NIALL E. LYNCH (CSBN 157959)	Filed April 5, 2006

LIDIA SPIROFF (CSBN 222253)

SIDNEY A. MAJALYA (CSBN 205047)

LARA M. KROOP (CSBN 239512)

Antitrust Division

U.S. Department of Justice

450 Golden Gate Avenue

Box 36046, Room 10-0101

San Francisco, CA 94102

Telephone: (415) 436-6660

Attorneys for the United States

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA	)	Case No. CR 06-0159 MMC

)

)	STIPULATION IN SUPPORT OF

v.	)	EXPEDITED SENTENCING

)	PURSUANT TO L.R. 32-1(b)

)

SOLVAY S.A.,	)

)	DATE: April 19, 2006
Defendant.	)	TIME:	2:30 p.m.

)	COURT: Hon. Maxine M. Chesney

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.

DATED: April 5____, 2006	Respectfully submitted,

SOLVAY S.A.	U.S. DEPARTMENT OF JUSTICE

BY:________/s/_________________ BY:__________/s/____________________

Edwin J. Buckingham III, Esq.	Niall E. Lynch

General Counsel	Assistant Chief, San Francisco Office

Solvay America, Inc.	Lidia Spiroff

Sidney A. Majalya

COUNSEL FOR DEFENDANT	Lara M. Kroop

Trial Attorneys

BY:_______/s/AP_______________	U.S. Department of Justice

Steven W. Thomas, Esq.	Antitrust Division

Steven R. Peikin, Esq.	450 Golden Gate Avenue

Adam S. Paris, Esq.	Box 36046, Room 10-0101

Sullivan & Cromwell LLP	San Francisco, CA 94102

1888 Century Park East	Telephone: (415) 436-6660

Los Angeles, CA 90067	Fax: (415) 436-6687

Telephone: (310) 712-6600