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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
BRADLEY CRAWFORD et al.,
Case No. 2:20-cv-12341
Plaintiffs,
Hon. Stephen J. Murphy, III
v.
NOTICE OF SETTLEMENT OF
FCA US LLC, CLASS ACTION
Defendant.
If you purchased or leased in the United States a Model Year 2014-2019 Dodge Ram 1500
EcoDiesel Truck manufactured between June 12, 2013 and October 23, 2019 (“Eligible Truck”),
you could be affected by a proposed class action settlement.
A federal court has authorized this notice. This is not a solicitation from a lawyer.
Please read this entire Notice carefully. This Settlement may affect your rights.
• This Notice is being sent to you pursuant to Rule 23 of the Federal Rules of Civil Procedure and an Order of
the United States District Court for the Eastern District of Michigan (“Court”). The Court is presiding over
a class action lawsuit called Crawford, et al. v. FCA US LLC, Civil Action No. 2:20-cv-12341 (SJM)(DRG)
(“Action”), which asserts claims on behalf of a class against Defendant FCA US LLC (“FCA US”). You are
receiving this notice because you are believed to have purchased an Eligible Truck, making you a “Class
Member” in the Action.
• The purpose of this Notice is to advise you that on September 11, 2025, the Court preliminarily approved a
proposed settlement of all claims asserted in the Action.1
• The lawsuit alleges that Model Year 2014-2019 Dodge Ram 1500 EcoDiesel Trucks or 1500 Classic Trucks
purchased or leased in the United States contained defective Exhaust Gas Recirculation (“EGR”) coolers that
were susceptible to thermal fatigue, leading the coolers to crack over time and leak coolant, which can cause
combustion within the intake manifold and lead to a vehicle fire. FCA US has not been found liable for any claims
alleged in the lawsuit. The Parties have reached a voluntary settlement to avoid lengthy litigation. People who
owned or leased the Eligible Trucks, referred to as “Class Members,” might be entitled to compensation if they
submit valid and timely claims.
• Under the proposed Settlement, FCA US will provide financial and other benefits for certain EGR cooler-related
repairs and/or fires that were caused by a failed EGR cooler.
• To qualify for benefits under the Settlement, you must have bought or leased an Eligible Truck in the United
States. To check whether your vehicle might be an Eligible Truck, you can visit the Settlement website at
www.EcoDieselEGRCoolerCase.com or call 888-885-2707 and ask whether your vehicle is included in the
Settlement. Whether you visit the website or call the toll-free number, you will need to have your Vehicle
Identification Number (“VIN”) ready.
1
The full terms of the Settlement are set forth in the Settlement Agreement between Plaintiffs and FCA US, a copy of which can be viewed
on the Settlement website, www.EcoDieselEGRCoolerCase.com. All capitalized terms used herein and not otherwise defined herein have the
meanings set forth in the Settlement Agreement. In the event of any conflicts between the terms of this Notice and the Settlement Agreement,
the Settlement Agreement shall control.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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• The benefits under the Settlement are:
o Warranty Extension. FCA US will provide a warranty extension applicable to the Eligible Truck that covers
the cost of all parts and labor needed to repair a failed EGR cooler. The extended coverage is for five years
from the date of the EGR cooler replacement under Recall VB1. If a Class Member has incurred out-of- pocket
costs to replace a failed EGR cooler within five years of a replacement under Recall VB1, FCA US will
reimburse those costs upon the Class Member’s submission of proof of repair and proof of payment of
those out-of-pocket costs. The Class Member must submit their proof of repair and proof of payment to
www.fcarecallreimbursement.com. If, as of the Effective Date, the five-year warranty extension period has
not yet concluded for a Class Member, and an EGR cooler repair becomes necessary, the Class Member will
be able to present their vehicle to an FCA US authorized dealership for a free repair. The Class Member need
not present any Settlement-related document to receive warranty service at an FCA US authorized dealership.
