IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY

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1 IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY x JOANN KRAJEWSKI, PAUL Consolidated Case No. 02-CV MCHENDRY, and MICHAEL LAMB, Division No. 8 Derivatively on Behalf of Nominal Defendant AMC ENTERTAINMENT, INC., Plaintiffs, v. LAURENCE M. BERG, LEON D. BLACK, PETER C. BROWN, CHARLES J. EGAN, JR., W. THOMAS GRANT, II, CHARLES S. PAUL, MARC J. ROWAN, PHILIP M. SINGLETON and PAUL E. VARDEMAN, Defendants, and AMC ENTERTAINMENT, INC., Nominal Defendant. x NOTICE OF SETTLEMENT HEARING TO ALL CURRENT SHAREHOLDERS OF AMC ENTERTAINMENT, INC. AS OF MAY 6, THIS NOTICE IS GIVEN pursuant to an Order of the Circuit Court of Jackson County, Division 8, Missouri, at Kansas City (the Court ) in the above-captioned putative derivative action. Plaintiffs brought this action on behalf of AMC Entertainment, Inc. ( AMC ). This Notice is given to advise you that a hearing shall be held on June 24, 2003 at 11 a.m. central time (the Final Hearing ) in the Circuit Court of Jackson County, Division 8, 415 East 12th Street, Kansas City, Missouri (i) to determine the fairness, reasonableness, and adequacy of the terms and conditions of a stipulated settlement between the parties to this action (the Settlement ) and whether the Court should approve the Settlement and enter a Judgment (as defined in Section III(A)(5) below) thereon; and (ii) to rule upon counsel for Representative Plaintiffs (as defined in Section III(A)(9) below) application for an award of reasonable attorneys fees and reimbursement of expenses. By this Notice, the Court does not express any opinion as to the merits of any claim or defense that has been or may be asserted in this action. THE FOLLOWING RECITATION DOES NOT CONSTITUTE FINDINGS OF THE COURT. IT IS BASED ON THE STATEMENTS OF THE PARTIES AND SHOULD NOT BE UNDERSTOOD AS AN EXPRESSION OF ANY OPINION OF THE COURT AS TO THE MERITS OF ANY OF THE CLAIMS OR DEFENSES RAISED BY ANY OF THE PARTIES. I. BACKGROUND 1. In August 1998, the board of directors of AMC ( the Board ) authorized certain loans to be granted to its then President and Chief Financial Officer, Peter C. Brown ( Brown ), and its then Executive Vice-President and Chief Operating Officer, Philip M. Singleton ( Singleton ), the proceeds of which were to be used by them to purchase shares of AMC common stock (the Loans ). 2. As a result of the Company s financial performance in fiscal year 2002, on May 13, 2002, the Board authorized the forgiveness of the Loans and the payment of the related taxes and interest on the Loans, conditioned upon the agreements of Brown and Singleton to retain the shares of AMC acquired with the proceeds of the Loans for a period of eighteen (18) months from the date of the loan forgiveness (the Loan Forgiveness ). 3. On June 6, 2002, AMC entered into an Agreement Regarding Forgiveness of Debt with Brown and Singleton, respectively (the Loan Forgiveness Agreements ). 4. On July 31, 2002, Joann Krajewski and Paul McHendry, purported shareholders of nominal defendant AMC, commenced a putative shareholders derivative action on behalf of AMC captioned Krajewski v. Berg, et al., Case No. 02-CV (the Krajewski Action ), in the Circuit Court of Jackson County, Division 8, Missouri, at Kansas City (the Court ). The Krajewski Action named Brown, Laurence M. Berg, Leon D. Black, Charles J. Egan, Jr., W. Thomas Grant, II, Charles S. Paul, Marc J. Rowan and Paul E. Vardeman (collectively, the Board of Directors ) and AMC as defendants. The Krajewski Action alleged that the Board of Directors breached their fiduciary duties and wasted corporate assets by, inter alia, approving the Loan Forgiveness and the Loan Forgiveness Agreements. 5. On August 2, 2002, Michael Lamb, a purported shareholder of nominal defendant AMC commenced a shareholder s derivative action captioned Lamb v. Berg, et al., Case No. 02-CV (the Lamb Action ), in the Circuit Court of Jackson County, Division 1, Missouri, at Kansas City, which was nearly identical to the facts alleged and claims asserted in the Krajewski Action. 6. On November 19, 2002, the Krajewski and Lamb Actions were consolidated under the caption Krajewski v. Berg, et al., Case No. 02-CV (the Missouri Action ), with the pleading in the Krajewski Action designated as the operative petition (the First Consolidated Petition ) in the Missouri Action. 7. On November 25, 2002, Defendants filed a joint motion to dismiss the First Consolidated Petition for failure to (a) make a pre-suit demand on the Board of Directors to obtain redress of the matters of which they complained pursuant to Missouri Supreme Court Rule and Delaware Chancery Court Rule 23.1; and (b) state a claim upon which relief can be granted.

