Volkswagen Diesel Resource Center

 

We know it’s nerve-wracking to figure out what the Volkswagen TDI Class Action Settlements mean to you. At Keller Rohrback’s VW Resource Center, you can find all the information you need about the Settlements, your rights, and how our attorneys can help!

Keller Rohrback L.L.P. has been representing plaintiffs against big corporations like Exxon and Enron for decades. We are committed to ensuring justice is secured for VW drivers in the face of VW’s misdeeds. Keller Rohrback L.L.P. has exceptional environmental and consumer lawyers. We welcome your call at 866.560.4043.


Volkswagen Case Updates

3-Liter “fix” approved for Touareg, Q7, Cayenne SUV

Regulators at the Environmental Protection Agency and California Air Resources Board have approved an emissions repair to over 38,000 cheating 3-Liter Diesel Sport Utility Vehicles. The repair will involve modifications to the computer systems and, in some cases, replacement of certain parts of the emissions system. Volkswagen, Porsche, and Audi will disclose the particulars of the repairs, warranty coverage and scheduling process in late October 2017.

You can read the letter from the regulatory agencies here, and visit www.vwcourtsettlement.com to schedule your fix appointment.

Court Grants Final Approval to 3.0-Liter Class Action Settlement & Bosch Class Action Settlement

On May 17, 2017, Judge Charles M. Breyer granted final approval to the 3.0-Liter Class Action Settlement with Volkswagen valued at $1.2-$4.04 billion, and also granted final approval to a $327.5 million settlement with Bosch (pls link to Bosch order), the supplier of the emissions software that was installed in some 2.0-liter and 3.0-liter Volkswagen, Audi and Porsche diesel vehicles.

Full information on the settlements, including the settlement agreements, class notices, executive summaries and FAQs are posted on VWCourtSettlement.com and BoschVWSettlement.com. Class members should consult the materials on the website for explanations and assistance in recovering their benefits under the settlements. The following videos briefly summarize the options available to class members with Generation One and Generation Two vehicles. Consumers can visit VWCourtSettlement.com to enter their vehicle’s VIN to learn if they have an eligible vehicle and see their range of compensation.

Transcript of 3L/Bosch Fairness Hearing Proceedings – 05/15/2017 – 02/14/2017

Preliminary Approval of VW/Audi/Porsche 3-liter and Bosch Settlements in Volkswagen “Clean Diesel” Litigation

Keller Rohrback is pleased to announce that Judge Charles Breyer of the Northern District of California has preliminarily approved two class action settlements in the Volkswagen “Clean Diesel” litigation. One settlement resolves claims against Volkswagen, Audi, and Porsche relating to 3.0-liter diesel vehicles, and the other resolves claims against Bosch, supplier of software installed in both 2.0- and 3.0-liter diesel vehicles. While the Bosch settlement is separate, owners and lessees of 2.0- and 3.0-liter Volkswagen, Audi, and Porsche diesel vehicles who make claims in the 2.0-liter and 3.0-liter class action settlements with Volkswagen will automatically receive additional benefits from the Bosch settlement.

Current and former owners and lessees of Volkswagen, Audi, and Porsche 3.0-liter diesel vehicles will soon be able to visit the 3.0-liter settlement website at https://www.vwcourtsettlement.com/en/3-0-models/ to learn more about these settlements, check their eligibility, and learn their options for returning or modifying their vehicles (when and if a modification is approved by EPA and CARB), and view an estimate of the restitution amount they will receive. 2.0- and 3.0-liter owners and lessees will be able to get more information about the Bosch settlement at https://www.boschvwsettlement.com/

There are three important deadlines to be aware of. If you wish to exclude yourself from either of the new settlements, you must do so by April 14, 2017. Instructions for how to do so can be found on the settlement websites. If you sold your 3.0-liter TDI vehicle prior to January 31, 2017, you may still qualify for benefits under the settlements, and must identify yourself to Volkswagen and by May 1, 2017 to receive benefits. The same deadline applies to identify yourself to Bosch if you wish to participate only in the Bosch settlement; you will automatically receive benefits from the Bosch settlement if you make a claim in the Volkswagen/Audi/Porsche 3.0-liter settlement. If you missed the deadline to register as an eligible seller in the 2.0-liter settlement with Volkswagen, you can still participate in the Bosch settlement, but must identify yourself to Bosch by May 1, 2017.

