IN RE STELLANTIS N.V. SECURITIES LITIGATION
Panitza Fiat Chrysler Securities Litigation
Case No. 19-CV-6770 (EK) (MMH)

Frequently Asked Questions

 

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  • You or someone in your family or an investment account for which you serve as a custodian may have purchased or otherwise acquired FCA and/or STLA common stock on a U.S. Exchange or in a transaction in the United States during the Class Period and may be a Settlement Class Member. This Internet Notice explains the Action, the Settlement, the Settlement Class Members’ legal rights, what benefits are available, who is eligible for them, and how to get them.  Receipt of the Notice does not mean that you are a member of the Settlement Class or that you will be entitled to receive a payment. If you wish to be eligible for a payment, you are required to submit the Claim Form.  See Question 8 in the Notice.

    The purpose of the Notice is to inform you of the existence of this case, that it is a class action, how you might be affected, and how to exclude yourself from the Class, if you wish to do so.  It is also being posted to inform you of the terms of the proposed Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation, and Lead Counsel’s application for an award of attorneys’ fees and reimbursement of Litigation Expenses (“Settlement Fairness Hearing”).  See ¶ 54 in the Notice for details about the Settlement Fairness Hearing, including the date and location of the hearing. 

    The Court in charge of the Action is the United States District Court for the Eastern District of New York, and the case is known as In re Stellantis N.V. Securities Litigation, Case No. 1:19 cv 06770 (EK) (MMS) (previously captioned In re Fiat Chrysler Automobiles N.V. Securities Litigation).  The Action is assigned to the Honorable Eric R. Komitee, United States District Judge.  The issuance of the Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action, and the Court still has to decide whether to approve the Settlement.  If the Court approves the Settlement and a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing.  Please be patient, as this process can take some time.

  • FCA, or the “Company,” traded on the New York Stock Exchange (“NYSE”) under the symbol “FCAU” from the beginning of the Class Period (February 26, 2016) through January 17, 2021, when the Company formally changed its name to Stellantis N.V. following a merger with Peugeot S.A. Since January 17, 2021, the Company’s shares have traded under the symbol “STLA.”

    Lead Plaintiff alleges that the Defendants made false and misleading statements to investors during the Class Period.  Specifically, Lead Plaintiff alleges that Defendants made false and misleading statements in violation of the Securities Exchange Act of 1934 (“Exchange Act”) regarding (i) the existence and scope of a bribery scheme involving the National Training Center and certain members of the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (the “UAW”); and (ii) the effects the scheme had on the 2015 Collective Bargaining Agreement an FCA affiliate, FCA US LLC (“FCA US”), negotiated with the UAW.

    On December 2, 2019, Jung Kyoon Kong filed a class action complaint in the United States District Court for the Eastern District of New York (the “Court”) styled Kong v. Fiat Chrysler Automobiles N.V., et al.

    On January 13, 2020, Jennifer H. Tan filed another class action complaint in the Court alleging violations of the federal securities laws, styled Tan v. Fiat Chrysler Automobiles N.V., et al.

    On January 31, 2020, Lead Plaintiff moved for consolidation of the actions and for the appointment of lead plaintiff for the class.  On March 10, 2020, after full briefing on the motions, the Court appointed Nicholas S. Panitza as Lead Plaintiff and approved Lead Plaintiff’s selection of Bernstein Liebhard LLP as Lead Counsel for the proposed class.

    On June 1, 2020, Lead Plaintiff filed and served the First Amended Class Action Complaint for Violations of the Federal Securities Laws (the “First Amended Complaint”), alleging violations of the Exchange Act against Defendants.

    On August 21, 2020, Defendants filed a joint Motion to Dismiss the First Amended Complaint.

    On October 21, 2020, Lead Plaintiff filed his Opposition to Defendants’ Motion to Dismiss the First Amended Complaint.

    On December 14, 2020, Defendants filed their Reply in Support of their Motion to Dismiss the First Amended Complaint.

