This page provides the answers to class members' most frequently asked questions. 

The information provided is in summary form and is not intended as a complete explanation of your rights. For full and complete information, you are directed to review carefully the Notice of Pendency of Class Action and Proposed Settlement, Stipulation and Agreement of Settlement, and Proof of Claim and Release.

A:  No, you are not.

A:  In a class action, one or more people called Class Representatives sue on behalf of people who have similar claims. All these people are a class or class members. In this case, the Class Representatives are Paul Minish, Verde Investments, Inc., Verde Reinsurance Co., Ltd., Donald and Bonnie Lee Siok, and Gary Kimmel. Reliance Group Holdings, Saul P. Steinberg, Robert M. Steinberg and Lowell C. Freiberg, which are being sued, are the defendants. The court will resolve the common issues for everyone in the class. The lawyers representing the class are called “class counsel".

A:  The Court did not decide in favor of the Plaintiffs or Defendants. Instead, both sides agreed to a settlement. That way, they avoid the risks and cost of a trial, and the people affected will receive compensation. The Class Representative and the Class Counsel think the settlement is best for all Class Members.

A:  Class Counsel believes that thousands of people are members of the class.

A:  No, you do not have to pay anything.

A:  We cannot offer any advice as to what you should do. That said, you have five options:

First, to qualify for a payment, you must submit a valid Proof of Claim and Release form. A Proof of Claim and Release form is being circulated with the Notice of Pendency of Class Action and Proposed Settlement. You may also get a Proof of Claim and Release form here. Read the instructions carefully, fill out the form, include all the documents the form asks for, sign it, and mail it postmarked no later than March 31, 2006.

Second, you can exclude yourself from the Class with respect to the Settlement. Pursuant to the Notice of Pendency of Class Action and Proposed Settlement, class members are allowed to request exclusion, in writing, postmarked on or before February 13, 2006. Persons who exclude themselves will NOT receive any share of the Settlement proceeds and will not be bound by the Settlement. Detailed directions on how to exclude yourself from the Settlement are contained on page seven of the Notice of Pendency of Class Action and Proposed Settlement.

Third, you may object and write to the court about why you do not agree with the Settlement or any part of it. Persons who exclude themselves from the Class are not affected by the settlements and may not object to the Settlement. Detailed directions on how to object to the settlement - and to make an appearance at the Settlement Fairness Hearing - are contained on page eight of the Notice of Pendency of Class Action and Proposed Settlement. Objections must be postmarked no later than February 13, 2006.

Persons who object to the Settlement must still submit a Proof of Claim and Release form in order to receive any share of the Settlements’ proceeds in the event the Court approves the Settlement. Submitting a Proof of Claim and Release does not waive any objection that you file. Submitting an objection does not exclude you from the Class.

Fourth, you may go to the Fairness Hearing. The Court will hold a hearing to decide whether to approve the proposed Settlement. You may attend and you may ask to speak, but you do not have to. Refer to “What is the Settlement Fairness Hearing?” below.

Lastly, you can do nothing. If you do nothing, you will get no money from this Settlement. If you do nothing, upon the effective date of the settlement, you will release all settled claims against the released parties. You must submit a Proof of Claim and Release form in order to share in the Net Settlement Fund.

A:  In exchange for the Settlement and dismissal of the Action, the Defendants have agreed to create a $15 million fund to be divided, after taxes, fees and expenses, among all Class Members who send in a valid Proof of Claim form.

Your share of the fund will depend on the total Recognized Claims represented by the valid Proof of Claim forms that Class Members return to the Claims Administrator, how many shares of Reliance common stock, and/or the principal amount of Reliance Bonds that you bought and when you bought and sold the common stock and/or bonds.

Proof of Claim and Release forms must be postmarked on or before March 31, 2006, to be considered valid.

A:  You may communicate with them by writing to:

Robert A. Wallner, Esq.,
Milberg Weiss Bershad & Shulman LLP
One Pennsylvania Plaza
New York, New York 00119-0165

OR

Sherrie R. Savett, Esq.
Berger & Montague, P.C.
1622 Locust Street
Philadelphia, Pennsylvania 19103

A:  You do not have to hire your own lawyer because Class Counsel is working on behalf of all Class Members. If you want your own lawyer to separately represent your own interests, to object to the Settlement or, if you exclude yourself, to bring a separate action against Reliance Group Holdings, Inc., you can hire a lawyer at your own expense.

A:  The court will hold a hearing at 4:30 pm on Tuesday, March 21, 2006 at the US District Court for the Southern District of New York, 500 Pearl Street, New York, New York 10007, to decide whether to approve the proposed settlements with Reliance Group Holdings. At this hearing, the court will consider whether the settlement with the Reliance Group Holdings defendants is fair, reasonable and adequate. The court will consider the proposed Plan of Allocation for the proceeds of the Settlement and the application of Plaintiff’s Co-Lead Counsel for attorneys’ fees and reimbursement of expenses. If there are written objections, the court will consider them. The court may also listen to people who have asked to speak at the hearing. After the hearing, the court will decide whether to approve the Settlement. We do not know how long these decisions will take.

A:  No, you do not.

A:  You can call the Claims Administrator toll free at 1-866-314-5811, or write to:

Reliance Group Holdings, Inc. Securities Litigation Settlement
c/o Analytics Incorporated, Claims Administrator
P.O. Box 2007
Chanhassen, Minnesota 55317-2007

To view detailed examples of acceptable documentation that can be submitted with your Proof of Claim and Release, please click on the following link: Documentation

For more detailed information concerning the matters involved in this Action, reference is made to the pleadings, to the Stipulation, to the Orders entered by the court and to the other papers filed in the Action, which may be inspected during normal business hours, at the Office of the Clerk of the United States District Court for the Southern District of New York, United States District Courthouse, 500 Pearl Street, New York, New York 10007.

A:  If you received a deficiency letter regarding your claim, this means that your claim has been processed and found to be deficient in whole or in part because it contains missing or incomplete information. Your deficiency letter contains the reason(s) why your claim is deficient and instructions for correcting the problem(s) with your claim. If you do not understand why your claim is deficient, please look through the following list of common reasons for claim deficiencies for a better explanation. You may also call our toll-free number to request assistance at the end of the automated system.

Common reasons for claim deficiencies:

No documentation of current authority to file: If you are submitting a claim on behalf of anyone but yourself, you must show that you are authorized to file the claim on their behalf.

No documentation of purchases or sales of Reliance stock or bonds: You must provide documentation for each transaction during the Class Period as well as proof of beginning and ending holdings. For more information on what documentation is acceptable, please call our toll-free line.

Ending Holdings do not match sum of transactions: You purchase transactions, less sales transactions, do not add up to what you claimed were your ending holdings. Please provide missing transactions or correct ending holdings with documentation.

Not a Class Member: The information you provided with your claim does not qualify you as part of this settlement. Typically this would be if you did not show any purchases of Reliance stock or bonds during the Class Period.

Duplicate Claim: One or more other claims have already been filed with the same information. This claim will be rejected while the other(s) will be processed.

Unable to verify name(s) listed: Perhaps you changed your name, or the signature does not match the name on the claim form. Please provide documentation which explains the discrepancy.