Judge Breyer will hold a hearing on May 11, 2017 to decide whether to grant final approval of the Settlements, and, when and if final approval is granted, buybacks, lease terminations, and approved vehicle modification will begin as soon as possible. Certain 3.0-liter class members will also be able to obtain part of their restitution payment as soon as their claim is submitted and accepted.

Additional information can be found on the Court’s website: http://www.cand.uscourts.gov/crb/vwmdl.

Transcript of Preceedings – 3L and Bosch Preliminary Approval Hearing – 02/14/2017

Volkswagen, Audi, Porsche 3.0-Liter Settlements to Compensate Consumers, Protect Environment and Hold VW Accountable for Emissions Conduct

Class and government settlements provide substantial cash payments to fully compensate owners and lessees, ensure vehicles no longer illegally pollute environment

San Francisco, CA—Settlement agreements were filed today by the consumer plaintiffs and the Federal Trade Commission in the Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation that, if approved, will provide owners and lessees of Volkswagen, Audi and Porsche 3.0-liter diesel vehicles substantial cash compensation in addition to buybacks, trade-ins, government-approved emissions modifications or compliant repairs, depending on the generation of vehicle. The proposed settlements were filed in the Northern District of California as part of the multidistrict litigation currently overseen by Judge Charles R. Breyer.

Upon final court approval, consumers’ options and compensation will depend on whether their vehicles are classified as Generation One or Generation Two. The engine designs for each generation are different, with different prospects for emissions compliance. The cash payments in addition to these options are only available to those who participate in the class action settlement, which covers approximately 75,000 3.0-liter TDI vehicles.

Generation One (Model Years 2009-2012): These vehicles – like 2.0-liter vehicles – cannot be repaired to be compliant with their originally certified emissions standards. Therefore, owners will have the option of a buyback, trade-in, or an EPA- and CARB-approved emissions modification plus substantial cash compensation ranging from $7,755 to $13,880. Lessees will also be eligible to have their lease terminated and receive cash compensation.

 Generation Two (Model Years 2013-2016): Government regulators believe these newer vehicles can be repaired to fully comply with the original emissions standards to which they were certified. If this is achieved and approved by the EPA and CARB, Generation Two owners will receive this repair plus substantial cash compensation ranging from $7,039 to $16,114. Lessees are also eligible for this repair plus cash payment. Consumers may choose to receive half this payment upfront, before any repair is approved, and the other half upon repair completion.

If the EPA and CARB do not approve an emissions compliant repair by deadlines set out in the class settlement agreement, a process (described below) will follow in which Class Counsel can ask the Court to order a buyback, or other remedies if the repair results in reduced performance as detailed in the settlement agreement.

Under the consumer agreements, Volkswagen will pay approximately $1.2 billion in combined compensation, assuming an Emissions Compliant Repair becomes timely available for all Generation Two vehicles. If such repairs do not become available by deadlines detailed in the settlement, Volkswagen has agreed to pay approximately $4.04 billion dollars. Under the related DOJ 3.0-Liter Consent Decree, Volkswagen will pay an additional $225 million to mitigate the environmental effects of excess NOx emissions.

“This agreement builds on the successes of the 2.0-liter settlement by providing substantial benefits to both consumers and the environment,” said Elizabeth Cabraser, Court-appointed Lead Counsel and chair of the 21 member Plaintiffs’ Steering Committee, which negotiated the settlement on behalf of class members. “We are another step closer to achieving our goal: providing consumers fair value for their vehicles, while repairing or removing illegally polluting vehicles from the road. We are appreciative of the guidance provided by Judge Breyer; the Settlement Master, former FBI Director Robert Mueller; and the efforts and cooperation of DOJ, EPA, FTC and CARB.”

A settlement resolving claims against Bosch was also filed today with the court. Under this agreement, which includes 2.0-liter and 3.0-liter TDI owners and lessees, Bosch will pay $327.5 million. Typical 2.0-liter owners will each receive $350 and 3.0-liter owners will each receive $1,500 in addition to their Volkswagen settlement payments. For example, a combination of Bosch and 3.0-liter repair payments for Generation Two owners would range from $8,539 to $17,614; Generation One owners who choose a buyback would receive combined payments from $26,255 to $58,657. Class members will receive a separate notice about how to obtain the Bosch payments.

