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.” Id.16The district court proposed that “[a] limited portion of the fund might be earmarked for all class members filing claims who demonstrate both exposure to Agent Orange and the existence of adverse health effects. An additional lump sum amount might be targeted to those veterans suffering from total physical disability or death from a disease such as cancer.” Id. at 860.In Re HOLOCAUST VICTIM ASSETS LITIGATION (Swiss Banks)SPECIAL MASTER’S PROPOSAL, September 11, 2000 R&O-698027.1B - 5III.Distribution Plan ApprovalThe district court considered several distribution plans, including one proposed bythe Plaintiffs’ Management Committee (“PMC”) on behalf of various plaintiffs’ counsel, andanother submitted by Kenneth R. Feinberg, Esq., the court-appointed Special Master who hadassisted the parties in settlement negotiations. Ultimately, the district court adopted, in amodified form, Special Master Feinberg’s proposed distribution plan, which Judge Weinsteindescribed asan elegant solution . . . [combining] insurance-type compensation to give as much help as possible to individuals who, in general, are most in need of assistance, together with a foundation run by veterans with the flexibility and discretion to take care of individuals and groups most in need of help.
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