BENEFITS TO CURRENT ANDFORMER OWNERS AND LESSEES

VW8,4

2001 - 2004 VOLKSWAGEN PASSATWITH 1.8L TURBO ENGINE

• T h e August 2004 8-year/unlimited mileage Extended Warrantyremains in effect (you may continue to use the oilrecommended in your owner's manual),

• I f you paid for sludge-related repairs or engine replacement inthe Past and have not been reimbursed, you may submit or re-submit your claim for reimbursement. Even if your claim wasdenied in the past, you may resubmit your claim to the OilSludge Settlement Administrator.o 1 0 0 % Reimbursement with proper documentation

regarding last two required oil changes• 5 0 % Reimbursement without proper documentation

regarding last two required oil changes

• I n addition, i f you are a current owner, you will have a 10-year/120,000-mile Enhanced Oil Sludge Warranty Extension ifyou use VW specification 502 00 oil or a synthetic oil certified ascomplying with VW specification 502 Oa

• I f your vehicle suffers sludge-related damage in the future (10years/120,000 miles), be advised that any sludge-relatedrepairs or engine replacements must be performed at anauthorized Volkswagen dealer or they will not be covered.

o 1 0 0 % Reimbursement with proper documentation ofrequired oil changes

• Y o u are entitled to a one-time $25 discount off the price of anoil change at any authorized VW dealer using VW specification502 00 oil or a synthetic oil certified as complying with VWspecification 502 00, which must be used within one (1) yearafter the Final Judicial Approval Date.

• IMPORTANT: To protect your rights to the benefits of theEnhanced Oil Sludge Warranty Extension, you must:a. U s e the correct oil.b. Change your oil according to the schedule in the owneeS

manualC. K t It ILMILISSC Ia lfga r tMlia lS its hingt i . ,

VW 84

NOTICE

2001 - 2004 VOLKSWAGEN PASSATWITH 1.81 TURBO ENGINE

• Y o u should use only VW specification 502 00 oil or asynthetic oil certified as complying with VW specification502 00 in the 1.81 Turbo engine.

• T h e 1.81 Turbo engine requires quality engine lubrication(oil).

• M a n y synthetic oils provide better engine lubricationthat can outlast most traditional petroleum-based oils.

• A t the time of printing, all the engine oils Volkswagen isaware of that meet VW specification 502 00 aresynthetic-based.

• I f you do not use quality engine oil, long-term damagecan occur that will require expensive engine repairs.

• Qu al i ty engine oil helps your vehicle's 1.8T engine runsmoothly and helps prevent the formation of harmfulsludge and deposits that can lead to expensive repairs.

• E ngi ne damage caused by using the wrong engine oil isnot covered by the 10-year/120,000-mile Enhanced OilSludge Warranty Extension.

• I n order to be entitled to the 10-year/120,000-mileEnhanced Oil Sludge Warranty Extension, you must useoil that conforms to VW specification 502 00 or syntheticoil certified as complying with VW specification 502 00.You must maintain oil change records which documentthe use of VW specification 502 00 oil or a synthetic oilcertified as complying with VW specification 502 00 atthe specified service intervals to be eligible for the 10-year/120,000-mile Enhanced Oil Sludge WarrantyExtension. I f you choose to use the oil recommended inthe owner's manual, you are still entitled to the benefitsof the August 2004 8-year/unlimited mileage ExtendedWarranty.,

• A n y sludge related repairs or engine replacements mustbe performed at an authorized Volkswagen dealer orthey will not be covered.

111M11111

0i178267-0173199

f.',AN DIEGO,. CA 9

December 20 2010

S u l-4 * cl Class Action Settlarnant NO4k41

Enhanced OH Sludge Warranty Extension for 20014064 illodol YewVolkswagen Passat and Passel Wagon Vehicles Equipped wit1i111 Turbo Engine

()ear volkswegen Owner of VIN

O r records show that you are a current or former owner or iessee of a 2001-2004 modal Am •dolitsvawPassat or Passel Wagon with a 181. turbo engine We are writing to inform you Mat Voikaviwjan Grow OfAmerica, Inc (Volkswagen") has agreed to a proposed class action settlement which is boric sobmated to theCourt for approval The class action complaints allege that the St_ turbo engines are prone to the forrnabon of oilsludge and coking deposits even when maintained according to me recommended maintenance ~ n e s and 04gualitv specifications Volkswagen denies all the aliegations in the class action complaints NonetNtess 4 theSettlement is approved by the Court, Volkswagen has agreed to provide an Enhanced Oil Siodge narrantiExtension covering oil sludge related engine repairs or engine replacerrents on 2001-20C4 MC13et yearVOlkswagen Patisetunri Peitisitt Wagon ve111006 tiquipped witti 1.& turbo engines and other bagletatio Kelempa

"A the Class Notice

What Is the Issue?

