All names marked with** and ended with*** are part of the Hepatitis C Counsel Group. The toll free number to get you in touch with any of these lawyers is 1- 800- 229- LEAD (5323). It may not be working yet so please be patient.

Form letter and information for pre-1986 transfusions in all provinces except BC and Quebec

1. Camp Church and Associates

Sharon Matthews / Kim Graham, 4th Floor, Randall Building, Vancouver, B.C., V6B 1Z5

1-800-689-2322

2. Grant Kovacs Norell
Barristers & Solicitors
930 - 1040 W. Georgia Street
Vancouver, B.C.
V6E 4H1

Bruce Lemer
Telephone: (604) 609-6699
Fax: (604) 609-6688

3. Before August 1, 1986

Klein Lyons David A Klein, 805 West Broadway, Suite 500, Vancouver, B.C. V5Z 1K1

(604)874-7171

(604)874-7180 (FAX)

1. Docken and Company

Clint Docken, #215-840 6th Avenue SW, Calgary, Alberta T2P 3E5,

(403)269-3612

2. Huckvale and Company

Ross Wilde, 612 3rd Avenue South, Lethbridge, Alberta, T1J 0H5

(403)328-8856

**

Kapoor, Selnes, Klimm & Brown

William A. Selnes, 417 Main Street, P.O. Box 2200,Melfort, Saskatchewan S0E 1A0

(306)752-5777

(306)752-2712 (FAX) ***

Botan and Associates

Allan Botan Suite 605, 201 Portage Avenue, Winnepeg, Manitoba R3B 3K6

(204) 943-2960

**

1. Tinkler and Morris

Phillip Tinkler, Suite 304, 150 York Street, Toronto, Ontario, M5H 3S5

(416) 362-2900 ex 23 ***

2. Dempster, Dermody, Riley and Buntain

William Dermody, 4 Hughson Street South, 2nd Floor, Hamilton, Ontario, L8N 3Z1

(905) 572- 6688

3. ** LEAD COUNSEL

Harvey T Strosberg, 600 Westcourt Place, Windsor, Ontario, N9A 6V4

(519)258- 9333

(519)258- 9527 (FAX) ***

**

4. Elliot, Rodrigues & Daffem

R. Douglas Elliot, 181 University Avenue, Suite 1050, Toronto, Ontario, M5H 3M7

(416)362-1989

(416)362-6204 (FAX) ***

**

5. Kenneth Arenson,

Personal Injury Lawyers

Email Kenneth

179 John St. Toronto,Ontario, M5T 1X4,

(416) 593- 4445 (TELEPHONE)

(416)593- 6606 (FAX) ***

Form letter re pre-August 1, 1986 infections

[Month], 1997

[Name and Address]

Dear

RE: HCV CLASS ACTION

Thank you for your inquiries regarding the Hepatitis C Class Action. Our firm is part of the team involved in this Class Action. In this letter, we hope to answer any questions that you may have about the Class Action and your relationship to the proposed class.

At the end of this letter, we will outline what we believe your options to be. Attached to this letter is a form that will allow you to indicate which of the options you are interested in pursuing. Please return this form within twenty-one days after receiving this letter. If you do not return the form to our offices, we will assume that you do not wish to pursue any of the options we have outlined and we will not take any action on your behalf in this matter.

A. INFORMATION ABOUT THE PROPOSED CLASS ACTION

1. Our proposed class of people currently includes persons infected with Hepatitis C from a blood transfusion between August 1, 1986 and June 30, 1990 in any province other than Quebec or British Columbia. We intend to seek court approval for the Class Action in the fall of 1997. This is called certification of the class.

2. The proposed Class includes families of people who have been infected by Hepatitis C from a blood transfusion between August 1, 1986 and June 30, 1990.

3. The proposed Class includes Estates of people who were infected with Hepatitis C from blood transfusion between August 1, 1986 and June 30, 1990, and who died as a result.

4. The proposed Class Action is being brought only against the Canadian Red Cross Society, the federal government and all provincial governments except Quebec and British Columbia. We are not naming individual physicians or hospitals as defendants in the proposed Class Action.

