an Order in the form of the proposed Order Re: Distribution of Class Settlement Fund annexed hereto as Exhibit A.

s/ Beth J. Kushner Beth J. Kushner, SBN 1008591 411 East Wisconsin Avenue, Suite 700 Milwaukee, WI 53202 Tel.

Sherrie R. Savett Robin Switzenbaum 1622 Locust Street Philadelphia, PA 19103-6365 Tel.

Richard Bemporad David C. Harrison Jeanne D’Esposito One North Lexington Avenue White Plains, NY 10601-1714 Tel.

I make this affidavit in support of Plaintiffs’ application for an Order (a) approving the administrative actions taken by my firm in accepting and rejecting the claims submitted by claimants herein; (b) requesting payment to Heffler, Radetich & Saitta L.L.P. of its fees and expenses in connection with the services performed and to be performed in giving notices to the Class, in the processing the Proofs of Claim, and the administration and distribution of the Settlement Fund; (c) directing payment to Internal Revenue Service of a quarterly estimated tax payment; and (d) directing distribution of the Net Settlement Funds to eligible claimants whose claims have been accepted.

or Social Security Number of the claimant, and the purchase and sales transactions listed on the claim were then entered into a computerized database.

Claims which were properly submitted and supported with adequate documentary evidence were recognized on the basis of the following “Recognized Loss” formula as stated in the Plan of Allocation in the Notice as previously approved by the Court: For Shares Purchased between August 10, 2000 and October 4, 2000 and:

Heffler, Radetich & Saitta, L.L.P. will determine and pay the final tax estimate at the time of the distribution to claimants.

For the foregoing reasons, it is respectfully requested that this Court enter an Order (1) approving Heffler, Radetich & Saitta, L.L.P.’s administrative determinations accepting and rejecting claims as herein set forth; (2) authorizing payment to Heffler, Radetich & Saitta, L.L.P. of a total of $18,564.58 for the balance of its fees and expenses incurred and to be incurred in connection with its services performed and to be performed in Case 2:01-cv-01034-LA Filed 01/06/06 Page 7 of 8 Document 139

Eric L. Pruitt Baker Donelson Bearman Caldwell & Berkow 420 North 20th Street, Suite 1600 Birmingham AL 35203 Commissioner for Trademarks P.O.

Failure to file the Section 8 Affidavit will result in the cancellation of the registration.

The registration shall remain in force for 10 years, subject to the provisions of Section 8, except that the registration shall expire for failure to file an Application for Renewal under Section 9 of the Trademark Act, 15 U.S.C. Sec.

Failure to file the Application for Renewal will result in the expiration of the registration.

PTO Form 1963 (Rev 5/2006) OMB No. 0651-0055 (Exp 12/31/2011) Combined Declaration of Use in Commerce & Application for Renewal of Registration of a Mark under Sections 8 & 9 Input Field

PTO Form 1963 (Rev 5/2006) OMB No. 0651-0055 (Exp 12/31/2011) Combined Declaration of Use in Commerce & Application for Renewal of Registration of a Mark under Sections 8 & 9 To the Commissioner for Trademarks:

is filing a Combined Declaration of Use in Commerce & Application for Renewal of Registration of a Mark under Sections 8 & 9.

This is done within an exclusive territory where the franchisee can develop long—lerm relationships, which benefit Peaches ‘n Clean and our customer.