Free Declaration - District Court of Colorado - Colorado

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Exhibit C

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UNITED STATES DISTRICT COURT DISTRICT OF KANSAS In re SPRINT CORPORATION SECURITIES ) LITIGATION ) ) ) This Document Relates To: ) ) ALL ACTIONS. ) ) Master File No. 01-4080-CM CLASS ACTION REVISED ORDER AWARDING ATTORNEYS' FEES AND REIMBURSEMENT OF EXPENSES AND AMOUNTS FOR CERTAIN LEAD PLAINTIFFS

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This matter having come before the Court on December 16, 2003, on the application of Lead Plaintiffs' counsel for an award of attorneys' fees and reimbursement of expenses incurred in the Action and the reimbursement of time and expenses for certain Lead Plaintiffs, the Court, having considered all papers filed and proceedings conducted herein, having found the settlement of this litigation to be fair, reasonable and adequate and otherwise being fully informed in the premises and good cause appearing therefor: IT IS HEREBY ORDERED, ADJUDGED AND DECREED that: 1. All of the capitalized terms used herein shall have the same meanings as set forth in

the Stipulation and Agreement of Settlement dated as of April 7, 2003 (the "Stipulation"). 2. This Court has jurisdiction over the subject matter of this application and all matters

relating thereto, including all Members of the Class who have not timely and validly requested exclusion. 3. The Court awards plaintiffs' counsel attorneys' fees of seventeen and one-half

percent (17.5%) of the Settlement Fund and expenses in the aggregate amount of $375,000, together with the interest earned thereon for the same time period and at the same rate as that earned on the Settlement Fund until paid. Said fees and expenses shall be allocated among plaintiffs' counsel in a manner which, in Co-Lead Counsel's good-faith judgment, reflects each such counsel's contribution to the institution, prosecution and resolution of the Litigation. 4. In addition to the awards made in ¶3, Lead Plaintiffs Amalgamated Bank as Trustee

for the Longview Collective Investment Fund ($10,000), New England Health Care Employees Pension Fund ($4,500), Plumbers and Pipefitters National Pension Fund ($10,000), and PACE Industry Union-Management Pension Fund ($2,667) are awarded the amounts set forth by their names as reimbursement for their time and expenses incurred in representing the Class.

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5.

The Court finds that the amount of fees awarded is fair and reasonable under the

"percentage-of-recovery" method. 6. The awarded attorneys' fees and expenses and interest earned thereon, and the time

and expense reimbursement to the plaintiffs listed in ¶4 above, shall be transferred from the Settlement Fund immediately after the date this Order is executed subject to the terms, conditions and obligations of the Stipulation and in particular ¶19 thereof, which terms, conditions and obligations are incorporated herein. IT IS SO ORDERED. Dated this 16 day of December 2003, at Kansas City, Kansas. s/ Carlos Murguia CARLOS MURGUIA United States District Judge

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UNITED STATES DISTRICT COURT DISTRICT OF KANSAS
In re SPRINT CORPORATION SECURITIES LITIGATION ) ) ) )

Master File No. 01-4080-CM This Document Relates To All Actions

NOTICE OF PENDENCY AND SETTLEMENT OF CLASS ACTION TO: ALL PERSONS OR ENTITIES THAT PURCHASED SPRINT CORPORATION PUBLICLY TRADED FON OR PCS COMMON STOCK (THE "SUBJECT SECURITIES") FROM OCTOBER 4, 1999 THROUGH SEPTEMBER 19, 2000, INCLUSIVE

PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. YOUR RIGHTS MAY BE AFFECTED BY PROCEEDINGS IN THIS ACTION. PLEASE NOTE THAT IF YOU ARE A MEMBER OF THE CLASS YOU MAY BE ENTITLED TO SHARE IN THE PROCEEDS OF THE SETTLEMENT FUND DESCRIBED IN THIS NOTICE. TO CLAIM YOUR SHARE OF THIS FUND, YOU MUST SUBMIT A VALID PROOF OF CLAIM AND RELEASE POSTMARKED ON OR BEFORE FEBRUARY 2, 2004. This Notice has been sent to you pursuant to Rule 23 of the Federal Rules of Civil Procedure and Orders of the United States District Court for the District of Kansas (the "Court"). The purpose of this Notice is to inform you of the settlement of this class action (the "Action") and of the hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the settlement. This Notice describes the rights you may have in connection with the settlement and what steps you may take in relation to the settlement and the Action. The settlement creates a fund in the principal amount of $50,000,000.00 in cash (the "Settlement Fund") which is earning interest. Based on an estimate of the number of shares entitled to participate in the settlement and the anticipated number of claims to be submitted by Class Member(s), the average distribution from the Settlement Fund would be approximately $0.13 per share before deduction of Court-approved fees and expenses. However, your actual recovery from the Settlement Fund will depend on a number of variables, including the number of claimants, the number of shares you purchased, the expense of administering the claims process, and the timing of your purchases and sales of stock, if any. The parties to the Action do not agree on the average amount of damages per share that would have been recoverable if Plaintiffs were to have prevailed on the claims asserted in the Action, or even whether the Plaintiffs would have prevailed on any of those claims. The issues on which the parties disagree include: (1) the appropriate economic model for determining the amount by which the trading prices of the Subject Securities were allegedly artificially inflated (if at all) at any time during the class period; (2) the effect of various market forces influencing the trading prices of the Subject Securities at various times during the class period; (3) the extent to which external factors, such as general market conditions, influenced the trading price of the Subject Securities at various times during the class period; (4) the extent to which the various matters that Plaintiffs alleged were materially false or misleading influenced (if at all) the trading price of the Subject Securities at various times during the class period; (5) the extent to which the various allegedly adverse material facts that Plaintiffs alleged were omitted influenced (if at all) the trading price of the Subject Securities at various times during the class period; (6) the impact (if any) of the alleged omission of alleged material adverse facts on Sprint shareholders' vote to approve the merger with WorldCom, Inc. ("WorldCom"); and (7) whether any of the statements made or facts allegedly omitted were false, material or otherwise actionable under the federal securities laws. Counsel for the Plaintiffs believe that the settlement is a substantial recovery and is in the best interests of the Class. Because of the risks associated with continuing to litigate and proceeding to trial, there was a danger that the Plaintiffs would not have prevailed on any of their claims, in which case the Class would have received nothing. In addition, the amount of damages recoverable by the Class, if any, was and continues to be vigorously challenged by the Settling Defendants. If the Action were tried, recoverable damages, if any, would have been limited to losses caused by conduct actionable under the securities laws and, had the Action gone to trial, Settling Defendants intended to assert that all or most of the losses of the Members were caused by non-actionable market, industry or general economic factors. Settling Defendants also would have asserted that throughout the class period as well as in the proxy materials issued in connection with Sprint's proposed merger with WorldCom, the uncertainties and risks associated with Sprint's and WorldCom's business and financial condition as well as the proposed merger were fully and adequately disclosed. Plaintiffs' Co-Lead Counsel have not received any payment for their services in conducting the Action on behalf of the Members of the Class, nor have they been reimbursed for their out-of-pocket expenditures. If the settlement is approved by the Court, Plaintiffs' Co-Lead Counsel will apply to the Court (1) for attorneys' fees not to exceed 17.5% of the settlement