    In December 2020, after Defendants’ motion to dismiss was fully briefed, the Parties agreed to explore the possibility of a settlement.  As part of those discussions, and for settlement purposes only, Defendants provided Lead Counsel with hundreds of pages of documents and other information Lead Counsel requested regarding the criminal investigation of FCA US by the U.S. Department of Justice (“DOJ”).

    On January 27, 2021, FCA US pled guilty to one count of conspiracy to violate the Labor Management Relations Act, 18 U.S.C. § 371, and 29 U.S.C. §§ 186(a)(2) and (d)(1).  The terms of the Plea Agreement included, among other things, a $30 million fine and a three-year monitorship.

    On January 28, 2021, Lead Plaintiff filed the Second Amended Class Action Complaint for Violation of the Federal Securities Laws (the “Second Amended Complaint”) against Defendants.

    During the weeks that followed, the Parties continued to engage in Settlement negotiations and ultimately reached agreement on a settlement releasing all claims against Defendants in return for a cash payment of five million dollars ($5,000,000) for the benefit of the Settlement Class.

    On October 15, 2021, the Court preliminarily approved the Settlement, authorized the Notice to be disseminated to potential Settlement Class Members, and scheduled the Settlement Fairness Hearing to consider whether to grant final approval to the Settlement.

  • Lead Plaintiff and Lead Counsel believe that the claims asserted against Defendants have merit; however, they also recognize the substantial risks in continuing to litigate the Action.  For example, Defendants have raised a number of arguments and defenses, including that Defendants made no misrepresentations and that Lead Plaintiff would not be able to establish that Defendants acted with the requisite intent.  Even assuming that Lead Plaintiff could establish Defendants’ liability, the amount of damages that could be attributed to the allegedly false statements would be contested.  Additionally, Lead Plaintiff and Lead Counsel recognize the significant expense and length of continued proceedings necessary to pursue their claims against Defendants through further motion practice, trial, and appeals.  Thus, there were very significant risks attendant to the continued prosecution of the Action.

    In light of these risks, the amount of the Settlement, and the immediacy of recovery to the Settlement Class, Lead Plaintiff and Lead Counsel believe that the proposed Settlement is fair, reasonable, and adequate, and in the best interests of the Settlement Class.  Lead Plaintiff and Lead Counsel believe that the Settlement provides a favorable result for the Settlement Class, namely $5 million in cash (less the various deductions described in the Notice), as compared to the risk that the claims in the Action would produce a smaller, or no recovery after the pending motion to dismiss was decided or after summary judgment, trial and appeals, possibly years in the future.

    Defendants have denied the claims asserted against them in the Action and deny having engaged in any wrongdoing or violation of law of any kind whatsoever.  Defendants have agreed to the Settlement to eliminate the burden and expense of continued litigation, and the Settlement may not be construed as an admission of any wrongdoing by Defendants in this or any other action or proceeding.

  • If there were no Settlement and Lead Plaintiff fails to establish any essential legal and factual element of his claims against Defendants, neither Lead Plaintiff nor the other members of the Settlement Class would recover anything from Defendants.  Also, if Defendants were successful in proving any of their defenses in connection with their current motion to dismiss, or in the future at summary judgment, at trial, or on appeal, the Settlement Class could recover substantially less than the amount provided in the Settlement, or nothing at all.

  • This Action is a class action.  In a class action, one or more persons or entities (in this case, Lead Plaintiff) sue on behalf of people and entities who or which have similar claims. Together, these people and entities are a “class,” and each is a “class member.”  Bringing a case, such as this one, as a class action allows the adjudication of many similar claims of persons and entities which might be too small to bring economically as separate actions.  One court resolves the issues for all class members at the same time, except for those who exclude themselves, or “opt out” from the class.

    The Court directed, for the purposes of the proposed Settlement, that everyone who fits the following description is a Settlement Class Member and subject to the Settlement unless they are an excluded person (see Question 6 in the Notice) or take steps to exclude themselves from the Settlement Class (see Question 11 in the Notice):  all persons and entities who purchased or otherwise acquired, on a U.S. Exchange or in a transaction in the United States, FCA and/or STLA common stock between February 26, 2016 and January 27, 2021, both dates inclusive.