Under certain conditions, the 1•13I turbo engine can encounter problems resulting from a condition known as oatsludge The best protection against oil sludge is the use of oil conforming to VW specification 502 00 accordingrecommended oil change intervals Fo r that reason. we strongly recommend that you use engine oil thatexpressly conforms to VW specification 502 00 or a syntriebc oil certified as complying with VW tat qualitystandard 502 00

A implecie wth env * sludge may exhibit a constantly or occasionally illuminated Red Engine Oil PressureWarning tight

What WISI Volkswagen Do?Volkswagen is p ro w" an Enhanced Oil Sludge Warranty Extension covenng o0 Midge retated repairs or enginef"erAecement tot 2001-2004 model year Volkswagen Passat vehicles adistopect ivith the 1.81 tu f t engsra&S Anysludge rotated rect.*, or engine replacements must be performed at an authorized Volkswagen dealer orthey *411 not be covered. t he penoc of tNs extended warranty ,s 10 mars or 12000 miles •,-. d " t r g e r x m l i t

first. frOm tot teNditS o n , * in-sonnce date In order to be entitled to the 10-year-120 0 0 0 - m i l e E n h a n c e d O S

Sludge Warmly Extention, you u s e oil tot meets Volkswagen specification 502 00 or srahsbc 04certifiedSs cornslyesa gni VOlkotvagon owookabon 502 00 The vehicles moms in-service date delltsed as to Msto view* was lelverwl to either the ongral purchaser or the ovnal lessee, or 1 tie vehicle ow Plocodserval as a *demonstrator or 40 o m b e n y • m o r . o n M e d i a s s u c h W i t te w as I k la O we n in w i nd s -

The August 2004 Illearknilmited nasal* Extended Warranty omens in toned (picreded you utie the direcommended in your owner s Manuel) Nit 4 rxi ults I r e l meets VW sPecnicalnln 502 O D a t 1 1 00, 1 1 1S C 0 1

cisttAsd as tornotying alb VW soecticatton 502 00, you a t s o be enured to the 10-poi012000,o0leEnhanced 00 Sludge Warmly Extension.

Votkologeow'1 A.-mecat lestMO O PillPrOn Az o oAuthom M kt ise 44)26

The 8-yearunlimited mileage extended warranty and the 10-year/120,000-mile Enhanced Oil Sludge WarrantyExtension are fully transferable to any subsequent owner and do not affect - and are in addition to - any otherapplicable warranty covering your vehicle.

Dunng the 10-yeart120,000-mile Enhanced Oil Sludge Warranty Extension period, Volkswagen will providewarranty coverage for engine repairs required because of oil sludge, as long as you can provide documentation of(i) use of oil meeting VW specification 502 00 or a synthetic oil certified as complying with VW specification 50200 for all oil changes after your receipt of this letter, and (ii) oil changes at the intervals specified in themaintenance schedule for your vehicle. A detailed statement regarding coverage under the warranty extension isset forth in the enclosed Class Notice

Volkswagen is providing a one-time $25 oil change discount redeemable at any Volkswagen dealership within one(1) year from the date of Final Judicial Approval of the settlement. This entitles you to a $25 discount off the priceof an oil and filter change using oil that meets VW specification 502 00 or a synthetic oil certified as complyingwith VW specification 502 00 Please visit www mollsludgesettlement.com to determine when this $25 discountbecomes available

What We Would Like You to Do

• Y o u must use oil meeting NAN specification 502 00 or a synthetic oil certified as complying with VWspecification 502 00 to be entitled to the 10-year/120,000-mile Enhanced Oil Sludge WarrantyExtension

• I f you choose to use the oil recommended in your original owner's manual, you will remain eligible forthe &year/unlimited mileage warranty extension, but you will not be eligible for the 10-year/120,000-mileEnhanced Oil Sludge Warranty Extension.

• Volkswagen strongly recommends that, (1) you follow the maintenance schedule in your owner's manualand have the engine oil changed at the prescribed oil change intervals, (n) you use only engine oilmeeting VW specification 502 00 or a synthetic oil certified as complying with VW specification 502 00,and (iii) keep records of the oil changes and oil used in order to obtain the benefit of the 10year/120,000 mile extended warranty referred to above, I f you do not follow these procedures, theEnhanced Oil Sludge Warranty Extension will not apply,

• A list of oils that as of the printing date of this letter) meet VW specification 502 00 is included in theenclosed owner's manual supplement.

• A s a reminder that oil meeting VW specification 502 00 is recommended for your vehicle, an enginecompartment sticker with instructions for installing it on your vehicle is enclosed.

• Please remember under some circumstances the engine oil should even be changed more frequentlyChange oil more often if you dnve mostly short distances, operate the vehicle in dusty areas or mostlyunder stop-and-go traffic conditions, or when you use your vehicle where temperatures stay below thefreezing point for long pehods of time

• I f your vehicle has symptoms of engine oil sludge, please contact your authorized Volkswagen dealer assoon as possible and arrange for an appointment, so that your vehicle can be serviced without delay.

• Please keep this letter with your Warranty Booklet and deliver it to any new owner, along with theowner's manual.

Reimbursement for Engine Repair or Engine Replacement

If you paid for sludge-related repairs or engine replacement in the past and have not been reimbursed, you maysubmit or re-submit your claim for reimbursement. Even if your claim was denied in the past, you may resubmityour claim to the Settlement Administrator.

