THE FOLLOWING QUESTIONS AND ANSWERS ARE DESIGNED TO PROVIDE GENERAL INFORMATION ABOUT THE JOINT PLAN OF REORGANIZATION AND TO DIRECT YOU TO PAGES OF THE DISCLOSURE STATEMENT THAT MAY BE OF INTEREST TO YOU.

THESE QUESTIONS AND ANSWERS DO NOT REPLACE OR CHANGE THE MORE DETAILED PROVISION OF THE JOINT PLAN OF REORGANIZATION.

WE URGE YOU TO CAREFULLY REVIEW THE JOINT PLAN AND DISCLOSURE STATEMENT TO UNDERSTAND HOW THE SPECIFIC PROVISIONS AFFECT YOUR CLAIM.

Ql. What is in the package of materials that I received?

Al. Your package contains several documents, the largest of which is the "Disclosure Statement." the Bankruptcy Code requires this document to be mailed to all creditors when a debtor - Dow Corning in this case - files a plan to pay its creditors and emerge from bankruptcy. That plan is called the "Amended Joint Plan of Reorganization." Other documents included in your package are letters from Dow Corning and the Tort Claimants Committee (TCC) which represents the interests of implant claimants, - a "Special Note" to implant claimants that summarizes the Disclosure Statement and, most importantly, your ballot. The first thing you should do is check your package for a ballot.

If you do not have one or you misplace it, you may call toll-free 1-800-651-7030 in the U.S. and Canada, or outside the U.S. call U.S. 202-332-5510, and they will provide a ballot to you.

Call the same numbers if you want to receive other Plan documents (including the detailed standards to qualify for settlements). You may also visit the Tort Claimants Committee web site at http://www.tortcomm.org or the Dow Corning web site at http://www.implantclaims.com.

If you have questions about the Plan or voting your ballot, please call the toll-tree Information Center at 1-888-577-7526 during the hours of 8:00 a.m. to 12:00 midnight Eastern time, Monday through Saturday (U.S. and Canada claimants only). Outside of the U.S. and Canada, you can call collect U.S. 718-361-4500 to reach the Information Center.

Q2. Is this just Dow Corning's proposal?

A2. No. The Plan is the result of lengthy negotiations between Dow Corning and the Tort Claimants Committee. Both parties strongly support the Plan and urge you to vote YES. Because both parties support it, it is called the Joint Plan of Reorganization.

Q3. What is a "Disclosure Statement " and what do I do with it?

A3. The Disclosure Statement is lengthy because it summarizes how all creditors- will be treated in the Plan, i.e., whether and how much they will be paid. If you have an implant and filed a claim in the bankruptcy - or if you are a spouse or child of an implant claimant - you are a creditor, There are different types of creditors. Each group of similar creditors is placed in a separate group or "class" in the Plan. For example, breast implant claims from United States claimants are in Class 5, breast implant claims from foreign claimants are in Class 6.1 and 6.2, and claims for other types of implants - such as hip, knee, TMJ, etc. - are in Classes 9, 10. 1 and 10. 2.

The purpose of the Disclosure Statement is to inform you of the terms of the Plan and your rights and provide information sufficient for you to decide how to vote.

Q4. Who received the package of materials?

A4. The package of materials was mailed to everyone who filed a "proof of claim." in the Dow Coming bankruptcy case, or who had this claim filed on their behalf by others. For example, other companies such as Bristol Myers or Baxter filed claims on behalf of women who had sued them for problems with their breast implant(s). So, even if you did not personally file a proof of claim, a claim may have been filed for you and you were sent a copy of the Plan. If a claim was filed on your behalf, you need to file a "Notice of Intent" if you want to take over the claim for yourself and participate it the bankruptcy as a claimant, and you need to do so immediately if you wish to vote on the Plan. Call toll-free 1-800-651-7030 in the U.S. and Canada and outside the U.S. and Canada and outside the U.S. call U.S. 202-332-5510 to get information and the necessary form.

(For more information on this topic, go to pages 24-25 and 86-87 in the document entitled "Disclosure Statement")

Q5. Do I have to vote?

