The Notices advise that the Ontario Superior Court of Justice and Superior Court of Québec respectively have approved a nationwide settlement of class actions. It also provides information about the Settlement, which pertains to all economic loss claims relating to the 2014 recalls of certain GM vehicles alleged in fifteen (15) lawsuits brought on behalf of persons who owned or leased the recalled GM vehicles. These economic loss class claims are made by current and former owners and lessees of GM vehicles subject to recalls relating to Delta ignition switches, key rotation, Camaro knee-key, and/or electric power steering with the Transport Canada recall numbers listed in FAQ 3.

One of the fifteen lawsuits is Edward Oberski et al. v. General Motors LLC et. al. filed in the Ontario Superior Court of Justice ("Ontario Court") bearing Court File No. CV-14-50203-CP ("Ontario Action"), and two of the lawsuits are filed in the Superior Court of Québec ("Québec Court", and together with the Ontario Court, the "Courts"), Michael Gagnon v. General Motors of Canada et. al., Court File No. 500-06-000687-141 and Michael Gagnon v. General Motors of Canada et. al., Court File No. 500-000729-158 ("Québec Actions") (collectively, "Actions").

The other twelve lawsuits being settled (the "Related Actions") are as follows: (i) George Shewchuck v General Motors of Canada Limited, et. al., Court File No. QBG 1396/14, Bradie Herbel v. General Motors of Canada Limited et. al., Court File No. QBG 480/14, Dale Hall v. General Motors of Canada Limited et. al., Court File No. QBG 1273/15, and Rene Fradette v. General Motors of Canada Limited et. al., Court File No. QBG 1181/15, each in Saskatchewan Court of Queen's Bench, (ii) Garth Coen v. General Motors of Canada Limited et. al., Court File No. 14-1262, British Columbia Supreme Court, (iii) Holly Standingready v. General Motors of Canada Limited, Court File No. 1403-04964, Alberta Court of Queen's Bench, (iv) Catherine Seeley v. General Motors of Canada Limited et. al., Court File No. C114-88682, Manitoba Court of Queen's Bench (v) Chris Spicer v. General Motors of Canada Ltd. et al., Court File No. MC-176-14, New Brunswick Court of Queen's Bench, (vi) Sue Brown et. al. v. General Motors of Canada Limited et. al., Court File No. 427140 and Alex Mulford v. General Motors of Canada Ltd., Court File No. 426204, both in Nova Scotia Supreme Court, (vii) Meghan Dunphy v. General Motors of Canada Ltd., Court File No. 201401G2284CP, Newfoundland Supreme Court, and (viii) Academie Ste Cecile International School et. al. v. General Motors of Canada Limited, Court File No. CV-14-20629-CP, Ontario Superior Court.

The Notices explain the terms of the Settlement and your legal rights.

Settlement Class Representatives in the Actions and plaintiffs in the Related Actions filed proposed class action claims against New GM and GM Canada alleging that consumers overpaid when they bought or leased GM vehicles that were subject to certain 2014 recalls. New GM and GM Canada deny these allegations. The Settlement Class Representatives, New GM and GM Canada (together the "Parties") negotiated the Settlement to resolve these economic loss claims, as well as all economic loss claims for these recalls that have been or may be asserted by the Settlement Class against New GM and GM Canada and certain other released parties. The Settlement avoids the risk and cost of a trial and provides Settlement benefits to Settlement Class Members (defined in FAQ 3). The Settlement Class Representatives in the Actions, the plaintiffs in the Related Actions and their lawyers think that the Settlement is in the best interests of all Settlement Class Members and that it is fair, reasonable, and adequate.

A Settlement Class Member is a member of the Settlement Class. The Settlement Class, which has been certified or authorized by the Ontario Superior Court of Justice and the Superior Court of Québec for Settlement purposes only, is defined as: 

All Persons resident in Canada other than Excluded Persons, who, at any time on or before the Recall Announcement Date of the Recall(s) applicable to their Subject Vehicles, owned, purchased, and/or leased a Subject Vehicle in any of the provinces/territories in Canada.

"Subject Vehicles" means the GM Motor vehicles subject to the Recalls as specifically defined by the vehicle identification numbers (VINs) provided by GM to the Settlement Administrator.

The "Recalls" and the "Recall Announcement Date" are as follows:

*Only those vehicles with a vehicle identification number that is subject to one or more of the above Recalls are included in the Settlement as a Subject Vehicle. Please use the VIN Lookup tool to see if your vehicle qualifies. 