If you can provide documentation of proper maintenance, you may be entitled to 100% reimbursement, I f youcannot provide documentation of proper maintenance, you will be entitled to 50% reimbursement. The enclosedClass Notice explains how to make a claim for reimbursement.

We regret any inconvenience this matter has caused, and we wish you many more years of driving pleasure withyour vehicle Thank you for driving a Volkswagen!Sincerely,

Volkswagen GroupolAmenca, Inc

(1111,1q1!MI111(1),1.11,10,41111

SAN DIEGO, CA 9

VIN NUMBER:

0

OIL SLUDGE SETTLEMENTREIMBURSEMENT CLAIM FORM

THE UNITED STATES DISTRICT COURTDISTRICT OF MASSACHUSETTSCASE NUMBER: 1:07-MD-01790

Evening Phone. ( ) _

Daytime Phone: ( _ _ ) _

YOU MUST MAIL YOUR COMPLETED AND SIGNED CLAIM FORM AND REQUIRED DOCUMENTATIONPOSTMARKED ON OR BEFORE JUNE 27, 2011, ADDRESSED AS FOLLOWS

Oil Sludge Settlement AdministratorPO Box 2410

Faribault, MN 55021-9110

PLEASE SUBMIT THE FOLLOWING DOCUMENTS WITH THIS FORM.

L C op i es of receipts, invoices and/or repai r orders are acceptable. PLEASE NOTE; DOCUMENTS WILL NOT BE RETURNED D O NOT STAPLEDOCUMENTS.

2. T h e documentation you submit must show all of the following:• T h e name and address of the claimant.

• T h e make, model year, and Vehicle Identification Number (VIN) of the vehicle.

• N a t u r e of repair or replacement ( including par ts and labor charges) (i.e• repair orders, bills, receipts, invoices, etc ), when, and w hoperformed it and, where applicable, similar information with respect to towing or rental car costs up to a combined limit of $250 which youpaid in connection with such repair or replacement.

• T h a t the repair or replacement was required because of oil sludge formation in the engine.

• Y o u r claim will be acted upon within 60 days of receipt.

Customer's Signature X

El I 111111J111! 1111) I I I k ill 1 1 )1

FOR (WHOM. USE ONLY

fl C h eck here if the pre-printed information is incorrect or it thereis no preprinted information and complete the following:

Name

Address:

VIN No.:

City. State. Zip Code:

3. C o p y of proof of payment (i.e. cancelled check, bank statement, invoice or receipt marked "paid," etc.) for the repair, replacement, or expense inquestion and date of payment Requests for reimbursement may include parts, labor, fees and taxes.

If your claim is approved, you will receive a check from the Oil Sludge Settlement Administrator if the Settlement is finally approved. There maybe a delay to allow the Settlement to become final. Notification of approval of your claim will include the best available information as to theearliest date on which payment May be expected. Fur ther information will be posted at www.vwoilsludgeSettlement.com.

If your claim is incomplete, the Oil Sludge Settlement Administrator will contact you and identi fy the documentation that is needed to supportyour claim, and you will be offered the oppor tuni ty to resubmit additional documentation.

y, I f your claim is denied in whole or in par t, you will be contacted by the Oil Sludge Settlement Administrator concerning the reason(s) for thedenial.

My signature to this document attests, under penalty of perjury, that the information provided is true, accorate and correct, that all statements madein support of my request for reimbursement are true to the best of my knowledge and the accompanying documents are actual copies reflecting theactual expense(s) incurred relating to such claims.

I 111111 !I II 111111111111 0 ,

VSUP4

Engine Oil SupplementVolkswagen models with

1.81 Turbo engine

This Document Relates to All Cases

THE UNITED STATES DISTRICT COURTDISTRICT OF MASSACHUSETTS

In re Volkswagen and Audi D o c k e t No. 1:07-md-01790Warranty Extension Litigation

TO ALL CURRENT AND FORMER OWNERS AND LESSEES OF MODEL YEAR 22Q12004 VOLKSWAGEN PASSAT VEHICLES EQUIPPED WITH 1.8 LITER TURBO ENGINES.IMPORTED OR DISTRIBUTED FOR SALE OR LEASE IN THE UNITED STATES BYVOLKSWAGEN OF AMERICA, INC.

This Notice advises you of a proposed Class Action Settlement of the above-captionedactions, the conditional certification of the Class, the Hearing before the Court todetermine the fairness, adequacy and reasonableness of the proposed Settlementand the application of Class Counsel for fees, reimbursement of costs and expensesin the prosecution of these actions and incentive payments to the RepresentativePlaintiffs. This proposed Settlement is intended to resolve consolidated lawsuitsrelated to complaints of oil sludge in affected Settlement Class Vehicles by providingcertain cash reimbursements, making available the Enhanced Oil Sludge WarrantyExtension coverage (10 years/120,000 miles) for sludge-related engine repairsor engine replacement, and providing revised maintenance recommendationsconcerning use of the proper engine oil.

You SHOULD READ THE ENTIRE NOTICE CAREFULLY BECAUSE YOUR LEGAL RIGHTS AREAFFECTED WHETHER YOU ACT OR NOT. YOUR RIGHTS AND OPTIONS ARE EXPLAINED INTHIS NOTICE.

