lass Counsel:
C ettlement Administrator:
S ou may access the Settlement Website by
Y
Attorney Richard Shenkan Class-Settlement.com using the camera on your mobile device to
Shenkan Injury Lawyers, LLC. PO Box 9009 scan this QR code:
6550 Lakeshore St. West Bloomfield, MI 48323 Hicksville, NY 11802-9009
Email: [email protected] Toll Free Number: 1 (877) 268-2976
Fax No: 1-(888) 769-1774
Toll Free Number: 1(800) 490-9287
OURT OF COMMON PLEAS
C
LACKAWANNA COUNTY, PENNSYLVANIA
NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
RE: Case No. 14-cv-5108
Steven Roses, individually and on behalf of all others similarly situated v. Peoples Security Bank & Trust
Company and Peoples Financial Services Corp.
A Court has authorized this Notice. This is not a solicitation from a lawyer. You are receiving this
Notice because you may be a Class Member for purposes of a proposed Settlement. Your rights may
be affected whether or not you act in response to this Notice. Please read this Notice carefully.
HY HAVE YOU BEEN SENT THIS NOTICE
W p eople who meet this definition are known as “Class
The class action lawsuit Steven Roses, individually and on Member(s).”
behalfofallotherssimilarlysituatedv.PeoplesSecurityBank&
Trust and Peoples Financial Services Corp., 14-cv-5108, (the he relevant time period for theSettlementisfromSeptember
T
“Litigation”), is pending before the Honorable Margaret A. 15,2008throughNovember7,2017. AccordingtoDefendants’
BisignaniMoyleintheCourtofCommonPleasofLackawanna records,youareaClassMember.Ifyoudonotexcludeyourself
County,Pennsylvania.ThepartiestotheLitigationhavereached (optout)fromtheSettlementasdiscussedherein,thenyouwill
a proposed settlement (the “Settlement”). be subject to and bound by the terms of the Settlement.
he Settlement, if approved by the Court, will resolve the
T Accordingly, please read this Notice carefully.
Litigation filed by Steven Roses (“Plaintiff” or “Class
Representative”) against Peoples Security Bank & Trust and nder the Settlement, Defendants will provide a gross
U
Peoples Financial Services Corp. (“Defendants”) over whether settlementpaymentof$1,152,673.00toaSettlementFundtobe
Defendants complied with the Pennsylvania Uniform used to pay (i) a pro rata cash payment for each Account
Commercial Code (“UCC”), independently, andinconjunction associated with aClassMember;(ii)thecostsofadministering
with the Pennsylvania Motor Vehicle Sales Finance Act theSettlement;(iii)attorneys’feesandexpenses,asawardedby
(“MVSFA”), and the Fair Credit Extension Uniformity Act. the Court, and (iv) an Incentive Payment to the Class
Plaintiff alleges that Defendants violated the requirements Representative, as awarded by the Court. The pro rata cash
relating to various laws governing therepossessionofvehicles payments for Accounts with more than one borrower will be
and collection of debt.Defendantsdenyanddisputetheclaims split evenly among the co-borrowers, unless requested
asserted in the Litigation. The Settlement avoids thecostsand otherwise, as explained below.
risks to the parties associated with proceeding with the ro Rata Cash Payments
P
Litigation.