    Receipt of the Notice does not mean that you are a Settlement Class Member.  The Parties do not have access to your transactions in FCA and/or STLA common stock.  Please check your records or contact your broker to see if you are a member of the Settlement Class.  If one of your mutual funds purchased FCA and/or STLA common stock during the Class Period, that alone does not make you a Settlement Class Member.  You are a Settlement Class Member only if you individually purchased FCA and/or STLA common stock during the Class Period on a U.S. Exchange or in a transaction in the United States.

  • Yes.  There are some individuals and entities who or which are excluded from the Settlement Class by definition.  Excluded from the Settlement Class are: (i) Defendants; (ii) current and former officers and directors of FCA and their immediate families; (iii) legal representatives, heirs, successors or assigns of such excluded Person or entity; and (iv) any entity in which Defendants have or had a controlling interest.

    If you sold all of your FCA common stock prior to the first alleged disclosure, which occurred on November 20, 2019, and made no subsequent purchases from November 20, 2019 through January 27, 2021, you are not a member of the Settlement Class because you were not damaged.

    Also excluded from the Settlement Class are any persons and entities who or which exclude themselves by submitting a request for exclusion that is accepted by the Court.  See “How do I exclude myself from the Settlement Class,” described in Question 11 in the Notice.

  • In exchange for the Settlement and release of the Released Plaintiffs’ Claims, FCA has agreed to create a $5,000,000 cash fund, which may accrue interest, to be distributed, after deduction of Court-awarded attorneys’ fees and litigation expenses, Notice and Administration expenses, Taxes, and any other fees or expenses approved by the Court (the “Net Settlement Fund”), among all Settlement Class Members who submit valid Claim Forms and are found to be eligible to receive a distribution from the Net Settlement Fund (“Authorized Claimants”).

  • To qualify for a payment, you must submit a Claim Form online on the File a Claim page of this website and upload your supporting documentation for all of your transactions.   The deadline to submit your Claim through the Case Website is 11:59 P.M. PST, February 13, 2022.

    If you are unable to fill out a Claim Form online, please print the Claim Form entitled “Proof of Claim and Release Form” (also called the “Claim Form”) available on the Important Documents page of this website, fill it out and mail it to the Claims Administrator at the address below, postmarked no later than February 13, 2022:

    Panitza Fiat Chrysler Securities Litigation
    c/o JND Legal Administration
    P.O. Box 91396
    Seattle, WA 98111

    Please note that if you choose to print and mail a form, you will need to manually enter each transaction. Please retain all records of your ownership of and transactions in FCA and/or STLA common stock, as they may be needed to document your Claim.

    Typically, most class members submit electronic claims. Submitting a claim by mail increases the time necessary to process the Claim. You can contact your broker or nominee directly and use their portal to download your transactions which can be saved as a cvs or xls file.  In this case you can contact us at info@PanitzaFiatChryslerSecLitigation.com in order to set up a secure FTP site to submit your data.

    The Claims Administrator will process your claim and determine whether you are an “Authorized Claimant.”

  • The Court will hold a Settlement Fairness Hearing on February 17, 2022 to decide, among other things, whether to finally approve the Settlement.  Even if the Court approves the Settlement, there may be appeals which can take time to resolve, perhaps more than a year.  It also takes a long time for all of the Claim Forms to be accurately reviewed and processed.  Please be patient.

  • If you are a member of the Settlement Class, unless you exclude yourself, you will remain in the class, and that means that, upon the “Effective Date” of the Settlement, you will release all “Released Plaintiffs’ Claims” against the Defendants’ Releasees.