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proceeds, and reimbursement of expenses incurred not to exceed $375,000, and (2) compensation of up to $10,000 for each of the Lead Plaintiffs to reimburse them for their time and expenses incurred in prosecuting the Action, all to be paid from the Settlement Fund. If the amounts requested by Plaintiffs' Co-Lead Counsel are approved by the Court, the average cost would be approximately $0.02 per share. The average cost per share could vary depending on the number of shares for which valid claims are submitted. This Notice is not an expression of any opinion by the Court about the merits of any of the claims or defenses asserted by any party in the Action. For further information regarding this settlement you may contact: Rick Nelson, Milberg Weiss Bershad Hynes & Lerach LLP, 401 B Street, Suite 1700, San Diego, California 92101, Telephone: 800/449-4900. Please do not contact the Court or Sprint. I. NOTICE OF SETTLEMENT HEARING ON PROPOSED SETTLEMENT A settlement hearing will be held on December 16, 2003, at 9:30 a.m., before the Honorable Carlos Murguia, United States District Judge, District of Kansas, United States Courthouse, 500 State Avenue, Kansas City, Kansas (the "Settlement Hearing"). The purpose of the Settlement Hearing will be to determine: (1) whether the settlement consisting of $50,000,000.00 in cash (plus accrued interest) should be approved as fair, reasonable and adequate to Members of the Class (as defined below); (2) whether the proposed plan to distribute the settlement proceeds (the "Plan of Allocation") is fair, reasonable, and adequate; (3) whether the application by Plaintiffs' Co-Lead Counsel for an award of attorneys' fees and reimbursement of expenses and the Lead Plaintiffs' request for reimbursement of their time and expenses should be approved; and (4) whether the Action should be dismissed with prejudice and the Settling Defendants released from all Released Claims against them. The Court may adjourn or continue the Settlement Hearing or modify any dates set forth herein without further notice to the Class. II. DEFINITIONS USED IN THIS NOTICE 1. "Authorized Claimant" means a Member (or the representative of such Member including, without limitation, agents, administrators, executors, heirs, successors, and assigns), who submits a Proof of Claim and Release and who is entitled to a distribution from the Distribution Fund. 2. The "Class" means all persons or entities who, between October 4, 1999 and September 19, 2000, inclusive (the "Class Period"), purchased the Subject Securities and who suffered a loss as a result. Excluded from the Class are the Settling Defendants, members of the immediate family of each of the Individual Defendants, any entity in which Sprint has or had a controlling interest, and the legal representatives, heirs, executors, successors or assigns of any such excluded party and those Members of the Class that timely and validly exclude themselves from the Class. 3. "Final Judgment" means that judgment to be entered by the Court approving the Settlement, dismissing the Action with prejudice and without costs to any party, releasing all Released Claims, and enjoining Members from instituting, continuing, or prosecuting any action asserting one or more Released Claims. 4. "Individual Defendants" means William T. Esrey, Ronald T. LeMay, Kevin E. Brauer, Arthur B. Krause, Andrew J. Sukawaty, John E. Berndt, Theodore H. Schell, Thomas E. Weigman, Don A. Jensen, Bruce Branyan, William E. McDonald, Martin J. Kaplan, Gene M. Betts, James Richard Devlin, Michael B. Fuller, Len J. Lauer, John P. Meyer, Arthur Allan Kurtze, I. Benjamin Watson, III, Linda Koch Lorimer, Dubose Ausley, Warren L. Batts, Michel Bon, Irvine O. Hockaday, Jr., Harold S. Hook, Charles E. Rice, Louis W. Smith, Ron Sommer and Stewart Turley. 5. "Lead Plaintiffs" means the named Class representatives for the Class, specifically New England Health Care Employees Pension Fund, Amalgamated Bank, as Trustee for the Longview Collective Investment Fund, EmployerTeamsters Local Nos. 175 & 505 Pension Trust Fund, United Brotherhood of Carpenters, PACE Industry UnionManagement Pension Fund and Plumbers & Pipefitters National Pension Fund. 6. "Member" means any person or entity who is a member of the Class (including beneficial owners of Subject Securities purchased on their behalf by others during the Class Period), and including, without limitation, the Plaintiffs, but excluding those persons or entities who submit (or for whom are submitted) valid and timely requests for exclusion from the Class in accordance with the procedures set forth in this Notice. 7. "Named Plaintiffs" means New England Healthcare Employees Pension Fund, Harris Elliott Firestone and Jacques Sargent. 8. "Net Settlement Fund" (or "Distribution Fund") means the Settlement Fund less all fees and expenses allowed by the Federal Court and any taxes that may be payable from the Settlement Fund. 9. "Plaintiffs' Co-Lead Counsel" means Milberg, Weiss, Bershad, Hynes & Lerach, LLP and Scott & Scott, LLC. 10. "Plaintiffs' Liaison Counsel" means Walters, Bender, Strohbehn & Vaughan, P.C. 2