TheamountremainingintheSettlementFund,afterpaymentof
he Settlement defines the “Class”1 as: individuals including
T the attorneys’ fees and expenses, the Incentive Award to the
Plaintiff but excluding Anthony Rakus, who within the Class Class Representative,andpaymentofsettlementadministration
Period: (a) financed a motor vehicle primarily for personal, expenses,willbedividedamongtheClassMembersonanequal
familyorhouseholdusethroughDefendantsorwhoseconsumer per-Accountbasis.Thiswillresultinananticipatedproratacash
loancontractorinstalmentsalescontractwasassignedtooneof payment of approximately $1,300 per Account. Ifyouwereto
theDefendants;(b)hadaPennsylvaniaaddressasofthedateof exclude yourself from the Settlement and pursue the claims
repossession; (c) experienced the repossession of their vehicle made in this Class Action in your ownindividuallawsuit,and
byoratthedirectionofeitherDefendant,assecuredparty;and assuming you ultimately prevailed, you would be entitled to
(d) Either: (A) Were sent a Notice of Repossession by receive either actual damages, for anyactualdamagesyoucan
Defendant(s)ortheiragentwhichfailedto:(1)statetheintended prove,or(ifyoupurchasedtherepossessedvehicleforconsumer
method of disposition; or, (2) state the time and place of any use) minimum statutory damages. Your minimum statutory
publicdisposition;or(3) state that the debtor is entitled toan
accountingoftheunpaidindebtednessandthecharge,ifany,for damages are computed by adding the credit service charge
such an accounting; or (B)Were sent no such notice at all. The (financecharge)plus10%oftheprincipalamountofyourloan.
This information is set forth in your Retail Installment Sales
1
CapitalizedTermsaredefinedintheSettlementAgreement,acopyof
Contract. Pro rata cash payments on Accounts withmorethan
which will be promptly provided upon request.. one borrower will be split evenly among the co-borrowers,
1
nlessrequestedotherwisepursuanttotherequirementssetforth
u our Options
Y
below.ProratacashpaymentsonAccountswithmorethanone
borrowerwheretheSettlementAdministratorcandeterminethat At this time, you are assumed to be a Class Member who is
participating in the Settlement. Therefore, your rights will be
one of the co-borrowers is now deceased will be paid to the affected even if you do nothing. Please read this Notice
surviving co-borrower, absent a request by the legal carefully. The following is a general summary of the actions you
representative, executor, or administrator of the estate of the can take and theresultsofthoseactions.Ifyouwanttohavea
deceased co-borrower pursuant to the requirements set forth detailed discussion regarding your specific situation or have
below. Pro rata cash payments for Accounts with only one other questions or concerns, youmaycontactClassCounselat
borrowerwheretheSettlementAdministratorcandeterminethat 1-(800) 490-9287.
a borrowerisdeceasedwillnotbepaidabsentarequestbythe
legal, executor or administrator of the estate of the deceased
borrower pursuant to the requirements set forth below.
YOUR ACTION RESULT OF THAT ACTION
DO NOTHING ou remain in the Settlement. If the Settlement is approved, you will receive the benefits
Y
summarized in this notice. In exchange, you give up the right to sue Defendants for matters
concerningyourAccountandtherepossessionandsaleofyourvehicleuptotheendoftheClass
Period as set forth in the Settlement Agreement.
ASK TO BE EXCLUDED ou are removed from the Settlement. You will not receive the benefits summarized in this
Y
Notice.However,thisistheonlyoptionthatallowsyoutopursue(orcontinue)yourownlawsuit
or to participate in any other lawsuit against Defendants concerning your Account or the
repossessionandsaleofyourvehicle.Thedeadlineforyoutosubmityoursignedrequesttobe
excluded is September 21, 2026, so you must actpromptly.Notethatifyouexcludeyourself
fromtheSettlement,thentheSettlementwillnotimpactyou,andtherefore,youhavenorightto
objecttotheSettlement.SeeParagraphs15-17and21below.Ifyouexcludeyourselfsothatyou
can pursue yourownindividuallawsuitagainsttheDefendantsandyouexecutedanarbitration
agreement, the Defendants may attempt to enforce the arbitration agreement torequireyouto
submit your claim(s) through arbitration.
BJECT TO THE
O I fyouobjecttotheSettlement,youarestillintheSettlement,butyouhavenotifiedtheCourtin
writingthatyoudonotliketheSettlementandthereason(s)why.Thedeadlineforyoutosubmit
SETTLEMENT asignedobjectionisSeptember21,2026,soyoumustactpromptly.SeeParagraph20,below.If
youexcludeyourselffromtheSettlement,thentheSettlementwillnotimpactyou,andtherefore,
you have no right to object to the Settlement.
