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IN RE:                              )
METROPOLITAN LIFE INSURANCE         )
COMPANY SALES PRACTICES             )        MISC. DOCKET NO. 96-179
LITIGATION                          )        MDL NO. 1091
                                    )
THIS DOCUMENT RELATES TO:           )        SUMMARY NOTICE OF CLASS
                                    )        ACTION, PROPOSED SETTLE-
                                    )        MENT AND FAIRNESS HEAR­ING
Amodeo       C.A. No. 96-0795       )
Biggs        C.A. No. 96-0038       )
Caskey       C.A. No. 95-1426       )
Garrett      C.A. No. 96-0436       )
Oddi         C.A. No. 96-0051       )
                                    )

TO:

ALL PERSONS OR ENTITIES WHO OWN OR OWNED ANY PERMANENT LIFE INSURANCE POLICY OR ANY DEFERRED ANNUITY CONTRACT OR CERTIFICATE ISSUED BY METROPOLI­TAN LIFE INSURANCE COMPANY, METROPOLITAN INSURANCE AND ANNUITY COMPANY, OR METROPOLITAN TOWER LIFE INSURANCE COMPANY (TOGETHER, "METLIFE") IN THE UNITED STATES DURING THE PERIOD FROM JANUARY 1, 1982 THROUGH DECEMBER 31, 1997 (THE "CLASS PERIOD") PURSUANT TO AN INDIVIDUAL SALE.

The above-captioned consolidated class action lawsuit (the "Action") has been pending against MetLife in the United States District Court for the Western District of Pennsylva­nia (the "Court"). The parties to the Action have reached a proposed settlement pursuant to a Stipulation of Settlement and exhibits thereto (the "Settlement Agreement"). The Court has preliminarily certified a Class for settle­ment purposes and has authorized the publication of this notice.

PLEASE TAKE NOTICE that the Court (United States District Judge Donetta W. Ambrose and United States Magistrate Judge Kenneth J. Benson, sitting jointly) will hold a fairness hearing on December 2, 1999, at 10 a.m., at the federal Courthouse, U.S. Post Office and Courthouse, Seventh Avenue and Grant Street, Pittsburgh, Pennsylvania, in Courtroom 5 on the 6^th Floor, to determine:(1) whether the Class should be finally certified for settlement purposes; (2) whether the proposed settlement of the Action should be approved as fair, reasonable and adequate; (3) whether the Action should be dismissed with prejudice pursuant to the terms of the pro­posed settlement; (4) whether Class Members should be bound by the release set forth in the proposed settlement; (5) whether Class Members should be permanently enjoined from, among other things, starting, continuing, intervening in, participating in, or receiving any benefits from (as Class Members or otherwise), any lawsuit, arbitration, administrative, regulatory or other proceeding or order in any jurisdiction based on or relating to the claims, facts or circum­stances set forth in the Action and/or the Released Transactions (as defined in the Settlement Agreement); (6) whether incentive awards, if requested, of up to $2,500 per person for certain plaintiffs who have served as class representatives in this or other class actions against MetLife should be approved; and (7) whether Co-Lead Counsel for Plaintiffs' application for an award of attorneys' fees and expenses should be approved.

A detailed Notice of Class Action, Proposed Settlement and Fairness Hearing (the "Class Notice") has been mailed to the last known address, as reflected by MetLife's records, of the current or last owner(s) of record of affected Policies and Annuities. The Class Notice describes in detail the proposed settlement and Class Members' rights. The proposed settlement and the scheduled court hearing may affect those rights. If you are a member of the Class and have not received a copy of the Class Notice, you should obtain one immediately, either by (i) calling The MetLife Class Action Information Center at 1-800-843-4790 (or if you use TDD/TTY, 1-800-846-0798) or (ii) writing to The MetLife Class Action Information Center, P.O. Box 1564, Faribault, Minnesota 55021-1564.

(1) The Settlement Class. The Court has preliminarily certified a Class of Policy owners and Annuity owners for settlement purposes only. The Class includes all persons and entities (such as companies or trusts), except those listed below, who have or had an ownership interest in one or more permanent life insurance policies or deferred annuity contracts or certificates issued by MetLife in the United States during the Class Period pursuant to an individual sale.