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11. "Plan of Allocation" means that plan or formula of allocation of the Distribution Fund described in the Notice, which plan or formula shall govern the distribution of the Distribution Fund. 12. "Released Claims" means any and all claims, rights, demands, causes of action, suits, matters, and issues, whether known or unknown, suspected or unsuspected, liquidated or unliquidated, including but not limited to all claims for attorneys' fees related to the Action, that have been, might have been or could be asserted against the Released Parties by Plaintiffs or any Member of the Class, arising out of or related, directly or indirectly, in any way, to the allegations, transactions, facts, matters or occurrences, representations or omissions involved, set forth, referred to or that could have been asserted in the Action relating to the purchase of the Subject Securities during the Class Period, whether such claims, rights, demands, causes of action, suits, matters, and issues arise under any state or federal statutory or common law against any of the Released Parties. 13. "Released Parties" means each and every one of the following: the Settling Defendants and each of their parents, subsidiaries or affiliates, or any of their respective present or former directors, officers, employees, agents, insurers, attorneys, advisors, successors, heirs, assigns, executors, personal representatives and immediate families. 14. "Settlement Administrator" means Gilardi & Co. LLC or such other or subsequent person or entity that the Court shall appoint. 15. "Settling Defendants" means Sprint and the Individual Defendants. 16. "Settlement Effective Date" means the date upon which the Final Judgment becomes final and no longer subject to appeal or review (or further appeal or review), whether by exhaustion of any possible appeal, lapse of time, or otherwise. 17. "Settlement Fund" means the sum of $50,000,000.00 and any interest earned thereon. 18. "Settlement Hearing" means the hearing to be held by the Federal Court to consider final approval of the Settlement pursuant to Rule 23(e) of the Federal Rules of Civil Procedure. 19. "Settling Parties" means Plaintiffs, the Members, and the Settling Defendants. 20. "Sprint" (or the "Company") means Sprint Corporation. 21. "Subject Securities" means the publicly-traded FON and PCS common stock issued by Sprint. 22. "Unknown Claims" means any Released Claims which any Plaintiff or Class Member does not know or suspect to exist in his, her or its favor at the time of the release of the Released Persons which, if known by him, her or it, might have affected his, her or its settlement with and release of the Released Parties, or might have affected his, her or its decision not to object to this settlement. With respect to any and all Released Claims, the Settling Parties have stipulated and agreed that, upon the Settlement Effective Date, the Plaintiffs, and each of the Class Members, by operation of the Final Judgement, waive any and all provisions, rights and benefits conferred by Cal. Civ. Code §1542, which provides: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR, and any other law of any jurisdiction (domestic or foreign), or principle of common law, which is similar, comparable, or equivalent to said provision. III. THE ACTION On or after June 25, 2001, Plaintiffs, for themselves and for all others similarly situated, filed actions in the United States District Court for the District of Kansas, entitled New England Health Care Employees Pension Fund v. Sprint Corp., Case No. 01 CV 04080, Harris Elliott Firestone v. Sprint Corp., 01 CV 02415, and Sargent v. Sprint Corp., 01 CV 04115. By Order dated September 5, 2001, the Federal Court consolidated all such actions under the caption In re Sprint Corporation Securities Litigation, Master File No. 01-4080-CM (the "Action"). On or about November 30, 2001, Plaintiffs filed a Consolidated Class Action Complaint (the "Complaint"). The Complaint alleges claims for violations of §§10(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 of the Securities and Exchange Commission. The Complaint alleges that the Settling Defendants did not adequately disclose the risks of regulatory non-approval of the proposed merger by which Sprint would have been acquired by WorldCom, Inc. and the fact that a shareholder vote in favor of the merger, as opposed to a merger itself, would trigger "change in control" provisions contained in certain Sprint stock option plans. Plaintiffs alleged that the trigger of these change of control provisions resulted in a substantial number of options to purchase Sprint securities vesting in certain Sprint directors and/or officers to the damage of Class Members. Plaintiffs also alleged that Settling Defendants made material misrepresentations regarding Sprint's financial results which had the effect of artificially inflating the trading prices of Sprint's securities. The Settling Defendants have denied and continue to deny all of these allegations and all other allegations alleged in 3