EQUEST AN ALTERNATIVE
R I fyouareaco-borroweronanAccount,youmayalsorequestanalternatedivisionoftheprorata
DIVISION OF THE PRO RATA cashpaymentbetweenco-borrowersonanAccount,ratherthanthepresumptiveequaldivision.
CASH PAYMENT ThisisnotthesameasobjectingtotheSettlementandyouwillstillbeapartoftheSettlement.
(CO-BORROWERS ONLY) Thedeadlineforyoutosubmitarequestforalternatedivisiontotheequalpaymentallocationis
September 21, 2026, so you must act promptly. SeeParagraph 22, below.
ProratacashpaymentsforAccountswithmorethanoneborrowerwhereoneoftheco-borrowers
REQUEST AN ALTERNATIVE isnowdeceasedwillbepaidtothesurvivingco-borrower,absentawrittenrequestbythelegal
DISTRIBUTION OF THE PRO representative, executor,oradministratoroftheestateofthedeceasedClassMembersupported
RATA CASH PAYMENTS by sufficient documentation. For Accounts with only one borrower where the Settlement
RELATING TO ACCOUNTS Administrator can determinethattheborrowerisdeceased,nopaymentswillbemadeabsenta
WITH DECEASED CLASS writtenrequestbythelegalrepresentative,executor,oradministratoroftheestateofthedeceased
EMBERS
M Class Member supported by sufficient documentation. The deadline for you to submit such
written requests is September 21, 2026, so you must act promptly. Creditors, heirs, or legal
representativesofdeceasedClassMembersestatesareresponsibleforhiringtheirowncounselto
represent them, should they deem it necessary. See Paragraph 11, below.
O TO THE HEARING
G nless you ask to be excluded, you are still in the Settlement and get the benefits of the
U
WHERE THE COURT Settlementthatyouareeligiblefor(asexplainedinthisNotice),ifapprovedbytheCourt.Youdo
CONSIDERS WHETHER TO notneedtoattendthehearingtogetthebenefitsoftheSettlement,butyouareinvitedtoattend
APPROVE THE andwillbeaffordedanopportunitytospeakinCourtaboutthefairnessoftheSettlement(should
SETTLEMENT you choose to do so). If youobjecttotheSettlement,youneedtostateinyourobjectionyour
intention to appear at the fairness hearing. See Paragraphs 23 through 25 below.
2
WHAT THIS NOTICE CONTAINS
BASIC INFORMATION
1. Why is there a Notice? 3 17. If I exclude myself, can I still benefit from this
2. What is this Litigation About? 3 Settlement? 5
3. Why is this a Class Action? 3
4. Why is there a Settlement? 3 THE LAWYERS REPRESENTING YOU
WHO IS IN THE SETTLEMENT? 18. Do I have a lawyer in the case?
5
19. How will the lawyers be paid? 5
5. How do I know if I am part of the Settlement? 4
6. What if I am not sure whether I am included in the OBJECTING TO THE SETTLEMENT
Settlement? 4 20. How do I tell the Court if I do not like the Settlement?5
THE SETTLEMENT BENEFITS 21. What is the difference between objecting and asking to
be excluded? 5
7. What does the Settlement provide? 4
8. When will I receive my benefits? 4 EQUESTINGANALTERNATIVEDIVISIONOFPAYMENTS
R
9. What am I giving up and what claims might I still have (FOR CO-BORROWERS)
to pursue if I remain in the Settlement? 4 22. If I am a co-borrower, can I request an alternative
10. Will this affect my taxes? 4 division (alternative to the equal division) of the pro
11. What happens if this notice is addressed to a Class rata cash payment as between both co-borrowers? 5
Member that has passed away? 4 THE COURT’S FAIRNESS HEARING
12. What happens if this debt was discharged in or is
presently included in a bankruptcy? 4 23. When, where, and how will the Court decide whether to
13. What happens if I voluntarily surrendered my vehicle, approve the Settlement? 6
redeemed my vehicle, or reinstated my Account? 4 24. Do I have to attend the fairness hearing? 6
25. May I speak at the hearing? 6
HOW TO GET BENEFITS
GETTING MORE INFORMATION
14. Do I need to do anything to get the benefits of the
settlement? 5 26. How do I get more information? 6
EXCLUDING YOURSELF FROM THE SETTLEMENT
15. How do I exclude myself from the Settlement? 5
16. If I do not exclude myself, can I sue the Defendants for
the same thing later? 5
BASIC INFORMATION he Defendants, on the other hand, contend that the
T
post-repossessionconsumerdisclosurenoticesitsenttoPlaintiff
. Why is there a Notice?
