U.S. Steel Clairton Coke Works Plant Explosion: Potential Compensation for Affected Residents

I, , ("Client"), hereby retain Milberg Coleman Bryson Phillips Grossman, LLC ("Law Firm") to be Client's attorneys in connection with Client's claims for injuries and/or losses arising from the U.S. Steel Clairton Coke Works Explosion and related evacuation (the "Litigation").

Scope of Representation.

Client engages and retains the Law Firm to represent Client in connection with Client's claims for economic and non-economic damages, losses, attorneys' fees, interest, and all other remedies with respect to the Litigation. The Law Firm agrees to represent Client and, if it is determined after sufficient inquiry and investigation that a reasonable basis exists on which to file a lawsuit or other legal proceedings, to file a lawsuit or other legal proceedings on behalf of Client.

Power of Attorney.

Client grants Law Firm power of attorney to perform all actions that Law Firm, in the exercise of its professional judgment, deem necessary for the Litigation, including, but not limited to, communicating and negotiating with insurance carriers and other responsible parties, entering an appearance on Client's behalf, filing a lawsuit, advancing expenses, engaging experts, negotiating a settlement of Client's claims, and otherwise procesuting Client's claims to final conclusion.

Attorneys' Fees.

Attorneys' fees will be calculated by multiplying the contingent fee percentage by any Recovery obtained on Client's behalf. "Recovery" means any judgments, settlement payments, insurance payouts, appraisal awards, amounts applied toward Client's debts or liens, attorneys' fee awards, common benefit payments, insurance liens, interest payments, exemplary or special damages, court costs, and any non-monetary consideration that Client obtains.

The contingent fee percentage that Client assigns Law Firm is 33.33% of any Recovery.

Additional Counsel.

Law Firm may wish to affiliate additional counsel for this case. Should this occur, the fees paid to such other counsel, if any, shall come out of the fees stated in Paragraph 3 above, and will not increase the contingency fee.

Contingent Fee Agreement.

If there is no recovery, client owes no attorneys' fees for this engagement. Law Firm will collect their attorneys' fees directly from the Recovery, if any.

Advanced Expenses.

Law Firm, in its sole discretion, may advance costs necessary to prosecute Client's claims. Such expenses include, but are not limited to, investigation expenses, filing fees, court costs, delivery costs, expert and consulting fees, court reporter costs, mailing costs, travel expenses, online legal research costs, estimator fees and expenses, and trial expenses. Such expenses will be deducted off the top of Client's recovery; however, if there is no recovery, Law Firm wll pay all advanced expenses and Client will not be obligated to reimburse Law Firm.

Disbursement of Recovery.

Any recovery shall be deposited into Law Firm's trust account. Law Firm shall provide Client with a detailed closing statement of Law Firm's receipt of any recovery.

Class Action.

Law Firm, in its discretion, may bring Client's case as a class action, meaning that the lawsuit would be filed on behalf of Client and all other people who are similarly situated. Client agrees that the Law Firm has sole discretion whether to identify Client as a proposed class representative. As a class action lawsuit, the Law Firm shall seek to obtain certification of a "class" of persons or entities to which Client belongs and for which Client will act as a "class representative" if Law Firm so recommends. The Law Firm shall seek appointment by the court as class counsel and agree to undertake the representation on behalf of the class.

Once a suit is filed, the Law Firm shall take reasonable steps to keep Client informed of significant developments and to respond to any inquiries Client may have with respect to the progress of the litigation. Client agrees to fulfill the duties of a class representative, if proposed as such, which are explained further below. If the action is certified as a class action and Client is certified as the named class representative, Client will retain the right, as a member of the class and as class representative, under the class action rules, to approve, oppose, or comment upon any proposed settlement of all or part of the class action.

Client further understands that either the Law Firm or the Court may determine that this lawsuit is best handled with a group of other cases aggregated for settlement and/or trial preparation. Client authorizes the Law Firm to enter into aggregate settlement negotiations and to disclose the amount of the proposed settlement values to other Clients whose cases are included in the aggregate of cases. For any matters relating to settlement, Client will be guided by the views and advice of the Law Firm.

If the lawsuit is certified as a class action, and if a monetary recovery is obtained for the class, either by settlement or judgment, the Law Firm will apply to the Court for reimbursement of their costs and payment of their fees by defendant(s) out of, or in addition to such recovery. The Law Firm's application for fees must be approved by the Court. Client will be provided with notice of the Law Firm's fee request. In the event that no recovery is obtained, then no fees, expenses of litigation, or costs shall be owed by the Client to the Law Firm. Client has read the following summary of "Duties of a Class Representative," and understands that any questions about these duties should be discussed with the Law Firm:

A class representative represents the interests of all members of a class in litigation to obtain appropriate relief and/or recover money damages for the class. As a potential class representative, you understand that you must adequately and fairly represent the class. This means that as a potential class representative, you intend to always consider the interests of the class just as you would consider your own interests.

A class representative is not required to be particularly sophisticated or knowledgeable with respect to the subject of the lawsuit. However, he/she should remain interested in the progress of the lawsuit and must make every effort to provide his/her lawyer and the court with all relevant facts of which he/she is aware.

A class representative participates actively in the lawsuit, such as by reading the complaint and understanding it to the best of his/her ability, cooperating fully in any discovery that is permitted of the class representative, such as by testifying at deposition and trial, answering written interrogatories, producing documents and by keeping generally aware of the status and progress of the lawsuit. The Law Firm will keep the class representative informed of major events during the litigation in order to ensure that all class representatives are well informed. The class representative should confer with his/her lawyer any time he/she feels it is appropriate to do so.

The class representative is required to vigorously prosecute the litigation. This means that the class representative must authorize his/her lawyer to do what is necessary to successfully prosecute the case on behalf of the class and to consult with counsel concerning the prosecution of the litigation.