2 8. On December 30, 2002, Michael Malone, a purported shareholder of nominal defendant AMC commenced a shareholder s derivative action captioned Malone v. Brown et al., C.A. No NC, in the Court of Chancery of the State of Delaware in and for New Castle County (the Delaware Action ), which was nearly identical to the facts alleged and claims asserted in the Missouri Action. The Delaware Action and the Missouri Action are collectively referred to as the Actions. 9. Throughout the Fall of 2002, plaintiffs counsel in the Missouri Action conducted further investigation of plaintiffs claims. As a result of this investigation, on or about January 12, 2003, plaintiffs counsel in the Missouri Action contacted Defendants counsel to raise the issue of exploring a possible settlement of the Missouri Action. 10. On or about January 24, 2003, plaintiffs in the Missouri Action filed an amended consolidated derivative petition (the Second Consolidated Petition ) purportedly on behalf of nominal defendant AMC against the Singleton and the Board of Directors (collectively, the Individual Defendants ) alleging breaches of fiduciary duty and corporate waste arising from the Loan Forgiveness and Loan Forgiveness Agreements. 11. On February 13, 2003, Defendants filed a motion to dismiss the complaint in the Delaware Action (the Delaware Complaint ) for failure to (a) make a pre-suit demand on the Board of Directors seeking redress of the matters of which they complained pursuant to Delaware Chancery Court Rule 23.1; and (b) state a claim upon which relief can be granted. 12. On February 24, 2003, Defendants filed a joint motion to dismiss the Second Consolidated Petition filed in the Missouri Action for failure to (a) make a pre-suit demand on the Board of Directors seeking redress of the matters of which they complained pursuant to Missouri Supreme Court Rule and Delaware Chancery Court Rule 23.1; and (b) state a claim upon which relief can be granted. 13. On April 3, 2003, the Court of Chancery of the State of Delaware in and for New Castle County ordered a ninety (90) day stay of the Delaware Action in order to allow the parties time to pursue the Settlement embodied in the Stipulation of Settlement dated as of April 25, 2003 (the Stipulation ). 14. Plaintiffs counsel have conducted a thorough investigation into the matters alleged in the Actions and the parties have engaged in good faith negotiations with regard to the possible settlement of the Actions. 15. The parties and their counsel believe that the terms and conditions of the Settlement are fair, reasonable, adequate and proper, and acknowledge that their Settlement is a result of extensive arm s-length negotiations between the parties and their counsel. 16. The Board of Directors of AMC has approved the terms of the Settlement and believes that the Settlement is in the best interests of AMC and its shareholders. 17. As of April 25, 2003, counsel for all parties in the Actions signed the Stipulation, which sets forth the terms of the proposed Settlement. II. THE PARTIES POSITIONS AS TO THE DESIRABILITY OF THE PROPOSED SETTLEMENT A. The Individual Defendants Denials of Wrongdoing and Liability 1. The Individual Defendants vigorously deny all allegations that they breached any fiduciary duties, or that they committed corporate waste or any other wrongful act or violation of law in connection with any of the matters alleged or that could have been alleged in the Actions, and disclaim any wrongdoing or liability whatsoever. Further, the Individual Defendants specifically continue to deny that the Representative Plaintiffs, AMC, or former AMC shareholders or Current AMC Shareholders (as defined in Section III.A.1 herein) were damaged in any manner by the conduct alleged by the Representative Plaintiffs in the Actions. 2. AMC and the Individual Defendants state that they have agreed to the compromise and settlement of the Actions subject to the terms and conditions set forth in the Stipulation and in exchange for the agreements contained therein, to avoid the burden and expense of continued litigation of the Actions, and to compromise and settle those claims that have been asserted, or that could have been asserted, in the Actions. B. Claims of the Representative Plaintiffs and the Benefits of Settlement 1 The Representative Plaintiffs state that after the extensive factual and legal investigations described above, they have concluded that while they believe the claims asserted in the Actions have merit, the Settlement will provide substantial