NAFSAGR PO BOX 737 AMSTERDAM, NY 12010
Phone/Fax 518-843-9986
Email NAFSAGR@AOL.COM

----Original Message-----
From: NAFSAGR@aol.com [mailto:NAFSAGR@aol.com]
Sent: Wednesday, June 16, 1999 9:14 AM

June 16, 1999

   I am pleased to inform you that after 21 months of effort, and meetings with scores of law firms, we have reached an agreement with a firm that is willing to take our cases on a contingent basis. This firm is prepared to file class action lawsuits, in numerous states across the country, on behalf of the independently owned Autoglass replacement shops within that state. They will decide which states are most appropriate after reviewing the facts, and potential plaintiffs within a given state. All of the shops within the state will be part of the class, once it is defined and identified; unless they elect to opt out as a participant. It is important to understand that even though these will be class action lawsuits within given states, they will have national impact.

   In each instance various "causes of action" will be cited. These, essentially state that class members have a right to sue because a certain law has been violated, and the class members have been harmed, as a result. For instance; the class members have been harmed because a network illegally steered customers in violation of the statute in that state which prohibits steering, (first cause of action). The second cause of action might state that class members have been harmed because the network refused to pay the customary amount paid, (which they were reimbursed by the insurance company) in violation of the state unfair business practices laws. Another cause of action may utilize the Unfair Business Practices Act, alleging that the networks, by illegally steering customers, have gained an unfair competitive advantage. Since the only way the network could effectuate the illegal steering is through the use of wire, and mail; fraud; RICO may be deemed appropriate. The attorneys will decide, in each state, which causes of action to are most appropriate to allege.

   There are several reasons why we have elected to take action in individual states, rather than a federal action. Some of the reasons are as follows. In each instance we will be in front of a state judge whose constituents, both glass shops and the public, have been effected. By filing numerous state actions we eliminate the possibility of drawing one judge that may be very conservative, or have sympathy toward insurance companies, and might dismiss the action. We are able to bring the state's unfair business practice statutes, and several states have very strong statutes of this type, to protect the businesses that reside in the state.

   In order for NAFSAGR to complete its mission, and in order for you to benefit, there are several steps, which must be undertaken. The first, is to identify between two and five shops that are willing to act as plaintiffs. Once we have these, we will file the action, and request that we be granted "class" status. The plaintiffs would then be the "Class Representatives," and have the only voice in reaching decisions about the suit. We also need to gain minimal financial support from a limited number of other shops. This will be used to set off any out of pocket expense for the plaintiffs; to set off my expense, and provide me with some income during the process. It is imperative that we establish a system that protects the plaintiffs from any out of pocket expense. Bear in mind, there will be no legal expenses incurred by plaintiffs. A lawsuit of this magnitude would require very significant legal fees, probably in excess of several hundred thousands of dollars. This firm is prepared to bear that expense.

   Allow me to act as a "Dutch Uncle," for a moment. Our industry has been devastated by the illegal practices of these networks, and insurance companies. You have been harmed. Every time I have spoken, all over the country, I have heard the complaints, the anger, the frustration, and the despair. Only you can do something about this. I cannot make this happen, without a few of you stepping forward. If you do nothing, chances are others will also do nothing, and the end result is that nothing will get done to end this. This opportunity will not come again. We can now try to put an end to the way we are effected by networks. We can do so, with no legal fees. We can do it, if you help, and recruit a few of your friends from the industry to help.

Please contact me, at your earliest convenience, if you are willing to help in this effort.

Yours truly,

Vince Salluzzo