Case No. 20-cv-13079 in the United States District Court for the Eastern District of Michigan, Southern Division


A court authorized this Notice.  This is not a solicitation from a lawyer.

This Notice of Proposed Class Action Settlement and Hearing provides important information regarding your right to participate in or to opt out of a proposed settlement in a putative class action lawsuit (referred to in this notice as the “Settlement”).  Named Plaintiffs, Gabriel Green and Valerie Hall-Green (“the Greens” or “Plaintiffs”), filed a lawsuit against Defendant FCA US LLC (“Defendant”), in which they allege that Defendant provided them and other putative class members with a COBRA Notice that did not adequately inform class members how to exercise their right to elect COBRA coverage.  Plaintiffs and Defendant are referred to in this notice together as the “Parties.”  Defendant disputes the allegations and has asserted that the COBRA Notice complied with all applicable laws.  That case is pending in the U.S. District Court, Eastern District of Michigan, Southern Division.  The judge has not made any determination about who is right or wrong in the case.  A summary of the claims asserted in the lawsuit and the proposed Settlement follows.



Do Nothing

If you do nothing and the Court approves this settlement, you will receive a settlement payment (the amount of which is described below).  As a member of the Settlement Class, you will release Defendant and others from any potential liability regarding the COBRA Notice, including but not limited to the issues raised in this lawsuit.

Ask to be Excluded by

June 27, 2022

If you do not want to be included in the case and the Settlement, you must take action to exclude yourself.  This is called “opting out.”  To opt out, you must send a written opt-out request to the Settlement Administrator by June 27, 2022.  Your written opt-out request must (i) state the case name and number (Green, et al. v. FCA US LLC, No. 2:20-cv-13079); (ii) state your name, address, telephone number, and email address; and (iii) include your personal signature.  If you elect to opt out, you will not receive a settlement payment and will not release claims, and you may pursue your own individual action against Defendant for the claims raised in this case if you choose to do so.

Object by June 27, 2022

If you do not like the Settlement, or any of its specific terms, you may “object.”  To object, you must file a written objection with the Court and send a copy of your objection to the Settlement Administrator by June 27, 2022.  Your written objection must (i) state the case name and number; (ii) provide the specific grounds for your objection; (iii) state whether your objection pertains to just you individually, or all or some of the proposed Settlement Class; (iv) state your name, address, telephone number, and email address; (v) state whether you intend to appear and speak at the Final Approval Hearing, either with or without your own counsel; and (vi) include your personal signature (and your counsel’s signature, if you have your own representation).  You may not file an objection if you opt out of the Settlement.

Go to a Hearing on August 8, 2022

If you wish to be heard, you may attend the Final Approval Hearing and ask to speak in Court about the fairness of the Settlement.  You are not required to attend the hearing.  If you opt out, you may not present your opinions regarding the Settlement at the Final Approval Hearing.


The Court still has to decide whether to approve this settlement, which may take some time, as explained below.