• F o r current owners or lessees, this package also includes a customerletter, a Supplement to your Owner's Manual with current informationand recommendations regarding oil maintenance applicable to yourSettlement Class Vehicle and an oil maintenance reminder sticker tobe placed under the hood of your vehicle according to the enclosedinstructions.

• Please place the Supplement in your Owner's Manual so that youand anyone servicing your vehicle will be in a position to observe andfollow it and affix the oil maintenance reminder sticker under thehood of your vehicle according to the enclosed instructions.

• I f you are not the current owner or lessee of the vehicle, please passon this entire package to the current owner or lessee.

CONTENTS

BASIC INFORMATION1. W H Y DID YOU GET THIS NOTICE PACKAGE?2. H o w CAN You GET MORE INFORMATION?3. WHAT ARE THESE LAWSUITS ABOUT?4. WHAT IS A CLASS ACTION?5. WH Y IS THERE A PROPOSED SETTLEMENT?6. DOES THIS NOTICE AFFECT You?THE SETTLEMENT BENEFITS - WHAT YOU GET7. W H A T DOES THE SETTLEMENT PROVIDE To You?8. W H A T DOES THE SETTLEMENT PROVIDE To THE ENTIRE CLASS?9. WHAT CLAIMS WILL YOU RELEASE?THE LAWYERS REPRESENTING YOU10. WHO IS REPRESENTING THE SETTLEMENT CLASS?11. Ho w WILL THE LAWYERS BE PAID?

1

PAGE 2

PAGE 5

PAGE 9

PAGE 10YOUR OPTIONS12. Ho w CAN You EXCLUDE YOURSELF FROM THE SETTLEMENT?13. Ho w CAN You OBJECT To THE SETTLEMENT?14. WHAT DOES IT MEAN To OBJECT?15. Ho w Do YOU FILE AN OBJECTION TO THE SETTLEMENT?16. WHEN AND WHERE WILL THE COURT DECIDE

WHETHER To APPROVE THE SETTLEMENT?17. Do YOU HAVE To Go To THE FAIRNESS HEARING?18. MAY You SPEAK AT THE HEARING?

GETTING MORE INFORMATION P A G E 1219. ARE THERE MORE DETAILS ABOUT THE SETTLEMENT?

According to our records, you or someone in your family may have purchased orleased a model year 2001-2004 Volkswagen Passat vehicle equipped with a 1.8liter turbo engine, imported or distributed for sale or lease in the United Statesby Volkswagen of America, Inc. (now named Volkswagen Group of America, Inc.,and referred to hereinafter as "VWGoA"). These vehicles have been included inthe proposed Settlement Class of lawsuits consolidated for pretrial proceedings inthe United States District Court for the District of Massachusetts (the "Court") andassigned to the Hon. Joseph L. Tauro.The Court has ordered this Notice to be sent to you because you have a right to knowabout the proposed Settlement of a class action lawsuit and about all of your options.This Notice explains the lawsuit, the proposed Settlement, your legal rights, whatbenefits are available, who is eligible for them, and how to get them.

VWN4

y did you get this notice packsge?

BASIC INFORMATION

Sid mon; infoirotodost-7?

You c a n contact t h e O i l Sludge Settlement Administrator c ot insetiritatIM21Illitil1elenteM11311,9.M fOr AnSWer5 to aLkestIons about the osoProwtOsettlement Please do not contact the Court Personnel there wig not be able toanswer your questions.

• • •,,,,,,gr9911 .. **I

S M 6 1 1 1 11/ 4 1 t ,1 1 1 / 1 1 / 41 1 0 0 1 1 1f t ,

04011C12001 - 2004 VOLKSWAGIN PASSAT WITH 1 i t TURBO ENGINE

,in t C iSS * 1 4-non ( J r n p w er e“e . . .. eg in r j an 4i -a ry

Plainttits allege that the 1 8 liter turbo engines •sistaiied ti Seitternent Class Vehiclesate Prone to the formation cif oil sludge and cong deposits even when maintainedWording to the reCOMMPrO0fi trI4intqinartre intervals and oil Quality tberificationsPlaintiffs further allege that the August 20(4 blended Oil Sludge Warranty fi Yeats/unlimited mileage) violated aoolirable rOnSUrner OrateCtierl laws The Defendantsdeny any defect, wrongdoing, or liability whatsoever and deny that this litigationCould be certified as a class action for trial

• Y o u should use only VW specification 502 00 oil or a gynthetic oilcertified as complying with VW specification 502 00 in the L E Turboengine.

• T h e 1.81. Turbo engine requires quality engine lubrication (oil)• M a n y synthetic oils provide better engine lubrication that can outlast

most traditional petroleum-based oils.• A t the time of printing, Jj the engine oils Volkswagen is aware of that

meet VW specification 502 00 are syntheta-based• I f you do not use quality engine oil, long-term damage can OCCUr that

will require expensive engine repairs.• Q u a l i t y engine oil helps your vehicle's 1.8T engine run smoothly and

helps prevent the formation of harmful sludge and deposits that canlead to expensive repairs.