The warranty extension follows the Eligible Truck and is not personal to any owner or lessee.
o Reimbursement Program. Class Members may submit reimbursement claims for out-of-pocket tow truck,
rental car, and coolant costs that relate to a failed EGR cooler. FCA US will pay up to a maximum of $750,000
for all tow truck, rental car, and coolant claims. Claims shall not exceed $500 per Eligible Truck for rental car
reimbursements. Claims shall not exceed $75 for coolant reimbursements. All claims must be accompanied
by proof of ownership of a Eligible Truck, proof of payment of a reimbursable expense, and proof of a repair
showing the payment was made in connection with a contemporaneous repair of a failed EGR cooler. If all
valid claims exceed $750,000, they will be paid on a pro rata basis.
o Payments to Class Members Who Suffered an Eligible Truck Fire. Class Members may submit a claim
for $3,000 for a vehicle fire that was caused by a failed EGR cooler. All claims must be accompanied by proof
of ownership of a Eligible Truck and proof of a fire in the Eligible Truck that was caused by a failed EGR
cooler. The acceptable proof of a fire is a police report, insurance report or fire department report and the
acceptable proof of cause is a police report, insurance report, fire department report, or vehicle repair record
that mentions an EGR cooler or origin in the area of an EGR cooler.
• The Court still has to decide whether to finally approve the Settlement. Final approval of the Settlement by the
Court will resolve the lawsuit.
• Your legal rights will be affected whether or not you act. This Notice includes important information about the
lawsuit and the Settlement.
A SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
The only way to get a reimbursement or compensation. However, it is not necessary
SUMBIT A PROOF OF to submit a proof of payment or Claim Form to benefit from the warranty extension.
PAYMENT OR CLAIM FORM The deadline to submit proof of payment or submit a Claim Form is May 16, 2026.
Any extension of this date will be posted on the Settlement website.
Get no reimbursement, compensation, or coverage under the warranty extension.
This is the only option that allows you to ever file or be a part of any pending or
EXCLUDE YOURSELF future lawsuit against FCA US about the legal claims in this case. The deadline to
submit a request for exclusion is February 8, 2026.
In order to object to the Settlement, you must remain a member of the lawsuit—you
cannot ask to be excluded. You may object to the Settlement by writing to the
OBJECT Settlement Administrator and the Court (identified on page 13) and indicating why
you do not like the Settlement. The deadline to object is January 9, 2026.
GO TO THE COURT’S
FINAL FAIRNESS HEARING If you submit a written objection, you may (but you do not have to) attend the
ON March 17, 2026 at hearing and, at the discretion of the Court, speak to the Court about your objection.
10:00 a.m.
Get no reimbursement or compensation. However, you will receive the benefit of
DO NOTHING the warranty extension.
Your rights and options are explained in more detail in this Notice.
Please read this Notice carefully and completely.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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WHAT THIS NOTICE CONTAINS
BASIC INFORMATION..............................................................................................................................................4
1. Why did I get this Notice?
2. What is this lawsuit about?
3. Who is the Defendant?
4. Why is this a class action?
5. Why is there settlement of this Action with FCA US?
WHO IS AFFECTED BY THE SETTLEMENT?............................................................................................................5
6. Am I a member of the Class?
7. If I bought or leased an Eligible Truck that has not had problems, am I included?
8. What if I am still not sure whether I am included?
THE BENEFITS OF THE SETTLEMENT..................................................................................................................... 5
9. What does the Settlement provide?
10. How do I receive reimbursement or make a claim?
11. When would I get my reimbursement or payment?
12. What if my request for reimbursement or claim is found to be deficient?
13. What am I giving up to receive a payment?
EXCLUDING YOURSELF FROM THE CLASS...........................................................................................................8
14. Can I exclude myself from the Class?
15. If I do not exclude myself, can I sue for the same thing later?
16. If I exclude myself, can I get the benefits of this Settlement?
THE LAWYERS REPRESENTING YOU......................................................................................................................9
17. Who Represents me?
18. How will the lawyers be paid?
OBJECTING TO THE SETTLEMENT AND/OR THE REQUEST FOR ATTORNEYS’ FEES, EXPENSES AND SERVICE
AWARDS................................................................................................................................................................... 9
19. How do I object to the Settlement?
20. What is the difference between objecting and excluding?
THE COURT’S FAIRNESS HEARING..................................................................................................................... 10
21. When will the Court decide whether to approve the Settlement?
22. Do I have to come to the hearing?
23. May I speak at the hearing?
IF YOU DO NOTHING.............................................................................................................................................. 11
24. What if I do nothing?
GETTING MORE INFORMATION............................................................................................................................ 11
25. Where can I get more information?
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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Basic Information
1. Why Did I Get This Notice?
You received this Notice because you appear in FCA US’s records as having purchased or leased in the United States a
Model Year 2014-2019 Dodge Ram 1500 EcoDiesel Truck manufactured between June 12, 2013 and October 23, 2019.
