Stipulation in Support of Expedited Sentencing Pursuant to L.R. 32-1(b)

On March 14, 2006, the United States filed a two-count Information charging Solvay S.A. ("Solvay") with one count of participating in a conspiracy in the United States and elsewhere to suppress and eliminate competition by fixing the price of hydrogen peroxide(Count One) beginning on or about July 1, 1998 and continuing until on or about December 1, 2001, in violation of the Sherman Antitrust Act, 15 U.S.C. § 1, and also charging Solvay with one count of participating in a conspiracy to suppress and eliminate competition by fixing the price of sodium perborates sold to Procter & Gamble (Count Two) beginning on or about June 1, 2000 and continuing until on or about December 1, 2001, in violation of the Sherman Antitrust Act, 15 U.S.C. § 1. Solvay is scheduled for a change of plea and possible sentencing before this Court on April 19, 2006. Solvay will waive Indictment and plead guilty under Fed. R. Crim. P. 11(c)(1)(C). The United States and Solvay have filed a Joint Sentencing Memorandum describing the material terms of the plea agreement and the agreed upon sentencing recommendation.

IT IS HEREBY STIPULATED AND AGREED as follows:

Solvay waives its right to a presentence report. The United States and Solvay request that the Court sentence Solvay on an expedited basis pursuant to Crim. L.R. 32-1(b), on April 19, 2006. The United States and Solvay respectfully submit that the Joint Sentencing Memorandum and the Plea Agreement provide sufficient information for the Court to impose a sentence on April 19, 2006, the same date as the change of plea hearing, without a presentence report.