PRELIMINARY APPROVAL ORDER

NANCY J. ROSENSTENGEL, District Judge.

This matter is before the Court on Plaintiff's Unopposed Motion for Preliminary Approval of Class Settlement. (Doc. 223). After reviewing and considering the motion, all supporting documents, the Master Shell Settlement Agreement ("Shell Agreement"), the Master ConocoPhillips Settlement Agreement ("ConocoPhillips Agreement"), and the Class Settlement Administration Agreement ("Administration Agreement") ("Agreements"), and the arguments of counsel at the preliminary approval hearing held July 20, 2017, the Court ORDERS as follows:

1. All terms in this Order not defined herein shall have the meanings set forth in the Agreements.

2. The Agreements, and all of their terms and conditions that pertain to the Class Action, including the Administration Agreement and the Settlement Allocation Plan, are preliminarily approved as fair, just, reasonable, and adequate, subject to further consideration at a final approval hearing (the "Final Approval Hearing").

3. For purposes of settlement only, the Court conditionally accepts the definition of the Settlement Class Area to mean

4. For purposes of settlement only, and pursuant to Federal Rule of Civil Procedure 23(b)(3), the Court conditionally certifies a Settlement Class consisting of:

5. The Court finds, for settlement purposes only, that class certification under Federal Rule of Civil Procedure 23(b)(3) is appropriate in that, in the settlement context: (a) the Settlement Class is so numerous that joinder is impracticable; (b) there are questions of law and fact that are common to all members of the Settlement Class, which questions predominate over individual issues; (c) Plaintiff's claims are typical of the claims of the Settlement Class; (d) Plaintiff and her attorneys will fairly and adequately protect the interests of the Settlement Class; and (e) a class action is superior to other available methods for the fair and efficient adjudication of the controversy.

6. For purposes of this action only, the Court makes the following findings:

7. The Court appoints Plaintiff Jeana Parko as Class Representative of the Settlement Class, and further appoints the law firm of Simmons Hanly Conroy as Class Counsel.

8. The Court appoints Tiffaney Janowicz, of Rust Consulting, as Neutral Arbitrator to review and determine, if necessary, any challenges or disputes arising from claims made by Members of the Settlement Class as set forth in the Administration Agreement. The fees of the Neutral Arbitrator shall be paid from the Total Class Settlement Fund.

9. The Final Approval Hearing shall be held before this Court on December 18, 2017, at 9:30 a.m., at the United States District Court for the Southern District of Illinois, 750 Missouri Avenue, East St. Louis, IL 62201, to determine whether the proposed settlement of the Class Action on the terms and conditions provided for in the Agreements is fair, reasonable, and adequate to the Class and should be approved by the Court and to determine any amount of fees and expenses that should be awarded to Class Counsel. The Court may grant final approval of the Agreements at or after the Final Approval Hearing with any appropriate modifications agreed to by the parties and without further notice to the Members of the Settlement Class.

10. A motion in support of final approval of the settlement and Class Counsel's application for attorneys' fees and expenses shall be filed and served no later than November 6, 2017, and any responding papers shall be filed and served no later than November 17, 2017.

11. The Court approves the form and substance of the updated Class Notice, the Publication Notice, and the Claim Form provided by the parties on July 31, 2017 and attached to this order as Exhibits 1 and 2, except that the dates in all documents shall be updated by the parties in order to ensure compliance with this Order. Further, the Court approves the terms on which notice shall be provided included in, or annexed to, the Administration Agreement as Exhibits 2, 3, and 1, respectively.

12. The Court directs that, no later than August 30, 2017, the Class Notice and Claim Form as approved by the Court be sent by first-class mail to each record owner and current and/or former residents of property in the Settlement Class Area. Also, no later than August 30, 2017, the Publication Notice shall be published in the Edwardsville Intelligencer, the Alton Telegraph, and the Belleville News Democrat at least three times in a three-week period; and the Class Notice be posted at the Village of Roxana Village Hall and at the Roxana Public Library beginning on the date of the first publication appearance and ending on the date of the Final Approval Hearing. The Court further directs that, no later than August 30, 2017, (a) Class Counsel shall establish a toll-free telephone number providing information to Members of the Settlement Class of the details of the Class Settlement including details related to membership, claim recovery and exclusion; and (b) Class Counsel shall establish a website providing copies of the Class Notice, Claims Form and Opt-Out Notice.

13. The Court finds the form, content and mailing of the Class Notice and Publication Notice and the terms on which notice shall be provided as set forth in ¶ 11 hereto, meet the requirements of Rule 23 of the Federal Rules of Civil Procedure, due process, and constitute the best notice practicable under the circumstances and shall constitute due and sufficient notice to all persons entitled thereto.

14. Pursuant to Rule 53(c) of the Federal Rules of Civil Procedure, the Court appoints Rust Consulting, Inc. ("Claims Administrator") to supervise and administer the notice as well as the processing of claims in accordance with the terms of the Administration Agreement.

15. Any person seeking to be excluded from the Settlement Class must submit a timely written and signed request for exclusion complying with the procedures specified in the Class Notice and Claim Form to the Claims Administrator at the addresses set forth in the Class Notice. The last day on which such notice may be submitted shall be October 16, 2017. Persons who opt out of the Settlement Class in accordance with the requirements specified in the Class Notice and Claim Form will not receive any monetary relief available under the Settlement and will not be bound by any orders or judgments entered in this case relating to such relief.