The Court has directed that this Notice be sent to you because, as a potential member of the Class, you have the right to
know about the Settlement reached in this Action between Plaintiffs (on behalf of the Class) and Defendant FCA US,
and about all of your options before the Court decides whether to approve the Settlement. This Notice explains the
lawsuit, the Settlement, and your legal rights.
The Court in charge of this Action is the United States District Court for the Eastern District of Michigan. The case
is called Crawford, et al. v. FCA US LLC, Civil Action No. 2:20-cv-12341 (SJM)(DRG). United States District Court
Judge Stephen J. Murphy, III is overseeing this Action. The persons who brought this case are the plaintiffs, and the
company they sued is called defendant.
2. What Is This Lawsuit About?
The lawsuit alleges that Model Year 2014-2019 Dodge Ram 1500 EcoDiesel Trucks, manufactured between
June 12, 2013 and October 23, 2019, and purchased or leased in the United States (“Eligible Trucks”) contained
defective Exhaust Gas Recirculation (“EGR”) coolers that were susceptible to thermal fatigue, leading the coolers to
crack over time and leak coolant, which can cause combustion within the intake manifold and lead to a vehicle fire.
FCA US denies the allegations and the Court has not made any final decision on the merits of Plaintiffs’ claims
because the parties have agreed to settle the claims. On September 11, 2025, the Court granted preliminary approval
of the Settlement.
3. Who Is The Defendant?
The Defendant is FCA US. The Settlement would resolve all claims against FCA US.
4. Why Is This A Class Action?
In a class action, one or more individuals or entities, called “class representatives,” sue on behalf of others who have
similar claims. The class representatives in this case are Bradley Crawford, Christian Christensen, Glenn Brainard,
Jacob Lane, Russell Raley, Hank Vanderhulst, Michael O’Brien, Dennis Sullivan, Matthew Ogren, Shaun Graham,
Brandon Bailey, Gregory Briggs, Kara Gulbranson, Derek Griesel, Patrick Phelan, James Deale, Paul Maier, Nathan
Felker, Greg Gouker, Leroy Mault, Dennis Diaz, Reyes Vargas, Gary Grendahl, Kevin Hunting, Justin Ewing, and
Kwaterski Construction, Inc. (collectively referred to herein as “Plaintiffs”).
The Plaintiffs and the individuals or entities with similar claims are individually “class members,” together forming
a class. One court resolves the issues for all class members, except for those who exclude themselves from the class.
5. Why Is There A Settlement Of This Action With FCA US?
FCA US has denied all liability and wrongdoing in this case and has asserted various defenses to the Plaintiffs’ claims.
The Court did not decide in favor of the Plaintiffs or Defendant. Instead, both sides agreed to the Settlement. That
way, they avoid the cost and risk of a trial, and the Class Members affected can get compensation.
This Settlement is the product of extensive negotiations between lawyers for the Plaintiffs and Defendant. The Plaintiffs
and Proposed Co-Lead Class Counsel think the Settlement is fair and in the best interests of all Class Members.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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Who is Affected by the Settlement?
6. Am I A Member Of The Class?
The Class is defined as:
All individuals who purchased or leased in the United States a Model Year
2014-2019 Dodge Ram 1500 EcoDiesel Truck manufactured between June 12, 2013
and October 23, 2019.
Excluded from the Settlement Class are: FCA US; any affiliate, parent, or subsidiary of FCA US; any entity in which
FCA US has a controlling interest; any officer, director, or employee of FCA US; any successor or assign of FCA US;
and any judge to whom this Action is assigned, his or her spouse; individuals and/or entities who validly and timely
opt out of the settlement; and current or former owners of Eligible Trucks who previously released their claims in an
individual settlement with FCA US relating to the Action.