• Engine damage caused by using the wrong engine oil is riot covered bythe 10-year/120,000-mile Enhanced Oil Sludge Warranty Extension.

• I n order to be entitled to the 10-year/120,000-mile Enhanced OilSludge Warranty Extension, you must use oil that conforms to VWspecification 502 00 or synthetic oil certified as complying with VWspecification 502 00. You must maintain oil change records WW1document the use of VW specification 502 00 oil or a synth** oilcodified as complying with VW specification 502 00 at the %pedaledN M ( ' intervals t o b e eligible for the 10.year/120,000.waspIlohentAid Oil Sludge Warranty Extension., i f you dimes to me tilie011 topcomtimenotd in the owner's manual, you *to I t i o d tothe benefits of the August 2004 S•yarategaillatted tornsay losomisedWiwranty*Ng iludesrelAted reP40,11 1 1 1 1 1 1 0 1 . 0 n * t e l p i a t e mo n i t m at t o r t el o v v we

at $o author/tape Wag:swipe alloalot ow VMS Wit mit tie woototi.

WhattsIn a class action, one or more persons called Class Representatives are allowed to rmr,as plaintiffs on behalf of people who assert similar claims (i.e., "Class Members")

After extensive pre-trial litigation and discovery, both sides have agreed to aSettlement. By agreeing to a Settlement, both sides avoid the costs and risk', ofa trial, and members of the Settlement Class obtain the benefits provided in theSettlement. The Court has not decided in favor of either side and has not decidedwhether these lawsuits can or should be certified as a class action for trial ThePlaintiffs, acting as Class Representatives, and their attorneys believe that theSettlement is fair and adequate.

The proposed Settlement Class, which the Court has conditionally certified, Includespersons who fit the following description:All current and former owners of record or lessees of model year 2001-2004Volkswagen Passat vehicles equipped with 1.8 liter turbo engines, imported ordistributed for sale or lease in the United States by Volkswagen of America, Inc.If you fit within this description, this Notice applies to you.The Settlement Class Vehicles described above is a subclass of a broader proposedSettlement Class, which includes all current and former owners and lessees of 1998-2004 Volkswagen Passat vehicles equipped with 1.8 liter turbo engines, as well ascertain 1997-2004 Audi A4 vehicles equipped with 1.8 liter turbo engines, importedand distributed for sale or lease in the United States by VINGoA. The relief availableto each subclass varies based on the terms of the Settlement.

If you have owned or leased any other Settlement Class Vehicle(s) within this broaderdefinition, and you have not received a Notice regarding such Settlement Class Vehicle(s),please consult the Settlement website, www.vwoilsludEesettlementicom or contactthe Oil Sludge Settlement Administrator by e-mail at i n k a y t i g i b l u d g o l i t he m otcorn or toll free, at 1-877-522-0447, to obtain the appropriate Notice(s) applicable toany such Settlement Class Vehicle(s) which you own or lease or have ever owned orleased, and/or as to which you want to review the relief provided.

VWN4 - 4 -

-

' E w a* SUMMARY OF SETTLEMENT BENEFITS

• T h e August 2004 8-year/unlimited mileage Extended Warranty remainsin effect (you may continue to use the oil recommended in your owner'smanual).

• I f you paid for sludge-related repairs or engine replacement in the a tand have not been reimbursed, you may submit or re-submit your claimfor reimbursement. Even if your claim was denied in the past, you mayresubmit your claim to the Oil Sludge Settlement Administrator,o 1 0 0 % Reimbursement with proper documentation regarding last

two required oil changeso 5 0 % Reimbursement without proper documentation regarding last

two required oil changesIn addition, if you are a current owner, you will have a 10-year/120,000-mile Enhanced Oil Sludge Warranty Extension i f you use VWspecification 502 00 oil or a synthetic oil certified as complying with VWspecification 502 00

• I f your vehicle suffers sludge-related damage in th_e_ future (10years/120,000 miles), be advised that any sludge-related repairs orengine replacements must be performed at an authorized Volkswagendealer or they will not be covered.o 1 0 0 % Reimbursement with proper documentation of required oil

changes• Y o u are entitled to a one-time $25 discount off the price of an oil change

at any authorized VW dealer using VW specification 502 00 oil or asynthetic oil certified as complying with VW specification 502 00, whichmust be used within one (1) year after the Final Judicial Approval Date.

• IMPORTANT: To protect your rights to the benefits of the Enhanced OilSludge Warranty Extension, you must:a. U s e the correct oil.b. Change your oil according to the schedule in the owner's manual,c. Keep your receipts and records of oil changes.

• NOTE: For additional information, see details below.

7 What doted* Settlement provide to you?Pursuant to the Settlement terms, VWGoA has agreed to an Enhanced Oil SludgeWarranty Extension (10 years/120,000 miles) and supplemental maintenanceguidelines and standards with respect to engine oil maintenance, as well asreimbursement of Unpaid Extended Oil Sludge Warranty Claims, and other benefitsas explained in greater detail below. The details of these programs, as they apply tothe subclass of Settlement Class Vehicles described in this Notice, are as follows;

and former owners and lessees1If you have paid out of pocket expenses arising from the repair or replacement ofyour engine which you believe should be covered or reimbursed under the ExtendedOil Sludge Warranty issued by W/GoA in August 2004, you may submit or resubmityour claim A claim form is enclosed.VWN4

To be eligible for reimbursement, your claim and supporting document m u s t ationsubmitted on or before June 27, 2011. Any claims received after June 27, 2011 wil-1not be considered for reimbursement.

