A proposed class action settlement (the “Settlement”), pending in the Superior Court for the State of California, County of Alameda (the “Court”), has been reached between Plaintiffs Finn Walsh, Jack Ronan, Timothy Walsh, and Katherine Walsh (“Plaintiffs”) and Premium Property Management & Development, Inc. (“Premium”), Haste Partners, LLC (“Haste”), Sam Sorokin, Craig Beckerman, and Maria DiBlasi (collectively, “Defendants”). The Court has granted preliminary approval of the Settlement. You may be entitled to receive money from this Settlement.

If you have received a Class Notice that was mailed or emailed to you, it is because you have been identified as a member of one or more of the Settlement Classes, which are defined as:

LEASE RENEWAL CLASS. All persons and their Guarantors who rented residential property in California and who executed and delivered a written notice of lease renewal or lease renewal form to Premium Property Management & Development, Inc. regarding renewing or extending the term of their lease for a residential property in California from September 1, 2016 through November 30, 2023 (the “Class Period”), and whose entire unit vacated the property before the commencement of the renewal period.

LEASE FEE CLASS. All persons who rented residential property in California and were charged for roommate add-on fees, roommate replacement fees, request to be removed fees, or lease transfer fees (collectively “Lease Fees”) by Premium Property Management & Development Inc. during the Class Period.

SECURITY DEPOSIT CLASS. All persons who rented residential property in California and were charged rent or fees as members of the Lease Renewal Class or the Lease Fee Class and who had deductions taken from their security deposits for that rent or fees by Premium Property Management & Development Inc. during the Class Period.

The Settlement Classes specifically exclude (1) any judicial officer presiding over the Litigation, (2) Defendants and Released Parties, and each of their current or former officers, directors, and employees; (2) legal representatives, successors, or assigns of any such excluded person, and (4) any person who properly executes and sends a timely Request for Exclusion.

This Class Notice explains the lawsuit, the Settlement, and your legal rights. It is important that you read this Notice carefully as your rights may be affected by the Settlement.

On August 26, 2020, Plaintiffs filed a Complaint against Defendants in the Superior Court of the State of California, County of Alameda, challenging Defendant’s landlord practices and alleging that Defendants violated multiple laws.

Defendants deny and dispute all claims asserted in the Litigation. Specifically, Defendants contend (and continue to contend) that the Litigation could not properly be maintained as a class action; and that Defendants should not be liable.

The Parties, all represented by counsel, engaged in private settlement discussions which led to a negotiated agreement. The Court granted preliminary approval of the Settlement on August 15, 2024. At that time, the Court also preliminarily approved the Plaintiffs to serve as the Class Representatives, and the Law Office of Ronald A. Marron to serve as Class Counsel.

Released Claims. Upon entry of final judgment and funding in full of the Settlement Fund by Defendants, Plaintiffs and the Settlement Class Members shall release any and all claims alleged or that could have been alleged in the Litigation (“Released Claims”).

 This means that, if you do not timely and formally exclude yourself from the settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendants about the legal issues resolved by this Settlement. It also means that all of the Court’s orders in this Litigation will apply to you and legally bind you.

Settlement Payment. Defendants have agreed to pay an “all in” amount of six hundred forty thousand dollars ($640,000) (the “Settlement Fund”) to fund the settlement. The Settlement Fund includes payment to settlement class members, the costs of class notice and claims administration, class counsel’s attorneys’ fees and expenses, and a service award to Plaintiffs.

 Amounts to be Paid from the Settlement Payment. The Settlement provides for certain payments to be made from the Settlement Payment, which will be subject to final Court approval, and which will be deducted from the Settlement Payment before settlement payments are made to class members, as follows:

• Attorneys’ Fees and Expenses. Payment to Class Counsel of an award of attorney’s fees of up to $390,000 and attorneys’ expenses of up to $40,000, subject to Court approval. Class Counsel has been prosecuting the Litigation on behalf of Plaintiffs and the Class on a contingency fee basis (that is, without being paid any money to date) and has been paying all litigation costs and expenses.
• Service Award. A service award to Plaintiffs of up to $7,500 each, or as may be approved by the Court, to compensate them for services on behalf of the class in initiating and prosecuting the Litigation, and for the risks they undertook.
• Calculation of Payments to Settlement Class Members. After all the above payments are deducted from the Settlement Payment, the remaining portion, called the “Net Settlement Amount,” shall be distributed to class members who do not request exclusion (“Settlement Class Members”). The Lease Renewal Settlement Class will receive a full refund of amounts paid or withheld from Lease Renewal Settlement Class Members’ security deposit for the purpose of payment of rent due after the commencement of the renewal period. The Lease Fee Settlement Class will receive a full refund of all Lease Fees paid or withheld. The Security Deposit Settlement Class will receive an additional payment equivalent to the amount of the security deposit withheld from members of the Lease Renewal class for rent due after commencement of the renewal period and/or from members of the Lease Fee Class for Lease Fees.

If the Settlement is approved by the Court, you will automatically be mailed a check for your Settlement Share to the same address as this Class Notice. You do not have to do anything to receive a payment. If your address has changed, you must contact the settlement administrator to inform them of your correct address to ensure you receive your payment.

Tax Matters. Neither Class Counsel nor Defendants’ counsel intends anything contained in this Settlement to constitute advice regarding taxes or taxability. You may wish to consult a tax advisor concerning the tax consequences of the payments received under the settlement.

Conditions of Settlement. This Settlement is conditioned upon the Court entering an order granting final approval of the Settlement and entering judgment.

If you have been identified as a member of one or more of the Settlement Classes, you have been sent a notice to your address with your estimated payment amount.

If you wish to dispute the estimated calculation of your Individual Settlement Proceed as set forth above, then you must submit a written, signed Request for Adjustment challenging the information along with supporting documents, to the settlement administrator at the address provided in this Notice no later than November 7, 2024.

 For Multi-Tenant Units: If you wish to request that Multi-Tenant Unit Proceeds be distributed other than on a pro-rata basis, then you must submit a written Request for Alternative Distribution providing instructions for any alternate division of the Multi-Tenant Unit Proceeds, signed and dated by all tenants who resided in the unit, to the settlement administrator at the address provided in this Notice no later than November 7, 2024.

If you have received a notice that we have identified you as a member of one or more of the classes, to get money from the settlement, you do not have to do anything. A check for your settlement payment will be mailed automatically to the same address as the notice you received. If your address is incorrect or has changed, you must notify the settlement administrator. The settlement administrator can be reached by email at [email protected]; or by U.S. mail at Premium Properties Settlement, c/o Classaura Claims Administration, 1718 Peachtree St NW #1080, Atlanta, GA 30309.

 The Court will hold a hearing on January 21, 2025 at 10:00 AM to decide whether to finally approve the Settlement. If the Court approves the Settlement and there are no objections or appeals, payments will be mailed within a few weeks after this hearing. If there are objections or appeals, resolving them can take time, perhaps more than a year. Please be patient. After entry of the judgment, the Settlement Administrator will send payment to all class members who do not opt out of the settlement.

If you do not wish to participate in the Settlement, you may exclude yourself from the Settlement or “opt out.” If you opt out, you will receive NO money from the Settlement, and you will not be bound by its terms.

To opt out, you must submit to the settlement administrator a written, signed Request for Exclusion, dated, mailed, and postmarked no later than December 7, 2024. The email address for the settlement administrator is [email protected] and the mailing address for the settlement administrator is Premium Properties Settlement, c/o Classaura Claims Administration, 1718 Peachtree St NW #1080, Atlanta, GA 30309. The request for exclusion must state in substance: “I wish to opt out of the settlement of the class action lawsuit entitled Walsh v. Premium Property Management & Development, Inc., Case No. RG20072409.” The request for exclusion must contain your name, current address, email address, and telephone number for verification purposes. The request for exclusion must be signed by you. No other person may opt out for a member of the Class.

For Settlement Class Members who resided in Multi-Tenant Units, all Settlement Class Members who resided in the Multi-Tenant Unit must jointly complete and sign the Request for Exclusion, and all Settlement Class Members who resided in the Multi-Tenant Unit will be excluded from the Settlement.