If you fall within this definition, and you did not previously exclude yourself from the Class, you are a Class Member.
7. If IBought Or Leased An Eligible Truck That Has Not Had Problems, Am I Included?
Yes. You did NOT have to experience problems with the EGR cooler or an engine fire to be included in this Settlement.
If you still own or lease an Eligible Truck, you are eligible to take advantage of the Settlement’s warranty extension
covering the cost of all parts and labor needed to repair a failed EGR cooler. The extended coverage is for five years
from the date of the EGR cooler replacement under Recall VB1.
8. What If I Am Still Not Sure Whether I Am Included?
Class Members have been identified using Vehicle Identification Numbers (“VINs”) obtained from FCA US. The
VINs were used to obtain the names and most current addresses of Class Members.
If you are still not sure if you are a Class Member, you can get more information by visiting
www.EcoDieselEGRCoolerCase.com. You may also contact the Settlement Administrator:
Crawford v. FCA US LLC
Settlement Administrator
PO Box 4219
Portland, OR 97208-4219|
The Benefits Of The Settlement
9. What Does The Settlement Provide?
In accordance with the terms of the Settlement, Defendants have agreed to:
1. Warranty Extension
FCA US will provide a warranty extension applicable to the Eligible Truck that covers the cost of all parts and
labor needed to repair a failed EGR cooler. The extended coverage is for five years from the date of the EGR cooler
replacement under Recall VB1.
If a Class Member has incurred out-of-pocket costs to replace a failed EGR cooler within five years of a replacement
under Recall VB1, FCA US will reimburse those costs upon the Class Member’s submission of proof of repair and
proof of payment of those out-of-pocket costs. The Class Member must submit their proof of repair and proof of
payment to the settlement administrator.
If, as of the Effective Date, the five-year warranty extension period has not yet concluded for a Class Member, and
an EGR cooler repair becomes necessary, the Class Member will be able to present their vehicle to an FCA US
authorized dealership for a free repair. The Class Member need not present any Settlement-related document to
receive warranty service at an FCA US authorized dealership.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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The warranty extension follows the Eligible Truck and is not personal to any owner or lessee.
Except for the durational limits of the warranty extension, the terms and exclusions of the Eligible Trucks’ applicable
warranties remain notwithstanding this Settlement. All rights and conditions under the applicable warranties will
continue to remain. Nothing in the Settlement Agreement is construed as diminishing or otherwise affecting any other
express or implied warranties covering the Eligible Trucks.
You do NOT need to submit any documentation to receive this warranty extension under this Settlement.
2. Reimbursement Program
Class Members may submit reimbursement claims for out-of-pocket tow truck, rental car, and coolant costs that relate
to a failed EGR cooler. FCA US shall pay up to a maximum of $750,000 for all tow truck, rental car, and coolant claims.
Claims shall not exceed $500 per Eligible Truck for rental car reimbursements. Claims shall not exceed $75 for coolant
reimbursements. All claims must be accompanied by proof of ownership of a Eligible Truck, proof of payment of a
reimbursable expense, and proof of a repair showing the payment was made in connection with a contemporaneous
repair of a failed EGR cooler. If all valid claims exceed $750,000, they will be paid on a pro rata basis.
3. Payments to Class Members Who Suffered an Eligible Truck Fire.
Class Members may submit a claim for $3,000 for a vehicle fire that was caused by a failed EGR cooler. All claims
must be accompanied by proof of ownership of a Eligible Truck and proof of a fire in the Eligible Truck that was
caused by a failed EGR cooler. The acceptable proof of a fire is a police report, insurance report or fire department
report, and the acceptable proof of cause is a police report, insurance report, fire department report, or vehicle repair
record that mentions an EGR cooler or origin in the area of an EGR cooler.
10. How Do I Seek Reimbursement Or Make A Claim?
Reimbursement Related to EGR Repair. To seek reimbursement of out-of-pocket costs related to an EGR cooler
repair under the warranty extension provided by the Settlement, you must submit a proof of payment of those
out-of-pocket costs to the settlement administrator per the below directions. All requests for reimbursement must
be received by May 16, 2026.
Reimbursement Related to Alleged EGR Failure.