The class representative may be responsible, through the Law Firm, to provide appropriate notice to the class, depending on whether the legal rules or the judge requires such notice. The Law Firm will undertake this task on the class representative's behalf and be responsible for all costs, the reimbursement of which will be contingent on the outcome of the litigation. Notice is usually accomplished by mailing a copy of the notification to identifiable class members and/or publishing a copy of the notification in magazines or electronic media.

A class representative recognizes and accepts that any resolution of the lawsuit, such as by settlement or dismissal, is subject to court approval, and must be designed in the best interests of the class as a whole. The Law Firm will consult with the class representative before recommending a settlement. The class representative will not participate in any settlement negotiations without his/her lawyer's consent.

As a potential class representative, you are volunteering to represent many other people with similar claims and damages, because you believe that it is important that all benefit from the lawsuit equally, because you believe that a class lawsuit will save time, money and effort, and thus will benefit all parties and the court system. You also understand and believe that the class action is an important tool to assure protection of people or businesses injured in a similar way as you if you become a class representative.

Right to Withdraw.

Client may discharge the Law Firm at any time. Likewise, the Law Firm may withdraw at any time if Client breaches this contract, Client refuses to cooperate with the Law Firm or to follow its advice on a material matter, or any fact or circumstance exists that would render the Law Firm's continuing representation of Client unlawful, unethical, or ineffective. If possible, the Law Firm will give Client reasonable notice of the Law Firm's intent to withdraw so that Client has time to arrange alternative representation. If necessary, the Law Firm will obtain Court approval before withdrawing from the case.

If the Law Firm elects to withdraw, Client will take all steps necessary to free the Law Firm of any obligation to perform further. The Law Firm and Client each agree to sign any documents reasonably necessary to effect or complete the Law Firm's discharge or withdrawal and the Law Firm agrees to deliver any necessary papers to Client upon withdrawal.

Should Client discharge the Law Firm or should the Law Firm withdraw its representation, Client hereby grants the Law Firm, as well as associate counsel, if applicable, a lien on any and all causes of action or claims Client may assert with respect to the injuries and/or damages which are the subject of this contract. The lien will attach to any recovery Client may obtain (whether by judgment, settlement or otherwise) or any other similar proceeding. The Law Firm's (and associate counsel's) lien will be for all time incurred and any sums due and owing by Client to the Law Firm (and associate counsel) at the conclusion or termination of the Law Firm's services, including both expenses and attorneys' fees. The amount due and owing for the Law Firm's services under this agreement shall be determined according to the Law Firm's hourly rates prevailing at the time of the Law Firm's discharge or withdrawal.

Client agrees that the files and documents compiled in connection with the Law Firm's investigation and prosecution of this matter constitute the work product and property of the Law Firm over which the Law Firm has complete control with respect to its use and/or disclosure.

Other Acknowledgments.

By your signature below you acknowledge your understanding and agreement with the following:

The Law Firm cannot and will not provide financial assistance to Client in connection with the pending or contemplated litigation.

Client has not been promised any specific result or special treatment different from the treatment that may be accorded to other class members. If successful, the Law Firm may ask the judge to award Client additional compensation for the extra time and effort expended as a class representative and for having the courage to challenge the conduct of the defendant(s). The Law Firm cannot guarantee the judge will grant such a request.

Law Firm may undertake efforts to obtain financing from third-parties for its regular operations or for case specific expenses for Client's matter. Client provides informed consent that Law Firm may provide these third-parties with confidential information concerning claims covered by this Agreement, provided that Law Firm takes appropriate and reasonable steps to preserve the confidentiality of such information, including by the use of appropriate nondisclosure agreements and other reasonable steps to avoid the waiver of attorney-client privilege and other confidentiality protections.

Client understands and agrees that it is mandatory to retain all relevant evidence related to the Litigation. Client agrees to maintain and provide such evidence to the Law Firm.

The Law Firm may use cloud computing services with servers located in a facility other than Law Firm's offices. Law Firm's electronic data, including emails and documents, may be stored in this manner. By entering into this Agreement, Client understands and consents to having communications, documents, and information pertinent to Client's matter stored through such a cloud-based service.

This agreement is to be interpreted under the laws of Maryland, including, but not limited to, the Maryland Rules of Professional Conduct, and any claim or lawsuit related to this Agreement or the legal services provided hereunder shall be brought within one year of the date that the problem or issue arose, and Baltimore, Maryland shall be the exclusive venue for any such dispute.

Scope of Agreement.

This document constitutes the written retainer and fee agreement between the Law Firm and Client and supersedes all other oral or written provisions except for any addendums to this that may be executed by the Parties. Client has read and understands this retainer and fee agreement and has had the opportunity to seek the advice of independent counsel before signing it. Client shall be presumed to have agreed to all of the provisions set forth in this contract unless Client notifies the Law Firm in writing of Client's objections within 15 days following the date of this Agreement.

I affirm and acknowledge that the Law Firm has not represented me in connection with my decision to enter into this Representation Agreement, and that I have the right and am encouraged to retain separate, independent counsel for consultation in connection with this Representation Agreement, including a review of this Representation Agreement. By signing below, I acknowledge that this agreement has been carefully read and reviewed and its contents understood, and that I agree to be bound by all its terms. The Law Firm will retain a signed copy of this engagement letter for our files.

With my signature below, I affirm that I have read and agree to the above Representation Agreement, the Class Representative Duties, and I acknowledge that the Law Firm has made no promises or guarantees to me about the outcome of my matter, and nothing in this Agreement shall be construed as such a promise or guarantee.

AGREED TO:

Date:
By:

MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN LLC:

Date:
By: