A Court has preliminarily approved a Proposed Settlement of several related class action lawsuits that may affect your rights. The lead case is entitled Susan Chamberlan et al. v. Ford Motor Company, Case No. C 03-2628 CW, pending in the United States District Court for the Northern District of California. The related class actions that are also a part of this Proposed Settlement include McGettigan v. Ford Motor Co., Case No. CV-2002-3400-JRL in the Circuit Court of Mobile County, Alabama and Rhea v. Ford Motor Co., CJ-05-55, in the District Court for Adair County, State of Oklahoma. The Court has scheduled a Fairness Hearing for final approval of the Proposed Settlement. Benefits for Class Members will only be made if the Court grants final approval.

This Proposed Class Action Settlement involves certain Ford motor vehicles, specifically those that were originally equipped with an all nylon-composite air intake manifold.

The vehicles ("Class Vehicles") involved in this Class Action are:

Under the Proposed Settlement, Ford is granting retroactive seven-year extended warranty coverage for fatigue cracking of the coolant crossover passage of the all nylon-composite intake manifold in the Class Vehicles, as explained below.

What is This Class Action About?

The Class Vehicles were equipped with an engine that contained an air intake manifold made entirely from a nylon-composite material. The plaintiffs in these class action lawsuits allege that the coolant crossover passage of these intake manifolds may crack, resulting in coolant leakage, and that Ford violated state law because it failed to disclose this fact to consumers who bought Class Vehicles.

Ford denies these allegations and any wrongdoing.

Why is there a Proposed Settlement?

The Parties litigated these class actions vigorously, primarily through the Chamberlan action, for over two years. After extended negotiations under the supervision of a Court-approved mediator, the Parties entered into a Proposed Settlement Agreement dated June 16, 2005. The terms of the Proposed Settlement are briefly summarized below. The following description does not supersede the terms of the Proposed Settlement Agreement and related documents and exhibits, which are available for public inspection in the office of the Clerk of the Court. The Clerk's Office is located at 1301 Clay Street, Oakland, CA 94612.

Counsel for the Plaintiffs believe that the Proposed Settlement is a fair and reasonable resolution of these class actions. In deciding this, they considered the substantial benefits from the Proposed Settlement for the Class Members. These benefits were balanced against the risk that (1) Plaintiffs and the Class may not win at trial, or (2) any favorable judgment could have been reversed on appeal, or at least delayed during an appeals period expected to last several years.

Who are Class Members?

All persons residing in the United States who currently own or lease, or previously owned or leased a 1996 through 2002 model-year Ford, Lincoln, or Mercury vehicle equipped with a 4.6-liter, 2-valve V-8 engine having an all nylon-composite air intake manifold as original equipment. Vehicles which have already received an extended warranty pursuant to a Ford Owner Notification Program action are not included. Specifically, Class Vehicles include those 1996-2001 Mercury Grand Marquis, 1996-2001 Ford Crown Victorias, 1996-2001 Lincoln Town Cars, 1997 Mercury Cougars and Ford Thunderbirds and Mustangs manufactured after June 24, 1997, certain 1998-2001 Ford Mustangs, and certain 2002 Ford Explorers that were equipped with the 4.6-liter, 2-valve V-8 engine.

The Class does not include: (1) Ford, its subsidiaries and affiliates, officers, and directors; (2) the Judge to whom this case is assigned and any member of the judge's immediate family; (3) persons, if any, who have suffered personal injury as a result of the failure of an air intake manifold in a Class Vehicle; and (4) persons who have settled with and released Ford from individual claims substantially similar to those alleged in the related class actions.

What Does the Proposed Settlement Provide?

If the Proposed Settlement is approved, Class Members who currently own a Class Vehicle will receive a retroactive extension of the new vehicle warranty coverage on the air intake manifolds. The extended warranty will cover:

fatigue cracks in the all-composite air intake manifold resulting in coolant leaks at the crossover coolant passage that occur within the first seven years after the vehicle's warranty start date, regardless of mileage. The warranty extension will allow vehicle owners to obtain a cost-free replacement for any intake manifold that has fatigue cracks and leaking coolant (as described above). Replacement must be done by a Ford dealer.

As part of the extended warranty, Ford will reimburse Class Members who have previously paid to replace a composite intake manifold on a Class Vehicle. The replacement must have occurred within the first seven years of vehicle operation. You will not be able to seek reimbursement for the cost of replacing the intake manifold unless the Court gives final approval to the Proposed Settlement.

If the Proposed Settlement is approved, Class Members will release all claims against Ford Motor Company that were made or could have been made in the Class Actions related to the intake manifold. The extended warranty will not be provided to Class Members unless and until the Court gives final approval to the Proposed Settlement during or after the Fairness Hearing presently scheduled for September 30. 2005.

Who Represents the Class?

The Court has appointed Plaintiffs Susan Chamberlan and Henry Fok (of California); Thomas McGettigan, Cathy McGettigan, and Pauline Langham (of Alabama); Andy Rhea (of Oklahoma); and James McDonald (of Michigan) to serve as Class Representatives. The Court appointed the law firms of Levy, Ram & Olson LLP and Cunningham, Bounds, Yance, Crowder & Brown LLC to act as the attorneys for all Class Members. You do not have to pay for Class Counsel's services. Instead, Class Counsel may apply to the Court for reasonable attorneys' fees. Under the Proposed Settlement, they may seek fees up to $4,500,000, as well as actual, reasonable costs incurred in the litigation. You have the right to appear in the action using your own attorney at your expense.

How Do I Participate in the Proposed Settlement?

If you wish to participate in the Proposed Settlement and remain a member of the Class, you need not do anything at this time. As a Class Member, you will be bound by all orders and judgments of the Court. Any claims you may have against Ford relating to the intake manifold of your vehicle will be terminated by the judgment entered in this case, even if your manifold fails in the future. This includes claims you may have for breach of warranty or negligence. This Proposed Settlement does not affect any claims for personal injury arising from any problem with the intake manifold on the vehicles described above.

When and Where Will the Court Decide Whether to Approve the Proposed Settlement?

On September 30, 2005, at 10:00 a.m., the Honorable Claudia Wilken will hold a Fairness Hearing to determine whether the Proposed Settlement is fair, adequate, and reasonable and should be finally approved.

How Do I Get More Information about the Proposed Settlement?

To contact Class Counsel, write to them at Levy, Ram & Olson LLP, 639 Front Street, Fourth Floor, San Francisco, California 94111, or at Cunningham, Bounds, Yance, Crowder & Brown LLC, P.O. Box 66707, Mobile, Alabama 36660. Do not contact Ford Motor Company or its Counsel regarding this Proposed Settlement. The Court cannot answer questions about the Proposed Settlement. Do not call or write the Court for information about the terms of the Proposed Settlement.