A5. You claim that Dow Corning owes you money. Bankruptcy law gives you an opportunity to vote to approve or reject the Plan, which says how you will be paid. This is an important right. The TCC and Dow Corning strongly urge you to review the materials and vote YES in support of the Plan.

Q6 What happens if I don't vote on the Plan?

A6. If you don't vote by neglecting to complete, sign and return your ballot. your voice will not be counted in determining how members of your class vote on the Plan. In effect, you'll be letting other members of your class decide for you.

Q7. How do I vote?

A7. Complete, sign and return your ballot to the Ballot Tabulation Agent using, the postage paid envelope provided. On your ballot there is one question. It states, "I vote as follows with regard to the Joint Plan of Reorganization." On the box below this question. we urge you to check "YES, I ACCEPT THE PLAN." Sign the ballot, print your name and follow the instructions. Australian claimants and claimants in British Columbia have additional options on their ballots. Please see the Disclosure Statement at pages 58-59, which discuss these options.

Q8. Where do I mail the ballot?
 

A8. Mail the ballot to:        Balloting Agent         P.O Box 2400         Pittsburgh, PA 15230

Overnight Delivery address: Centre City Tower  Suite 500  650 Smithfield St.  Pittsburgh, PA 15222

Q9. What is the deadline for voting?

A9. You must send your ballot so that it is received by the Ballot Tabulation Agent by 5 p.m. Eastern Time on May 14, 1999. For your vote to count, it is important that you mail your ballot early enough to meet this deadline.

Q10. What am I being asked to decide when I vote?

A10. If you vote YES, this means that you support the Plan. In other words, it means that you want the proposal to go forward and allow the claims to be paid. or allow you to litigate your claim. If you vote NO, this means that you do not want the Plan to be approved. If the Plan is not approved, the TCC and Dow Corning believe that the parties will likely continue to litigate. Before the Plan is approved it must be confirmed by the bankruptcy court.

Q11. What happens if enough claimants vote to approve the Plan?

A11. The bankruptcy court will hold a "Confirmation Hearing" to review the vote and any objections to the Plan. This hearing is scheduled to begin on June 28, 1999. The hearing will likely last at least a week. The bankruptcy court will then issue an order either approving or not approving the Plan. If the Plan is approved, the documents provide that the processing of claims can begin when the Plan goes into effect, unless "stayed' by an appellate court. The Plan goes into effect on the "Effective Date" which occurs after the Plan is approved and other necessary events occur.

Q12. Do I need to attend the Confirmation Hearing? Can I attend if I want to?

A12. You do not need to attend the Confirmation Hearing. If you wish to attend, you may do so.

Q13. What happens if the Plan is voted down?

A13. If the Plan is voted down by one or more classes, the parties may nevertheless request the bankruptcy court to approve the Plan anyway. If the court does not approve the Plan, then we believe the parties will continue to litigate in bankruptcy court over the tort claims and other issues. This litigation has already been going on for almost four years and could continue for years longer. This means that claims will be processed or paid, if at all, only after many years.

Q14. How can I possibly read and understand this big package?

A14. The parties understand that the materials are lengthy and complex. If you have a lawyer, we strongly recommend that you speak to him or her to reach an informed decision on how to vote. If you do not have an attorney, or if you still have questions even after consulting your attorney, you can call the "Information Center," which has been established by Dow Corning and the TCC to assist claimants with procedural questions.

The Information Center is staffed by representatives trained by Dow Corning's court approved solicitation agent. All communications with the Information Center will be kept confidential. The Information Center is not designed to help you with your claim or answer questions about whether your symptoms or injuries will qualify for compensation. This will come later as part of the claims assistance program. Again, if you have questions about the Joint Plan or voting your ballot, please call the toll-free Information Center at 1-888-577-7526 during the hours of 8:00 a.m. to 12:00 midnight Eastern time, Monday through Saturday (U.S. and Canada claimants only). Outside of the U.S. and Canada, you can call collect U.S. 718-361-4500 to reach the Information Center.