        “Released Plaintiffs’ Claims” means any and all claims, rights, duties, controversies, obligations, demands, actions, debts, sums of money, suits, contracts, agreements, promises, damages, losses, judgments, liabilities, allegations, arguments and causes of action of every nature and description, whether known claims or Unknown Claims, whether arising under federal, state, local, common, statutory, administrative or foreign law, or any other law, rule or regulation, at law or in equity, whether class or individual in nature, whether fixed or contingent, whether accrued or unaccrued, whether liquidated or unliquidated, whether matured or unmatured, that Lead Plaintiff or any other member of the Settlement Class (i) asserted in the Action, or (ii) could have asserted in any court or forum that arise out of or relate in any way to the allegations, transactions, facts, matters or occurrences, representations or omissions asserted in the Action and that relate to the purchase, acquisition or ownership of shares of FCA or STLA common stock on (and for ownership, shares resulting from a purchase or acquisition on) the New York Stock Exchange or any other securities exchange located in the United States (“U.S. Exchange”) or otherwise in a transaction in the United States, during the Class Period, including claims relating to FCA US’s guilty plea.  “Released Plaintiffs’ Claims” does not include (i) any claims relating to the enforcement of the Settlement, or (ii) any claims of any person or entity who or which submits a request for exclusion from the Settlement that is accepted by the Court (the “Excluded Plaintiffs’ Claims”).  For the avoidance of doubt, this release is not a general release of any and all claims, including those unrelated to the allegations, transactions, facts, matters or occurrences, representations or omissions asserted in the Action.  

        “Defendants’ Releasees” means Defendants, together with their past, present or future affiliates (including FCA US), divisions, joint ventures, assigns, assignees, direct or indirect parents or subsidiaries, controlling shareholders, successors, predecessors and entities in which a Defendant has a controlling interest, and each of their past, present, or future officers, directors, agents, employees, partners, members, attorneys, controlling shareholders, advisors, investment advisors, auditors, accountants, insurers (including reinsurers and co-insurers) and Immediate Family members, and the legal representatives, heirs, trusts, trustees, executors, estates, administrators, beneficiaries, successors in interest or assigns of any of the foregoing.  For the avoidance of doubt, Defendants’ Releasees expressly includes Sergio Marchionne, the Estate of Sergio Marchionne, and Roland Iseli and Alessandro Baldi as Co-Executors of the Estate of Sergio Marchionne.

         “Unknown Claims” means any Released Plaintiffs’ Claims that Lead Plaintiff or any other Settlement Class Member does not know or suspect to exist in his, her or its favor at the time of the release of such claims, and any Released Defendants’ Claims which any Defendant does not know or suspect to exist in his or its favor at the time of the release of such claims.  With respect to any and all Released Claims, the Parties stipulate and agree that, upon the Effective Date of the Settlement, Lead Plaintiff and Defendants shall expressly waive, and each of the Settlement Class Members shall be deemed to have, and by operation of the Judgment or the Alternative Judgment, if applicable, shall have, expressly waived, the provisions, rights, and benefits conferred by any law of any state or territory of the United States, or principle of common law or foreign law, which is similar, comparable, or equivalent to California Civil Code § 1542, which provides: “A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.”  The Parties acknowledge that they may hereafter discover facts in addition to or different from those which he or it or their counsel now knows or believes to be true with respect to the subject matter of the Released Claims, but, upon the Effective Date, Lead Plaintiff and Defendants shall expressly settle and release, and each of the other Settlement Class Members shall be deemed to have, and by operation of the Judgment or the Alternative Judgment, if applicable, shall have, settled and released, any and all Released Claims without regard to the subsequent discovery or existence of such different or additional facts.  Lead Plaintiff and Defendants acknowledge, and each of the other Settlement Class Members shall be deemed by operation of the Judgment or the Alternative Judgment, if applicable, to have acknowledged, that the foregoing waiver was separately bargained for and is a key element of the Settlement of which this release is a part.

    The “Effective Date” will occur when an Order entered by the Court approving the Settlement becomes Final and is not subject to appeal or further appeal. If you remain a member of the Settlement Class, all of the Court’s order, whether favorable or unfavorable, will apply to you and legally bind you.  Upon the Effective Date, FCA will also provide a release of any claims against Lead Plaintiff and the Settlement Class arising out of or related to the institution, prosecution, or settlement of the claims in the Action.