benefits to AMC and its stockholders which, when weighed against the attendant risks of continued litigation, warrant settlement of the claims; that they have determined that they have obtained adequate information to determine the value of the Actions and to enter into the Stipulation on a fully informed basis without the need for any additional discovery or information which could be obtained if the Actions were not settled as provided for therein; that they have considered the expense and length of time necessary to prosecute the Actions through trial, the defenses asserted by and available to Defendants, the uncertainties of the outcome of the Actions, and the fact that the resolution of the Actions, even if this Court and/or the Court of Chancery of the State of Delaware in and for New Castle County found in Representative Plaintiffs favor, would likely be submitted for appellate review, enhancing both the risk and the time required for final adjudication of the Actions; that in light of all of these considerations, the Representative Plaintiffs and their counsel have engaged in arm s-length negotiations with counsel for Defendants in an effort to achieve the certainty of a positive outcome in the Actions and have determined that it is in the best interests of AMC and its shareholders to settle the Actions by (i) obtaining a Judgment approving of the Settlement in the Missouri Action; and (ii) within two (2) days after the Court approves the Settlement of the Missouri Action, voluntarily dismissing the Delaware Action with prejudice and with each side to bear its own costs. III. THE TERMS OF THE PROPOSED SETTLEMENT The following is a summary of the terms of the proposed Settlement as set forth in the Stipulation A. Definitions The following terms have the meanings specified below 1. Current AMC Shareholders means Persons that are record owners and/or beneficial owners of AMC common stock as of May 6, 2003 and who continue to hold their AMC common stock as of the date of the Final Hearing. 2

3 2. Defendants means the Individual Defendants and nominal defendant AMC. 3. Derivative Settlement Counsel means Schiffrin & Barroway, LLP, Robert B. Weiser, Three Bala Plaza East, Suite 400, Bala Cynwyd, PA Effective Date means two (2) business days after the date on which the Final Judgment and Order becomes final in that it is no longer subject to further appeal or reargument, either because (a) the time for an appeal or reargument has expired with no appeal being taken or reargument being sought; or (b) an appeal has been taken or reargument has been sought but has been dismissed with no further right of appeal or reargument; or (c) the Final Judgment and Order has been finally affirmed with no further right of appeal or reargument, or it has otherwise become final. 5. Judgment or Final Judgment and Order means the Final Judgment and Order substantially in the form attached as Exhibit D to the Stipulation. 6. Person means an individual, corporation, limited liability corporation, professional corporation, limited liability partnership, partnership, limited partnership, association, joint stock company, estate, legal representative, trust, unincorporated association, government or any political subdivision or agency thereof and any business or legal entity and their spouses, heirs, predecessors, successors, representatives, or assignees. 7. Released Parties means any of the Defendants, their present and former affiliates, associates, officers, directors, agents, employees, attorneys, stockholders, insurers, advisors, investment bankers, investment advisors, appraisers, accountants, consultants, underwriters, brokers, dealers, commercial bankers, representatives, trustees, parents, subsidiaries, general and limited partners, heirs, executors, administrators, successors and assigns, whether or not served with process and whether or not such person(s) appeared in the Missouri Action or the Delaware Action. 8. Releasing Parties means any of (a) the Representative Plaintiffs, their employees, agents, representatives, general partners, limited partners, attorneys, advisors, accountants, trustees, financial advisors, lenders, investment bankers, associates, heirs, executors, personal representatives, estates, administrators, insurers, successors or assigns, either acting on its own behalf or on behalf of AMC and (b) AMC. 9. Representative Plaintiffs means any plaintiff that has entered an appearance in the Missouri Action or the Delaware Action. 