The Class does not include the following persons or entities under any circumstances:

• any present or former MetLife employee, director or sales representative, or his or her spouse;
  
  
• an insurance company that owns or owned a Policy or Annuity pursuant to an absolute assignment effected as part of an exchange under section 1035 of the Internal Revenue Code.

The Class also does not include certain other persons or entities (unless and to the extent such persons or entities are Class Members by virtue of their ownership interest in another Policy or Annuity that otherwise falls within the Class definition) who have or had an ownership interest in Policies or Annuities that:

• are timely excluded from the Class in accordance with the steps described below and in Part H of the Class Notice; or
  
  
• resulted in an award of relief pursuant to the nationwide class action settlement of savings and retirement plan claims in Horton v. Metropolitan Life Insurance Co., Civ. No. 93-1849-CIV-T-23A (M.D. Fla.); or
  
  
• were the subject of a release settling a claim or dispute and releasing MetLife from any further liability concerning such Policies or Annuities, provided that the release was signed by the person or entity while repre­sented by an attorney; or
  
  
• were terminated because of the death of the insured, the annuity owner or the annuitant; or
  
  
• were not accepted or paid for by the customer, or were returned to MetLife as part of the exercise of a free look provision in the Policies or Annuities; or
  
  
• were rescinded (a) as part of a reissue of a new Policy or Annuity, or (b) because of a material misrepresentation on the application for the particular Policy or Annuity, or (c) where the owner was represented by counsel and the premiums and other monies paid were returned to the owner with interest; or
  
  
• make the owner a member of the class involving the allegedly improper sale of life insurance policies or annuities in certain European countries, which was certified on August 24, 1998, by the United States District Court for the Southern District of New York in Dornberger v. Metropolitan Life Insurance Co., No. 95-CIV-10374 (LBS) (S.D.N.Y.); or
  
  
• were issued in connection with the Transamerica HomeFirst Reverse Mortgage Program.

(2) Choices and Deadlines for Class Members.If you are a Class Member, you have the following choices for each Policy or Annuity issued during the Class Period in which you have (or had) an ownership interest:

• You may remain in the Class and participate in the benefits under the proposed settlement if it is approved. Your interests will be repre­sented without cost to you by the law firms of Milberg Weiss Bershad Hynes & Lerach LLP and Specter Specter Evans & Manogue, P.C., which are acting as Co-Lead Counsel for the Class. If you remain in the Class, you will be bound by all orders and judgments entered in this case, whether favorable or unfavorable. You will not be able to start or continue any other claim, lawsuit or other proceeding against MetLife relating to your Policies or Annuities that are encompassed by the Release, which is reprinted in full as Appendix A to the Class Notice.
  
  
• If you remain in the Class, you must decide now between two types of relief offered under the proposed settlement for each of your Policies or Annuities you decide to keep in the Class: General Relief and Claim Evaluation. You cannot participate in both. In addition, if you own or owned certain Policies, you will also automatically receive the DAC Tax Relief described below and in Part E of the Class Notice.
  
  
  • If you want to receive General Relief (described below and in Part E.1 of the Class Notice) for each of your Policies or Annuities, you do not need to do anything now (other than call the toll-free number and request a Class Notice if you have not received one). You automatically will re­ceive the General Relief for which you are eligible if the proposed settlement is approved.
    
    
  • If you want to submit a claim to Claim Evaluation (described below and in Part E.2 of the Class Notice) for any of your Policies or Annuities, you must return the Election Form enclosed with the Class Notice to The MetLife Class Action Information Center, P.O. Box 1564, Faribault, Minnesota 55021-1564. Your Election Form must be received no later than November 2, 1999. After the proposed settlement is approved and any appeals have been exhausted, you will receive a Claim Form with instructions on how to file your claim to ob­tain benefits under Claim Evaluation. If your Election Form is not received by November 2, 1999, you will not receive any relief under Claim Evaluation. Instead, you automatically will receive the General Relief for which you are eligible and the DAC Tax Relief, if applicable.
    