The Recall Announcement Date is a certain date that is the end of the month following the month of GM's last initial notification to owners/lessees of each Recall.

Go to the VIN Lookup tool to see if your GM vehicle is covered by the Settlement. Have your vehicle identification number ready.

The Settlement Class is comprised of the four Subclasses below (the "Subclasses"):

• Subclass 1: The Delta Ignition Switch Subclass, comprised of those Settlement Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to Transport Canada Recall Nos. 2014-038, 2014-060 and 2014-101.
• Subclass 2: The Key Rotation Subclass, comprised of those Settlement Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to Transport Canada Recall Nos. 2014-273, 2014-246, 2014-284.
• Subclass 3: The Camaro Knee-Key Subclass, comprised of those Settlement Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to Transport Canada Recall No. 2014-243.
• Subclass 4: The Electric Power Steering Subclass, comprised of those Settlement Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to Transport Canada Recall No. 2014-104.

Settlement Class Members with a Subject Vehicle covered by both the Delta Ignition Switch Recall and the Electric Power Steering Recall shall be members of both the Delta Ignition Switch Subclass and the Electric Power Steering Subclass and shall be eligible to receive settlement payments allocated to both Subclasses. Settlement Class Members with multiple Subject Vehicles shall be members of the Subclasses applicable to each of their respective Subject Vehicles.

Under the Settlement, each Settlement Class Member will be deemed to have waived, released, and promised not to sue for any economic loss claims that the Settlement Class Member has or may have in the future, directly or indirectly, against New GM, GM Canada and certain other released parties (the "Released Parties").

The Settlement does not apply to claims for personal injury (and related family/dependent claims), wrongful death or actual physical property damage relating to the 2014 recalls. These class claims have been discontinued from the class actions as such claims may be pursued individually (not in a class action) if permitted in your province, and any such individual claims have not been waived or released by the approval of the Settlement. As a result of the discontinuance in the class actions, the limitation periods (legal deadlines for commencing a lawsuit) are no longer suspended and began to run again. After the limitation period, your right to sue will be extinguished. Get advice from your own lawyer about legal deadlines for individual lawsuits.

The Settlement will prohibit Settlement Class Members from suing or being part of any other lawsuit or claim against the Released Parties that relates to the subject matter of the Actions, Related Actions and the Recalls, including, but not limited to, those relating to the design, manufacturing,  advertising,  testing,  marketing,  functionality,  servicing,  sale,  lease or resale of the Subject Vehicles (the "Released Claims"). The specifics of the Released Claims are set out in more detail in the Settlement Agreement, which is posted on the Important Documents page. The Settlement Agreement describes the Released Claims in specific legal terminology. Talk to your own lawyer if you have questions about the Released Claims or what it means.

The Settlement Agreement allows Settlement Class Members to submit a claim to the Settlement Administrator, and, if eligible, receive a payment from the Settlement Fund Amount, as described below.

i.  The Settlement Fund Amount

In exchange for Settlement 'Class Members' release of the Released Claims, there will be a CA$12 million settlement fund established (the "Settlement Fund Amount"). Settlement payments to eligible Settlement Class Members will only occur if both (i) the Approval Orders of the Ontario Court and the Québec Court and (ii) the orders dismissing the Related Actions with prejudice and without costs become Final, among other orders, and after Administrative Expenses (such as for claims administration) are deducted.

ii.  How will payments for eligible claims be allocated?

A "Net Settlement Amount" shall be determined by deducting Administrative Expenses, taxes and any honoraria payments from the Settlement Fund Amount. The entire Net Settlement Amount shall be distributed to Settlement Class Members with claims determined to be eligible by the Settlement Administrator. Members of the Delta Ignition Switch Subclass shall receive twice (2x) the amount paid to members of the Camaro Knee-Key and Electric Power Steering Subclasses, and members of the Key Rotation Subclass shall receive one-and-a half times (1.5x) the amount paid to members of the Camaro Knee-Key and Electric Power Steering Subclasses. An eligible Settlement Class Member with a Subject Vehicle subject to both the Delta Ignition Switch Recall and the Electric Power Steering Recall will receive both the Delta Ignition Switch Subclass and the Electric Power Steering Subclass settlement payments. The calculation process for the Net Settlement Amount is set out in the Settlement Agreement.

iii.  How do I get a payment from the Net Settlement Amount?