10. Representative Plaintiffs Counsel means counsel who have appeared for any of the Representative Plaintiffs. 11. Settled Claims means any and all past, present or future losses, causes of action, suits, demands, costs, expenses, matters or issues, known or unknown, contingent or absolute, accrued or unaccrued, apparent or unapparent, that have been or could have been asserted in either the Missouri Action or the Delaware Action (including Unknown Claims, as defined below), which have arisen from any of the acts, facts, transactions, occurrences, representations or omissions set forth, alleged or otherwise asserted in the Missouri Action or the Delaware Action. 12. Senior Executive Officers means officers who hold the following positions at AMC (i) Chief Executive Officer; (ii) President and Chief Operating Officer; (iii) Executive Vice-President and Chairman, AMC Film; (iv) Senior Vice-President, Chief Financial Officer and Secretary; (v) Executive Vice-President, North America Operations; and (vi) President, AMC Film. 13. Settling Parties means, collectively, each of the Defendants and the Representative Plaintiffs on their own behalf and/or derivatively on behalf of AMC. 14. Unknown Claims means any Settled Claims which the Releasing Parties do not know or suspect to exist in their favor at the time of the release of the Released Parties which, if known by them, might have affected their settlement with and release of the Released Parties or might have affected their decision not to object to this Settlement. With respect to any and all Settled Claims, the Releasing Parties stipulate and agree that, upon the Effective Date, the Releasing Parties shall be deemed to have, and by operation of the Judgment shall have, expressly waived, the provisions, rights and benefits of California Civil 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. The Releasing Parties expressly waive, and by operation of the Judgment shall have expressly waived, any and all provisions, rights and benefits conferred by any law of any state or territory of the United States, or principle of common law, which is similar, comparable or equivalent to California Civil Code 1542, notwithstanding that the Settling Parties do not concede that any law, other than the law of the State of Missouri or Delaware, is potentially applicable to the Settlement of the Settled Claims. The Releasing Parties may hereafter discover facts in addition to or different from those which they now know or believe to be true with respect to the subject matter of the Settled Claims, but the Releasing Parties, upon the Effective Date, shall be deemed to have, and by operation of the Judgment shall have, fully, finally, and forever settled and released any and all Settled Claims, known or unknown, suspected or unsuspected, contingent or non-contingent, whether or not concealed or hidden, which now exist, or heretofore have existed upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a breach of any duty, law or rule, without regard to the subsequent discovery or existence of such different or additional facts. The foregoing waiver was separately bargained for and is a key element of the Settlement of which this release is a part. B. Terms of The Settlement 1. As promptly as practicable following the Effective Date (as defined below), the Compensation Committee of the AMC Board of Directors (the Compensation Committee ) shall adopt its first committee charter (the Charter ) containing the following a. Composition i. nomination/election process procedures to review and consider recommendations for membership, including issues of tenure and rotation 3

4 b. Meetings and Procedures i. procedures for calling meeting/quorum requirements i iv. formation of sub-committees reporting to full Board with respect to Compensation Committee meetings rules regarding minimum number of meetings in executive session (minimum of two (2) executive session meetings per year) v. set annual compensation calendar to make clear the issues to be considered at Compensation Committee meetings c. Responsibilities i. review goals and objectives of (and oversee generally) Company s executive compensation plans; recommend revisions to goals and objectives and/or to terms of plans i iv. evaluate annually the performance of Chief Executive Officer and other Senior Executive Officers as the Compensation Committee may determine in light of goals and objectives of executive compensation plans and determine compensation based on this evaluation review and approve employment/severance arrangements and perquisites/other