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Precision Shareholder Litigation

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WELCOME TO THE PRECISION SHAREHOLDER LITIGATION WEBSITE

This website has been established to provide general information related to the
proposed settlement of the case known as NECA-IBEW Pension Trust Fund (The
Decatur Plan), et al. v. Precision Castparts Corp., et al., Case No.
3:16-cv-01756-YY (the "Litigation"), pending before the United States District
Court for the District of Oregon, Portland Division (the "Court"). The
capitalized terms used on this website, and not otherwise defined, shall have
the same meanings ascribed to them in the Stipulation of Settlement (the
"Stipulation") dated January 8, 2021, which can be found and downloaded by
clicking on the Case Documents tab above. Your rights may be affected by the
Settlement if you purchased, sold, or held Precision Castparts Corp.
("Precision") common stock during the period from and including October 9, 2015,
the record date for Precision’s special meeting regarding the sale of Precision
to Berkshire Hathaway Inc. (the "Merger"), through and including the
consummation of the Merger on January 29, 2016 (the "Class").

The law firms of Robbins Geller Rudman & Dowd LLP and Berger Montague PC
represent the Class, including you. These lawyers are called Lead Counsel. You
will not be charged for these lawyers. They will be paid from the Settlement
Fund to the extent the Court approves their application for fees and expenses.
If you want to be represented by your own lawyer, you may hire one at your own
expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Pendency and Proposed Settlement of
Class Action (the "Notice"), on September 2, 2016, plaintiffs NECA-IBEW Pension
Trust Fund (The Decatur Plan) and Angela Lohmann, the former trustee for the
Angela Lohmann Revocable Trust (together, the “Original Plaintiffs”), filed the
initial Class Action Allegation Complaint (the “Initial Complaint”).

On November 1, 2016, the Original Plaintiffs filed a motion seeking their
appointment as lead plaintiffs and the appointment of Lead Counsel. On November
21, 2016, the Court granted the Motion to Appoint Lead Plaintiffs and appointed
the Original Plaintiffs as Lead Plaintiffs and Lead Counsel as Lead Counsel.

Throughout proceedings the parties also participated in mediation efforts with a
highly experienced mediator, Robert A. Meyer, Esq., of JAMS. On or around March
5, 2019, the parties submitted their respective mediation materials to Mr.
Meyer. On March 13, 2019, the parties attended a mediation session in Los
Angeles, California. While those initial mediation efforts were unsuccessful,
the parties remained in regular contact with Mr. Meyer, keeping him updated
about developments throughout the course of the Litigation. During this time,
the parties’ counsel continued to discuss the potential for resolution of this
matter with Mr. Meyer, as they had done periodically throughout this Litigation.
After a series of discussions, Mr. Meyer informed the parties on October 14,
2020, of a mutual agreement in principle on the essential economic elements of a
settlement of the Litigation. On October 14, 2020, the parties informed the
Court of this agreement in principle to settle the Litigation. 

WHAT DOES THE SETTLEMENT PROVIDE?

The Settlement, if approved, will result in the creation of a cash settlement
fund of $21,000,000.00 (the “Settlement Fund”). The Settlement Fund less taxes,
tax expenses, notice and administrative costs, any award of attorneys’ fees and
Lead Plaintiffs’ expenses (“Net Settlement Fund”) will be distributed to Class
Members who submit valid, timely Proofs of Claim (“Claimants”) on a pro rata
basis pursuant to the Plan of Allocation that is described in the Notice.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not
replace the information contained in the Notice and Stipulation, both of which
can be found and downloaded by clicking on the Case Documents tab above. We
recommend that you read the Notice and other relevant case documents carefully.


YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM The only way to receive a payment. Proofs of Claim must
be postmarked or submitted online on or before May 6, 2021. EXCLUDE YOURSELF
Receive no payment. This is the only option that allows you to ever be part of
any other lawsuit against the Defendants or any other Released Persons
concerning the issues raised in this Litigation. Exclusion requests must be
postmarked no later than April 16, 2021. OBJECT Write to the Court about why you
oppose the Settlement, the Plan of Allocation, the request for attorneys’ fees,
and/or the expenses of Lead Plaintiffs. You will still be a Member of the Class.
Objections must be received by the Court and counsel on or before April 16,
2021. APPEAR AT A HEARING ON MAY 7, 2021 Ask to speak in Court about the
fairness of the Settlement. Requests to speak must be received by the Court and
counsel on or before April 16, 2021. DO NOTHING Receive no payment from the
Settlement. Members of the Class who do nothing remain bound by the terms of the
Settlement.





IMPORTANT DATES AND DEADLINES

Submit Proof of Claim: May 6, 2021 File Objection: April 16, 2021 Request
Exclusion: April 16, 2021 File Notice of Intention to Appear: April 16, 2021
Court Hearing on Fairness of Settlement: May 7, 2021, at 1:00 p.m.

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