16. Any Request for Exclusion or Opt-Out Notice shall state the name, address, and telephone number of the person requesting exclusion, provide proof of eligibility for membership in the Settlement Class, and contain a clear statement communicating that such person elects to be excluded from the Settlement Class, does not wish to be a Member of the Settlement Class, and elects to be excluded from any judgment entered pursuant to the Shell Settlement Agreement and the ConocoPhillips Settlement Agreement. No person who submits a timely Request for Exclusion or Opt-Out Notice may file an objection to the Settlement and all such persons shall be deemed to have waived any rights or benefits under the Agreements.

17. All Members of the Settlement Class who do not opt out by the Court-imposed deadline shall be bound by the terms of the Class Settlement and their Claims against the Shell Defendants and the ConocoPhillips Defendants will be released and extinguished.

18. Each Member of the Settlement Class who wishes to object to the terms of the Class Settlement, including, but not limited to, the Settlement Class Allocation Plan, and any fees or expenses sought by Class Counsel, shall file a written notice of objection no later than October 16, 2017. Such objections shall state the name, address and telephone number of the person and provide proof of membership in the Settlement Class, as well as a detailed statement of each objection asserted, including the grounds for objection and reasons for appearing and being heard, together with any documents such person wishes to be considered.

19. Any Member of the Settlement Class may, but need not, appear at the Final Approval Hearing, at the Member's own expense, individually or through counsel of the Member's choice. Each Member of the Settlement Class who intends to appear at the Final Approval Hearing must file a Notice of Appearance with the Court. Notice of any such appearance shall be served, on or prior to the date of its filing, on the Claims Administrator. The Claims Administrator shall serve any such Notice of Appearance on Class Counsel and the counsel for Defendants within seven (7) days of receipt. Any Member of the Settlement Class who does not enter an appearance will be represented by Class Counsel. Objectors who fail to properly or timely file their objections with the Clerk of the Court, along with the required information and documentation set forth above, or to serve them as provided above shall not be heard during the Final Approval Hearing, nor shall their objections be considered by the Court.

20. All proceedings in Village of Roxana, Illinois v. Shell Oil Co., et al., No. 3:12-cv-00577-NJR-PMF (S.D. Ill.); Village of Roxana, Illinois v. Shell Oil Co., et al., No. 3:12-cv-00334-NJR-PMF (S.D. Ill.); and Parko, et al. v. Shell Oil Co., et al., No. 3:12-cv-00336-NJR-PMF (S.D. Ill.) are hereby stayed, other than such proceedings as may be necessary to carry out the terms and conditions of the Agreements.

21. Pending Final Approval, each Member of the Settlement Class who has not timely opted out of the Settlement Class in accordance with the Court's directions, is enjoined from maintaining, commencing, prosecuting or pursuing either directly, representatively or in any other capacity any Released Claim as defined in the Agreements in any court or other forum.

22. If the Agreements are terminated or are not consummated for any reason, the foregoing conditional certification of the Settlement Class, the appointment of the representative Plaintiff as representative of the Settlement Class, and appointment and designation of Class Counsel as counsel for the Settlement Class shall be void and of no effect, and the parties to the Agreements shall be returned to the status each occupied before entry of this Order without prejudice to any legal argument that any of the parties to the Agreements might have asserted before the Agreements.

23. No discovery with regard to the Settlement or the Agreements shall be permitted other than as may be directed by the Court upon the proper showing by the person seeking such discovery by motion properly noticed and served in accordance with this Court's local rules.

24. Neither the Settlement, nor the Agreements, nor any provision thereof, nor any negotiations, statements, or proceedings in connection therewith shall be construed as, or be deemed to be evidence of, an admission or concession on the part of the representative Plaintiff, Class Counsel, any Member of the Settlement Class, Defendants, or any other person. Further, neither the Settlement, Agreements, nor any communications shall be offered or received in evidence in any action or proceeding, or be used in any way as an admission or concession of liability or wrongdoing of any nature, nor shall they be used as evidence or concession or admission that any person has or has not suffered any damage.

IT IS SO ORDERED.

NOTICE OF PENDENCY OF CLASS ACTION AND SETTLEMENT

The following statement is being issued by the law firm Simmons Hanly Conroy LLC regarding settlement of litigation concerning the Wood River Refinery in the Village of Roxana, Illinois.

The purpose of this notice is to inform you of the pendency and settlement of a class action entitled Parko, et al. v. Shell Oil Co., et al., No. 3:12-cv-00336-NJR-PMF, pending in the United States District Court for the Southern District of Illinois. The Court has scheduled a settlement approval hearing on December 18, 2017, at 9:30am, in Courtroom 3 of the federal courthouse, located at 750 Missouri Avenue, East St. Louis, Illinois, before the Honorable Judge Nancy J. Rosenstengel.

In the Parko class action, Plaintiff Jeana Parko alleges on behalf of herself and prospective class members that releases from or related to the operation of the Wood River Refinery located within the Village of Roxana, Illinois, have caused soil and groundwater contamination of neighboring properties and resulted in exposure and property damage to nearby residents. Plaintiff sued Shell Oil Company and Equilon Enterprises, LLC (the "Shell Defendants") and ConocoPhillips Company, WRB Refining LP, ConocoPhillips WRB Partner LLC, and Cenovus GPCO LLC (the "ConocoPhillips Defendants"). All defendants in the Parko class action have denied and continue to deny these claims. The Shell Defendants and the ConocoPhillips Defendants have separately reached agreements with Plaintiff to settle the Parko class action.

If you own or owned or occupy or occupied real property in the Village of Roxana, Illinois, within the geographical area referred to as the Study Area, as defined by the Illinois Environmental Protection Agency ("IEPA"), at any time between January 1, 1986 and the present, you may have a claim to receive benefits in the proposed class action settlement and you may be entitled to receive a monetary payment. The settlement class area is defined as the area enclosed by, and commencing at, the southwest corner of South Central Avenue and Rand Avenue (the "Beginning Point"), extending north along the east side of South Central Avenue to the south side of the alley between First Street and East Tydeman Avenue, then extending east along the south side of the alley to the east side of South Chaffer Avenue, then extending south to a point due east of the Beginning Point, then extending west to the Beginning Point. A figure depicting the settlement class area is contained in the Class Notice, which you may obtain as described below.

If you believe you are a member of the settlement class, you may visit www.RoxanaClassSettlement.com to review or download a copy of the Class Notice and Claim Form and to request additional information. You may also call or contact Class Counsel at the following address:

A copy of the Shell Settlement Agreement, the ConocoPhillips Settlement Agreement, the Class Notice, Claim Form, information on how to object to or be excluded from the Settlement Class, and other important documents and information are also available for inspection or copying at the Court. Details concerning eligibility for payments, as well as your options if you are member of the Settlement Class are contained in these documents.

If you are a member of the Settlement Class and do nothing you will receive no benefits under the settlement, but you will be bound by any final judgment approving the proposed settlement.

For additional information, you may go to www.RoxanaClassSettlement.com or contact the Class Counsel listed above.

SOURCE: Simmons Hanly Conroy LLC

For More Information, visit www.RoxanaClassSettlement.com or call toll-free 1-866-903-1197.

PARKO LITIGATION

CLASS SETTLEMENT CLAIM FORM

THIS CLAIM FORM MUST BE POSTMARKED NO LATER THAN OCTOBER 2, 2017 TO BE VALID FAILURE TO COMPLY WITH THIS REQUIREMENT WILL RESULT IN DISMISSAL OF YOUR CLAIM

Only individuals satisfying the requirements set forth in the Class Notice are Members of the Settlement Class potentially eligible to receive a Settlement Payment if the proposed Settlements are approved by the Court. IF YOU BELIEVE YOU ARE A MEMBER OF THE SETTLEMENT CLASS AS DESCRIBED IN THE NOTICE, YOU MUST SUBMIT A CLAIM FORM IN ORDER TO REQUEST A MONEY PAYMENT. Only one Claim Form may be submitted per individual. If the Claim Form is not postmarked or electronically submitted by OCTOBER 2, 2017, this will result in the dismissal of your claim and you will not be entitled to any monetary recovery received under this action. If the Claim Form is incomplete, or if you fail to submit the required proof of residency, you will not be eligible for Settlement Benefits.

In order to receive a Settlement Payment, you must be able to prove that you own or owned property or occupy or occupied property located in the Settlement Class Area during the Settlement Time Period, as defined in the Shell Settlement Agreement and the ConocoPhillips Settlement Agreement. Accordingly, in order to be eligible for a Settlement Payment, you must submit written proof and supporting documentation of your ownership and/or residence within the Settlement Class Area for any duration between January 1, 1986 and the present. Valid forms of written proof include, but are not limited to, utility bills, telephone bills, deeds, purchase agreements, rental agreements, or other similar documents showing your address and dates of ownership or residence. YOUR CLAIM WILL BE DENIED IF PROOF OF CLASS OWNERSHIP OR RESIDENCE IS NOT SUBMITTED.

You can complete this Claim Form and mail it to PARKO LITIGATION CLASS SETTLEMENT, c/o Rust Consulting, Inc., PO Box 2570, Faribault, MN 55021-9570, or electronically submit it at www.RoxanaClassSettlement.com. The completed Claim Form together with the required supporting documentation must be postmarked or electronically submitted no later than OCTOBER 2, 2017. If you have any questions, you may call Class Counsel at the number provided in the Class Notice or call the Settlement Administrator toll-free at 1-866-903-1197 or visit the case website at www.RoxanaClassSettlement.com. Do not go to any Shell, ConocoPhillips or court website or call any Shell, ConocoPhillips or court phone numbers, as no information pertaining to the Settlements is available there.

PLEASE PRINT NEATLY. COMPLETION OF ALL FIELDS IS REQUIRED.