100% Reimbursement: If you can submit documentary proof of performance of thelast two oil changes required by your maintenance schedule prior to the repair orreplacement with oil quality as originally specified by the owner's manual applicableto your vehicle, with a permissible variance of 20% of the time and mileage intervals,you will be reimbursed 100% for parts and labor, plus reasonable associated expenses,1.e towing and/or rental car costs (up to a combined limit of $250) of the coveredrepair or replacement.

50% Reimbursement: if you cannot provide such proof, VWGoA will pay 50% ofdocumented parts, labor and reasonable associated expenses with respect to therepair or replacement.

VWGoA will not pay any claim for personal injury (including physical, psychological, ormental injury), for death, or for damage to property other than engines of SettlementClass Vehicles, as part of the Settlement, because claims of this type are not affectedor released in any way by the Settlement.

You will be advised of the decision on your claim within sixty (60) days. However,payments may be delayed if the Court's decision approving the Settlement is appealedand may not be made if the Settlement is not approved. Up to date information as tothe status of the Settlement can be obtained at www.vwoilsludgesettlement.com orby calling 1-877-522-0447 toll free.

Enhanced Oil Sludge Warranty Extension (current owners or lessees onlyiVWGoA is instituting an Enhanced Oil Sludge Warranty Extension applicable to2001-2004 Volkswagen Passat vehicles with 1.8 liter turbo engines, for 10 years or120,000 miles, whichever comes first, after the date the Settlement Class Vehicleenters service in the hands of the first retail purchaser or lessee or as a companycar. To maintain the enhanced Oil Sludge Warranty Extension, you must perform allscheduled oil maintenance from this point forward at currently specified intervalsusing only VW specification 502 00 oil or a synthetic oil certified as complyingwith VW specification 502 00. Accordingly, to qualify for engine repair or enginereplacement at any authorized Volkswagen dealer under the Enhanced Oil SludgeWarranty Extension, you will be required to provide proof that you have used only VWspecification 502 00 oil or a synthetic oil certified ascomplying with VW specification502 00 for all oil changes required 30 days after the date this Notice is mailed.

100% Reimbursement: If an oil sludge related engine repair or replacement becomesnecessary before the first two specified oil change intervals 30 days after the date thisNotice is mailed, you will qualify for 100% coverage, parts and labor, provided thatyou can document the last two required oil changes before the repair or replacement,using the engine oil required- by the owner's manual originally supplied for yourvehicle at the time of its first entering into service.

SO% Reimbursement: If you cannot provide such documentation, you will qualify for50% parts and labor coverage for oil sludge related engine repairs or replacements.

VWN4 - 6 -

100% Reimbursement: For oil sludge related engine repair or repiacernentbecomes necessary after the first two specified Oil change intervals 30 days after thedate this Notice is mailed, engine repairs or replacements due to oil vudge will becovered 100%, but only if you can document that all oil and filter changes required 30days after the date this Notice is mailed have been performed at the required intervalusing VW specification 502 00 oil or a synthetic oil certified as complying with vWspecification 502 00,

Full details of this warranty extension are set forth below

With respect to Sludge Related Engine Repairs or Sludge Related Engine Replacementsrequired after the date of Class Notice, eligibility for coverage under the Enhanced OttVtidge Warranty Extension will be as follows.

(1) Payment of Repair Costs After Class Notice (Two or More Required CtilChanges Using VW 502 00): The Settlement Class Member shall be providedwith Engine Repair and/or Engine Replacement at 100% parts and iabor if, atthe time of such Engine Repair or Engine Replacement two or more oil andfilter changes have been required by the maintenance schedule applicableto the Settlement Class Vehicle since 30 days after the date that Class Noticeis mailed and the Settlement Class Member submits Proof of ill, such oilchanges after receipt of Class Notice using VW specification 502 00 oil or asynthetic oil certified as complying with VW specification 502 00.

(2) Payment of Repair Costs After Class Nohce (One Required Oil Change UsingVW 502 00): (a) The Settlement Class Member shall be provided with EngineRepair and/or Engine Replacement at 100% parts and labor if, at the time ofsuch Engine Repair/Engine Replacement, only one oil and filter change hasbeen required by the maintenance schedule applicable to the SettlementClass Vehicle since 30 days after the date that Class Notice is mailed and theSettlement Class Member submits (I) Proof of one oil and fitter change afterreceipt of Class Notice using VW specification 502 00 oil or a synthetic oilcertified as complying with VW specification 502 00 and (ii) Proof of the lastoil and filter change required by the maintenance schedule applicable to theSettlement Class Vehicle prior to the date of the Class Notice with oil qualityas originally specified in the owner's manual applicable to the SettlementClass Vehicle.