1 and the Class Members complied in all respects with its
A CourthasauthorizedthisNoticebecauseyouhavearightto statutoryobligations,thatitotherwisecompliedwiththelawin
know about the proposed Settlement and your options. In all respects, and that it denies any and all liability. The
summary fashion, this Notice explains the Litigation, the key Defendants further contend that they are entitled to pursue
terms of the proposed Settlement and your legal rights. If the collectionoftheDeficiencyBalances,andassertotherdefenses.
Court approves the Settlement, after any appeals are resolved, TheseissueshavenotyetbeendecidedbytheCourt,and,ifthe
the Settlement Administrator will make the pro rata cash Settlementisapproved,theseissueswillnotberesolvedonthe
payments to Class Members. merits.
. What is this Litigation About?
2 . Why is this a Class Action?
3
The Plaintiff has claimed that the Defendants violated the In a class action, one or more people called “representative
Pennsylvania Uniform CommercialCode(UCC)independently plaintiffs” or “Class Representatives” sue on behalf of
and in conjunction with the Pennsylvania Motor VehicleSales themselves and other people with similar claims (“Class
Finance Act (MVSFA) by (1) failing to send its borrowers Members”). All these people together are the “Class.” In this
proper Notices of Repossession after Defendants repossessed Litigation, the Plaintiff Steven Roses is the Class
Class Members motor vehicles (2) failing to send proper Representative. If this Settlement is approved, the Settlement
post-sale notices after the repossessed vehicles were sold or will resolve the claims of all Class Members except for those
otherwise disposed of. Plaintiff has also claimed that the individuals who exclude themselves from the class.
Defendants (1) violated the Fair Credit Extension Uniformity
Actbyengaginginunfairordeceptiveactsorpractices,(2)were . Why is there a Settlement?
4
unjustlyenrichedbyClassMembers’paymentstowardsinvalid The Court has not decided in favor of the Plaintiff or
Deficiency Balances and by proceeds of improper sales of Defendants.Instead,bothsideshaveagreedtoaSettlement.By
collateral, and (3) illegally obtained title to the repossessed agreeingtotheSettlement,bothsidesavoidthecostandriskofa
vehicles via false certifications on PennDOT forms. Plaintiffs, trial, and the individuals affected may decide whether to
ontheirownbehalfandonbehalfoftheClassMembers,sought participate in the Settlement. Class Counsel recommends the
to recoverthegreaterofactualandstatutorydamages,punitive Settlement. Without a Settlement,therewouldcontinuetobea
damages, treble damages, and certain declaratory, injunctive, dispute concerning class certification and disputes concerning
and equitable relief, including the vacating of Deficiency liabilityanddamagesthatwouldneedtobedeterminedattrial.
Balances on Class Members’ Accounts, and the removal of A trial could result in a greater benefit to Class Members, a
Class Members’ credit tradelines related to the subjectvehicle smaller benefit to Class Members, or nobenefitatalltoClass
and repossession. Members.AtrialcouldalsopotentiallyresultinClassMembers
being held liable for the Deficiency Balances which, though
3
isputed, Defendants claimareowed.ThisSettlementprovides
d . When will I receive my benefits?
8
relief in the form of pro rata cash payments. This Settlement ClassMemberswillreceivetheirbenefitsaftertheCourtgrants
does not mean that Defendants did anything wrong. finalapprovaloftheSettlement(seeQuestion23)andafterany
WHO IS IN THE SETTLEMENT? appeals are resolved. If there are appeals, resolving them can
take time. Please be patient.