  • If you do not want to be eligible to receive a payment from the Settlement, but you want to keep any right you may have to sue or continue to sue the Defendants’ Releasees on your own for the Released Plaintiffs’ Claims, then you must take steps to remove yourself from the Settlement Class.  This is called excluding yourself or “opting out.”  Please note: If you bring your own claims, Defendants will have the right to seek their dismissal.  Also, Defendants may terminate the Settlement if Settlement Class Members who purchased in excess of a certain amount of shares of FCA and/or STLA common stock seek exclusion from the Settlement Class.

  • To exclude yourself from the Settlement Class, you must mail a signed letter stating that you “request to be excluded from the Settlement Class in In re Stellantis N.V. Securities Litigation, Case No.1: 19-CV-06770 (EK) (MMS).”  You cannot exclude yourself by telephone or e-mail.  Each request for exclusion must also: (i) state the name, address, and telephone number of the person or entity requesting exclusion, and in the case of entities, the name and telephone number of the appropriate contact person; (ii) state the number of shares of FCA and/or STLA common stock that the person or entity requesting exclusion (A) owned as of the opening of trading on February 26, 2016; (B) purchased/acquired on a U.S. Exchange or otherwise in the United States between February 26, 2016 and January 27, 2021, as well as the dates and prices of each such purchase; (C) sold between February 26, 2016 and January 27, 2021, as well as the dates, number of shares, and prices of each such sale; and (iii) be signed by the person or entity requesting exclusion or an authorized representative.  A request for exclusion must be mailed, so that it is received no later than January 27, 2022 to:

    Panitza Fiat Chrysler Securities Litigation
    c/o JND Legal Administration
    P.O. Box 91396
    Seattle, WA 98111

    Your exclusion request must comply with these requirements in order to be valid.

    If you ask to be excluded, do not submit a Claim Form because you cannot receive any payment from the Net Settlement Fund. Also, you cannot object to the Settlement because you will not be a Settlement Class Member. However, if you submit a valid exclusion request, you will not be legally bound by anything that happens in the Action, and you may be able to sue (or continue to sue) Defendants in the future. Please note, however, if you decide to exclude yourself from the Class, you may be time-barred from asserting the claims covered by the Action. In addition, Defendants will have the right to assert any and all defenses they may have to any claims that you may seek to assert. If you have a pending lawsuit against any of the Defendants, please speak to your lawyer in the case immediately.

  • The Court appointed the law firm of Bernstein Liebhard LLP to represent all Settlement Class Members.  These lawyers are called “Lead Counsel.”  You will not be separately charged for these lawyers.  The Court will determine the amount of Lead Counsel’s fees and expenses, which will be paid from the Settlement Fund.  If you want to be represented by your own lawyer, you may hire one at your own expense.

  • Lead Counsel has not received any payment for its services in pursuing claims against the Defendants on behalf of the Settlement Class, nor has Lead Counsel been reimbursed for its out of pocket expenses.  Before final approval of the Settlement, Lead Counsel will apply to the Court for an award of attorneys’ fees in an amount not to exceed 33 1/3% of the Settlement Fund, which will include any accrued interest.  Lead Counsel also intend to apply for reimbursement of Litigation Expenses in an amount not to exceed $100,000, which amount will include an application for reimbursement of the reasonable costs and expenses incurred by Lead Plaintiff directly related to the representation of the Settlement Class in accordance with 15 U.S.C. § 78u-4(a)(4).  The Court will determine the amount of any award of attorneys’ fees and reimbursement of Litigation Expenses.  Such sums as may be approved by the Court will be paid from the Settlement Fund.  Settlement Class Members are not personally liable for any such fees or expenses.

  • If you are a Settlement Class Member, you can object to the Settlement or any of its terms, the proposed Plan of Allocation, and/or the Fee and Expense Application.  You can ask the Court not to approve the Settlement, but you cannot ask the Court to order a different Settlement; the Court can only approve or deny this Settlement.  If the Court denies approval of the Settlement, no payments will be made to Settlement Class Members, the Parties will return to the position they were in before the Settlement was agreed to, and the Action will continue.