The settlements are subject to Court approval. If preliminary approval is granted after a hearing currently scheduled for February 14, 2017, class members will receive more information about the terms of the settlement. At that time, consumers can also visit www.VWCourtSettlement.com to enter their vehicle’s VIN to learn if they have an eligible vehicle and see their expected compensation amount. Additional information can also be found on the Court’s website: http://www.cand.uscourts.gov/crb/vwmdl.

Affected consumers do not need to take any action at this time. When and if the Court grants final approval, the claims process will open to eligible owners, lessees and post-September 18, 2015 sellers without delay from any appeals, and payments will commence shortly after. The ultimate deadline to file a claim will be December 31, 2019. For purposes of calculating buyback payments, under the settlement, vehicle value remains frozen as of September 18, 2015 (the date the emissions allegations became public), meaning its value generally will not depreciate while consumers go through the claims process.

Generation One Vehicles (2009-2012 Volkswagen Touareg and Audi Q7 3.0-liter TDI diesel engine vehicles)

The agreement will compensate those who currently own or lease an eligible Generation One vehicle, or sold their vehicle after September 18, 2015 or November 2, 2015 (the date the emissions allegations became public and the date the allegations specific to 3.0-liter vehicles became public, respectively). No matter the option they choose, eligible owners will also receive cash compensation in addition to the value of a buyback, trade-in or approved modification in an amount ranging from $7,755 to $13,880. Lessees will also be eligible to have their lease terminated and receive cash compensation. The Bosch compensation will increase these figures as well.

Vehicle Buyback

Eligible owners who choose the buyback program will receive a payment equal to the September 2015 National Automobile Dealers Association (“NADA”) Clean Trade-In value of the car (the vehicle value before the emissions conduct became public), adjusted for their options and mileage. This equals a total payment ranging from $24,755 to $57,157.

Trade-In Credit

If owners prefer, they will instead have the option of receiving a trade-in credit equal to the buyback amount to purchase a new or used vehicle at a Volkswagen or Audi dealership. If the purchase is less than the trade-in credit, the consumer will receive the balance.

Approved Emissions Modification

If owners and lessees prefer, they can wait and see whether an emissions modification is approved by EPA and CARB for their vehicles. If an EPA- and CARB-approved emissions modification becomes available, Volkswagen will modify their non-compliant 3.0-liter vehicle free of charge. If a modification is not approved for a certain vehicle, the buyback program will still be available, or a class member can withdraw from the settlement. Volkswagen and Audi have a final deadline of November 10, 2017 to submit proposed emissions modifications of Generation One vehicles to regulators.

Generation Two Vehicles (2013-2016 Volkswagen Touareg; 2013-2015 Audi Q7; 2014-2016 Audi A6, A7, A8, A8L and Q5; and, 2013-2016 Porsche Cayenne 3.0-liter TDI vehicles)

Unlike Generation One vehicles, government regulators are providing Volkswagen an opportunity to repair these newer vehicles to fully comply with the original emissions standards to which they were certified. The class settlement imposes a set of deadlines, or “Decision Dates,” by which the regulators must have approved the repairs for these vehicles – October 23, November 8 and December 20, 2017 for the three groups of Generation Two vehicles described in the settlement. With these repairs, eligible owners will also receive additional cash compensation ranging from $7,039 to $16,114. Lessees are also eligible for these repairs, plus cash payment. Consumers may choose to receive half their cash payment as soon as the Court grants final approval, and the other half upon repair completion.

If the EPA and CARB have not made a final decision on a vehicle group by the applicable Decision Date, Class Counsel will ask the Court under an expedited procedure to order a buyback. The Court can extend a Decision Date if there is good cause to do so. If the Court does not extend a Decision Date, then Volkswagen can extend the date for up to 90 days total, in exchange for an Extension Payment of $500 per 30-day extension for each vehicle. After that, a buyback will occur if a repair is still not approved. During this period, a Class Bridge Warranty covers vehicles whose warranties would otherwise expire. Total buyback payments for all Generation Two owners would be $43,153 to $99,862. The Bosch compensation will increase these figures as well.