To help you understand what the Plan is and what your rights are, the Tort Claimants Committee has also set up a series of meetings in various locations. The dates, times, and locations of meetings are included in the Tort Claimants Committee letter. The Tort Claimants Committee has also set up four "conference calls" which you can dial in from your home and listen to explanations of the Plan by representatives of the Tort Claimants Committee. Information on how to pre-register for one of the conference calls is also included in the Tort Claimants Committee letter.

Q15. Can my attorney submit my vote for me?

A15. Yes, but only if you have authorized him or her to do so.

Q16.  If I vote "yes " does this mean I can't go to trial on my case?

A16. No. Claimants may vote "YES" to support the Plan but still maintain their right to a jury trial. If the Plan is approved, there will be a separate opportunity to "opt out" of the settlement program contained in the Plan to pursue your individual case. You do not need to do anything right now except to vote on the Plan.

Q17. When do I decide whether I want to settle or to litigate my claim?

A17. If the Plan is approved by the bankruptcy court, you will be sent a "Participation Form." These forms will be mailed after confirmation of the Plan (which is expected in or after July 1999).

(For more information on this topic, go to page 56 and 85 in the document entitled "Disclosure Statement")

Q18. How much money will be paid to women with breast implants?

A18. The Plan provides that Dow Corning will pay up to $3.17 billion over 16 years to resolve all claims related to Dow Corning products, including breast implants. This amount is worth up to $2.35 billion in today 's dollars, and includes all settlements, administrative costs, litigation judgments, and legal expenses. Other amounts over and above the $3.17 billion are set aside to pay commercial creditors (for example, banks that loaned Dow Corning money) and other types of claimants.

(For more information on this topic, go to pages 16-19 in the document entitled "Disclosure Statement")

Q19. I've heard of the Revised Settlement Program (RSP) offered by other breast implant manufacturers. Is this Plan the same thing as the RSP?

A19. No. The Revised Settlement Program or "RSP" was a settlement offered by some breast implant manufacturers as part of the MDL 926 proceeding before Chief Judge Sam Pointer in Birmingham, Alabama. Because Dow Corning filed for bankruptcy in May 1995, it did not participate in the RSP. The present Plan with Dow Corning is similar in many ways to the RSP, but we believe it contains improvements over and above what women could receive in the RSP. For example, all women with breast implants, whether they are sick now or become sick in the future, can rely on the original global settlement criteria - such as Atypical Connective Tissue Disease (ACTD) - to recover money for disease. Women can also recover rupture payments under the Joint Plan even if they do not have a disease claim. Women can also recover more money for having their implants removed ($5,000) than they could have under the RSP ($3,000).

(For more information on this topic, go to pages 2-3 and 35 in the document entitled "Disclosure Statement")

Q20. My name and/or address on my package is wrong. How do I correct it?

A20. There is a box on the ballot to check and note your correct name and/or address. When you return your ballot, your new name and/or address will be updated in the computer database.

Q21. If I registered with the Claims Office in Houston, am I considered registered for the plan?

A21. No. You must have filed either a Proof of Claim or a Rule 3005 Notice of Intent form with the Bankruptcy Court in Michigan.

Q22. Who is eligible for the Plan?

A22. Persons who can document that they have a Dow Corning implant can participate. Also, persons with a silicone gel breast implant implanted after 1/1/76 and before 1/1/92 made by either Baxter, Bioplasty, Bristol Myers, Cox-Uphoff or Mentor can participate.

SETTLEMENT OPTIONS FOR WOMEN WITH BREAST IMPLANTS

Q23. What injuries can I recover for under this Plan?

A23. If you elect to settle your claim through the Settlement Facility and do not want to litigate your case, then there are three types of injuries for which you can recover compensation.

• Explantation
• Rupture
• Disease or Expedited Release (If you choose the Expedited Release you will forever waive your right to file a disease claim).

Q24. Can I qualify for and be compensated for more than one option?

A24. Yes. You may apply for and, if eligible, recover all three types of compensation. You should carefully read about the criteria and deadlines for each option to see if you will qualify.

(For more information on this topic, go to pages 78-80 in the document entitled "Disclosure Statement")

Q25. What should I submit to the Claims Office now?