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the Action, and moved to dismiss the Complaint. On September 30, 2002, the Court granted in part and denied in part the Settling Defendants' motions to dismiss. Thereafter, counsel for Plaintiffs and counsel for the Settling Defendants engaged in substantial arm's length negotiations in an effort to resolve the Action, including conducting numerous telephone conferences and a mediation before Professor Eric Green, during which the terms of any agreement were extensively debated and negotiated. IV. CLAIMS OF THE PLAINTIFFS AND BENEFITS OF SETTLEMENT The Plaintiffs believe that the claims asserted in the Action have merit. However, counsel for the Plaintiffs recognize and acknowledge the expense and length of continued proceedings necessary to prosecute the Action against the Settling Defendants through trial and appeal. Counsel for the Plaintiffs also have taken into account the uncertain outcome and the risk of any litigation, especially in complex actions such as the Action, as well as the difficulties and delays inherent in such litigation. Counsel for the Plaintiffs also are mindful of the inherent problems of proof of, and possible defenses to, the violations asserted in the Litigations. Counsel for the Plaintiffs believe that the settlement set forth in the Stipulation confers substantial benefits upon and is in the best interests of the Class. V. SETTLING DEFENDANTS' STATEMENT AND DENIALS OF WRONGDOING AND LIABILITY The Settling Defendants have denied and continue to deny each and all of the claims and contentions alleged by the Plaintiffs in the Action. The Settling Defendants expressly have denied and continue to deny all charges of wrongdoing or liability against them or any of them arising out of any of the conduct, statements, acts or omissions alleged, or that could have been alleged, in the Action. The Settling Defendants also have denied and continue to deny, inter alia, the allegations that the Plaintiffs or Class Members have suffered any damage or harm, that the price of Sprint FON and/or PCS common stock was artificially inflated by reason of any alleged misrepresentations, non-disclosures or otherwise, or that the Plaintiffs or the Class Members were harmed by any of the conduct alleged in the Action. Nonetheless, the Settling Defendants have concluded that further conduct of the Action would be protracted, expensive, and distracting to Sprint and its management and that it is desirable that the Action be fully and finally settled in the manner and upon the terms and conditions set forth in the Stipulation. The Settling Defendants also have taken into account the uncertainty and risks inherent in any litigation, especially in complex cases like the Action. The Settling Defendants have, therefore, determined that it is desirable that the Action be settled in the manner and upon the terms and conditions set forth in the Stipulation. VI. TERMS OF THE PROPOSED SETTLEMENT The Settlement Fund ("Settlement Fund") consists of $50 million in cash, plus interest thereon. A portion of the Settlement Fund will be used for certain administrative expenses, including costs of printing and mailing notice of the settlement, the cost of publishing newspaper notices, payment of any taxes assessed against the Settlement Fund and costs associated with the processing of claims submitted. In addition, as explained below, a portion of the Settlement Fund may be awarded by the Court to Plaintiffs' Co-Lead Counsel as attorneys' fees and for reimbursement of out-of-pocket expenses. The balance of the Settlement Fund (the "Net Settlement Fund" or the "Distribution Fund") will be distributed according to the Plan of Allocation described below to the Class Members who submit valid and timely Proof of Claim and Release forms. VII. PLAN OF ALLOCATION The Net Settlement Fund will be distributed to Class Members who submit valid and timely Proof of Claim and Release forms ("Authorized Claimants") under the Plan of Allocation described here. You will be eligible to participate in the distribution of the Net Settlement Fund only if you have a net loss on all transactions in Sprint publicly traded FON and/or PCS common stock. To the extent there are sufficient funds in the Net Settlement Fund, each Authorized Claimant will receive an amount equal to the Authorized Claimant's claim, as defined below. If, however, the amount in the Net Settlement Fund is not sufficient to permit payment of the total claim of each Authorized Claimant, then each Authorized Claimant shall be paid the percentage of the Net Settlement Fund that each Authorized Claimant's claim bears to the total of the claims of all Authorized Claimants. Payment in this manner shall be deemed conclusive against all Authorized Claimants. Claims will be calculated as follows: Sprint FON Group Common Stock 1. For shares of Sprint FON Group common stock that were purchased from October 4, 1999 through June 27, 2000, and (a) sold prior to June 28, 2000, the claim per share is $0.00; 4