Volkswagen represents that these emissions compliant repairs will not affect important performance attributes of these vehicles (mileage, torque and peak horsepower), and Volkswagen will be required to make an additional payment of $500 per affected vehicle if an approved repair results in reduced performance in any of these attributes, as required to be reported to the EPA and CARB. Class Counsel could also seek additional remedies if this reduced performance exceeded levels detailed in the settlement agreement.

Additional benefits to both Generation One and Generation Two class members include one free AdBlue refill and oil change for their eligible vehicle while awaiting an emissions modification or repair, buyback, trade-in, or lease termination; refunds of unused portions of extended warranties and service plans; loaner cars while their vehicles are being modified or repaired; and for Class Members who get a buyback, forgiveness of auto loan balances to the extent these exceed their buyback amount.

Court Grants Final Approval to 2.0-Liter Settlement

Keller Rohrback is pleased to report that this morning, Judge Charles Breyer granted final approval to the 2.0L class action TDI settlement.

In the settlement approved today, October 25, 2016, in the Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation, owners and lessees of Volkswagen and Audi 2.0-liter diesel vehicles will receive substantial compensation through buybacks and lease terminations, government-approved emissions modifications, and cash payments, while fixing or removing these polluting vehicles from the road. Class members can now visit www.VWCourtSettlement.com to learn if they have an eligible vehicle and begin the claims process to register for and schedule their Buyback, Lease Termination, or if approved, their Emissions Modification.

Under the class action settlement agreement, Volkswagen will create a funding pool of up to $10.033 billion dollars. The settlement will provide consumers the choice of:

  • A Buyback or lease termination on approximately 475,000 2.0-liter diesel vehicles.
  • If approved by the EPA and California Air Resources Board (or CARB), an emissions modification to ensure the vehicle no longer generates excess nitrogen oxide emissions.

Whether they choose a Buyback or an approved emissions modification, the settlement also offers eligible owners and lessees cash compensation. This is in addition to the vehicle’s buyback value or approved modification.

Under agreements with EPA and CARB, which are incorporated in the class action settlement agreement, Volkswagen will pay an additional $2.7 billion for environmental remediation and commit another $2.0 billion to promote Zero Emissions Vehicle technology. Volkswagen will also be required to pay additional money into a mitigation trust if it fails to remove from commerce or modify at least 85 percent of covered 2.0 liter vehicles by June 30, 2019. Volkswagen also reached separate agreements with the Federal Trade Commission as well as a number of State Attorneys General.

Vehicle Buyback:

Under the terms of the class action settlement, eligible owners who choose the Buyback program will receive a payment based on the September 2015 National Automobile Dealers Association (“NADA”) Clean Trade-In value of the car (before the “defeat device” was revealed), adjusted for their options and mileage. Certain owners will be eligible for forgiveness of their car loan obligations, and certain lessees will be able to terminate their lease with no penalty for early termination. Volkswagen may begin buying back eligible vehicles as early as the fall of 2016, just over one year after the diesel emissions issues were first revealed.

Vehicle Fix:

Alternatively, if owners or lessees prefer, they can wait and see whether an emissions modification is approved by EPA and CARB for their vehicles. If and when an EPA and CARB-approved emissions modification becomes available, Volkswagen will modify their non-compliant 2.0-liter vehicle free of charge. If a modification is not approved for a certain vehicle, the Buyback Program will still be available, or a class member can withdraw from the settlement. Volkswagen will be prohibited from re-selling, in the U.S. or abroad, any vehicle that does not receive an approved emissions modification.

Cash Payments:

Current and certain former owners and lessees will also receive cash payments in addition to the buyback value or approved modification. The amount for current owners and lessees is the same whether one participates in the buyback, lease termination, or modification program. Certain former owners and lessees will receive cash payments even though they no longer have a vehicle to sell back or fix. The settlement agreement includes a formula for how this cash payment is determined. For example, most owners who purchased a 2.0-liter vehicle before September 18, 2015 will be eligible for a payment ranging from $5,100 to approximately $10,000 per vehicle. This cash is to be paid on top of the September 2015 Clean Trade-in value for those participating in the Buyback Program.

Class members can visit www.VWCourtSettlement.com to learn if they have an eligible vehicle. Now that the Court has granted final approval, the claims process will open to eligible Volkswagen and Audi 2.0 liter owners and lessees. Volkswagen and Audi 3.0-liter vehicles are not covered in this settlement, as those claims continue to be litigated. Additional information can also be found on the Court’s website: http://www.cand.uscourts.gov/crb/vwmdl.