A25. Nothing. No documents need to be sent to the Claims Office right now. If the Plan is approved, appropriate forms and materials will be sent to you later.

PRODUCT IDENTIFICATION FOR BREAST IMPLANT CLAIMANTS

Q26. Should I be doing anything now to document my claim?

A26. If you have not already done so, you may want to obtain records from your doctor[s] to prove who manufactured your implant. Product identification is required to recover benefits under the Plan. Without this proof, you will not be able to recover any compensation.

Q27. How do I know if my implant was made by Dow Corning?

A27. Dow Corning manufactured silicone gel and saline breast implants. It did not manufacture or sell implants with polyurethane foam. The implant brand names for Dow Corning are Silastic, Silastic II, Silastic MSI or MSI, and Varifil. For certain time periods,  the implant records may identify Cronin (1963 - 1971) or Mueller or V. Mueller (1968 - 8/31/74). A complete list of products and brand names will be provided with the claim form materials.

EXPLANTATION PAYMENT OPTION

Q28. What is the Explantation Payment Option?

A28. If you had your Dow Corning breast implants removed anytime after December 31, 1990 and within 10 years of when the Plan goes into effect, then you may be eligible for a $5,000 explantation payment for domestic claims. If you were or are reimplanted with silicone gel breast implants, then you cannot recover this explant money. You can recover the explant money if you were reimplanted with saline breast implants.

(For more information on this topic, go to pages 3 and 78 in the document entitled "Disclosure Statement")

Q29. How long will the Explantation program last?

A29. Claimants have 10 years after the Plan goes into effect to have their Dow Corning breast implant removed and to file documents supporting this claim.

Q30. What documents do I need to file to get an explantation payment?

A30. You do not need to file anything at this time. If the Plan is approved, you will be provided an Explantation Form which you must complete. Detailed instructions will be given to you on what to do and where to send your documents.

(For more information on this topic, go to pages 3 and 78 in the document entitled "Disclosure Statement")

Q31. Do I have to be explanted before I can get the Explantation payment?

A31. Yes.

Q32. What if I can't afford to be explanted? How can I ever participate in the Explantation Payment Option?

A32. The Plan provides a procedure to allow you and the Claims Office to make arrangements with your doctor or hospital in advance so you can be explanted and have the payment for the procedure go directly to the health care provider.

RUPTURE PAYMENT OPTION

Q33. What is the Rupture Payment Option?

A33. If one or more of your Dow Corning silicone gel breast implants has ruptured, you may be eligible for the Rupture Payment. Only claims for ruptured Dow Corning breast implants will be paid. Also, it must be a rupture of a silicone gel implant, or the gel portion of a double-lumen implant. Ruptured saline implants are not eligible.

Rupture claims for domestic claimants that are approved will receive a $20,000 Base Payment and, if enough money is available, an additional $5,000 Premium Payment.

Q34. What is the deadline for the Rupture Program?

A34. All documentation of the ruptured Dow Corning silicone gel breast implant must be submitted by the second anniversary of the date the Plan goes into effect.

Q35. What documents do I need to file to get a Rupture Payment?

A35. You do not need to file anything at this time. If the Plan is approved, you will be provided with a Rupture Form which you must complete. Detailed instructions will be given to you on what to do and where to send your documents. Generally, you will need your operative report and, if available, a pathology report.

Q36. What is the definition of "rupture"?

A36. The definition of rupture is identical to that used in the Revised Settlement Program. Your documents must describe a tear or other opening in the envelope surrounding the silicone gel lumen.

(For more information on this topic, go to pages 4 and 78-79 in the document entitled "Disclosure Statement")

Q37. Do I have to be explanted to recover a Rupture Payment?

A37. Yes. However, the Plan recognizes a limited exception if a claimant's doctor documents a specific serious chronic medical condition that precludes explantation surgery and documents by MRI that the implant is ruptured.

(To read more about this exception, go to page 79 in the document entitled "Disclosure Statement")

DISEASE PAYMENT OPTION

Q38. What is the Disease Payment Option?