PLEASE INCLUDE PROOF OF OWNERSHIP OR RESIDENCE WITHIN THE SETTLEMENT AREA DURING THE SETTLEMENT STIME PERIOD. IF NO SUPPORTING DOCUMENTATION IS INCLUDED WITH THIS CLAIM FORM, YOUR CLAIM WILL BE DENIED. IF YOU OWNED OR LIVED AT MORE THAN ONE PROPERTY IN THE SETTLEMENT CLASS AREA DURING THE SETTLEMENTTIME PERIOD, OR IFYOU OWNED OR LIVED ON MORE THAN ONE PARCEL, YOU MAY SUBMIT ADDITIONAL PAGES WITH THE INFORMATION REQUESTED IN QUESTIONS 2-7 FOR EACH SUCH ADDRESS OR PARCEL. PLEASE NOTE YOU MUST SUBMIT THE REQUIRED SUPPORTING DOCUMENTATION FOR EACH PROPERTY AND PARCEL AND TIME PERIOD THAT YOU IDENTIFY.

THE CLASS SETTLEMENTS PROVIDE THAT ALL CLASS MEMBERS AGREE TO THE FOLLOWING TERMS. PLEASE INITIAL EACH OFTHE FOLLOWING PARAGRAPHS OR YOUR CLAIM WILL BE DENIED.

_______ By submitting this Claim Form, I acknowledge that, as more fully set forth in the Shell Settlement Agreement, I am releasing all claims against the Shell Defendants which directly or indirectly arise from (a) Shell's operations; or (b) the past, present and future environmental condition of the Wood River Refinery, the IEPA Study Area and surrounding areas, and/or Plaintiffs' properties; or (c) Shell's past, present, and future remediation and site closure activities at these areas conducted in order to satisfy the requirements of Shell's RCRA permit and/or to satisfy the regulations and requirements of IEPA; or (d) activities related to, associated with, or in any way connected to the Actions and the facts and circumstances alleged therein; or (e) any event, cause or matter which in whole or in part, is or could have been, the subject of the Actions.

________ By submitting this Claim Form, I acknowledge that, as more fully set forth in the ConocoPhillips Settlement Agreement, I am releasing all claims against the ConocoPhillips Defendants which directly or indirectly arise from (a) the Claims in the Parko class action; or (b) the past and present environmental condition of the Wood River Refinery, the IEPA Study Area and surrounding areas, and/or Plaintiffs' properties; or (c) the ConocoPhillips Defendants' past, present, and future remediation and site closure activities at these areas conducted in order to satisfy the requirements of Shell's RCRA permit and/or to satisfy the regulations and requirements of IEPA; or (d) activities, as of the Effective Date, related to, associated with, or in any way connected to the Actions and the facts and circumstances alleged therein; or (e) any event, cause or matter, as of the Effective Date, which in whole or in part, is or could have been, the subject of the Actions.

_______ I acknowledge that the Shell Defendants have the sole and exclusive right to determine how any IEPA-directed remediation and site closure should be completed; to negotiate with IEPA and any other regulatory agencies, whether federal, state or local; and to hire, contract, or employ any agents or contractors to perform the investigation, remediation and site closure at or in connection with the Wood River Refinery, the Study Area, neighboring properties and surrounding areas allegedly affected by the Wood River Refinery.

_______ If I currently own property in the Settlement Class Area, I acknowledge that my property is or may be within the boundary of a Groundwater Management Zone ("GMZ") established pursuant to the authority of the IEPA in connection with Defendants' ongoing and future remediation activities in or around the Village of Roxana.

______ I agree to provide access to my property to the Shell Defendants, their contractors, and/or the appropriate regulatory authorities at reasonable times to be mutually agreed upon to perform remediation activities including: (1) monitoring, and/or (2) engaging in remedial or mitigation activities including inspections, and/or (3) performing vapor intrusion assessment and/or mitigation activities.

______ I agree that if I construct future structures or modify existing structures on my property I will comply with the design criteria set forth in 35 Illinois Administrative Code Part 742, as more fully set forth in the Shell Settlement Agreement, the ConocoPhillips Settlement Agreement, and the Class Notice.

________ If I currently own property in the Settlement Class Area, I agree to disclose to any future purchasers of my property that the property is in an area (or is in close proximity to an area) that may be subject to an IEPA-directed remediation.

I declare under penalty of perjury that the information supplied in this Claim Form by the undersigned is true and correct to the best of my recollection, and that this form was executed on the date set forth below.

If you have any questions or need more information, please visit the website, www.RoxanaClassSettlement.com or call the Administrator toll-free at 1-866-903-1197.

IF YOU OWN OR OWNED PROPERTY OR OCCUPY OR OCCUPIED PROPERTY LOCATED WITHIN THE BOUNDARIES OF THE MAP ON PAGE 3 OF THIS NOTICE BETWEEN JANUARY 1, 1986 AND TODAY, YOU MAY HAVE A CLAIM TO RECEIVE BENEFITS IN PROPOSED CLASS ACTION SETTLEMENTS

IF YOU WISH TO PARTICIPATE IN THE PROPOSED SETTLEMENTS YOU MUST SUBMIT THE ATTACHED CLAIM FORM NO LATER THAN OCTOBER 2, 2017

YOU MAY BE ENTITLED TO A MONEY PAYMENT

IF YOU DO NOT COMPLETE AND SUBMIT THE ATTACHED CLAIM FORM YOU WILL NOT RECEIVE ANY COMPENSATION UNDER THE PROPOSED SETTLEMENTS