On August 25, 2016, Judge Breyer held a Status Conference at which the parties updated the Court on the status of the litigation. Lead Counsel for the Plaintiffs’ Steering Committee informed the Court that settlement notices for 2.0-liter vehicles have been mailed or emailed to class members, and Judge Breyer urged class members to read and make sure they understand the notices before they made any decisions regarding their Eligible Vehicles. Keller Rohrback, along with the other firms appointed to the Plaintiffs’ Steering Committee, is available to answer any questions about the Class Action Settlement that current and former owners and lessees of 2.0-liter vehicles may have.

The parties also updated Judge Breyer on the progress toward fixing emissions systems on the 3.0-Liter Class Vehicles and resolving that portion of the litigation. Judge Breyer set a deadline of October 24, 2016, for Volkswagen to propose a fix to the EPA, ordered the parties to begin settlement discussions, appointed former FBI Director Robert Mueller, who served as Settlement Master during the negotiation of the 2.0-liter Settlements, to moderate these discussions, and scheduled another status conference on these issues for November 3, 2016, with the goal of pushing the 3.0-liter portion of the case toward resolution by settlement or trial.

Judge Breyer will hold another hearing on October 18, 2016 to decide whether to grant final approval of the 2.0-liter Settlements. When and if final approval is granted, class members will be able to finalize their claims submissions and begin scheduling appointments for buybacks, lease terminations, or approved vehicle modifications, and, for eligible sellers and former lessees, to finalize their claims in order to receive compensation payments.

Additional information can be found on the Court’s website: http://www.cand.uscourts.gov/crb/vwmdl.

Read the full Transcript

Preliminary Approval of VW Settlement Granted

Keller Rohrback is pleased to announce that Judge Charles Breyer of the Northern District of California has preliminarily approved the class action settlement in the Volkswagen “Clean Diesel” Matter.

Current and former owners and lessees of Volkswagen and Audi 2.0 liter TDI vehicles can now visit the settlement website at www.VWCourtSettlement.com and check their eligibility, register their vehicles, learn their options for returning or modifying their vehicles (when and if a modification is approved by EPA and CARB), and receive an estimate of the restitution amount they will receive.

In addition, if you sold your 2.0 liter TDI vehicle prior to June 28, 2016, you may qualify as an Eligible Seller, and you must identify yourself to VW by September 16, 2016, or you will not be eligible to receive restitution.

Judge Breyer will hold a hearing in October 18, 2016 to decide whether to grant final approval of the Settlements, and, when and if final approval is granted, buybacks, lease terminations, and approved vehicle modification will begin without delay.

Additional information can be found on the Court’s website: http://www.cand.uscourts.gov/crb/vwmdl.

Read the full Transcript

During the Court’s June 30, 2016 Status Conference, Judge Breyer thanked the parties for complying with the Court’s orders regarding filing proposed settlement papers, and especially for addressing the expectations of consumers in the proposed settlements.

Judge Breyer next inquired as to the status of the settlement discussions regarding 3.0-Liter vehicles, and requested that the Parties keep Settlement Master Mueller and the Court apprised of the parties’ on-going efforts.

Judge Breyer will hold a preliminary approval hearing regarding the 2.0-Liter proposed settlements on July 26th and a status conference on August 25, 2016.

Read the whole Transcript of the Conference

On June 15, 2016, in a stipulation requested by Settlement Master Robert Mueller, the Court granted a seven day extension of the deadline for the Plaintiffs’ Steering Committee to file its motion for preliminary approval of the settlement agreement. The deadline for the parties to file for Preliminary Approval is now JUNE 28, 2016, on which date the terms of the settlement agreement will become public. No other hearing dates have been moved.

Read the June 15th order

In the transcript of the May 24, 2016 status conference, the Court notes that there has been “substantial progress” toward a settlement for owners and lessees of the 2-liter vehicles. Judge Breyer reported that the parties are “on track to meet the Court’s deadline” of June 21 to submit details of that settlement to the Court and public.

The Court has scheduled a Hearing regarding whether the Court should grant preliminary approval of the settlement on July 26, 2016 at 8 a.m. in San Francisco.