A38. Breast implant claimants may apply and, if eligible, receive payments for certain listed diseases. There are two disease options - Disease Option I allows Claimants to qualify based on the disease criteria in the original global settlement. These diseases include both classic and atypical presentations of Scleroderma,  Systemic Lupus,  Polymyositis,  Dermatomyositis, Mixed Connective Tissue Disease, Overlap Syndrome and Sjogren's Syndrome. The category also includes Atypical Neurological Disease and ACTD.

The second option is Disease Option II - which is identical to the criteria in the Long Term Benefit Schedule of the Revised Settlement Program. In general, these criteria are much more restrictive than those in Disease Option I.

Women who qualify under Disease Option I will receive base payments ranging from $ 10,000 to $50,000 for domestic claimants, depending on the level of their disability. The disability definitions are the same as in the original global settlement.

Women who qualify under Disease Option II will receive base payments ranging from $75,000 to $250,000 for domestic claims depending on the severity of their disease. The severity criteria are the same as the Long Term Benefit Schedule criteria under the Revised Settlement Program.

Q39. Are there any additional payments for approved disease claims?

A39. The Plan provides that, if sufficient funds are available, "Premium Payments" can be made to those claimants whose disease claims are approved. The Premium Payments are up to an additional 20% of the original approved amount. This means that if you qualified under Disease Option I Disability Level C for S10,000,  you would be eligible to receive an additional 20% or $2,000 as a Premium Payment.

Q40. Are Premium Payments available under Disease Option I and Disease Option II?

A40. Yes, if sufficient funds are available.

Q41. Do I have to pick a Disease Option now?

A41. No. You do not need to do anything at this time except vote. If the Plan is approved,  you will be provided forms and materials to file a disease claim. Detailed instructions will be given to you on what to do and where to send your documents.

Q42. I already submitted my disease materials to the Claims Office in Houston. Will these be considered, or do I need to resubmit the materials?

A42. After you have submitted your Participation Form, you may rely on materials you submitted to the Claims Office in Houston. You do not have to resubmit anything. You may also submit new materials that you wish the Claims Office to consider. You do not have to submit anything at this time.

Q43. Is there a distinction between "Current Claimants" and "Other Registrants" such as in the Revised Settlement Program?

A43. No. If you participated in the Revised Settlement Program, that status does not apply to your status in the Joint Plan. All claimants may use the original global settlement disease criteria to qualify for a disease payment.

Q44. If I have breast implants from Dow Corning and a silicone gel breast implant from either Bristol, Baxter or 3M, can I still participate and get benefits?

A44. Yes, you can participate. However, the disease portion of your payment will be reduced by 50%. The reduction applies only if the Bristol, Baxter or 3M breast implant is a silicone gel breast implant. If you also had an approved rupture as a Current Claimant in the RSP, and you have another approved rupture under the Plan, your rupture payment will be reduced by 50%.

Q45. What if I have or had breast implants from Dow Corning and from another company such as McGhan, Cox-Uphoff or Bioplasty? Will my disease claim be reduced by 50%?

A45. No. The 50% reduction applies only if your other implant(s) were/or are from Bristol, Baxter of 3M.

Q46. If I recover Disease Option I benefits now at level "C" and later become more ill, can I recover additional compensation?

A46. There is a fund for claimants who elected and qualified for Disease Option 1 from which they may recover additional compensation if they become totally disabled and meet the criteria for disability Level A in the future. This is called the Disease Option I Increased Severity Fund. Up to $15 million (in today's dollars) is available to pay these claims. Claimants who become more ill but do not meet the disability criteria for total disability (Level "A") will not receive any additional compensation.

Q47. Is there an increased severity payment for Disease Option II claims?

A47. Yes. Claimants who originally qualified for a Disease Option II payment and who later qualify for a higher compensation level - based either on a new compensable disease or an increased severity of an existing disease - may be eligible for additional compensation.

Q48. What if I don't have a Disease claim?

A48. If you do not currently have a Disease claim, you may elect to receive an Expedited Release payment of $2,000. If you elect the payment, you will waive the right to receive a disease payment in the future. It is called a release payment because you are releasing your right to the disease claim forever. You will still be eligible to apply for the Explantation and Rupture options.

