If you are a member of the Settlement Class and do not request to be excluded, you can tell the Court you like the Settlement and it should be approved, or you can ask the Court to deny approval by filing a written objection. You can object to the Settlement and/or to Class Counsel’s Fees and Expenses Application and request for Class Representative service awards. You cannot ask the Court to order a different settlement; the Court can only approve or reject the proposed Settlement. If the Court denies approval of the Settlement, no Settlement payments will be sent out and the Action will continue. If that is what you want to happen, you must object on a timely basis. You are not required to submit anything to the Court unless you are objecting or wish to be excluded from the Settlement.
To object to or comment on the Settlement, you must do either of the following:
- File your written objection or comment, and any supporting papers or materials, on the Court’s docket for this case, Sampson, et al. v. Subaru of America, Inc., United States District Court for the District of New Jersey, Civil Action No. 1:21-cv-10284-ESK-SAK, via its electronic filing system, no later than August 28, 2025, or
- File your written objection or comment, and any supporting papers or materials, with the Court in person at the Clerk’s Office of the United States District Court for the District of New Jersey, located at the Mitchell H. Cohen Building & U.S. Courthouse, 4th & Cooper Streets, Camden, NJ 08101, no later than August 28, 2025, or
- Mail your written objection or comment, and any supporting papers or materials, to each of the following, by U.S. First-Class mail, post-marked no later than August 28, 2025:
COURT
Clerk of the Court
United States District Court
for the District of New Jersey
Mitchell H. Cohen Building
& U.S. Courthouse
Camden, NJ 08101
CLASS COUNSEL
Capstone Law APC
Attn: Cody Padgett
1875 Century Park East, Suite 1000
Los Angeles, California 90067
DEFENSE COUNSEL
Shook, Hardy & Bacon LLP
Attn: Homer B. Ramsey
1 Rockefeller Plaza, Suite 2801
New York, NY 10020
Regardless of the above method you choose, your written objection must state clearly that you are objecting to the Settlement or the request for Class Counsel Fees and Expenses and/or Class Representative service awards in Sampson, et al. v. Subaru of America, Inc., United States District Court for the District of New Jersey, Civil Action No. 1:21-cv-10284-ESK-SAK, and must include all of the following: (i) your full name, address and telephone number; (ii) the model, model year and VIN of your Settlement Class Vehicle, (iii) proof that you own(ed) or lease(d) the Settlement Class Vehicle (i.e., a true copy of a vehicle title, registration or license receipt); (iv) a written statement of all your factual and legal grounds for objecting; (v) copies of any papers, briefs and/or other documents upon which the objection is based and which are pertinent to the objection; (vi) the name and address of any counsel representing you; (vii) a statement of whether you intend to appear at the Final Fairness Hearing, either with or without counsel, and the identity(ies) of any counsel who will appear on your behalf at the Final Fairness Hearing; and (viii) a list of all other objections submitted by you, and/or any counsel representing you, to any class action settlements in any court in the United States in the previous five (5) years, including the full case name with jurisdiction in which it was filed and the docket number, or affirmatively state, in your objection, that you and/or your counsel have not objected to any other class action settlement in the United States in the previous five (5) years.
Subject to the approval of the Court, any Settlement Class Member may appear, in person or by counsel, at the Final Fairness Hearing. In order to appear, the Settlement Class Member must, by the objection deadline of August 28, 2025, file with the Clerk of the Court and serve upon all counsel designated in the Class Notice (see above), a Notice of Intention to Appear at the Final Fairness Hearing. The Notice of Intention to Appear must include copies of any papers, exhibits or other evidence and identity of witnesses that the Settlement Class Member (or his/her counsel) intends to present to the Court in connection with the Final Fairness Hearing.
Any Settlement Class Member who does not submit a written objection to the proposed Settlement, or Class Counsel’s application for Fees and Expenses and/or the Class Representative service award, within the above deadline and in full compliance with the above requirements and procedure for a valid objection shall waive his/her/its right to do so, and to appeal from any order or judgment of the Court concerning the Settlement, Fees and Expenses and/or service award.
Any Settlement Class Member who does not provide a Notice of Intention to Appear in accordance with the deadline and other requirements set forth in the Long Form Class Notice shall be deemed to have waived any right to appear, in person or by counsel, at the Final Fairness Hearing.