I f you received this Notice in the mail, Defendants’ records
indicate you are a Class Member and are included in this 9. WhatamIgivingupandwhatclaimsmightIstillhave
Settlement, unless you exclude yourself. Even if you did not to pursue if I remain in the Settlement?
receive a mailed notice, you may still be aClassMemberand Unless you exclude yourself from the Settlement, you will
included in this Settlement, as described below. becomeaClassMemberandyouwillgiveupyourrighttosue
(or continue alawsuitagainst)theDefendantspertainingtothe
5. How do I know if l am part of the Settlement? subject Account, including repossession-related matters. The
claims which you would be releasing are set forth in the
ou are included in the Settlement if you fall within the
Y SettlementAgreement.AfullcopyoftheSettlementAgreement
definitionoftheClass,assetforthintheSettlement,anddonot will be promptly provided to you at your request.
exclude yourself from the Settlement (seebelowforwherethe
related documents can be requested or reviewed). 0.Will this affect my taxes?
1
PotentialTaxObligation:WhileyouwillnotbeissuedanyIRS
Tax Form 1099-MISC or 1099-C in connection with this
6. What if I am not sure whether I am included in the settlement, you should promptly consult a tax professional
Settlement? relatingtothissettlementasyoumayhaveataxobligationthat
I f you arenotsurewhetheryouareincludedintheSettlement, should not be overlooked if you choose not to opt-out of this
you may call, write, or email Class Counsel or theSettlement settlement.You should retain this document for taxpurposes.
Administrator with questions. 11.What happens if this notice is addressed to aClass
Member that has passed away?
lass Counsel
C ettlement Administrator
S Proratacashpaymentswithmorethanoneborrowerwherethe
Attorney Richard Shenkan Class-Settlement.com Settlement Administrator can determine that one of the
Shenkan Injury Lawyers, LLC. PO Box 9009 co-borrowers is now deceased will be paid to the surviving
6550 Lakeshore St. Hicksville, NY 11802-9009 co-borrower,absentawrittenrequestbythelegalrepresentative,
West Bloomfield, MI 48323 Toll Free: 1-(877) 268-2976 executor, or administrator of the estate of the deceased
Email: [email protected] co-borrower, supportedbydocumentationsufficienttoshowan
Fax No: 1-(888) 769-1774 open estate and one or more persons legally entitled to the
Toll Free: 1-(800) 490-9287 payment(s). For Accounts with only one borrower where the
Settlement Administrator can determine that the borrower is
deceased,nopaymentswillbemadeabsentawrittenrequestby
THE SETTLEMENT BENEFITS thelegalrepresentative,executor,oradministrator,oftheestate
. What does the Settlement provide?
7 of the deceased co-borrower, supported by documentation
sufficient to show an open estate and one or more persons
If the Settlement is approved and becomes final, the amount legally entitled to the payment(s). Any such requests will be
remaining in the Settlement Fund, after payment of the denied unless there is anopened/reopenedestateatthetimeof
attorneys’ fees and expenses, the Incentive AwardtotheClass the request and/or upon approval of Class Counsel. Any such
Representative, and payment of settlement administration writtenrequestsmustbesent(postmarked,emailed,orfaxed)to
expenses, will be divided among the Class Members (who do the Settlement Administrator at the mailing address, email, or
not exclude themselves from this Settlement) on an equal fax number listed in this Notice by September 21, 2026. Any
per-Accountbasis.Thiswillresultinananticipatedproratacash suchwrittenrequestsmust:(a)includedocumentationsufficient
payment approximately $1,300 per Account. to show an open estate and/or one or more persons legally
entitledtopayment(s);and(b)bepersonallysignedbythelegal
I fyouweretoexcludeyourselffromtheSettlementandpursue representative, executor or administrator of an estate of the
the claims made in this Class Action in your own individual deceased Class Member, and/or creditor of the deceasedClass
lawsuit, and assuming you ultimately prevailed, you would be Member.