    
  • If you remain in the Class, you may object to any aspect of the proposed settlement. To do so, you must file a written objection in accordance with Part I.2 of the Class Notice. The Court must receive your written objection(s) no later than November 2, 1999 at the following address:
    
    Clerk of the Court
    United States District Court
    U.S. Post Office and Courthouse
    Seventh Avenue and Grant Street
    Pittsburgh, Pennsylvania 15219
    Re: Misc. Docket No. 96-179, MDL No. 1091

    You also must mail your written objection(s) to the attorneys for the parties, as described in Part I.2 of the Class Notice, by the same deadline If you submit a written objec­tion(s), you (or an attorney acting for you at your own expense) may appear at the Court hearing to make your objection(s). If the Court does not agree with your objection(s), you nevertheless will be bound by the orders and judgment in this Action, but will still be eligible for relief under the settlement.

  • You may exclude yourself from the Class by submitting a formal, written request for exclusion for each Policy or Annuity that you wish to exclude. The exclusion request must comply with Part H of the Class Notice and must be mailed to the following address so that it is received no later than November 2, 1999:
    
    The MetLife Class Action Information Center
    P.O. Box 1564
    Faribault, Minnesota 55021-1564
    Re: Exclusion from the Class
    
    

    Please write the words "EXCLUSION REQUEST" on the lower left-hand corner of the front of the envelope. If you are excluded from the Class (i) you will not be eligible for any benefits under the proposed settlement; (ii) you will not be allowed to object to the proposed settlement, and (iii) you will not be bound by any orders or judgments entered in this case.

(3) Settlement Relief. There are three categories of benefits available under the pro­posed settlement: General Relief, Claim Evaluation and Deferred Acquisition Cost ("DAC") Tax Relief. Class Members must choose between General Relief and Claim Evaluation for each of their Policies or Annuities. DAC Tax Relief is available automatically if you own or owned certain Policies identified in the Settlement Agreement.

1. General Relief.Simply by remaining in the Class and not electing to participate in Claim Evaluation for a particular Policy or Annuity, you automatically will receive the General Relief for which you are eligible. There are two forms of General Relief: the Settlement Death Benefit for Policies and the Accidental Death Benefit for Annuities.
   
   
   • The Settlement Death Benefit.For each Class Member who owns or owned an eligible Policy (not an Annuity), the Settlement Death Benefit pro­vides, for a limited period, a free death benefit payable upon MetLife's receipt of due proof of the death within the prescribed period of the person whose life is insured under the Policy (or an Alternate Measuring Life, as defined in Part E.1 of the Class Notice, designated by the Class Member in accordance with the procedures described in Part E.1 of the Class Notice). The length and amount of the Settlement Death Benefit will depend on the type of Policy, the face amount of the Policy, the age of the person whose life is insured under the Policy (or the Alternate Measuring Life), and whether the Policy is still in force, and, if not, when it was terminated. The Settlement Death Benefit will last for a period ranging from 12 to 59 months, in an amount ranging from 2.5% to 16.6% of the face amount of the Policy that makes the Class Member eligible for relief.
     
     
   • The Accidental Death Benefit.For each Class Member who owns or owned an eligible Annuity (not a Policy), the Accidental Death Benefit pro­vides, for a limited period, a free death benefit payable upon MetLife's receipt of due proof of the accidental death within the pre­scribed period of the annuitant under the Annuity (or an Alternate Measuring Life, as defined in Part E.1 of the Class Notice, designated by the Class Member in accordance with the procedures described in Part E.1 of the Class Notice). The Accidental Death Benefit will last for three years, and the amount of coverage will range from $1,500 to $5,500, depending on the Annuity Account Value, as that term is defined in the Settlement Agreement.
     
