<p align= justify >According to the complaint, plaintiffs are challenging the sale of Safeco to Liberty Mutual and its wholly owned subsidiary Big Apple Merger Corporation (”Big Apple”) in a proposed transaction (the “Sale Agreement”) which protects and advances the interests of Safeco’s directors and Liberty Mutual at the expense of Safeco’s public shareholders and defendants’ efforts to conceal material information from plaintiff and Safeco’s other public shareholders in conjunction with the same. Specifically, as further alleged below, a majority of Safeco’s directors will receive extensive personal compensation as a result of the Sale Agreement- compensation that they would not” otherwise receive at this time absent the Sale Agreement. This conflict of interest caused these directors to be unable to fairly and thoroughly evaluate the Sale Agreement to ensure that they are in the best interest of Safeco and its public shareholders- Additionally, Safeco’s directors caused Safeco to file a proxy statement with the SEC on or about May 23, 2008 (and, through the SEC, distribute to Safeco’s shareholders over the Internet) which concealed material information from plaintiff and Safeco’s other public shareholders.</p>