The Court also noted that “[e]ngineering studies and testing for the [3-liter-engine cars] are ongoing, and the parties are moving as quickly as possible to resolve these issues.  I have been assured that the parties are working diligently on resolving the 3-liter-engine cars’ issues.”

Read the transcript of the May 24th status conference

The transcript of the April 21, 2016 status conference includes the Court’s announcement of the agreement in principle for resolution as to the 2-liter affected vehicles. The Court imposed a deadline of June 21, 2016, for the filing of a motion seeking preliminary approval of this agreement, after which the terms of the agreement will become public.

Read the transcript of the April 21st status conference

VW News


Case Documents

Transcript of 3L/Bosch Fairness Hearing Proceedings – 05/15/2017

Order Granting Final Approval of the Consumer and Reseller Dealership 3.0-Liter Class Action Settlement – 05/15/2017

Order Granting Final Approval of the Bosch Class Action Settlement – 05/15/2017

Transcript of Preceedings – 3L and Bosch Preliminary Approval Hearing – 02/14/2017

Consumer and Reseller Dealership 3.0-Liter Class Action Settlement Agreement and Release (Settlement Agreement) – 01/31/2017

Plaintiffs’ Notice of Motion, Motion, and Memorandum Support of Preliminary Approval of the 3.0-Liter Tdi Class Action Agreement and Approval of Class Notice – 01/31/2017

Order Granting Final Approval of the 2.0-Liter TDI Settlement – 10/25/2016

Transcript of Proceedings – Final Approval Hearing – 10/18/2016

Status Conference Hearing Transcript – 08/25/2016

Preliminary Approval Hearing Transcript – 07/26/2016

Order Granting Preliminary Approval of Settlement – 07/26/2015

Motion for Approval of Amended Class Action Agreement and Approval of Class Notice – 07/26/2016

(Amended) Consumer Class Action Settlement Agreement and Release – 07/26/2016

Transcript of Proceedings – 06/30/2016

Plaintiff’s Consolidated Consumer Complaint – 02/22/2016

Order Appointing Plaintiffs’ Steering Committee – 01/21/2016

Pretrial Order No. 6: Appointment of Robert S. Mueller III as Settlement Master – 01/19/2016

Intent to Appoint Robert S. Mueller as Settlement Master – 01/11/2016

MDL Transfer Order – 12/08.2015


List of Affected Vehicles

 

Volkswagen
  • Jetta TDI (Model Years 2009 – 2015)
  • Jetta Sportwagen TDI (Model Years 2009 – 2014)
  • Beetle TDI and Beetle Convertible TDI (Model Years 2013 – 2015)
  • Golf TDI (Model Years 2010 – 2015)
  • Golf Sportwagen TDI (Model Year 2015)
  • Passat TDI (Model Years 2012 – 2015)
  • Touareg TDI (Model Years 2009 – 2016)
Audi
  • A3 TDI (Model Years 2010 – 2015)
  • A6 TDI (Model Years 2014 – 2016)
  • A7 TDI (Model Years 2014 – 2016)
  • A8 TDI (Model Years 2014 – 2016)
  • A8L TDI (Model Years 2014 – 2016)
  • Q5 TDI (Model Years 2014 – 2016)
  • Q7 TDI (Model Years 2009 – 2016)
Porsche
  • Cayenne Diesel (Model Years 2013 – 2016)

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Praise from Clients

“We wanted to be part of the solution and speak up for people who were victimized by VW’s deception. As lifelong environmentalists who have always tried to put our money where our mouth is and walk the talk, we wanted to make sure this kind of massive fraud does not ever take place again. From Exxon Valdez settlements to the Santa Barbara oil spill, Keller Rohrback has been out front fighting for the people. Thanks for taking the lead once more.”
“I wanted to thank you for the wonderful job your firm is doing to help protect the Plaintiffs and class members from Volkswagens’ deceptive business practices. . . . I can see from your prompt replies to my calls and emailed questions that your firm has the ‘best interests’ of all of the plaintiffs in mind.”
“From the beginning of the case, everyone at Keller Rohrback showed attention to detail, dedication, and passion to the members of the case. The journey from start to finish took years to complete and yet 100% effort was always given. This effort resulted in a very reasonable settlement that benefited the most people possible. Thank you for representing the members with utmost personable attention.”