THIS NOTICE IS ONLY A SUMMARY OF YOUR RIGHTS. THIS NOTICE IS SENT TO YOU BY ORDER OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS TO INFORM YOU THAT YOU MAY BE ELIGIBLE TO RECEIVE SETTLEMENT BENEFITS FROM THE PROPOSED SETTLEMENTS OF A CLASS ACTION LAWSUIT AGAINST DEFENDANTS SHELL OIL COMPANY AND EQUILON ENTERPRISES, LLC (THE "SHELL DEFENDANTS") AND CONOCOPHILLIPS COMPANY, WRB REFINING LP, CONOCOPHILLIPS WRB PARTNER LLC, AND CENOVUS GPCO LLC (THE "CONOCOPHILLIPS DEFENDANTS").

If the proposed Class Settlements receive final approval from the Court, you may be entitled to receive a money payment from the Shell Defendants and the ConocoPhillips Defendants if you meet the eligibility criteria and you submit the attached Claim Form with the required documentation by no later than October 2, 2017. If the Claim Form is not postmarked or electronically submitted by October 2, 2017, the Court will dismiss your individual claim for benefits, and you will not be entitled to any monetary recovery received under this Class Action or any other action against the Shell Defendants or the ConocoPhillips Defendants relating to these Claims. Failure to act will result in the loss of your legal rights for a money payment.

If you do not want to be part of the Settlements with the Shell Defendants or the ConocoPhillips Defendants, YOU MUST TAKE THE STEPS DESCRIBED IN THIS NOTICE BY OCTOBER 2, 2017, to exclude yourself ("opt out"). If you choose to opt out, you will not receive money payment for claim benefits and will not be bound by the Settlements. If you do not exclude yourself from the Settlements, you will be bound by all terms of the proposed Settlements if they are approved, even if you do not submit a Claim Form.

This is not a lawsuit against you. Your participation in these Settlements will not cause you to owe any out-of-pocket attorneys' fees, and you will not be required to incur any out-of-pocket costs, except for any incidental costs or expenses that you may incur in submitting the Claim Form and the required supporting documentation. Attorneys' fees and expenses associated with this Class Action will be automatically deducted from your monetary award. You will be responsible for any taxes that may be due on your settlement award.

GENERAL INFORMATION ABOUT THE SETTLEMENTS

Why Did I Receive this Notice?

You have received this Notice and the attached Claim Form because you may have owned or occupied property in the Settlement Area on or after January 1, 1986, and thus have been identified as a potential Member of a Settlement Class in a class action lawsuit entitled Jeana Parko, et al. v. Shell Oil Company, et al., Case No. 3:12-cv-00336-NJR-PMF, which is pending in the United States District Court for the Southern District of Illinois. You may be eligible for Settlement benefits if you own or owned property or occupy or occupied property in the Settlement Class Area, defined below, within the Settlement Time Period, also defined below. Only Members of the Settlement Class that submit a Claim Form and the required supporting documentation by October 2, 2017, are eligible to receive monetary benefits from the proposed Settlements.

What Is the Lawsuit About?

The Representative Plaintiff, Jeana Parko, brought a lawsuit against the Shell Defendants and the ConocoPhillips Defendants in April 2012 as a proposed class action on behalf of persons who owned property or lived in the Village of Roxana, Illinois, near the Wood River Refinery (the "Facility"), who claim to have suffered damages as a result of alleged soil and groundwater contamination allegedly caused by releases from the Facility. All Defendants deny Plaintiff's allegations in the Complaint and further deny that they are liable to Plaintiff or to any Member of the Settlement Class based on the claims asserted in the Complaint. Plaintiff and Defendants have concluded, however, that the proposed Settlements are in the best interest of Plaintiff, the Members of the Settlement Class and all Defendants because of the uncertainty, expense, risk, and delays of litigation. The Shell Defendants and the ConocoPhillips Defendants reached separate agreements with the Plaintiff. The Court has given preliminary approval to both Settlements.

How Can I Tell if I Am a Member of the Settlement Class Eligible to Receive a Money Payment?

You are a Member of the Settlement Class if you own or owned or occupy or occupied real property in the Village of Roxana, Illinois, within the geographical area generally referred to as the Illinois Environmental Protection Agency ("IEPA") Study Area (the "Study Area"), between January 1, 1986 to the date of this notice.

Specifically, the Settlement Class Area is defined as follows:

The Settlement Time Period is defined as the period of time between January 1, 1986, to the date of this Notice.

SETTLEMENT BENEFITS

What Do Class Members Receive if the Settlements Are Approved?

MONEY PAYMENTS: The Defendants are paying a total of $4,830,000.00 to settle the claims of the Class Members Individuals who own or owned or occupy or occupied real property in the Settlement Class Area during the Settlement Time Period and who submit timely and valid Claim Forms with all required supporting documentation will receive monetary relief based on a number of factors, including, but not limited to: the period and length of occupancy on the property; the period and length of ownership of the property; the type of property (residential, commercial, other); if residential, the assessed value of the property; where the property is located with respect to groundwater conditions presented in a Groundwater Contour Plume figure submitted to IEPA in April 2012 reflecting groundwater monitoring completed during the first quarter of 2012 (the "2012 Map"); and whether the ownership or occupancy of the member of the Settlement Class ended before March 2007. The total amount of each Claimant's money payment has not yet been determined. The actual amount you receive will depend on the factors noted above, as well as on the total number of eligible Class Members who submit valid Claim Forms.

Properties located outside the Settlement Class Area as defined above and as shown in the Settlement Class Area map are not included in the Settlements. The Parties have agreed, and the Court has ruled, that the groundwater studies and investigations conducted in the area do not provide a basis for including any property outside the Study Area in the Settlement Class Area. Members of the Settlement Class who qualify for membership in the Settlement Class based solely on occupancy (but who did not own a property in the Settlement Class Area) will not be entitled to any compensation for any period of time they lived outside the Settlement Class Area.

RIGHTS OF MEMBERS OF THE SETTLEMENT CLASS

What Rights and Options Do I Have as a Member of the Settlement Class?

If you are a Member of the Settlement Class, you have the following options:

1. You May Participate in the Settlement and Receive Benefits: If you are a Member of the Settlement Class, and if you wish to receive a monetary payment, you must complete and return the attached Claim Form, along with the required supporting documentation relating to each property and/or parcel as to which you are asserting a claim, to the address listed on the Claim Form, or submit them electronically at www.RoxanaClassSettlement.com. Examples of documents you may submit in support of your claim include documents which show your name, address and claimed dates of ownership and/or residence, including but not limited to deeds; mortgage papers; leases; driver's licenses; utility bills; insurance policies; pay stubs; or income, property or other tax forms. If the Settlements receive final approval from the Court, and if you have properly and timely completed and submitted a qualifying Claim Form and the required supporting documentation postmarked or electronically submitted by October 2, 2017, you will receive written confirmation that your claim has been approved and the amount of your monetary payment. If the Member of the Settlement Class is a minor or protected person under Illinois law, or is deceased and died after the Class Action was filed on April 16, 2012, the minor's parent, a duly appointed guardian ad litem or executor, executrix, administrator or administratrix may complete the Claim Form for the minor, protected person or deceased person.

If you remain a Member of the Settlement Class your interests will be represented by Class Counsel without additional outof-pocket cost to you. The attorneys' fees and costs will be automatically deducted from your settlement award. You will be bound by all orders and judgments entered by the Court, whether favorable or unfavorable to the Settlement Class, but you will have the right to support or oppose the Settlements at the Final Approval Hearing.

2. You May Object to the Settlements: If you disagree with any portion of the Settlements, you may remain a Member of the Settlement Class and formally object to the Settlements. You may not object to any term of the Settlements if you exclude yourself (opt out) from the Settlement Class (see Option #3, below). If you decide to remain a Member of the Settlement Class and formally object, you will be bound by all orders and judgments entered by the Court, including those relating to the Settlements, and will not be permitted to later exclude yourself from the Settlements even if the Court disagrees with your objection. Instructions for lodging a formal objection are set forth on pages 11-12 of this Notice. Your written objection must be postmarked or electronically submitted by October 2, 2017, or it will not be considered by the Court.

3. You May Exclude Yourself from the Settlements: If you do not wish to participate in the proposed Settlements providing for monetary relief, you have the right to exclude yourself ("opt out"). Your Request for Exclusion must be postmarked or electronically submitted by October 2, 2017. If you exclude yourself, you will not receive any monetary benefit available under the proposed Settlements and you will not be bound by any orders or judgments entered by the Court. You are not required to opt out from the Settlements to refuse or forego any money payment to which you may be entitled under the Settlements. If you do not timely submit a Claim Form, you will remain a Member of the Settlement Class but you will not receive any money payment in the Settlements.

4. You May Remain a Member of the Settlement Class and Not Submit a Claim: If you are a member of the Settlement Class and do nothing — meaning that you do not submit a Claim Form and you do not submit a request to be excluded — you will receive no Settlement Payment, but you will be bound by any final judgment approving the proposed Settlements.

What Happens if I Submit a Claim Form? (Option # 1, above)

If you submit a Claim Form, the Shell Defendants and the ConocoPhillips Defendants have the right to verify the validity and accuracy of your Claim Form and the document(s) you provide in support of your claim. If your Claim Form is considered valid and supported by sufficient documentation, you will receive a written notification that your claim has been approved. You will be later notified of the amount of your monetary award.

If your Claim Form and/or supporting documents are found to be invalid or insufficient, you will receive notification in writing within fifteen (15) days after your Claim Form was received. You will then have fifteen (15) days to cure the deficiencies in your claim. If your claim is denied after you attempt to cure the deficiencies, you will have the right to appeal the denial to a Neutral Arbitrator appointed by the Court. The decision of the Neutral Arbitrator will be final.