entitledtoreceiveeitheractualdamages,foranyactualdamages 12.What happens if this debt was discharged in or is
youcanprove,or(ifyoupurchasedtherepossessedvehiclefor presently included in a bankruptcy?
consumer use) minimum statutory damages. Your minimum
statutory damages are computed by adding the credit service
charge (finance charge) plus 10% of the principal amount of I f the loan obligation was discharged in bankruptcy (yours
yourloan.ThisinformationissetforthinyourRetailInstallment and/or your co-borrower’s bankruptcy)orispresentlypartofa
Sales Contract. bankruptcy proceeding, then you should consult a bankruptcy
attorney regarding this matter. You may have an obligation to
notifythebankruptcytrusteeregardingthecashpaymentyouare
ro rata cash payments on Accounts with more than one
P expectedtoreceive.Thelawatissueinthiscasepermitsyouto
borrower will be split evenly among the co-borrowers, unless obtain minimum statutory damages regardless of whether you
requested otherwise pursuant to the requirements set forth suffered an injury (See 13 Pa. C.S. §9625, Comment 4).
below, in paragraph 22.
13.WhathappensifIvoluntarilysurrenderedmyvehicle,
redeemed my vehicle, or reinstated my Account?
ro rata cash payments onAccountswithadeceasedborrower
P Because the lawsuit challenges the content of the Notices of
will be handled as set forth below, in paragraph 11. Repossession and Post-Sale Notices and isnotbasedonactual
harm you may have suffered, you are aClassMemberevenif
ore details areintheSettlementAgreement,acopyofwhich
M you voluntarily surrendered your vehicle, redeemed your
will be promptly provided upon request.. vehicle, or reinstated your loan with either Defendant.
4
HOW TO GET BENEFITS lassCounselhasaskedtheCourttoawardattorney’sfeesinan
C
amountnottoexceedFiveHundredandSeventySixThousand,
14.Do I need to do anything to get the pro rata cash Three Hundred and Thirty Six Dollars ($576,336.00) and for
payment reimbursementofexpensesinanamountnottoexceedSeventy
No.IftheCourtapprovestheSettlement,youdonotneedtodo Five Thousand Dollars ($75,000). The attorney’s fees and
anythingfurtherinordertoremainapartoftheSettlementand expenses awarded by the Court, including payment to the
receivetheproratacashpaymentdescribedherein,asapplicable SettlementAdministrator,willbepaidoutofthe$1,152,673.00
to you. Settlement Fund. Class Counsel will also request Incentive
Payments of no more than $15,000 for the Representative
EXCLUDING YOURSELF FROM THE SETTLEMENT Plaintiff for his services as Class Representative fortheClass,
I FYOUDONOTWANTTHEPRORATACASHPAYMENT, which will also be paid from the Settlement Fund. The Court
ANDYOUINSTEADWANTTOKEEPTHERIGHTTOSUE could decide to award less than the amounts requested for
THE DEFENDANTS, OR CONTINUE TO SUE THE Attorney’s Fees and Expenses and Incentive Payments.
DEFENDANTS, RELATING TO YOUR ACCOUNT, THEN OBJECTING TO THE SETTLEMENT
YOU MUST TAKE STEPS TO EXCLUDE YOURSELF
FROM (OR “OPT OUT” OF) THE SETTLEMENT. 0.How do I tell the Court if I do not like the Settlement?
2
IfyouareaClassMember(i.e.,youarenotexcludingyourself
fromtheSettlement),youcanobjecttotheSettlementifyoudo
5.How do I exclude myself from the Settlement?