Q49. How long do I have before I must decide whether to take the Expedited Release Payment?

A49. This program will be available for the first three years after the Plan goes into effect. After that, the Claims Administrator may continue the program.

Q50. I have saline Dow Corning beast implants. Am I eligible for Disease payments?

A50. Yes.

FOREIGN CLAIMANTS

Q51. I am not a U.S. citizen. Am I a domestic or a foreign claimant under the Plan?

A51. Claimants who are not citizens of the United States and who are not "resident aliens" within the United States, Puerto Rico, the territories and possessions of the United States, or a United States military facility (referred to as the Greater U.S.) are treated as foreign claimants under the Plan.

Q52. Are the compensation options described above available to foreign claimants?

A52. Yes. Foreign claimants who are not covered by the separate settlements in Canada or who do not accept the separate settlement offer for claimants from Australia are eligible to receive all three types of compensation - Explantation, Rupture and Disease or Expedited Release.

Q53. Are the compensation amounts the same for domestic and foreign claimants?

A53. While the qualification standards and criteria are the same for both domestic and foreign claimants, the payment amounts for foreign claimants are adjusted in recognition of the lower compensation generally paid for tort claims outside the United States.

Q54. I am a citizen of Canada. What settlement class do I fit in?

A54. Generally, you are part of Class 6. There are three subclasses for Canadians, depending on the province in which you reside. Most residents of Quebec are in a subclass 6A and are covered by a separate class action settlement in Quebec.

Most residents of Ontario are in a subclass 6B and are covered by a separate class action settlement filed in the province of Ontario.

Most residents of British Columbia and the remaining provinces are in subclass 6C provided that (1) they do not opt out of the separate class action in British Columbia, or (2) they are residents of any province of Canada other than British Columbia, Quebec and Ontario who timely elect to be bound by the class action.

Each of these subclasses - Class 6A, 6B and 6C - has settled separately with Dow Corning and their claims will be treated in accordance with their separate settlement agreements. Claimants who opted out of their provinces' separate settlements are treated in Class 6.1.

(For more information on this topic, go to pages 57 - 59 in the document entitled "Disclosure Statement")

SPOUSES AND CHILDREN

Q55. My wife has Dow Corning breast implants. Is there a separate recovery for me or for children?

A55. No. Payments to women with Dow Corning breast implants include all claims by that woman, her spouse and her children (except for children's direct claims for injuries). There is no separate recovery or compensation for spouses.

Q56. Can I or a guardian for my child pursue the child's claim for injuries under this Plan?

A56. Yes. Although, there is no compensation offered for children's direct claims in the Settlement Facility, children's claims may be pursued in the Litigation Facility.

(For more information on this topic, go to pages 7 and 81 in the document entitled "Disclosure Statement")

OTHER IMPLANT CLAIMANTS

Q57. I do not have a breast implant, but I do have another type of an implant manufactured by Dow Corning, such as a TMJ implant, or a hip or finger joint implant. Do I receive any compensation?

A57. People filing claims for other Dow Corning implant products may be eligible to receive compensation out of a total fund of $36 million (in today's dollars) within the larger amount being made available to resolve tort claims. Generally, you will receive compensation if you can show that you had a Dow Corning implant that broke during normal usage, or which caused certain other localized injuries. These payments include $5,000 for certain small joint implants such as for wrists, toes, and for chin, facial, nasal, testicular, penile and TMJ implants. The amount of $7,500 is for qualifying knee implants and $10,000 for qualifying hip implants and more severe TMJ injuries.

There is also an Expedited Release Payment for these other products. This option may be appropriate for people with non-breast implant claims who do not provide medical records to apply for higher payments. The only qualification for this $1,000 payment is to demonstrate that the implant was manufactured by Dow Corning. If you accept this payment, you cannot apply for the higher scheduled payments.

(For more information on this topic, go to pages 5-6 and 83 in the document entitled "Disclosure Statement:)

Q58. How do I find out if my other type of implant is covered by the Plan?

A58. Detailed information about brand names will be provided to you with your claim form. For more information, review the document called the Dow Corning Settlement Program and Claims Resolution Procedures. See Question 1 for information on getting this document.