5. Although the proposed class does not include hemophiliacs, there may be a future class proceeding which does include hemophiliacs. We are encouraging other counsel to commence such a class action. It is more difficult to establish liability in hemophilia cases involving Hepatitis C, especially given the multiple infusions and the various products infused.

6. The proposed Class includes only people infected with tainted blood from a blood transfusion. It does not include people infected by blood products, such as hemophiliacs. We formed the opinion that there were not sufficient common issues to justify joining together hemophiliacs and transfusion recipients.

7. We have chosen the dates for our proposed Class Action based on the date when the American Association of Blood Banks commenced surrogate testing blood donations (August 1, 1986) and the date when the Canadian Red Cross Society apparently commenced testing blood donations for antibodies to the Hepatitis C virus (June 30, 1990).

PEOPLE INFECTED BY TRANSFUSIONS BETWEEN 1982 AND JULY 31, 1986:

These persons may in the future wish to form a class action or may wish to commence individual actions. Persons infected in this period may be able to establish negligence, but they are not part of the current class action.

OPTIONS FOR PEOPLE INFECTED BETWEEN 1982 AND JULY 31, 1986:

Please note that we will not take any action on your behalf until the specific date of your Hepatitis C infection from a blood transfusion has been verified. If you are interested in any of the options listed below, we will require you to verify the date on which you received tainted blood (not just the date(s) of any blood transfusion). This information can be obtained through inquiries by your physician and by contacting the Red Cross. Alternatively, we will assist you in verifying the date of your infection. The following options are appropriate for you to take if you know that you were infected with tainted blood between 1982 and 1986 or if you do not know the date that you were infected.

In light of the information we have set out above, we believe that your options are listed below.

We ask that you check the applicable box and return this form to us.

1. [ ] You want us to monitor the situation on your behalf and inform you if government compensation is offered for which you are eligible, or if a Class Action for people infected between 1982 and 1986 is begun. There are no legal costs involved in this option.

2. [ ] You want us to assist you in verifying the date of your Hepatitis C infection. You may be billed for our time and will be required to pay our out of pocket expenses.

3. [ ] If you are concerned about preserving your litigation rights, we will issue an individual Statement of Claim on your behalf. We will need to review your medical records and confirm with the Red Cross when you received the blood transfusion infected with Hepatitis C. Our block fee for issuing a Statement of Claim is $750.00. This does not include any charges imposed by hospitals for copies of their records. You must pay that expense. We will not issue a Statement of Claim unless this fee has been paid. However, we cannot guarantee that we will be able to act as your counsel for the duration of any such action. As a result, it may become necessary for you to retain other counsel at a later date after the claim has been issued. The individual actions will be held in abeyance to the extent possible while the current Class Action proceeds.

4. [ ] You wish to retain other counsel, or do not wish our firm to have further involvement in your case.

IF YOU WISH TO PURSUE EITHER OPTION 1, 2, OR 3 YOU MUST CONTACT US WITHIN TWENTY-ONE DAYS OF RECEIVING THIS LETTER. WE WILL ASSUME THAT ANYONE WHO HAS NOT CONTACTED US WITHIN THIS TIME PERIOD DOES NOT WISH TO PURSUE ANY OF THE OPTIONS AND WE WILL TAKE NO ACTION ON THEIR BEHALF. WE WILL ASSUME YOU HAVE SELECTED OPTION #4 IF WE DO NOT RECEIVE A REPLY.

NAME: (Please print)

Telephone Number:

Fax Number:

E-mail:

Signature:__________________________

DATE OF BIRTH

ADDRESS: (please print)

DATE OF INFECTION BY TRANSFUSION:

NAME OF HOSPITAL WHERE TRANSFUSION OCCURRED:

NAME OF PHYSICIAN WHO NOW TREATS YOU:

end of form______________________________________

I believe that my colleagues on the Ontario group of lawyers are also doing this, and people may choose who they wish to sign on with. The names and addresses are conveniently given in Darlene Morrow's site. Look for the asterisks [*]. **

6. Harvin Pitch

70 Bond Street, Toronto, Ontario, M5B 1X3

(416)865-5310 ***