1 not like anypartofit.InordertoobjecttotheSettlement,you
Inordertoexcludeyourself(opt-out),youmustdosoinwriting. mustdosoinwriting.TheCourtwillconsideryourviews.The
Thewrittenrequestmustbesentviamail,fax,oremail(withan written objection must be sent via mail,fax,oremail(withan
attachment containing the class members’ signature) to the attachment containing the class members’ signature) (to the
SettlementAdministratoratthemailingaddress,faxnumber,or SettlementAdministratoratthemailingaddress,faxnumber,or
email listed in this NoticebySeptember21,2026,Thewritten email listed in this NoticebySeptember21,2026.Thewritten
exclusion request must: (a) set forth the Class Member’s full objection must: (a) identify the case name and number; (b)
name, current address, telephone number; (b) contain the identify the name, address, telephone number of the Class
signatures of each Class Member who is a borrower on the Member objecting and, if represented by counsel, of his/her
Account (ortheirguardianoradministratororexecutoroftheir counsel; (c) be personallysignedbythepersonobjecting(orif
estate); and (c) state an intent of all signatory(s) not to representedbycounsel,signedbyhis/hercounsel);(d)statethe
participate in the Settlement. basis and grounds for the objection with specificity; and (e)
provide a statement of whether he/she intends toappearatthe
Final Approval Hearing, either with or without counsel. The
16.If I do not exclude myself, can IsueDefendantsfor written objection must also be mailed to the Clerk of Judicial
the same thing later? Records, Civil Division, Lackawanna County Government
No. Unless you exclude yourself, you giveupanyrighttosue Center, 123 Wyoming Ave,FirstFloor,Scranton,PA18503by
theDefendantsforclaimsrelatingtothesubjectAccount,asset September21,2026. Ifyoudonotobjectinwritingassetforth
forth in the Settlement Agreement. If you have a pending abovebythedeadline,youshallbedeemedtohavewaivedsuch
lawsuit, speak toyourlawyerinthatcaseimmediatelybecause objection, unless otherwise ordered by the Court.
your legal rights may be adverselyaffectedbythisSettlement.
YoumustexcludeyourselffromthisSettlementinordertostart 21.Whatisthedifferencebetweenobjectingandasking
or to continue your own lawsuit for claims relating to your to be excluded?
Account.YourrightsmaybeaffectedbythisSettlement.Acopy Objecting to the Settlement is informingtheCourtthatyoudo
of the full Settlement Agreement will be promptly provided not like something about the Settlement, and that you, for a
uponrequest.YoumaycontacttheSettlementAdministratorand clearlystatedreason,donotwanttheSettlementtobeapproved
request that a copy of the Settlement Agreement be sent to you. orthatyouobjecttoaparticularpartoftheSettlement.Youcan
object onlyifyoudonotexcludeyourselffromtheSettlement.
ExcludingyourselfisinformingtheCourtthatyoudonotwant
17.If I exclude myself, can I still benefit from this to be part of the Settlement.Ifyouexcludeyourself,youhave
Settlement? no basis to object because the Settlement no longer affects you.
No.Ifyouexcludeyourself,youwillnotreceiveanymoneyor
other benefits as a result of the Settlement. REQUESTING AN ALTERNATIVE DIVISION OF PAYMENTS
THE LAWYERS REPRESENTING YOU (FOR CO-BORROWERS)
8.Do I have a lawyer in the case?
1 22.If I am a co-borrower, can I request an alternative
Yes.TheCourthasapprovedRichardShenkanandthelawfirm division (alternative to the equaldivision)ofthepro
of Shenkan Injury Lawyers, LLC, to represent the Class. This rata cash payment as between both co-borrowers?
lawyerandlawfirmarecalled“ClassCounsel.”Youwillnotbe Yes. If you are notexcludingyourselffromtheSettlementand
charged individually for their legal services; rather, Class you and a co-borrower would like to request an alternative
Counsels’ fees will be paid from theSettlementFundwiththe division of the pro rata cash payment as between both
approval of the Court. If you want to be represented by your co-borrowers,youmustdosoinwriting.Thewrittenrequestfor
own lawyer, you may hire one at your own expense. Class analternativedivisionmustbesentviamail,fax,oremail(with
Counsels’ contact information is listed in paragraph 6 above. an attachment containing the classmembers’signatures)tothe
ClassMemberscanspeakwithClassCounselatnochargeabout SettlementAdministratoratthemailingaddress,faxnumber,or
this case. In connection with the Court’s appointment, Class emaillistedinthisNoticebySeptember21,2026.Thewritten
Counsel doesnotrepresentdeceasedClassMember’screditors, request for an alternative division must: (a) identify the case
heirs, or legal representatives relating to effectuating any name; (b) identify the names and addresses of the Class
settlement payments to any heir(s), legal representatives, or Membersrequestinganalternativedivisionofpayment(s);(c)be
creditors of the deceased Class Members. personally signed by both co-borrowers or their legal
representativesrequestinganalternativedivisionofpayment(s);
19.How will the lawyers be paid? and (d) provide a description of how the co-borrowers have
5
a greedforanyalternativedivisionofpayment(s)tobemadeas 5.May I speak at the hearing?