personal benefits for Senior Executive Officers evaluate appropriate level (and form) of compensation of non-employee directors for service on Board and committees v. produce annual report on executive compensation for inclusion in proxy statement as required by SEC rules vi. review annually the composition of the peer group and other market data and provide generalized disclosure for inclusion in the proxy statement concerning the industries from which the peer group is drawn. d. Outside Advisors i. in furtherance of its responsibilities, the Compensation Committee shall have the authority to retain an outside consultant (reporting solely to the Compensation Committee and independent of any consultant AMC may be using) determine scope of consultant s role e. Amendments a. advising Compensation Committee as to overall compensation philosophy b. gathering peer group and other market data to aid in setting compensation levels for Senior Executive Officers and non-employee directors c. recommending appropriate revisions to the Charter and/or procedures to remain up-to-date with best practices. i. Charter may be amended from time to time as Compensation Committee may determine. 2. As promptly as practicable following the Effective Date, AMC, Brown and Singleton shall enter into amendments of the Loan Forgiveness Agreements, in the forms attached to the Stipulation as Exhibits A-1 (as to Brown) and A-2 (as to Singleton), which shall amend paragraph 2 of the Loan Forgiveness Agreements to extend the period during which Messrs. Brown and Singleton are required to retain the shares of AMC they acquired with the proceeds of loans that were forgiven on May 13, 2002 from eighteen (18) months from June 6, 2002, to twenty-one (21) months from June 6, Following the Effective Date, the Compensation Committee shall retain a compensation consultant to assist the Compensation Committee with respect to compensation decisions for Senior Executive Officers for fiscal year IV. SETTLEMENT HEARING AND APPROVAL 1. On June 24, 2003, at 1100 a.m. central daylight time, the Court will hold a Final Hearing to approve the Settlement on the terms set forth above and in the Stipulation. If the Court approves the Settlement and enters the Judgment (substantially in the form attached to the Stipulation as Exhibit D) at the Final Hearing, all Settled Claims (including Unknown Claims) relating to the Releasing Parties and/or Released Parties will be compromised, settled, released, discharged and dismissed with prejudice. 2. Additionally, at the Final Hearing, Representative Plaintiffs Counsel will request that the Court approve their proposed Fees and Expenses as defined below. 3. Within two (2) days following the Effective Date, counsel for plaintiff in the Delaware Action shall file a notice with the Court of Chancery of the State of Delaware in and for New Castle County voluntarily dismissing the Delaware Action with prejudice and with each side to bear its own costs. 4

5 V. REPRESENTATIVE PLAINTIFFS ATTORNEYS FEES AND REIMBURSEMENT OF EXPENSES 1. Representative Plaintiffs Counsel in the Actions will apply to the Court for an award of reasonable attorneys fees and expenses not to exceed in the aggregate four hundred and fifty thousand dollars ($450,000) (the Fees and Expenses ). Defendants in the Actions will not oppose such application for Fees and Expenses filed in accordance with this Paragraph. Any such Fees and Expenses as are awarded by the Court to counsel for the Representative Plaintiffs shall be paid solely by the insurer to the Individual Defendants. None of the Defendants or any other Released Parties shall be responsible for, or bear any expenses, costs, fees or payments of, any attorneys fees or expenses awarded by the Court to Representative Plaintiffs Counsel. Payment of the Fees and Expenses shall be made by the insurer to the Individual Defendants to Derivative Settlement Counsel within five (5) business days after the later of the Effective Date or the entry of the Court s order awarding such fees and expenses and the final resolution of any appeals thereon. The Fees and Expenses include fees and expenses incurred by Representative Plaintiffs Counsel in connection with the prosecution and Settlement of the Actions. Derivative Settlement Counsel shall thereafter allocate the attorneys fees amongst Representative Plaintiffs Counsel in a manner in which it in good faith believe reflects the contributions of such counsel to the prosecution and settlement of the Actions. Each such Representative Plaintiffs Counsel s law firm, as a condition of receiving such Fees and Expenses, on behalf of itself and each partner and/or shareholder of it, agrees that the law firm and its partners and/or shareholders are subject to the jurisdiction of the Court for the purpose of enforcing the provisions of this paragraph. 