     
2. Claim Evaluation. If you believe you were misled by a misstatement or omission of material information by MetLife, or were otherwise harmed by wrongdoing in connection with your Policy or Annuity, you may elect to submit your claim to Claim Evaluation instead of automatically receiving General Relief. Claim Evaluation is provided at no cost to you.
   • In Claim Evaluation, the relief awarded can range from none at all to relief designed to redress any loss that may have resulted from the alleged wrongdoing, based on the nature and strength of your claim, as evidenced by your written description of your claim and any other documents or other materials you submit, as well as the documents and information that MetLife will assemble about your Policy or Annuity. For more information on the Claim Evaluation procedures, see Part E.2 of the Class Notice.
     
     
   • Examples of claims that may be resolved in Claim Evaluation include the following:
     
     
     • Replacement Claims: Any claim that, at the time you bought your Policy or Annuity, MetLife or its sales representatives misrepresented to you the advantages, disadvantages or finan­cial impact of using the cash or account value, dividends or interest from an existing policy or annuity - whether issued by MetLife or by any other company - to purchase a new MetLife Policy or Annuity.
       
       
     • Accelerated Payment or Vanishing Premium Claims: Any claim that MetLife or its sales representatives misrepresented to you that you would only have to pay a single or fixed number of premium payments on a Policy, that you would not have to pay additional premium payments out of pocket after a specified date or number of payments, or that MetLife would issue a "fully paid up" or "paid up" Policy for the originally illustrated face amount of insurance without any further premium pay­ments after a specified number of years.
       
       
     • Performance Claims: Any claim that, at the time you bought your Policy, MetLife or its sales representatives misrepresented to you that the cash or account value in your Policy would not be less than illustrated or would be maintained at a specific level over the life of the Policy, or that the dividends, interest credit­ing rates, or policy credits would never fall below certain levels or that charges would never rise above certain levels.
       
       
     • Savings and Retirement Claims: Any claim that, at the time you bought your Policy, MetLife or its sales representatives made misrepresentations: (1) that the product you were pur­chasing was a savings, investment or retirement plan, without adequately disclosing to you that the product was a life insur­ance policy, or (2) about the relative appropriateness of using life insurance solely to meet your savings and retirement goals, or (3) about the nature of the Policy by characterizing its premi­ums as "deposits," "contributions," or "outlays," or calling the Policy's values "savings," "capital," a "retirement account," a "money accumulation account" or a similar investment terminol­ogy.
       
       
     • Other Marketing Claims: For Policies, this is any claim not defined above that is based on alleged misrepresentations made in the marketing or sale of the Policy. For Annuities, this is a claim, if any exists, that is raised by the Amended Complaint in the Action and is not a Replacement Claim or a Tax Deferred Annuity Misrepresentation Claim.
       
       
     • Tax Deferred Annuity Misrepresentation Claims: Any claim that, at the time you bought your Annuity, MetLife allegedly improperly marketed and sold you a deferred annuity for fund­ing a qualified plan, such as an Individual Retirement Account ("IRA") or 401(k), on the basis of a tax-deferral advantage that does not exist, because any investment in a qualified plan is already tax-deferred.
       
       
   • An Alternative Dispute Resolution ("ADR") Process will be avail­able to address other types of claims not described above. In addition, if you remain in the Class and later assert a claim against MetLife that relates to your Policy or Annuity and is not released by the Release annexed as an appendix to the Class Notice, MetLife may require you to resolve that claim in an ADR Process. This ADR Process also will allow you to address claims relating to or arising out of the servicing and administration of your Policy or Annuity after you bought it, if you did not discover those claims prior to November 2, 1999, and you could not have learned of them before that date, even if you had used reasonable care.
     
     
3. DAC Tax Relief. You will be automatically eligible to receive the DAC Tax Relief if you own or owned certain Policies identified in the Settlement Agreement. The DAC Tax Relief provides free death benefit coverage for a limited time.If your Policy qualifies, you will receive a death benefit payable upon MetLife's receipt of due proof of the death within the pre­scribed period of the person whose life is insured under the Policy (or an Alternate Measuring Life, as defined in Part E.3 of the Class Notice, designated by the Class Member in accordance with the procedures de­scribed in Part E.3 of the Class Notice). The length and amount of the death benefit will depend on the face amount of the qualifying Policy, the age of the person whose life is insured under the qualifying Policy (or the Alternate Measuring Life), and whether the qualifying Policy is still in force, and, if not, when it was terminated. In addition, as of a date no later than 30 days after the date the settlement is implemented, MetLife will not include the costs associated with the DAC Tax as part of the cost of insurance charge or other charge or expense on the Policies identified in the Settlement Agreement if the costs associated with the DAC Tax currently are included in cost of insurance charges for those Policies.
   