(a) I f Proof that one oil and filter change using VW specification SO2 00 oilor a synthetic oil certified as complying with VW specification 502 00is submitted, but Proof of the last oil and filter change required by themaintenance schedule applicable to the Settlement Class Vehicle priorto 30 days after the date that Class Notice is mailed with oil quakyasoriginally specified in the owner's manual applicable to the SettlementClass Vehicle is not submitted, then the Settlement Oass Member shatibe compensated fifty percent (50%) for the Engine Repair and/or EngineReplacement

Payment of Repair Costs After Goss Notice Mg Rewired 04 °wove UsingVW 502 OOP (a) The Settlement Class Member shall be ;sided with ENO*Repair and/or Engine Replacement at 100% pans and tabor it at Ow timeof such Engine Repair/Engine Replacement no oil and filter ciumge has

(3)

VWN4

1 8 1 1 8 I t 1 8 I I •

Ilitloonalzawbalticami

lessees'Defendants have prepared and are disseminating with this Notice to current ownersand lessees of Settlement Class Vehicles the following education/information materialcontaining relevant information concerning sludge and customer measures, includingthe use of VW specification 502 00 oil or a synthetic oil certified as complying withVW specification 502 00, as well as appropriate user behavior which may help tocontrol and/or ameliorate sludge formation.

(a) A customer letter;(b) Owner's Manual Supplement, including a list of oils which are certified as

complying with VW specification 502 00;(d) An engine compartment sticker, with instructions for application; and(e) Information as to the available engine oils which are certified as complying

with VW specification 502 00 will be maintained and updated from time totime on the Settlement website, www,vwolisludResettlement•c9m.

1E What does the Settlement provide to the Entire Class?Pursuant to the Settlement terms, all current and former owners and lessees ofmodel year 1998 2004 Volkswagen Passat vehicles equipped with the 1,8 liter turboengine imported or distributed for sale or lease in the United States by Volkswagenof America, Inc. will be given the opportunity to request reimbursement of unpaidclaims for oil sludge related engine repairs or replacements and reasonable associatedexpenses as described in Section 7 above. A l l Settlement Class Members whocurrently own or lease Settlement Class Vehicles will receive revised oil maintenancerecommendations.Current owners and lessees of 2001-2004 model year Settlement Class Vehicleswill also be eligible for the Enhanced Oil Sludge Warranty Extension described insection 7 above. A more detailed statement of the relief available to each sub-classof Settlement Class Vehicles can be accessed at www.moilsludgesettlementicomor by contacting the Oil Sludge Settlement Administrator: Oil Sludge SettlementAdministrator, PO Box 2410, Faribault, MN 55021-9110, or 1-877-522-0447, toll free.

.̒$•9. VIM w i l l 'sou release?In connection with the Settlement, unless you exclude yourself from the Class, youwill release (i.e., give up) all claims that were made or that you could have made inthese lawsuits. This Settlement does not affect or release claims for personal injury(including physical, psychological, or mental injury), death, or damage to propertyother than engines of Settlement Class Vehicles.The entities released are the Defendants Volkswagen Group of America, Inc ,Volkswagen AG, Audi AG, and their present or former officers, directors, employees,agents, heirs, executors, administrators, successors, reorganized successors., aSsignS,subsidiaries, affiliates, parents, divisions, predecessors, and authorized dealers.

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You and the other Settlement Class Members are represented by The McNulty lawFirm, Irwin & Boesen, RC., and Berger & Montague, P.0 They believe the Settlementto be fair, reasonable and adequate and recommend the Settlement as in the bestVWN4 - 9 -

interests of the Class. These lawyers are called Class Counsel. You will not be chargedfor the services of these lawyers. These lawyers will be paid by VWGoA in an amountto be approved by the Court, without deducting or reducing any benefits availableto the Class. I f you want to be represented by your own lawyer, you may hire one atyour own expense.

1. flow will the lawyers be paid?- - -

Class Counsel will ask the Court for up to $37.5 Million for attorneys' fees and up toapproximately $1.75 Million for reimbursement of costs and expenses incurred in theprosecution and settlement of these actions. The Defendants do not dispute ClassCounsel's entitlement to an appropriate fee and reimbursement of cost and expenses,but may oppose the amounts requested by Class Counsel. The Defendants will paywhatever attorneys' fees and costs and expenses that the Court awards withoutreducing or limiting any of the benefits available to Settlement Class Members.Any contested proceedings as to fees, costs, expenses and reimbursement to theRepresentative Plaintiffs will proceed separately from any proceedings seekingapproval of the Settlement terms. In this manner, if the Court approves the Settlementterms other than fees, costs and compensation to the Representative Plaintiffs,\TWGoA will be obligated to provide all of the relief agreed to for Settlement ClassMembers, regardless of the progress or outcome of any such dispute.

