1. A.         What are the allegations against the Defendants?

   The Actions allege that AXA, S.A. and certain current and former affiliates (collectively, the "AXA Defendants") wrongfully failed to pay benefits under life insurance policies issued between 1880 - 1930 in the Turkish Ottoman Empire on the lives of persons of Armenian descent.

   B.        What is the AXA Defendants' Response to Plaintiffs' Allegations?

    The AXA Defendants deny these allegations, believe them to be false and misleading, and have asserted numerous defenses to the Plaintiffs' allegations.

    II.      WHO IS IN THE CLASS?

   The Settlement Class is composed of all beneficiaries, heirs of beneficiaries, owners, heirs of owners, and all other persons having Claims. "Claims" means any and all claims or potential claims of any nature, however they may be expressed, know or unknown, direct or indirect, under, concerning, or in any way arising out of or relating to the Life Insurance Policies, which any of the Plaintiffs or any of the Settlement Class members may have had, may now have, or may in the future have against any of the Released AXA Parties or any combination of them, whether or not such claims are or were time-barred under applicable law (including, without limitation, any and all claims for payment of death benefits, surrender values, cash values, endowments, or any other form of payment under the Life Insurance Policies). A “Life Insurance Policy" means a life insurance policy (which may include savings components or annuities) that (i) insured a life of, or was purchased by, a person of Armenian descent or ancestry and (ii) was issued at any time in the Turkish Ottoman Empire through and until the later of (a) December 31, 1920 or (b) such time as the Turkish Ottoman Empire ceased to exist, by (1) The Equitable Life Assurance Society of the United States, (2) L'Union Compagnie D'Assurance Sur La Vie Humaine (whose successors include, without limitation, L'Union des Assurance de Paris-Vie, sued in the Actions as L'Union des Assurance de Paris), (3) Caisse Paternelle, also known as "la Caisse Paternelle cie anonyme d'assurance mutuelles generale sur la vie humaine, en mutualite a primes fixes et contre les accidents sur 1es chemins de fer"; (4) la Confiance, (5) The Mutual Life Insurance Company of New York, (6) Nordstern Lebenversicherungs AG, or (7) any of their respective predecessors, successors, or subsidiaries, provided that the successor or subsidiary relationship with any of the six companies named herein was in existence prior to 1923.  Excluded from the Settlement Class are all persons who, in accordance with the procedures, conditions and deadlines set forth in the Supplemental Class Notice, either executed a timely request for exclusion (Opt Out) from the Settlement Class or were  subject to a request for exclusion from the Settlement Class timely submitted by another claimant under the same Life Insurance Policy.

   The Settlement Web Site has a searchable database that is in accordance with French law and on which individuals may research a family name to determine if they are part of the Settlement Class.  AXA shall, in accordance with French law, provided relevant information for this searchable database and reasonable assistance to the Settlement Administrator in developing this database, including providing the information in an electronic form or format.  In accordance with French law, the database and the Settlement Web Site may not include a full list of individually named insureds.  

   III.     WHAT CLAIMS ARE BEING SETTLED?

   The Settlement will resolve and bar any further litigation of Claims (as defined above) by Settlement Class members who do not Opt Out of the Settlement. 

   IV.     IMPORTANT DEADLINES AND THINGS YOU MUST DO TO PARTICIPATE IN THE SETTLEMENT IF YOU ARE A SETTLEMENT CLASS MEMBER.

   General information regarding the status of the Settlement, and the methods of, and requirements for, participating in the Settlement  approved by the Court, are posted on this Settlement Web Site.  

   1.              Opt Out Deadline.  The deadline by which you could submit your Opt Out Request if you wished to be excluded from the Settlement Class was April 14, 2006.  This option is not available anymore.

   2.              The Final Fairness Hearing.  The Final Fairness Hearing took place at 10:00 AM on May 15, 2006, before United States Judge Christina A. Snyder in Courtroom 5 of the United States District Court, located at 312 N. Spring Street, Los Angeles, California 90012.  At the Final Fairness Hearing, the Court determined that the proposed Settlement was fair, adequate and reasonable.  

   3.              Final Order and Judgement.  The Final Order and Judgement dated May 16, 2006, signed by United States Judge Christina A. Snyder is posted on this Settlement Web Site and available for viewing, downloading and printing by clicking here.

   4.              Deadlines and Procedures for Making Claims.  Settlement Class members are required to submit Notices of Claim to the Settlement Fund Board in order to have their claims considered for payment.  Timely submission of a Notice of Claim to the Settlement Fund Board will be required to participate in the Settlement. Notices of Claim must be submitted to the Settlement Fund Board by first class mail addressed to:

                  Settlement Administrator                           

AXA Settlement Claim Fund

900 Wilshire Blvd., Suite 614

Los Angeles, CA 90017