All reimbursement claims for out-of-pocket tow truck, rental car, and coolant costs that relate to a failed EGR cooler
shall be made to the settlement administrator, and the deadline for claims is May 16, 2026. To be valid, the claim
submission must include: (a) a completed Claim Form (available on the Settlement Website); (b) proof of payment of
a reimbursable expense, and proof of a repair showing the payment was made in connection with a contemporaneous
repair of a failed EGR cooler; and (c) documentation identifying the vehicle (including VIN) and ownership. Claims
that lack third-party records to verify a claim will be rejected.
Payment for Eligible Truck Fire.
All Eligible Truck fire claims shall be made to the settlement administrator, and the deadline for claims is
May 16, 2026. To be valid, the claim submission must include: (a) a completed Claim Form (available on the
Settlement Website); (b) proof of a fire (such as a police report, insurance report or fire department report); (c) proof
the fire was caused by a failed EGR cooler (such as a police report, insurance report, fire department report, or vehicle
repair record that mentions an EGR cooler or origin in the area of an EGR cooler); and (d) documentation identifying
the vehicle (including VIN) and ownership. Claims that lack third-party records to verify a claim will be rejected.
Submission of Claims.
Claims submitted pursuant to this Settlement may be submitted, at the election of the Claimant, to the settlement
administrator by U.S. mail, email, or through the dedicated Settlement Website.
The mailing address and email address to which Claimants may submit Claims is as follows:
Email address: [email protected]
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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Mailing address:
Crawford v. FCA US LLC
Settlement Administrator
PO Box 4219
Portland, OR 97208-4219
If you fail to submit a request for reimbursement or truck fire Claim Form, and the necessary documentation, by the
required deadlines, you will not receive compensation. Sending in a late request for reimbursement or Claim Form
late will be the same as doing nothing. Please DO NOT send requests for reimbursement or truck fire Claim Forms
to Co-Lead Class Counsel or the Court.
11. When Would I Get My Reimbursement Or Payment?
There is no date certain for receiving the requested reimbursements or payment for an Eligible Truck fire. Any
payments under the Settlement will begin once the Settlement has been finally approved by the Court and any
appeals from that decision are completed. If there are objections or appeals, the date will be later.
The Hon. Stephen J. Murphy, III, U.S. District Court Judge, will hold a Fairness Hearing at 10:00 a.m. on March
17, 2026, at the Theodore Levin U.S. Courthouse, Courtroom 216, 231 W. Lafayette Blvd., Detroit, MI 48226,
to decide whether to approve the Settlement. The hearing may be rescheduled without further notice to you, so
it is recommended you periodically check the Settlement Website - www.EcoDieselEGRCoolerCase.com - for
updated information.
12. What If My Request for Reimbursement or Claim Is Found To Be Deficient?
If a reimbursement claim for out-of-pocket tow truck, rental car, and coolant costs, or claim for an Eligible Truck fire,
is found to be deficient and is rejected during the review process by the Settlement Administrator, the Class Member
will be notified of the deficiency in writing. The Class Member will then have an opportunity to remedy the deficiency
within 30 days of the written notice.
13. What Am I Giving Up To Receive A Payment?
Unless you exclude yourself, you will remain in the Class, and that means that you cannot sue, continue to sue, or be
part of any other lawsuit against FCA US related to the EGR cooler in the Eligible Trucks. It also means that all of the
Court’s orders will apply to you and legally bind you.
As set forth in Sections II and VI of the Settlement Agreement:
In consideration for the Settlement Agreement, Plaintiffs, and each Class Member, on behalf of herself and any
other legal or natural persons who may claim by, through, or under them, agree to fully, finally, and forever release,
relinquish, acquit, and discharge the Releasees from the Released Claims.
