Lion Electric Stockholders Litigation $4M Settlement

This settlement is for eligible non-redeeming NGA Class A stockholders. Receiving the notice alone does not establish that you qualify or guarantee a payment.

• You had to hold NGA Class A common stock at the close of trading on April 21, 2021 and not redeem all of those shares.
• You must submit a timely, valid Proof of Claim and Release with adequate supporting documentation.
• Your payment, if any, is based on your recognized claim compared with the recognized claims of other approved claimants.

The notice contains detailed exclusions in addition to the basic ownership and non-redemption requirements.

• Defendants and their immediate families are excluded.
• The exclusion also covers specified affiliated or controlled persons and entities, and certain legal representatives, heirs, successors, and assignees, when they held the shares at the relevant time.
• Trusts, estates, entities, and accounts that held shares for an excluded person’s benefit are also excluded.

These figures are used to weigh approved claims against one another. They are not a promise of the amount you will receive.

• For shares sold after April 21, 2021 but before the May 6, 2021 merger closing, the loss amount generally uses the $10 redemption price minus the sale price if the sale price was below $10.
• For converted Lion Electric shares sold after May 6, 2021 and before November 1, 2023, the same $10-minus-sale-price approach applies when the sale price was below $10.
• Shares still held as Lion Electric shares at the close of trading on November 1, 2023 have a stated loss amount of $8.47 per share.
• Each eligible share also receives a $0.10 nominal amount under the plan.

Only eligible NGA Class A shares are covered by the plan. The notice also applies special rules to certain trading situations.

• No loss amount is available for NGA Class A shares redeemed before the merger or for Founder Shares.
• Options themselves cannot participate. If eligible shares were bought or sold by exercising an option, the plan uses the exercise date and exercise price for those shares.
• Short sales and purchases that cover short sales have a zero loss amount.

Submit the Proof of Claim and Release by the deadline with supporting records. Because the notice does not specify every document that will be accepted, use the claim form for the full documentation requirements.

• The notice requires adequate supporting documentation but does not list a fixed set of documents.
• Keep records showing your ownership of, and transactions in, NGA and/or New Lion Electric common stock. The notice says they may be needed to document your claim.
• The parties and the settlement administrator do not have your transaction information.

The amount paid can be different from the loss amount. It depends on the net fund and all approved claims.

• Approved claimants whose calculated distribution is less than $10 will not be paid.
• The initial distribution occurs only after claims are processed and the settlement has final approval.
• If money remains 180 days after the initial distribution, there may be another distribution to approved claimants who cashed their first checks and would receive at least $10, if doing so is cost-effective.

Not filing a claim is not the same as leaving the settlement. The notice says you cannot leave this class action settlement.

• No. This is a non-opt-out class, so class members cannot exclude themselves from the settlement.
• If you do not submit a valid claim, you will not receive a payment, but you remain bound by the settlement and its release of covered claims.

An objection is for challenging the settlement, allocation plan, or requested fees and expenses. It does not remove you from the class.

• You must file your written objection and supporting papers with the Register in Chancery, serve them on plaintiffs’ and defendants’ counsel, and email a copy to the listed counsel by November 13, 2026.
• Your objection must identify the case, provide your contact information, be signed, explain the factual and legal reasons for the objection, and include documents showing you are a class member.
• You may object in writing without attending the hearing. To speak at the hearing, you must also timely file and serve a notice of appearance, unless the court orders otherwise.

The court will consider properly submitted objections even if the objector does not attend.

• Class members do not need to attend the hearing to seek payment.
• The hearing is scheduled for December 1, 2026, at 11:00 a.m., in Wilmington, Delaware, unless the court changes it.
• The court may hold the hearing remotely or change its date or time without another written notice.

The five named plaintiffs may also ask for incentive awards up to $1,500 each, but those awards would come only from counsel’s fee award, not as an additional deduction from the fund.

• Plaintiffs’ counsel plan to request attorneys’ fees up to 20% of the $4 million settlement amount, plus litigation expenses.
• The court decides any fee and expense award.
• Any approved fees and expenses come from the settlement fund, reducing the amount available for distributions. Class members are not personally responsible for them.