2. The procedure for and the allowance or disallowance by the Court of any applications by any of the counsel to the Representative Plaintiffs for the Fees and Expenses are not part of the settlement set forth in the Stipulation, and are to be considered by the Court separately from the Court s consideration of the fairness, reasonableness and adequacy of the Settlement set forth in the Stipulation, and any order or proceeding relating to the Fees and Expenses, or any appeal from any order relating thereto or reversal or modification thereof, shall not operate to terminate or cancel the Stipulation, or affect or delay the finality of the Judgment approving the Stipulation and the Settlement of the Missouri Action. Notwithstanding anything in this Stipulation to the contrary, the effectiveness of the release of the Settled Claims and other obligations of the Settling Parties under the Settlement (except with respect to the payment of Fees and Expenses) shall not be conditioned upon or subject to (i) the Court s approval of Representative Plaintiffs Counsels application for Fees and Expenses; or (ii) the resolution of any appeal from the Court s entry of an Order that relates solely to the issue of Representative Plaintiffs Counsels application for an award of Fees and/or Expenses. 3. Defendants and the Released Parties shall have no responsibility for, and no liability whatsoever with respect to, the allocation among Representative Plaintiffs Counsel, and/or any other person who may assert some claim thereto, of any of the Fees and Expenses that the Court may award in the Actions. VI. CONDITIONS OF SETTLEMENT; EFFECT OF DISAPPROVAL, CANCELLATION OR TERMINATION 1. In the event the Court (a) does not approve the Settlement; or (b) does not approve the Stipulation in accordance with the terms agreed upon (unless any changes to the Stipulation are previously agreed upon by the parties); or (c) does not enter the Final Judgment and Order in the form attached to the Stipulation as Exhibit D (unless any changes to the Final Judgment and Order are previously agreed upon by the parties hereto); or (d) if the Court approves the Settlement and an appeal is taken therefrom and, on appeal, the Judgment is reversed in whole or in part, then the Stipulation and the Settlement shall become null and void for all purposes (except as otherwise provided in Section V.2 of the Stipulation and this Section VI), and all negotiations, transactions and proceedings connected with it shall be (i) without prejudice to the rights of any party to assert any claim or defense in the Actions; (ii) without prejudice to the rights of any party; (iii) shall not be deemed or construed as evidence or an admission by any party of any fact, matter, or thing; and (iv) shall not be admissible in evidence or used in any subsequent proceedings in either of the Actions, or any other action or proceeding. 2. In the event that the Stipulation is not approved by the Court or the Settlement set forth in the Stipulation is terminated or fails to become effective in accordance with its terms, the Settling Parties shall be restored to their respective positions in the Actions as of April 25, In such event, and except as otherwise provided in the Stipulation, the terms and provisions of the Stipulation shall have no further force and effect with respect to the Settling Parties and shall not be used in the Actions or in any other proceeding for any purpose, and any Judgment or order entered by the Court in accordance with the terms of the Stipulation shall be treated as vacated, nunc pro tunc. No order of the Court or modification or reversal on appeal of any order of the Court concerning the amount of the Fees and Expenses awarded by the Court to the Representative Plaintiffs Counsel shall constitute grounds for cancellation or termination of the Stipulation. VII. YOUR RIGHT TO BE HEARD AT THE HEARING 1. Any Current AMC Shareholder who objects to (i) the Settlement or any of the terms therein, (ii) the dismissal of the Actions, (iii) the Judgment to be entered approving the Settlement, or (iv) the application by Representative Plaintiffs Counsel for Fees and Expenses, or who otherwise wishes to be heard, may appear in person or