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<br />Direct Purchaser Settlement Class Members who file valid claims will receive their pro rata share of the Net Settlement
<br />Fund based on: (1) the Direct Purchaser Settlement Class Member's eligible purchases of Alum; (2) the total money avail-
<br />able to pay all claims; (3) the total dollar value of all valid claims submitted; and (4) the cost of settlement administration
<br />and notice and the Court -awarded attorneys' fees, expenses and Case Contribution Awards (see Question 16 below). In
<br />other words, the Net Settlement Fund shall be allocated on a pro rata basis based on the total dollar value of each Direct
<br />Purchaser Settlement Class Member's eligible purchase(s) of Alum in proportion to the total dollar value of all valid
<br />claims submitted.
<br />Interim DPP Lead Counsel's proposed plan for distributing the Net Settlement Fund to Direct Purchaser Settlement Class
<br />Members ("Plan of Distribution") will be presented to the Court with its papers in support of final approval of the Settle-
<br />ment. Details about the proposed Plan of Distribution will be available at www.Liq.uidAluminumDirectSettlement.com
<br />starting no later than September 17, 2018.
<br />Important! Direct Purchaser Settlement Class Members who exclude themselves in accordance with Question 13 below
<br />will not be able to share in the distribution from the Net Settlement Fund.
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<br />There is no date certain for making payments from the Settlement Funds. The Net Settlement Fund will be distributed to
<br />eligible Direct Purchaser Settlement Class Members after the Court grants final approval to the Settlement, all claims have
<br />been fully processed by the Settlement Administrator and the Court has authorized distribution of the Net Settlement Fund.
<br />Updates on this process will be made available at www.LiquidAluminumDirectsettlement.com.
<br />Please Note: The Settlement may be terminated on several grounds, including if the Court does not approve or materially
<br />modifies the Settlement. Should the Settlement be terminated, the Settlement Funds less the cost of settlement administra-
<br />tion and notice will be returned to GEO and this Action will proceed against the GEO Settling Parties as if the Settlement
<br />had not been reached. If the Settlement is terminated, there will be no payments made to Direct Purchaser Settlement Class
<br />Members.
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<br />s: ,�� . ` .,,3..,:- ,. .isx,.•a„H.:.- ..s. 2 ' ",x. ro?,-..x,���'" i":. ;M—;01 ' k k, 2` :�. ��
<br />Unless you exclude yourself, you will remain in the Direct Purchaser Settlement Class, and that means that you cannot
<br />sue, continue to sue, or be part of any other lawsuit against the GEO Settling Parties about the legal issues in this case. It
<br />also means that all of the Court's orders will apply to you and legally bind you. As set forth in paragraphs 15 and 16 of the
<br />Settlement Agreement:
<br />• Release: Upon Final Judgment and in consideration of payment of the Settlement Funds into the Direct Purchaser
<br />Escrow Account, and for other valuable consideration, the GEO Released Parties' shall be completely released,
<br />acquitted, and forever discharged from any and all claims, demands, actions, suits, causes of action, whether class,
<br />individual, or otherwise in nature (whether or not any Direct Purchaser Settlement Class Member has objected to
<br />the Settlement or makes a claim upon or participates in the Settlement Funds, whether directly, representatively,
<br />derivatively or in any other capacity) that the Releasing Parties' ever had, now has, or hereafter can, shall, or may
<br />ever have, that exist as of the date of Final Judgment, on account of, or in any way arising out of, any and all known
<br />The "GEO Released Parties" are the GEO Settling Parties, the GEO Settling Parties' heirs or executors, and GEO's current and former, direct and indirect
<br />parents, subsidiaries, affiliates, insurers, directors, officers, shareholders, and employees, other than Alex Avraamides, who shall not be deemed a Party to
<br />or a third -party beneficiary of the Settlement Agreement, and who is in no way released from any claims asserted by Direct Purchasers in the Consolidated
<br />Proceedings. As used in this Paragraph, "affiliates" means entities controlling, controlled by or under common ownership or control with, in whole or in
<br />part, any of the GEO Released Parties.
<br />s "Releasing Party" or "Releasing Parties" refers individually and collectively, to the Direct Purchaser Settlement Class and all Direct Purchaser Settlement
<br />Class Members, including the Direct Purchaser Class Plaintiffs and the Direct Action Direct Purchaser Settlement Class Members, each on behalf of
<br />themselves and their respective predecessors and successors; their current and former, direct and indirect parents, subsidiaries and affiliates; their present
<br />and former shareholders, partners, directors, officers, owners of any kind, principals, members, agents, employees, contractors, attorneys, insurers, heirs,
<br />executors, administrators, devisees, representatives; their assigns of all such persons or entities, as well as any person or entity acting on behalf of or through
<br />any of them in any capacity whatsoever, jointly and severally; and any of their past, present and future agents, officials acting in their official capacities,
<br />legal representatives, agencies, departments, commissions and divisions; and also means, to the full extent of the power of the signatories to the Settlement
<br />Agreement to release past, present and future claims, the following: (1) any Releasing Party's subdivisions (political or otherwise, including, but not limited
<br />to, municipalities, counties, parishes, villages, unincorporated districts and hospital districts), public entities, public instrumentalities and public educa-
<br />tion institutions; and (2) persons or entities acting in a parens patriae, sovereign, quasi -sovereign, private attorney general, qui tam, taxpayer or any other
<br />capacity, whether or not any of them participate in the Settlement. As used in this Paragraph, "affiliates" means entities controlling, controlled by or under
<br />common ownership or control with, in whole or in part, any of the Releasing Parties. 69
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