• “Released Claim(s)” means any and all claims, demands, debts, suits, liabilities, obligations, damages, actions,
rights of action, and causes of action of every nature and description, whether known or unknown, asserted
or unasserted, foreseen or unforeseen, regardless of any legal theory, existing now or arising in the future, by
Plaintiffs and any and all other Class Members relating to a defective EGR cooler in a Class Vehicle, whether
arising under statute (including a state lemon law), rule, regulation, common law or equity, and including, but
not limited to, any and all claims, causes of action, rights, or entitlements under any federal, state, local or other
statute, law, rule and/or regulation, as well as any claims relating to California Business and Professions Code
Sections 17200-17209, California Business and Professions Code Section 17500, or the California Consumer
Legal Remedies Act (California Civil Code Section 1750-1784), or other consumer protection, consumer fraud,
or unfair business practices or deceptive trade practices laws, premised on any legal or equitable theory. This term
includes any claims or causes of action in tort, contract, products liability, negligence, fraud, misrepresentation,
concealment, consumer protection, restitution, quasi contract, unjust enrichment, express warranty, implied
warranty, secret warranty and/or any injuries, losses, damages or remedies of any kind, in law or in equity, under
common law, statute, rule or regulation, seeking compensatory damages, economic losses or damages, exemplary
damages, punitive damages, statutory damages, restitution, recovery of attorneys’ fees or litigation costs, or any
other legal or equitable relief.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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• “Releasee(s)” means jointly and severally, individually and collectively, the entities that marketed the Class
Vehicles, entities that designed, developed, and/or disseminated advertisements for the Class Vehicles, FCA
US, and all affiliates of FCA US and their respective future, present, and former direct and indirect parents,
subsidiaries, affiliates, divisions, predecessors, successors, assigns, dealers, distributors, agents, principals,
suppliers, vendors, issuers, licensees, and joint ventures, and their respective future, present, and former officers,
directors, employees, partners, general partners, limited partners, members, managers, agents, shareholders
(in their capacity as shareholders) and legal representatives, and the predecessors, successors, heirs, executors,
administrators, and assigns of each of the foregoing. As used in this paragraph, “affiliates” means entities
controlling, controlled by, or under common control with a Releasee.
However, nothing in this Settlement will prohibit you from pursuing claims for (i) death, (ii) personal injuries,
(iii) damage to tangible property other than an Eligible Truck, or (iv) subrogation.
Excluding Yourself From The Class
If you want to keep the right to sue or continue to sue Defendant on your own about the legal issues being resolved
by the Settlement, then you must take steps to get out of the Class. This is called excluding yourself - or sometimes
referred to as “opting out.” If you opt out of the Class, you will not receive the benefits or reimbursements provided
in this Settlement.
14. Can I Exclude Myself From The Class?
If you want to keep the right to sue or continue to sue FCA US about the legal issues in this case, then you must
exclude yourself from the Class.
To exclude yourself, you must send a letter saying that you want to be excluded from the Class.
The letter must: (i) state your full name and current address; (ii) provide the model year and VIN of your Eligible Truck
and the approximate date(s) of purchase or lease; and (iii) specifically and clearly state your desire to be excluded
from the Settlement and from the Class. You must personally sign the letter requesting exclusion. Exclusions by letter
should be sent to:
Crawford v. FCA US LLC
Settlement Administrator
PO Box 4219
Portland, OR 97208-4219|
Exclusions sent by letter must be postmarked by February 8, 2026.
If you ask to be excluded from the Class, you will not get any benefit pursuant to the Settlement and you cannot
object to the Settlement. If you want to receive the benefits or reimbursements from the Settlement, do not
exclude yourself.
Warning! If your request for exclusion is sent after the deadline, your request for exclusion will be considered invalid
and you will not be excluded from the Class. You cannot exclude yourself on the phone or by email. Please keep
a copy or screenshot of any exclusion (or opting out) request for your records.
15. If I Do Not Exclude Myself, Can I Sue For The Same Thing Later?
No. Unless you exclude yourself, if the Court approves the Settlement, you give up any right to sue Defendant for the
claims that the Settlement resolves. If you have a pending lawsuit against Defendant related to the EGR cooler in the
Eligible Trucks, speak to your lawyer in that case immediately. You must exclude yourself from the Class in order to
continue your own lawsuit against Defendant.
16. If I Exclude Myself, Can I Get The Benefits Of This Settlement?
No. If you exclude yourself, do not send in a request for reimbursement or Claim Form for payment related to an
Eligible Truck fire. However, you may sue, continue to sue, or be part of a different lawsuit against FCA US and other
related entities or individuals for the claims that this Settlement resolves.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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The Lawyers Representing You
17. Who Represents Me?
The Court has preliminarily appointed The Miller Law Firm, P.C., Hagens Berman Sobol Shapiro LLP, and Robins
Kaplan LLP as Proposed Co-Lead Class Counsel to represent the Class.