    To object, you must send a signed letter stating that you object to the proposed Settlement, the proposed Plan of Allocation, and/or the Fee and Expense Application in In re Stellantis N.V. Securities Litigation, Case No. 1:19-CV-06770 (EK) (MMS).  Your objection must state why you are objecting and whether your objection applies only to you, a subset of the Settlement Class, or the entire Settlement Class.  The objection must also: (i) state the name, address, and telephone number of the person or entity objecting and be signed by the objector; (ii) state whether the objector is represented by counsel and, if so, the name address, and the telephone number of the objector’s counsel; (iii) contain a statement of the objection and the specific reasons for it, including any legal and evidentiary support (including witnesses) the Settlement Class Member wishes to bring to the Court’s attention; and (iv) include documentation identifying the number of shares of FCA and/or STLA common stock the person or entity (a) owned as of the opening of trading on February 26, 2016; and (b) purchased and/or sold on a U.S. Exchange or otherwise in the United States during the Class Period, as well as the dates, number of shares, and prices of each such purchase/acquisition and sale.  Unless otherwise ordered by the Court, any Settlement Class Member who does not object in the manner described in the Notice will be deemed to have waived any objection and will be forever foreclosed from making any objection to the proposed Settlement, the Plan of Allocation, and/or Lead Counsel’s Fee and Expenses Application.  Your objection must be filed with the Court at the address below, either by mail or in person, no later than January 27, 2022 and be mailed or delivered to each of the following counsel so that it is received no later than January 27, 2022:

    Court
    Clerk of the Court
    United States District Court
    Eastern District of New York
    225 Cadman Plaza East
    Brooklyn, NY 11201

    Lead Counsel
    Bernstein Liebhard LLP
    Attn: Stephanie M. Beige
    10 East 40th Street.
    New York, NY 10016

    Defendants’ Counsel
    Sullivan & Cromwell LLP
    Attn: William B. Monahan
    125 Broad Street
    New York, NY 10004

  • Objecting is telling the Court that you do not like something about the proposed Settlement, the proposed Plan of Allocation, or Lead Counsel’s Fee and Expenses Application.  You can still recover money from the Settlement. You can object only if you stay in the Settlement Class.  Excluding yourself is telling the Court that you do not want to be part of the Settlement Class.  If you exclude yourself from the Settlement Class, you have no basis to object because the Settlement and the Action no longer affect you.

  • The Court will hold the Settlement Fairness Hearing on February 17, 2022, at 9:30 a.m., in Courtroom 6G N, United States District Court for the Eastern District of New York, 225 Cadman Plaza E., Brooklyn, New York 11201, or as otherwise ordered by the Court.  At this hearing, the Court will consider whether: (i) the Settlement is fair, reasonable, and adequate, and should be finally approved; (ii) the Plan of Allocation is fair and reasonable and should be approved; and (iii) Lead Counsel’s Fee and Expense Application is reasonable and should be approved.  The Court will take into consideration any written objections filed in accordance with the instructions in Question 14 in the Notice.  We do not know how long it will take the Court to make these decisions.

    You should be aware that the Court may change the date and time of the Settlement Fairness Hearing, or hold the hearing telephonically or by video conference, without another notice being sent to Settlement Class Members.  If you want to attend the hearing, you should check with Lead Counsel beforehand to be sure that the date and/or time has not changed, check this website, or periodically check the Court’s website at https://www.nyed.uscourts.gov/judges-info/hearing-dates/court-calendar to see if the Settlement Hearing stays as calendared or is changed. Subscribers to PACER, a fee-based service, can also view the Court’s docket for the Action for updates about the Settlement Hearing through the Court’s online Case Management/Electronic Case Files System at https://pacer.uscourts.gov/.

  • No. Lead Counsel will answer any questions the Court may have.  However, you are welcome to attend at your own expense.  If you submit a valid and timely objection, the Court will consider it and you do not have to come to Court to discuss it.  You may have your own lawyer attend (at your own expense), but it is not required.  If you do hire a lawyer, he or she must file and serve a Notice of Appearance in the manner described in Question 18 in the Notice no later than January 27, 2022.