How Do I Exclude Myself from the Settlement Class? (Option # 3, above)

To exclude yourself from the Settlement Class, you must prepare a written Request for Exclusion stating:

Your Request for Exclusion must contain your name, current address, and address (es) in the Settlement Class Area during the Settlement Time Period (if different from your current address), and the dates you owned and/or lived on each such property. It must be signed and dated by you. Your Request for Exclusion must be filed with the Court in an individual capacity, not by anyone on your behalf (although a Request for Exclusion for a minor, protected person or deceased person as defined above may be filed by the minor's parent, a duly appointed guardian ad litem or executor, executrix, administrator or administratrix). You must also mail your Request for Exclusion to the Claims Administrator at the address below, postmarked by no later than October 2, 2017. Mail your Request for Exclusion to:

Alternatively, you can submit your Request for Exclusion to the Claims Administrator by submitting it electronically at www.RoxanaClassSettlement.com. Failure to comply with any of these requirements may result in your opt-out notice being declared invalid. If you exclude yourself from the Settlement Class, you will not be bound by any final judgment as to the Settlement Class, and you will not be entitled to receive a money payment or other benefits of the Settlements.

Release of All Claims Against Defendants

The Court has given preliminary approval to the Shell and ConocoPhillips Settlements. If the Court gives Final Approval to the Settlements, the Court will enter a judgment dismissing all Defendants with prejudice and releasing and forever discharging them from all manner of Claims from all Members of the Settlement Class who have not timely excluded themselves from the Settlement Class, whether or not they object to the Settlements and whether or not they have submitted a Claim Form. Included in the Settlement Agreements is something called a "Release of Claims." The Release paragraphs in each of the Settlement Agreements describe exactly the legal claims you give up if you stay in the Settlement Class. You must carefully read the Release of Claims in the Shell Settlement Agreement and in the ConocoPhillips Settlement Agreement so you understand what you give up in exchange for remaining a Member of the Settlement Class. You may speak to Class Counsel about these Settlements before the exclusion deadline in this case. You may also speak to your attorney, if you are already represented, or to an attorney of your choice, at your own expense.

The Release of Claims, included in the Settlement Agreements, provides that Members of the Settlement Class will release the Released Parties "from any and all claims, demands, actions, complaints, and causes of action connected in any way to the subject of the Actions, whether known or unknown, which the Plaintiffs ever had, now have, or may have in the future, regardless of whether such claims were actually asserted, which directly or indirectly arise from":

As to the Shell Defendants:

As to the ConocoPhillips Defendants:

ConocoPhillips Settlement Agreement, Paragraph E.1.

You may inspect a copy of the Shell Settlement Agreement, the ConocoPhillips Settlement Agreement, the Class Settlement Administration Agreement, and other settlement documents, all of which have been filed with the Court.

Other Obligations and Duties of Class Members

If you are a Member of the Settlement Class, and do not opt out (Option #3, above), you also will be bound by the following terms of the Shell Settlement Agreement and the ConocoPhillips Settlement Agreement:

1. You Agree Not to Object to the Shell Defendants' Investigation, Remediation and Site Closure Activities: Under Paragraph B.13 of the Shell Settlement Agreement, the Parties have agreed as follows:

2. You Will Provide a Written Acknowledgment of a Groundwater Management Zone: In accordance with the terms of the Shell Settlement Agreement and the ConocoPhillips Settlement Agreement, you will acknowledge, in writing, that your property is or may be within the boundary of a Groundwater Management Zone ("GMZ") established pursuant to the authority of the IEPA in connection with the Shell Defendants' ongoing and future remediation activities in or around the Village of Roxana.

3. You Will Agree to Provide Access to your Property for Continued Remediation Activities: Paragraph B.15 of the Shell Settlement Agreement provides that:

4. You Will Agree to Comply with 35 Illinois Administrative Code Part 742: Paragraph B.16 of the Shell Settlement Agreement and Paragraph B.13 of the ConocoPhillips Settlement Agreement provide that:

5. You Will Agree to Make Written Disclosures to Future Purchasers: In accordance with Paragraph B 17 of the Shell Settlement Agreement and Paragraph B14 of the ConocoPhillips Settlement Agreement, you will disclose to any future purchasers of your property that the property is in an area (or is in close proximity to an area) that may be subject to an IEPA-directed remediation. Such disclosure shall be made via the form required by the Illinois Residential Real Property Disclosure Act.

CLASS REPRESENTATIVE, CLASS COUNSEL, & ATTORNEYS' FEES

Who Represents the Settlement Class?

The Class Representative: The Court has appointed Jeana Parko as Class Representative.

Class Counsel: The Court has appointed the following attorneys to represent the Settlement Class for the purposes of Settlement of this lawsuit:

You will not be obligated to pay separately (out of pocket) for the services of the attorneys representing the Settlement Class in this lawsuit. The attorneys' fees and expenses of Class Counsel will be paid from the Settlement Fund and will be automatically deducted from your settlement award. You have the right to retain your own attorney in this matter, but if you do, you will be responsible for paying your own attorneys' fees and expenses. It is not necessary for you to retain your own counsel to participate in the Settlements or to exclude yourself from the Settlements.

You may already be represented by an attorney in connection with claims you may have against Defendants. If so, you may contact your attorney directly. The following attorneys are counsel of record in other lawsuits filed against Defendants:

What Are the Attorneys' Fees and Costs?