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(b) sold from June 28, 2000 through September 19, 2000, the claim per share is the lesser of (i) $5.59 per share (June 28, 2000 price decline) or, (ii) the purchase price less the sales price; (c) retained at the end of September 19, 2000, the claim per share is $8.47. 2. For shares of Sprint FON Group common stock that were purchased from June 28, 2000 through September 19, 2000, and (a) sold prior to September 20, 2000, the claim per share is $0.00; (b) retained at the end of September 19, 2000, the claim per share is $2.88. Sprint PCS Group Common Stock 1. For shares of Sprint PCS Group common stock that were purchased from October 4, 1999 through June 27, 2000, and (a) sold prior to June 28, 2000, the claim per share is $0.00; (b) sold from June 28, 2000 through September 19, 2000, the claim per share is the lesser of (i) $2.64 per share (June 28, 2000 price decline) or, (ii) the purchase price less the sales price; (c) retained at the end of September 19, 2000, the claim per share is $12.84. 2. For shares of Sprint PCS Group common stock that were purchased from June 28, 2000 through September 19, 2000, and (a) sold prior to September 20, 2000, the claim per share is $0.00; (b) retained at the end of September 19, 2000, the claim per share is $10.20. For Class Members who held shares at the beginning of the Class Period or made multiple purchases or sales during the Class Period, the first-in, first-out ("FIFO") method will be applied to such holdings, purchases and sales for purposes of calculating a claim. Under the FIFO method, sales of shares during the Class Period will be matched, in chronological order, first against shares held at the beginning of the Class Period. The remaining sales of shares during the Class Period will then be matched, in chronological order, against shares purchased during the Class Period. A Class Member will be eligible to receive a distribution from the Net Settlement Fund only if that Class Member had a net loss, after all profits from transactions in Sprint publicly traded common stock during the Class Period are subtracted from all losses. The Court has reserved jurisdiction to allow, disallow or adjust the claim of any Class Member on equitable grounds. VIII. PARTICIPATION IN THE CLASS If you fall within the definition of the Class, you are a Class Member unless you elect to be excluded from the Class (see Section IX below). If you do not request to be excluded from the Class, you will be bound by any Final Judgment entered with respect to the settlement in the Action whether or not you submit a Proof of Claim and Release form. If you are a Class Member, you need do nothing (other than timely file a properly filled out Proof of Claim and Release form if you wish to participate in the distribution of the Net Settlement Fund). Your interests will be represented by Plaintiffs' Co-Lead Counsel. If you choose, you may enter an appearance individually or through your own counsel at your own expense; provided, however, that in order to be heard at the Settlement Hearing or pose an objection to the Settlement, you and your counsel must follow the procedures set fort in Section XIII below. TO PARTICIPATE IN THE DISTRIBUTION OF THE NET SETTLEMENT FUND, YOU MUST TIMELY COMPLETE AND RETURN THE PROOF OF CLAIM AND RELEASE FORM THAT ACCOMPANIES THIS NOTICE. The Proof of Claim and Release form must be postmarked on or before February 2, 2004, and sent to the Sprint Claims Administrator at the address below. Unless the Court orders otherwise, if you do not timely submit a valid Proof of Claim and Release form, you will be barred from receiving any payments from the Net Settlement Fund, but will in all other respects be bound by the provisions of the Stipulation and the Final Judgment. IX. EXCLUSION FROM THE CLASS You may request to be excluded from the Class. To do so, you must mail a written request stating that you wish to be excluded from the Class to: Sprint Claims Administrator c/o Gilardi & Co. LLC P.O. Box 808003 5