If you want to be represented by your own lawyer and have that lawyer appear in court for you concerning the
Settlement, you may hire one at your own expense. If you hire your own lawyer, you must tell the Court and send a
copy of your notice to the Settlement Administrator at the address set forth in Question 25 below.
18. How Will The Lawyers Be Paid?
You are not personally responsible for payment of attorneys’ fees or expenses. Proposed Co-Lead Class Counsel will
apply to the Court for an award of attorneys’ fees, service awards, and expenses prior to the final approval hearing.
The Parties have agreed that Proposed Co-Lead Class Counsel may apply to the Court for up to $2,450,000, inclusive
of all attorneys’ fees and expenses. These attorneys’ fees and expenses shall be in addition to the benefits provided
directly to the Class and shall not reduce or otherwise have any effect on the benefits made to the Class.
Per agreement with FCA US, Proposed Co-Lead Class Counsel will also request with the Court a service award of
$5,000 for each Plaintiff appointed as a Class Representative. FCA US will separately pay these service awards and
they shall not reduce or otherwise have any effect on the benefits made to the Class. In addition, Proposed Co-Lead
Class Counsel may provide an additional $2,500 to some or all of the Class Representatives at Proposed Co-Lead
Class Counsel’s discretion. Any such $2,500 payment would come from the award of attorneys’ fees and expenses.
FCA US will also separately pay the costs to administer the Settlement. The payment of Settlement administration
costs will not reduce or otherwise have any effect on the benefits made to the Class.
Objecting to the Settlement and/or the Request for Attorneys’ Fees,
Expenses and Service Awards
19. How Do I Object To The Settlement?
If you are a Class Member (and have not excluded yourself), you may tell the Court that you object to (or disagree
with) all or part of the Settlement and/or Proposed Co-Lead Class Counsel’s request for an award of attorneys’ fees,
reimbursement of expenses, and service awards to Plaintiffs. You must give reasons for your objection(s). The Court
will consider your objections when it decides whether or not to finally approve the Settlement.
To state a valid objection, you must provide the following information in the written objection:
(i) the case name and number, Bradley Crawford, et al. v. FCA US, LLC, Case No. 2:20-cv-12341 (E.D. Mich.);
(ii) your full name, current address, and current telephone number;
(iii) the model year and VIN of your Eligible Truck(s);
(iv) a statement of the objection(s), including all factual and legal grounds for the position;
(v) copies of any documents you wish to submit in support;
(vi) the name and address of the attorney(s), if any, who represent you in making the objection or who may
be entitled to compensation in connection with the objection;
(vii) a statement of whether you intend to appear at the Final Approval Hearing, either with or without counsel;
(viii) the identity of all counsel (if any) who will appear on behalf of you at the Final Approval Hearing and
all persons (if any) who will be called to testify in support of the objection;
(ix) your handwritten signature, in addition to the signature of any attorney representing you in connection
with the objection, and
(x) the date of the objection.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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In addition, you must provide a list of any other objections submitted by you or your counsel to any class action
settlements in any court in the United States in the previous five years. If you or your counsel have not made any such
prior objection, you will affirmatively state so in the written materials provided with the objection.
Submitting an objection allows Proposed Co-Lead Class Counsel or counsel for Defendant to notice your deposition
and to seek any documentary evidence or other tangible things that are relevant to your objection. Failure to make
yourself available for such deposition or comply with expedited discovery requests may result in the Court striking
your objection or denying you the opportunity to be heard. The Court may require you or your counsel to pay the costs
of any such discovery should the Court determine the objection is frivolous or made for improper purpose.
To object, you must file your written objection(s) with the Court at the following address and postmarked by Friday,
January 9, 2026:
Clerk of Court
Theodore Levin U.S. Courthouse
231 W. Lafayette Blvd., Room 599
Detroit, MI 48226
You must also send a copy of your written objection(s) to Proposed Co-Lead Class Counsel and Counsel for Defendants,
through the Settlement Administrator at the following address and postmarked by Friday, January 9, 2026:
Crawford v. FCA US LLC
Settlement Administrator
PO Box 4219
Portland, OR 97208-4219|
Objections submitted after January 9, 2026 will not be considered. If you do not state your intention to appear in
accordance with the applicable deadlines and specifications, or you do not submit an objection in accordance with
the applicable deadlines and specifications, you will waive all objections and can be barred from speaking at the final
approval hearing.