Q59. I have both a Dow Corning breast implant and a Dow Corning hip implant. Can I recover for each of these implants?

A59. Yes.

Q60. I have a Dow Corning hip implant and another non-breast implant. Can I recover for each of these different types of implants?

A60. If you elect the Expedited Release Payment, then you may not recover for more than one implant type. If you can document a Medical Condition for each different type of implant, then you can recover for each implant type.

SILICONE MATERIAL CLAIMANT FUND

Q61. I received a silicone gel breast implant from Cox-Uphoff in 1981. Can I recover anything under this Plan?

A61. Yes. Anyone implanted between 1/1/76 and 12/31/91 who received a silicone gel breast implant from any of the following manufacturers may apply for either Disease or Expedited Release compensation from a separate subfund called the Silicone Material Claimant Fund. The manufacturers are: Baxter, Bioplasty, Bristol Myers, Cox-Uphoff, and Mentor. To determine if one of your breast implants can be identified as coming from one of these five companies, review the document called the Dow Corning Settlement Program and Claims Resolution Procedures. See Question 1 for information on getting this document.

Q62. I have a Mentor silicone gel breast implant and a Dow Corning breast implant. Which fund am I covered by?

A62. You are covered for your Dow Corning breast implant. You will be eligible to apply for Explantation,  Rupture, and Disease or Expedited Release payments. You will not be eligible to apply for additional benefits form the Silicone Material Claimant Fund.

Q63. How much can I recover from the Silicone Material Claimant Fund?

A63. Depending on the number of claimants who have approved claims, you can receive up to 40% of the amount listed on the Disease compensation grids, or if you do not have a Disease claim, you can recover an Expedited Release payment.

Q64. Can I get money for explantation for my Bioplasty implant from the Silicone Material Claimant Fund?

A64. No. There are no benefits for Explantation or Rupture under the Silicone Material Claimant Fund.

Q65. I have only a Bristol Myers silicone gel breast implant. Can I also recover 40% of the Disease compensation grid amount?

A65. You may apply for these benefits but the Plan requires that you "marshal" your recoveries against Bristol Myers first. Any funds you recover from Bristol Myers would reduce your recovery from the Silicone Material Claimant Fund dollar-for-dollar. This means that if you recovered any funds as a Current Claimant or from the Long Term Benefit Program of the Revised Settlement Program, or as an opt-out, it is unlikely that you would recover any additional Disease compensation from this Plan.

Q66. I received a saline implant, can I recover from the Silicone Material Claimant Fund?

A66. No. Only silicone gel breast implants are covered under the Silicone Material Claimant Fund. Also, the implant must have been implanted between 1/1/76 and 12/31/91.

Q67. How much money has been set aside to pay all of the approved Silicone Material Fund Claimants?

A67. There is a separate fund of $57.5 million (in today's dollars) available to resolve these claims.

(For more information on this topic, go to pages 6 and 83 in the document entitled "Disclosure Statement")

Q68. I cannot identify my implant manufacturer. Am I still covered by the Silicone Material Claimant Fund?

A68. No. You must be able to provide acceptable proof that you have one of the silicone gel breast implants from Baxter, Bioplasty, Bristol Myers, Cox-Uphoff and/or Mentor.

Q69. I have Cox-Uphoff silicone gel breast implants. I have already submitted my medical records for my Disease Claim to the Claims Office. Do I need to resubmit them somewhere else or may I rely on my prior submission?

A69. You may rely on your prior submission. At the appropriate time, you can also provide supplemental documents.

Q70. I have silicone gel breast implants from 3M and McGhan Medical. Am I eligible for the Silicone Material Claimant Fund?

A70. No.

LITIGATION OPTIONS

Note: This section applies to both breast implant and non-breast implant claimants.

Q71. I am a personal injury claimant. I want to vote in favor of this Plan, but I don't want to settle my claim. I want to litigate my claim. How do I do that?

A71. If you are in favor of the Plan, vote YES on the ballot and return it so that it is received by the Balloting Tabulation Agent by 5:00 p.m. Eastern Time on May 14, 1999. If the Plan is confirmed by the Court, you will then be provided a "Participation Form" in which you can elect to opt out of the Settlement Facility and into the Litigation Facility. This will allow you to litigate your claim.