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Petaluma, California 94975-8003 The request for exclusion must state: (1) your name, address, and telephone number; and (2) all purchases and sales of Sprint publicly traded FON and/or PCS common stock made during the Class Period, including the dates of purchase or sale, the number of shares of such securities purchased or sold and the price paid or received per share. YOUR EXCLUSION REQUEST MUST BE POSTMARKED ON OR BEFORE DECEMBER 2, 2003, AND, IN ORDER TO BE VALID, MUST CONTAIN ALL OF THE FOREGOING INFORMATION. IF YOU SUBMIT A VALID AND TIMELY REQUEST FOR EXCLUSION, YOU SHALL HAVE NO RIGHTS UNDER THE SETTLEMENT, SHALL NOT SHARE IN THE DISTRIBUTION OF THE NET SETTLEMENT FUND, AND SHALL NOT BE BOUND BY THE STIPULATION OR THE FINAL JUDGMENT. X. DISMISSAL AND RELEASES If the settlement is approved, the Court will enter a Final Judgment in each of the Actions. The Final Judgment will dismiss the Released Claims with prejudice as to all Settling Defendants. The Final Judgment will also provide that all Class Members who have not validly and timely requested to be excluded from the Class shall be deemed to have released and forever discharged all Released Claims (to the extent Members of the Class have such claims) against all Released Persons. XI. APPLICATION FOR FEES AND EXPENSES At the Settlement Hearing, Plaintiffs' Co-Lead Counsel will request the Court to award attorneys' fees not to exceed 17.5% of the Settlement Fund, plus reimbursement of the expenses, not to exceed $375,000, which were incurred in connection with the Action, plus interest thereon. In addition, certain of the Lead Plaintiffs in the Action may seek compensation of up to $10,000 each for their time expended and expenses incurred in prosecuting the Action. This compensation will be paid from the Settlement Fund. Class Members are not personally liable for any such fees or expenses. To date, Plaintiffs' Co-Lead Counsel have not received any payment for their services in conducting the Action nor have counsel been reimbursed for their out-of-pocket expenses incurred. XII. CONDITIONS FOR SETTLEMENT The settlement is conditioned upon the occurrence of certain events described in the Stipulation. Those events include, among other things: (1) entry of the Final Judgment by the Court as provided for in the Stipulation; and (2) expiration of the time to appeal from or alter or amend the Final Judgment. If, for any reason, any one of the conditions described in the Stipulation is not met, the Stipulation might be terminated and, if terminated, will become null and void, and the parties to the Stipulation will be restored to their respective positions as of April 6, 2003. XIII. THE RIGHT TO BE HEARD AT THE SETTLEMENT HEARING Any Class Member who has not validly and timely requested to be excluded from the Class, and who objects to any aspect of the settlement, the Plan of Allocation, the application for attorneys' fees and expenses, or the Lead Plaintiffs' request for time and expense reimbursement may appear and be heard at the Settlement Hearing. Any such Person must file a written notice of objection, filed with the Clerk of the Court on or before December 2, 2003, and served by hand or first class mail on each of the following: CLERK OF THE COURT UNITED STATES DISTRICT COURT DISTRICT OF KANSAS 259 U.S. Courthouse 500 State Avenue Kansas City, Kansas 66101 and MILBERG WEISS BERSHAD HYNES & LERACH LLP WILLIAM S. LERACH KEITH F. PARK RANDALL BARON 401 B Street, Suite 1700 San Diego, California 92101 Co-Lead Counsel for Plaintiffs Any such written objection must demonstrate the objecting person's membership in the Class, including the number of shares of Sprint publicly traded FON and/or PCS common stock purchased and sold during the Class Period, and contain a 6

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statement of the reasons for objection. Only Class Members who have submitted written notices of objection in this manner will be entitled to be heard at the Settlement Hearing, unless the Court orders otherwise. XIV. SPECIAL NOTICE TO NOMINEES If you, as nominee for a beneficial owner, hold or held any Sprint publicly traded FON and/or PCS common stock purchased during the Class Period, then, within ten (10) days after you receive this Notice, you must either: (1) send a copy of this Notice and the Proof of Claim and Release by first class mail to all such beneficial owners; or (2) provide a list of the names and addresses of such beneficial owners to the Sprint Claims Administrator: Sprint Claims Administrator c/o Gilardi & Co. LLC P.O. Box 808003 Petaluma, California 94975-8003 If you choose to mail the Notice and Proof of Claim and Release yourself, you may obtain from the Sprint Claims Administrator (without cost to you) as many additional copies of these documents as you will need to complete the mailing. Regardless of whether you choose to complete the mailing yourself or elect to have the mailing performed for you, you may obtain reimbursement for or advancement of reasonable administrative costs actually incurred or expected to be incurred by you in connection with forwarding the Notice and Proof of Claim and Release form and which would not have been incurred but for the obligation to forward the Notice and Proof of Claim and Release form, upon submission of appropriate documentation to the Sprint Claims Administrator. XV. EXAMINATION OF PAPERS This Notice is a summary and does not describe all of the details of the Stipulation. For full details of the matters discussed in this Notice, you may review the pleadings and Stipulation filed with the Court, which may be inspected during business hours, at the office of the Clerk of the Court, United States District Court, District of Kansas, 259 U.S. Courthouse, 500 State Avenue, Kansas City, Kansas 66101. Further, the Stipulation, its exhibits, the Complaint and additional copies of this Notice and the attached Proof of Claim are available on the Internet at www.gilardi.com. If you have any questions about the settlement of the Action, you may contact Plaintiffs' Co-Lead Counsel by writing: MILBERG WEISS BERSHAD HYNES & LERACH LLP WILLIAM S. LERACH KEITH F. PARK RANDALL BARON 401 B Street, Suite 1700 San Diego, California 92101 PLEASE DO NOT CONTACT THE COURT OR SPRINT REGARDING THIS NOTICE.

DATED: October 29, 2003

BY ORDER OF THE COURT UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

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