20. What Is The Difference Between Objecting And Excluding?
Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement
only if you are a Class Member and stay in the Class. Excluding yourself, or “opting out,” means that you are
removing yourself from the Class and will have no right to benefits from the Settlement. If you exclude yourself, you
also have no right to object to the Settlement, because the Settlement no longer affects you.
The Court’s Fairness Hearing
21. When Will The Court Decide Whether To Approve The Settlement?
The Court will hold a Fairness Hearing at 10 a.m. on March 17, 2026, at the Theodore Levin U.S. Courthouse,
Courtroom 216, 231 W. Lafayette Blvd., Detroit, MI 48226. At the Fairness Hearing, the Court will consider whether
the Settlement is fair, reasonable, and adequate and whether to approve the request for attorneys’ fees, expenses, and
service awards. The Court will listen to Class Members who have asked to speak at the hearing. If there are objections
or comments, the Court will consider them at that time. After the hearing, the Court will decide whether to approve
the Settlement and the request for attorneys’ fees, expenses, and service awards. We do not know how long a decision
will take to be made.
Important! The time and date of the Fairness Hearing may change without additional mailed or publication notice.
For updated information on the Fairness Hearing, visit www.EcoDieselEGRCoolerCase.com.
22. Do I Have To Come To The Hearing?
No. Proposed Co-Lead Class Counsel will be prepared to answer any questions the Court may have at the Fairness
Hearing. However, you are welcome to attend the hearing at your own expense. If you send an objection, you do not
have to come to court to explain. As long as you mailed your written objection on time as set out in this Notice, the
Court will consider it. You may also pay another lawyer to attend the hearing, but it is not required.
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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23. May I Speak At The Hearing?
You may ask the Court for permission to speak at the Fairness Hearing. If you wish to do so, you must file a Notice
of Intention to Appear with the Court at the following address postmarked by March 17, 2026:
Clerk of Court
Theodore Levin U.S. Courthouse
231 W. Lafayette Blvd., Room 599
Detroit, MI 48226
You must also mail copies of the Notice of Intention to Appear to the Settlement Administrator listed in Question 25
below, postmarked no later than March 17, 2026.
If You Do Nothing
24. What If I Do Nothing?
If you do nothing, you will not receive any reimbursements or payment from this Settlement. However, you will be
entitled to the benefits of the warranty extension. But, unless you exclude yourself, you will not be able to start a
lawsuit, continue a lawsuit, or be part of any other lawsuit against FCA US or other related entities or individuals
about the legal issues in this case, ever again.
The Settlement will not affect your right to sue Defendant for any claims not resolved by the Settlement, regardless
of whether or not you exclude yourself from the Settlement.
Getting More Information
25. Where Can I Get More Information?
This Notice summarizes the Settlement. More details are in the Settlement Agreement. You can review the Settlement
Agreement and other documents related to the Action by visiting www.EcoDieselEGRCoolerCase.com. In addition,
Proposed Co-Lead Class Counsel’s motions for final approval of the Settlement is currently due to be filed with the
Court by February 9, 2026. The motion requesting attorneys’ fees, expenses, and service awards is currently due to
be filed with the Court by December 10, 2025. Both motions will be available for review on the Settlement Website.
If you have questions or want more information, you may contact the Settlement Administrator toll free
888-885-2707 or via mail:
Crawford v. FCA US LLC
Settlement Administrator
PO Box 4219
Portland, OR 97208-4219
PLEASE DO NOT WRITE OR CALL THE COURT
OR THE CLERK’S OFFICE FOR INFORMATION.
DATED: [DATE] BY ORDER OF THE COURT UNITED STATES
DISTRICT COURT FOR THE EASTERN DISTRICT
OF MICHIGAN
Questions? Call 888-885-2707 toll-free, or visit
www.EcoDieselEGRCoolerCase.com.
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