YOUR OPTIONS

N o w • • • • • • • 1 1 1 6 1 L,• • • • • • • • O f t i e t a W

You may either become a member of the Settlement Class or you may "Opt-Out"and exclude yourself from the Settlement, as explained in Section 12 below. You donot need to do anything to become # member of the Settlement Class.

you exclude ent? •You have the right to "opt out" and exclude yourself from the proposed SettlementAny Class Member who intends to request exclusion from the Settlement Class mustmail a request for exclusion to Oil Sludge Settlement Administrator, P.O. Box 2410,Faribault, MN 55021-9110. This request must be postmarked no later than February3, 2011. Persons requesting exclusion must set forth their full name and currentaddress and list the make, model year, and, if available, the vehicle identificationnumber of their Settlement Class Vehicle(s). I f you do not exclude yourself from thisSettlement, you will be bound by the Settlement and any judgments or orders thatare entered in these lawsuits, and all claims that were or could have been assertedon your behalf, based upon the facts alleged in the complaints in these cases, willbe dismissed and released. By excluding yourself from the proposed Settlement,you will also give up your right to object to the Settlement and ask the Court not toapprove the Settlement.

If you do not agree with the Settlement or some part of it, you have the right to objectThis includes Class Counsel's request for payment of attorneys' fees and costs. If youexclude yourself from the Settlement Class, you give up your right to object to theSettlement, the application for attorneys' fees and costs and expenses, and incentiveawards to the Representative Plaintiffs.VWN4 -10-

14. What does it me;mc to object?Objecting is advising the Court that you disagree with the proposed Settlement and/or the application for attorneys' fees and costs and expenses. The fact that you objectwill not affect your rights under the Settlement or your status as a member of theSettlement Class.

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15. How do you Mean objection to the Settlement?•To object, you (or your attorney) must file your Objection with the Court on or beforeFebruary 3, 2011. Objectors must state in writing their full name, address, make, modelyear and vehicle identification number of their Settlement Class Vehicle, all objectionsand the reasons therefore, and include any and all supporting papers, including proofof membership in the Class and, if applicable, the objector's statement of intent toappear at the Fairness Hearing. If you do not timely file a written Objection and noticeof your intent to appear at the Fairness Hearing, you will not be permitted to objectat the Fairness Hearing to the Settlement or to any matters related to the Settlementor to the provisions of the Settlement Agreement, and you will be foreclosed fromseeking review by appeal or otherwise. T o object, you must file your Objectionwith Hon. Joseph L. Tauro, United States District Court, John Joseph Moakley UnitedStates Courthouse, 1 Courthouse Way, Boston, Massachusetts 02210, with courtesycopies to the additional addresses below, postmarked no later than February 3,2011. You must mail your Objection by this date. If you fail to do so, the Court willnot consider your Objection.CLASS COUNSEL

Peter J. McNultyMcNulty Law Firm827 Moraga Dr.Los Angeles, CA 90049

DEFENSE COUNSEL

Kirk D. TresemerIrwin & Boesen, P.C.4100 E. Mississippi Ave.,Ste. 1900Denver, CO 80246Oil SLUDGE SETTLEMENT ADMINISTRATOROil Sludge Settlement AdministratorPO Box 2410Faribault, MN 55021-9110

Russell D. HenkinBerger & Montague, P.C.1622 Locust St.Philadelphia, PA 19103

Herzfeld & Rubin, P.C.125 Broad StreetNew York, NY 10004ALL PAPERS SUBMITTED MUST INCLUDE THE CASE NUMBER: 1:07-MD-01790

_.6nTiA-111;.; a n d w he r e w il l the Court deci tte whether to approve the Settlement?

The Court will hold a Fairness Hearing on March 11, 2011, at 10:30 a.m., at the UnitedStates District Court for the District of Massachusetts, John Joseph Moakley UnitedStates Courthouse, 1 Courthouse Way, Boston, Massachusetts 02210 in Courtroom22. At this hearing, the Court will consider whether the Settlement is fair, reasonable,and adequate, including the relief to the Settlement Class, Class Counsel's applicationfor attorney's fees and reimbursement of costs and expenses and reimbursement tothe Representative Plaintiffs for their time, effort and services to the Class. I f thereare Objections, the Court will consider them. The Court will also decide what amountof Class Counsel's fees and expenses will be paid.

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No i f you send an Objection, you do not have to go to the Court to discuss it. Aslong as your Objection is postmarked by February 3, 2011, the Court will considerit. I f you do not object to the Settlement, you do not need to appear at the FairnessHearing You do have the right to attend. You also may have your own lawyer attendat your expense.

M r—* O a k at the hearing?,

You may ask the Court for permission to speak at the Fairness Hearing T o do so,you (or your attorney) must send a letter saying that it is your "Notice of Intentionto Appear." Be sure to include your name, address and telephone number, and yoursignature. Your Notice of Intention to Appear must be postmarked no later thanFebruary 3, 2011, and sent to the Clerk of the Court, with courtesy copies to ClassCounsel, Defendants' Counsel and the Oil Sludge Settlement Administrator at Omaddresses indicated in Item 15,

clETTINQ M OE INIQRMATION

Are there more details about the Settlement'?

This Notice summarizes the proposed Settlement More details are in the Notices tothe other subclasses. You can get a copy of the other Notices and/or the SettlementAgreement by accessing the Settlement website at www.molisludgesetttementicom,or by request to the Oil Sludge Settlement Administrator. Remember, please do notcontact the Court. Personnel there cannot give you additional information.

DATE: December 20, 2010

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