Class Counsel will ask the Court for an award of attorneys' fees and expenses based on the total value of the Settlements, and their efforts in the case, not to exceed Twenty-Five Percent (25%) of the Settlement Fund for attorneys' fees plus reimbursement of expenses. Defendants do not oppose the payment of fees and expenses to Class Counsel. The attorneys' fees and expenses awarded by the Court will be paid out of the Settlement Fund, as provided in the Shell Settlement Agreement and the ConocoPhillips Settlement Agreement. Attorneys' fees and expenses of litigation will be deducted from the Settlement Fund. You will not be required to pay any additional out-of-pocket attorneys' fees or expenses to Class Counsel over and above those deducted from your Settlement award.

FINAL APPROVAL OF SETTLEMENTS AND OBJECTIONS

When Will the Court Decide Whether to Give Final Approval to the Settlements?

The Court will hold a Final Approval Hearing on December 18, 2017, at 9:30 am, in Courtroom 3 of the United States District Court for the Southern District of Illinois, located at 750 Missouri Avenue, East St. Louis, Illinois, the Honorable Judge Nancy J. Rosenstengel, presiding (or her duly appointed successor), to determine whether the proposed Settlements are fair, reasonable, and adequate. The date is subject to change. You are not required to attend the Hearing either to participate in the Settlements or to exclude yourself from the Settlements, but you may attend the hearing at your own expense. Note that if you exclude yourself from the Settlements, you may not lodge any objection to the Settlements either in writing or at the Final Approval Hearing. If you are satisfied with the Settlements as described in this Notice, you need not submit any comment nor attend the hearing. You only need submit the attached Claim Form with the required supporting documentation by mail, postmarked by no later than October 2, 2017, to participate in the Settlements. Alternatively, you can submit your Claim Form and the required supporting documentation for each property and parcel for which you are stating a claim electronically on the Claims Administrator's website at www.RoxanaClassSettlement.com, by no later than October 2,2017.

If you remain in the Settlement Class and timely file a written objection to any term of or to the entire Settlements, you may ask for permission to present argument at the Final Approval Hearing, either individually, or through counsel paid for at your own expense. However, you do not have to come to the Court to present your objection. As long as you have properly filed your written objection, the Court will review it.

How Do I Object to the Settlements?

If you determine that you are dissatisfied with the Settlements or any term thereof, but wish to remain a Member of the Settlement Class and not exclude yourself, you are permitted, but not required, to submit a formal objection for the Court to consider in determining whether it will give final approval to the Settlements. To do so, you must file a statement explaining your objection with the Court, and mail or deliver a copy to Class Counsel and Defendants' Counsel at the addresses below or to the Claims Administrator. In order to be considered by the Court, all objections must be filed with the Court and mailed to Counsel and/or the Claims Administrator at the addresses below, postmarked or electronically submitted or delivered no later than October 2, 2017:

Any documents or other material you desire for the Court to consider in support of your objection must be included with your objection. You must mail or deliver to Class Counsel and Defendants' Counsel and/or the Claims Administrator copies of all papers you file in Court. Unless the Court directs otherwise, any Member of the Settlement Class who fails to serve a written objection as described above will not be entitled to object to the approval of the Settlements, to object to the judgment to be entered, or to be heard at the Final Approval Hearing. Unless otherwise ordered by the Court, any Member of the Settlement Class who does not make his or her objection in the manner provided in this Notice shall be deemed to have waived such objection and shall forever be foreclosed from making any objection to the fairness, reasonableness or adequacy of the proposed Settlements, and to the award of attorneys' fees and expenses to Class Counsel.

If you wish, you also may seek to present argument to the Court concerning your objection at the Final Approval Hearing. You are not required to present oral argument even if you elect to file an objection. To present oral argument, you must submit a Notice of Appearance and Intent to Present Argument along with your objection, which also must be filed with the Court and mailed or submitted to Defendant's Counsel and Class Counsel or to the Claims Administrator at the above addresses, postmarked or electronically submitted no later than October 2, 2017.

I HAVE OTHER QUESTIONS, WHAT DO I DO?

This Notice is intended to be a summary of the terms of the proposed Settlements. If you have any questions, please contact Class Counsel Ted N. Gianaris, Esq., at (618) 259-2222. You can also go to the website www.RoxanaClassSettlement. com, where you can find additional information regarding the Settlements, and where you can download relevant forms. Do not go to any website for the Shell Defendants or the ConocoPhillips Defendants, or call any phone numbers for the Shell Defendants or the ConocoPhillips Defendants, as no information pertaining to the Settlements is available there. The pleadings and other papers filed in this lawsuit are also available for inspection and/or copying at the Court.

This Notice is not intended to, and should not be construed as, an expression of any opinion by the Court with respect to the truth of the allegations in the lawsuit, the merits of the claims or defenses asserted, or of the proposed Settlements. This Notice is simply to advise you of the pendency of the lawsuit, the terms of the proposed Settlements, and your rights in connection with the proposed Settlements and claims process.

DO NOT CALL THE COURT OR THE COURT CLERK'S OFFICE TO INQUIRE ABOUT THESE SETTLEMENTS. THEY WILL BE UNABLE TO HELP YOU.

If you have any questions or need more information, please visit the website, www.RoxanaClassSettlement.com or call the Administrator toll-free at 1-866-903-1197.

Dated this 18th Day of August, 2017.