through counsel at the Final Hearing and present evidence or argument that may be proper and relevant; provided, however, that no person other than counsel for the Representative Plaintiffs and the Defendants shall be heard and no papers, briefs, pleadings or other documents submitted by any such person shall be received and considered by the Court (unless the Court in its discretion shall thereafter otherwise direct, upon application of such person and for good cause shown), unless not later than ten (10) business days prior to the Final Hearing such person files with the Court (i) a written notice of intention to appear, (ii) competent evidence that such person is a Current AMC Shareholder, (iii) a statement of such person s objections to any matters before the Court, and (iii) the grounds therefor or the reasons for such person s desiring to appear and be heard, as well as all documents or writings such person desires the Court to consider, and, on or before the date of such filing, serves the same documents upon the following counsel of record (a) Robert B. Weiser, Esq. SCHIFFRIN & BARROWAY, LLP Three Bala Plaza East, Suite 400 Bala Cynwyd, PA Tel (610) Fax (610) (b) Jay B. Kasner, Esq. SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Four Times Square New York, NY Tel (212) Fax (212)

6 2. In order to object to the Settlement, the notice of objection must demonstrate the Person s standing as a Current AMC Shareholder, i.e., that the Person held AMC common stock as of May 6, 2003, and that the Person continues to hold AMC common stock as of the date of the Final Hearing. 3. Unless the Court otherwise directs, no Person shall be entitled to object to the approval of the Settlement, to any Judgment entered thereon, to any award of Fees and Expenses, or to otherwise to be heard, except by serving and filing a written objection and supporting papers and documents as prescribed in Paragraph 1, above. Any Person who fails to object in the manner and within the time prescribed in Paragraph 1 above, shall be deemed to have waived the right to object (including the right to appeal) and forever shall be barred, in this proceeding or in any other proceeding, from raising such objection. 4. Pending final determination of whether the Court should approve the proposed Settlement, the Court has stayed all proceedings in the Missouri Action, other than proceedings as may be necessary to carry out the terms and conditions of the Settlement. However, such stay will be vacated if the Settlement is terminated as provided in Section VII of the Stipulation. 5. Pending final determination of whether the Court should approve the Settlement, the Representative Plaintiffs and all Current AMC Shareholders are barred and enjoined from commencing or prosecuting any action concerning the Settled Claims as defined in the Stipulation or any claims arising out of the facts alleged in the Missouri Action. However, nothing herein shall be construed to prevent the plaintiff in the Delaware Action from taking steps to extend the stay of the Delaware Action or otherwise to carry out the terms of the Settlement reflected in the Stipulation. VIII. REQUEST TO BROKERS AND OTHER NOMINEES Brokerage firms, banks and other persons or entities who are record holders of shares of AMC s common stock as of May 6, 2003, but do not hold that stock as beneficial owners, should send this Notice promptly to the beneficial owners. Additional copies of this Notice can be requested from The Garden City Group, Inc., Attn AMC Entertainment Inc. Shareholders Derivative Litigation, P.O. Box 9000 #6110, Merrick, NY , Tel (888) IX. SCOPE OF THIS NOTICE The foregoing description of the Actions, the Final Hearing, the proceedings to be held, the activities leading to the Settlement, the terms of the Settlement, the conditions of Settlement, the effect of disapproval, cancellation or termination of the Settlement, and other matters described herein do not purport to be all inclusive. Accordingly, you are referred to the Second Consolidated Petition and the Stipulation, filed with the Clerk of the Court, which may be examined during regular business hours at the offices of the Clerk of the Court at the Circuit Court of Jackson County, Division 8, 415 East 12th Street, Kansas City, Missouri. QUESTIONS REGARDING THE PROPOSED SETTLEMENT Please do not call or write the Court about the proposed Settlement. Questions may be directed to Robert B. Weiser Schiffrin & Barroway, LLP Three Bala Plaza East, Suite 400 Bala Cynwyd, PA (610) Dated May 6,