2
between each other. YoumayasktheCourtforpermissiontospeakatthehearing.To
do so, you must send a lettertotheClerkofJudicialRecords,
THE COURT’S FAIRNESS HEARING Civil Division by September 21, 2026 at theaddresslistedin
Question20sayingthatitisyour“NoticeofIntentiontoAppear
heCourtwillholdahearingtodecidewhethertoapprovethe
T attheFinalApprovalHearinginRosesv.PeoplesSecurityBank
Settlement.Youmayattendandyoumayasktospeak,butyou &TrustandPeoplesFinancialServicesCorp.,14-cv-5108”,and
do not have to do so. requestingthattheclerkfileyourNoticeofIntention.Youmust
23.When, where,andhowwilltheCourtdecidewhether include your name, address, telephone number, and signature.
to approve the Settlement? Your Notice of Intention to Appear must be (a) filed with the
Clerk of Judicial Records, Civil Division; and (b) sent
The Court will hold a fairness hearing onOctober14,2026at (postmarked, faxed, or emailed with an attachment containing
11:30 a.m. in Courtroom 3 at the Lackawanna County the class member’s signature) to Class Counsel at the mailing
Courthouse, 200 N. Washington St., Scranton, PA 18503. The address, fax number, or website listed in paragraph 6 of this
hearingmaybemovedtoadifferentdateortime,orbeheldvia Notice. Any such notice shall include copies of any papers,
videoconference or telephone conference, without additional exhibits, or other evidence sought to bepresented.Youcannot
notice(includinganearlierdate).Therefore,ifyouareplanning speakatthehearingifyouhaveoptedoutorexcludedyourself,
onattendingthefairnesshearing,itisagoodideatoconfirmin because the case no longer affects you.
advance that the date andtimeofthehearinghasnotchanged.
You may confirm this information by checking
www.PennSecurityClassAction.com or by calling 1-(800) GETTING MORE INFORMATION
490-9287. At this fairness hearing, the Court will consider 6.How do I get more information?
2
whethertheSettlementisfair,reasonable,andadequate.Ifthere
are objections, the Court will consider them and will listen to This notice brieflysummarizesthekeyaspectsoftheproposed
ClassMemberswhoasktospeakatthehearing.TheCourtmay Settlement.MoredetailsareintheSettlementAgreement.Case
also decide several other aspects of the Settlement including documentsareavailableatwww.PennSecurityClassAction.com.
how much to pay the Class Representative for his incentive ForacopyoftheSettlementAgreement,youmaycontactClass
award and Class Counsel for their services and expenses. Counsel at 1-(800) 490-9287 or [email protected]. You
Followingthehearing,theCourtwilldecidewhethertoapprove can alsocontacttheSettlementAdministratorat877-268-2976,
theSettlement.ItisunknownhowlongtheCourt’sdecisionwill or [email protected].
take. Please be patient.
4.Do I have to attend the fairness hearing?
2 ou may access the Settlement Website by
Y
No. Class Counsel will answer questions the Court mayhave, using the camera on your mobile device to
but you are welcome to come, at your expense. If you timely scan this QR code:
filed your written objection the Court will consider it. Youdo
nothavetocometoCourttotalkaboutit,butyoumay.Youmay
also pay your own lawyer to attend, but it is not required.
6