Written requests for exclusion that are postmarked after, or are incomplete, or unsigned will be rejected, and those Class Members will remain bound by the Settlement and the release described above.

If you exclude yourself from the Settlement, you will receive no money from the Settlement described in this Notice.

Any Class Member who has not opted out and believes that the Settlement should not be finally approved by the Court for any reason may object to the proposed Settlement. Objections may, but need not, be made in writing. Written objections must state: (1) the case name, which is Walsh v. Premium Property Management & Development, Inc., Case No. RG20072409; (2) the name, address, telephone number, and email address of the settlement class member; (3) a statement describing the objector’s membership in the Settlement Classes and identifying the specific Settlement Class(es) of which the objector is a member, (4) the basis for the objection, including any legal support for the objection; and (5) whether the Settlement Class Member intends to appear at the final approval/settlement fairness hearing.

In the alternative, Settlement Class Members may appear in Court (or hire an attorney to appear in Court) to present verbal objections at the Final Approval Hearing. The Court will entertain any objections from participating class members at the Final Approval Hearing. If an objecting party intends to appear at the Final Approval Hearing, the objector may file with the Court, at least thirty (30) days before the Final Approval Hearing (or such other deadline as may be set by the Court), a notice of intent to appear. The notice of intent to appear should list the name, address and telephone number of the attorney, if any, who will appear on behalf of that party.

To object to the Settlement, you cannot opt out. If the Court approves the Settlement, you will be bound by the terms of the Settlement in the same way as Class Members who do not object. Any Class Member who does not object in the manner provided in this Class Notice shall have waived any objection to the Settlement, whether by appeal or otherwise.

Written objections must be filed with the Court and mailed to counsel for the Parties no later than December 7, 2024.

The addresses for the Parties’ counsel are as follows:

LAW OFFICES OF RONALD A. MARRON, APLC
ATTN: Premium Properties Settlement
651 Arroyo Drive
San Diego, California 92103

DONAHUE FITZGERALD, LLP
ATTN: Premium Properties Settlement
1999 Harrison Street, 26th Floor
Oakland, California 94612-3520

The Court will hold a Final Approval Hearing at 10:00 AM on January 21, 2025 at the Superior Court of California, County of Alameda, in Department 23 of the Rene C. Davidson Courthouse, located at 1225 Fallon Street Oakland, CA 94612 before the Honorable Michael Markman. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. The purpose of this hearing is for the Court to determine whether to grant final approval to the Settlement. If there are objections, the Court will consider them. The Court will listen to people who have made a timely written request to speak at the hearing or who appear at the hearing to object. This hearing may be rescheduled by the Court without further notice to you. You are not required to attend the Final Approval Hearing, although any Class Member is welcome to attend the hearing.

The pleadings and other records in this litigation may be examined online on the Alameda County Superior Court’s website, known as “eCourt Public Portal,” at https://eportal.alameda.courts.ca.gov.

After arriving at the website, click the “Searches” tab at the top of the page, then select the Document Downloads link, enter the case number and click “Submit.” Images of every document filed in the case may be viewed at a minimal charge. Case names and/or numbers can also be used to search for documents. You may also view images of every document filed in the case free of charge by using one of the computer terminal kiosks available at each court location that has a facility for civil filings.

You may also visit the documents section of this website, email the settlement administrator at [email protected], or write to the settlement administrator at Premium Properties Settlement, c/o Classaura Claims Administration, 1718 Peachtree St NW #1080, Atlanta, GA 30309.

PLEASE DO NOT CALL THE COURT ABOUT THIS NOTICE.

IMPORTANT:

• You must inform the settlement administrator of any change of address to ensure receipt of your settlement payment.

• Settlement checks will be null and void 365 days after issuance if not deposited or cashed. In such event, the settlement administrator shall pay all funds from such uncashed checks to Tenants Together pursuant to the terms of the Settlement. If your check is lost or misplaced, you should contact the settlement administrator immediately to request a replacement.