(For more information on this topic, go to pages 56 and 85 in the document entitled "Disclosure Statement")

Q72. How will litigated claims be handled?

A72. The Plan establishes a Litigation Facility to handle the claims of all personal injury claimants who choose not to settle. The Litigation Facility will be under the jurisdiction of the United States District Court for the Eastern District of Michigan (the district in which the bankruptcy is currently pending). We will ask that Court to approve a case management order, already agreed to between Dow Corning and the Tort Claimants Committee, describing steps that will be taken to resolve claims through litigation.

The parties' intention is to preserve claimants' right to litigate under procedures similar to those in the non-bankruptcy civil justice system. There will also be a Special Master assisting the Court in managing the opt-out cases.

(For more information on this topic, go to pages 9 and 84-88 in the document entitled "Disclosure Statement")

Q73. Will there be a common issue/causation proceeding?

A73. After the opt-out deadline, the Litigation Facility will ask the District court to hold hearings to determine certain common issues, including whether there is sufficient admissible evidence to permit a jury trial as to whether silicone causes systemic diseases. Claimants will have the right to oppose such common issue proceedings, and the District Court will decide whether they will be held.

Q74. Do I need to file something now to opt out?

A74. No. You do not need to do anything at this time. If the Plan is confirmed by the Court, a Participation Form will be mailed to you. You can opt out at that time. You will have 180 days to elect to litigate and to return your form. It is possible that appeals will be filed by various parties that may delay the Plan from going into effect. Please note that if you are a claimant in British Columbia, Canada, you have specific opt-out rights as part of your Class 6C settlement, and the foregoing answer does not apply to you.

(For more information on this topic, go to page 85 in the document entitled "Disclosure Statement")

Q75. May I pursue claims against Dow Corning or Dow Chemical or their officers, directors?

A75. No. The plan provides for a release of all claims regarding silicone breast implants and other products against Dow Corning, its shareholders (Dow Chemical and Corning Incorporated) and their officers or directors.

(For more information on this topic, go to pages 11 and 89 in the document entitled "Disclosure Statement")

Q76. Can I pursue my claim against Dow Corning through the Litigation Facility and pursue my claim against Dow Chemical outside the Litigation Facility?

A76. No.

Q77. Of the $2.35 billion present value potential fund amount, how much is allocated to pay people who choose to litigate their claim, versus those who choose to settle their claim?

A77. There is a total of up to $400 million (in today's dollars) that will be used to fund litigation for all personal injury tort claims, including payment of defense costs of the Litigation Facility.

(For more information on this topic, go to pages 10-11 and 77 in the document entitled "Disclosure Statement")

CLAIMS PROCESSING

Note: This section applies to both breast implant and non-breast implant claimants.

Q78. Where will the Claims Office be?

A78. The existing Claims office for the Revised Settlement Program in Houston, Texas will process the claims of settling claimants under this Plan. There will be a new claims administrator appointed to oversee the processing of these claims.

(For more information on this topic, go to pages 3, 7 and 8 and 73-84 in the document entitled "Disclosure Statement")

Q79. Should I mail my claim documents and medical records to the Claims Office now?

A79. You should not mail these materials to the Claims Office in Houston yet. You are not required to do anything unless, and until, the Plan becomes effective. The Claims Office will not process any claims or documents until the Plan is confirmed and becomes effective.

Q80. I submitted my medical records to the Claims Office in Houston in 1994. Can I still use those records or do I have to resubmit them?

A80. Once you have submitted your participation form, you may rely on your prior submission. You will also be given an opportunity to supplement your prior submission with any new or recent medical records.

Q81. Will there be a Claims Assistance Program to assist claimants like there was in the Revised Settlement Program?

A81. The Plan provides that the Claims Office will set up a Claims Assistance Program to assist Claimants with completing their forms and identifying the manufacturer of their implants, and to answer questions about the status of their claim. The Claims Office will send Notification of Status letters to each claimant once his or her claim has been valuated.