  • You may ask the Court for permission to speak at the Settlement Hearing. To do so, you must include with your objection (see Question 14 in the Notice), no later than January 27, 2022, a statement that you, or your attorney, intend to appear in In re Stellantis N.V. Securities Litigation, Case No. 1:19 CV-06770 (EK) (MMS).  Persons who intend to present evidence at the Settlement Hearing must also include in their objections the identities of any witnesses they may wish to call to testify and any exhibits they intend to introduce into evidence at the hearing.  You may not speak at the Settlement Hearing if you exclude yourself or if you have not provided written notice in accordance with the procedures described in this Question and Question 14 in the Notice.

  • If you do nothing and you are a member of the Settlement Class, you will receive no money from this Settlement and you will be precluded from starting a lawsuit, continuing a lawsuit, or being part of any other lawsuit against Defendants and the other Defendants’ Releasees concerning the Released Claims.  To share in the Net Settlement Fund, you must submit a Claim Form (see Question 8 in the Notice).  To start, continue, or be part of any other lawsuit against Defendant or any of Defendants’ Releasees concerning the Released Claims in this case, to the extent it is otherwise permissible to do so, you must exclude yourself from the Settlement Class (see Question 11 in the Notice).

  • The Notice summarizes the proposed Settlement.  More details are in the Stipulation.  Lead Counsel’s motions in support of final approval of the Settlement, the request for attorneys’ fees and litigation expenses, and approval of the proposed Plan of Allocation will be filed with the Court no later than January 13, 2022, and will be available from Lead Counsel, the Claims Administrator, or the Court, pursuant to the instructions below.

    You may review the Stipulation or documents filed in the case at the Office of the Clerk, United States District Court for the Eastern District of New York, 225 Cadman Plaza East, Brooklyn, NY 11201 during weekdays (other than court holidays) from 10:00 a.m. through 12:00 p.m. and from 1:00 p.m. to 3:00 p.m. Subscribers to PACER can also view the papers filed publicly in the Action through the Court’s on-line Case Management/Electronic Case Files Systems at https://pacer.uscourts.gov/.

    You can also get a copy of the Stipulation and other case documents by visiting the Important Documents page of this website dedicated to the Settlement, or the website of Lead Counsel, www.bernlieb.com.

  • If you purchased publicly traded FCA and/or STLA common stock on a U.S. Exchange or in a transaction in the United States for the beneficial interest of persons or organizations other than yourself during the Class Period, WITHIN SEVEN (7) DAYS OF YOUR RECEIPT OF THE NOTICE, YOU MUST EITHER (a) provide to the Claims Administrator the name and last known address of each such person or entity; (b) request additional copies of the Postcard Notice from the Claims Administrator, which will be provided to you free of charge, and WITHIN SEVEN (7) DAYS of receipt, mail the Postcard Notice directly to all such persons or entities; or (c) request an electronic copy of the Postcard Notice from the Claims Administrator, and WITHIN SEVEN (7) DAYS of receipt thereof, email the Postcard Notice directly to all purchasers for which email addresses are available.  If they are available, you must also provide the Claims Administer with the e-mails of the beneficial owners.  If you choose to follow procedures (b) or (c), the Court has also directed that, upon making that mailing, YOU MUST SEND A STATEMENT to the Claims Administrator confirming that the mailing was made as directed and keep a record of the names, mailing addresses, and email addresses used.  Upon full and timely compliance with these directions, you may seek reimbursement from the Settlement Fund of your reasonable expenses actually incurred in connection with the foregoing, upon request and submission of appropriate documentation, up to a maximum of $0.05 plus postage at the current pre-sort rate used by the Claims Administrator per Postcard Notice mailed; $0.05 per Postcard Notice emailed; or $0.05 per name, address, and email address provided to the Claims Administrator.  All communications concerning the foregoing should be addressed to the Claims Administrator: 

    Panitza Fiat Chrysler Securities Litigation
    c/o JND Legal Administration
    P.O. Box 91396
    Seattle, WA 98111
    Tel: (833) 916-3600

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Mail
Panitza Fiat Chrysler Securities Litigation
c/o JND Legal Administration
P.O. Box 91396
Seattle, WA 98111