   

EACH OF THE FORMS OF SETTLEMENT RELIEF IS DESCRIBED IN GREATER DETAIL IN THE CLASS NOTICE. IF YOU BELIEVE THAT YOU ARE A CLASS MEMBER BUT YOU HAVE NOT RECEIVED A CLASS NOTICE, PLEASE CALL 1-800-843-4790 (OR IF YOU USE TDD/TTY, 1-800-846-0798) TO ASK FOR A CLASS NOTICE.

Receipt of relief under the proposed settlement may have tax consequences for you.You should consult your own tax advisor about possible tax con­se­quences.

(4) Preliminary Injunction.In its August 18, 1999, Order, the Court preliminarily enjoined all Class Members who have not been timely excluded with respect to a Policy or Annuity from filing, commencing, prosecuting, maintaining, intervening in, participating in (as Class Members or otherwise), or receiving any benefits or other relief from, any other claim, lawsuit, arbitration or administrative, regulatory or other proceeding or order in any jurisdiction based on, arising out of, or relating to the claims and causes of action, or the facts and circumstances relating thereto, in this Action and/or the Released Transactions as to that Policy or Annuity. The Court also preliminarily en­joined all per­sons from organizing or soliciting the participation of any Class Members into a separate class for purposes of pursuing as a purported class action (in­cluding by seeking to amend a pending complaint to include class allegations, or by seek­ing class certification in a pending action) any claim, lawsuit or other proceeding based on, arising out of, or relating to the claims and causes of action, or the facts and circumstances relating thereto, in this Action and/or the Released Transactions as to that Policy or Annuity. The parties will ask the Court to make the preliminary in­junction permanent as to all Class Members upon final approval of the settlement. All Class Members will be bound by the permanent injunction.

(5) Release. In exchange for the benefits to be provided under the pro­posed settlement, Class Members will release MetLife from liability for certain claims re­lating to Policies and Annuities. This Release is reprinted in full in Appendix A to the Class Notice.The Release may affect your rights if you decide to stay in the Class. You should read it carefully.

(6) Plaintiffs' Incentive Awards. Co-Lead Counsel for Plaintiffs may request at the hearing before the Court that incentive awards of no more than $2,500 per person be paid to some or all of the plaintiffs who have served as class representatives in this Action or other class actions against MetLife. These incentive awards would be in recognition of the special efforts and risks undertaken by the recipients on behalf of the Class. If awarded, these incentive awards would be deducted from the fund established to provide cash and credit relief in the Claim Review Process.

(7) Attorneys' Fees and Expenses. At the Fairness Hearing, Co-Lead Counsel for the Class will ask the Court for an award of attorneys' fees not to exceed $120,000,000 and expenses not to exceed $2,500,000, to be paid by MetLife. MetLife will not oppose Co-Lead Counsel's application for an award of fees and expenses up to these amounts. MetLife's payment of any such fees and expenses will not reduce or affect any benefits to be provided to the Class under the proposed settlement.

(8) Further Information. This is only a short summary of the proposed settlement. Further details are contained in the Class Notice mentioned above. If you are a member of the Class and you have not received a detailed Class Notice, if you need further informa­tion about the terms of the settlement, or if you need a large-print version of the Class Notice, please call The MetLife Class Action Information Center at 1-800-843-4790, or if you use TDD/TTY, 1-800-846-0798. Telephone calls may be monitored by counsel for Plaintiffs.

PLEASE DO NOT TELEPHONE THE COURT OR THE CLERK OF THE COURT.

Dated: August 18, 1999
           Pittsburgh, Pennsylvania

James A. Drach
Clerk of the Court

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