Free Response in Opposition to Motion - District Court of Arizona - Arizona

EXHIBIT 1

Case 2:04-cv-00424-ROS

Document 395-2

Filed 01/31/2008

Page 1 of 3

Proposed Letter for Defendants to Send To Agreed Upon Class Members At Least One Week Prior to Contact For Purposes of Ex Parte Interviews February 17, 2007

Dear In connection with your former role as [insert position of person being contacted] with [insert company name at time of employment, i.e. the Garrett Corporation; the Signal Companies, Inc.; Allied Corporation; AlliedSignal Inc.; and/or Honeywell International Inc.], Honeywell International Inc. seeks your cooperation in assisting the Company s fact gathering in connection with a class action lawsuit which is currently pending in the United States District Court for the District of Arizona entitled Barbara Allen v. Honeywell Retirement Earnings Plan, No. CV-04-0424 (ROS). In the suit, Plaintiffs claim, inter alia, that Defendants impermissibly reduced pension benefits following the merger of the Garrett Retirement Plan into the Signal Retirement Plan. Plaintiffs are seeking past and future retirement benefits and other relief from Defendants. Defendants dispute Plaintiffs claims and maintain that nothing occurred that was unlawful and that Plaintiffs are not entitled to additional benefits. We represent Defendants in this action. The named Defendants in this suit are the Honeywell Retirement Earnings Plan, which is the successor plan to the Garrett Retirement Plan; the Signal Retirement Plan; the Honeywell Secured Benefit Plan, which is the successor plan to the Garrett Secured Benefit Account; and the Plan Administrators of each of these plans. Defendants have identified you as someone who may have knowledge of relevant facts in connection with the claims or defenses in this suit, including knowledge of the 1983 and 1984 plan amendments, or subsequent amendments in 1993 or 2000. Susan Martin, Daniel Bonnett, and Jennifer Kroll of the law firm of Martin & Bonnett, P.L.L.C. ( Class Counsel ), represent the members of the Plaintiff Class in this lawsuit. You have been identified as someone who may be included in the class of individuals on behalf of whom this lawsuit has been brought. If Plaintiffs are successful, class members may receive monetary damages and/or an increase in pension benefits; if Defendants are successful, the class may receive no damages and/or no increase in pension benefits. Class Counsel has agreed that we may contact you and conduct voluntary interviews on the condition that you are advised of the rights described in this letter. You are under no obligation to speak to us and you will not be retaliated against in any way if you choose to speak with us or chose not to speak with us. If you would like, you may have Class Counsel present during the interview or you may have your own attorney present. Within the next two weeks, someone from our offices will be contacting you to arrange a voluntary interview to discuss your knowledge of certain relevant facts pertaining to this litigation. If you would like to speak with Class Counsel regarding any questions you may have about this letter or the lawsuit or your right to participate or decline to participate in a voluntary interview you may contact Class Counsel at:

Case 2:04-cv-00424-ROS

Document 395-2

Filed 01/31/2008

Page 2 of 3

Martin & Bonnett, P.L.L.C. 3300 N. Central Ave., Suite 1720 Phoenix, AZ 85012 Telephone (602) 240-6900 Facsimile (602) 240-2345 On behalf of the Honeywell Defendants, we appreciate your anticipated cooperation and look forward to speaking with you. Very truly yours,

Signature Block Counsel For The Honeywell Defendants

Case 2:04-cv-00424-ROS

Document 395-2

Filed 01/31/2008

Page 3 of 3