To receive money from this Settlement, you must submit online or postmark by mail a completed Claim Form by June 6, 2025. You may submit a Claim Form online via the File a Claim page on this website. Alternatively, you may complete a paper Claim Form available for download on the Important Documents page and submit your Claim Form by mail or courier to the address indicated on the Claim Form. For certain Settlement Class Members, both a complete Claim Form and additional documentation may be required to establish eligibility. Instructions are on the Claim Form and in the Online Claim Form. 

If you fail to submit a Claim Form by the required deadline, you will not receive a payment. Sending in a Claim Form late will be the same as doing nothing.

You are a Settlement Class Member and eligible to submit this Claim Form only if you are not an Excluded Person, and you:

1. Currently own or lease a Subject Vehicle and (a) you owned or leased it on or before the Recall Announcement Date and (b) your vehicle has either already had the applicable Recall repair(s) performed, or you will now have the Recall repair done (for free) by an authorized GM dealer. The Recall repair(s) must occur on or before the Final Recall Repair Date, which is August 5, 2025 or;
2. Formerly owned or leased a Subject Vehicle on or before the Recall Announcement Date. Certain former owners or lessees of a Subject Vehicle may need to provide documentation (or, if you don’t have documentation, make a signed solemn declaration as described below) showing that you are no longer in the possession, custody or control of the Subject Vehicle.

Certain lawyers representing Settlement Class Representatives ("Co-Lead Counsel"), listed below, negotiated the Settlement Agreement with New GM and GM Canada. You will not be charged for services performed by Co-Lead Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

If you want to contact Co-Lead Counsel, they can be reached at:

Rochon Genova LLP
Attn: Jon Sloan
121 Richmond Street West
Suite #900
Toronto, ON M5H 2K1
jsloan@rochongenova.com
Tel: 1-800-462-3864 or local (416) 363-1867

Kim Spencer McPhee Barristers P.C.
Attention: Megan B Mcphee
1203-1200 Bay Street
Toronto, ON M5R 2A5
mbm@complexlaw.ca
Tel: (416) 596-1414

Now that the Settlement is final, the amount approved by the Court to be paid to Co-Lead Counsel by the Defendants for plaintiffs' counsel fees, expenses, costs, disbursements and associated taxes (the "Maximum Plaintiffs' Counsel Fee Amount") is CA $4,397,500.00. This amount awarded by the Courts for plaintiffs' counsel fees, expenses, costs, disbursements and associated taxes will not come out of the Settlement Fund Amount.

No class member other than the Settlement Class Representatives or an intervenor in Québec will be required to pay legal costs arising from the class actions.

If you had wanted to opt out from the Settlement, you could have by sending an opt out form by mail, courier, or e-mail so that it was received on or before July 19, 2024. The deadline to exclude yourself from the Settlement has passed.

If you excluded yourself from the Settlement Class, you would not get any money or benefits from this Settlement. By excluding yourself, however, you will retain your individual right to sue the Released Parties for the economic loss claims alleged in the Actions and Related Actions, at your own expense. Get advice from your own lawyer about legal deadlines for individual lawsuits.

Excluded from the Settlement Class are (1) authorized GM dealers; (2) daily rental fleet purchasers, owners and lessees (that is a Person engaged in the business of rental of passenger cars, without drivers, to the general public on a daily or weekly basis and which purchases or leases vehicles for the purpose of such rentals) which shall be based upon GM data that it provides to the Settlement Administrator and shall be determinative; (3) governmental or quasi-governmental bodies; (4) the judicial officers presiding over the Actions and Related Actions and their immediate family members; (5) Actions Counsel as well as members of their staff and immediate family; (6) all Persons who have previously released their economic loss claims that are in any way, directly or indirectly, related to the issues corrected by the Recalls whose names shall be provided by GM to the Settlement Administrator; and (7) all individuals and entities that have validly opted-out of the Settlement.

If you are a Class Member, you could have objected to the Settlement if you didn’t like any part of it. To object, you must have sent an objection form to the Settlement Administrator by email to info@GMIgnitionSwitchSettlement.ca or by courier or mail to GM Ignition Switch Economic Settlement, c/o JND Legal Administration, PO Box 8111, Vancouver Main, Vancouver, BC V6B 4E2. If you are a Québec resident, you must have filed your objection form with the court.

If you wanted to appear and speak at the Final Approval Hearing to object to the Settlement, with or without a lawyer, you must have said so in your letter or brief. The deadline to file an objection was July 19, 2024, and has passed.

Note that Québec Settlement Class members may seek permission from the Superior Court of Québec to intervene if the intervention is considered helpful to the Class. A Québec Settlement Class member who intervenes may be required to submit to a pre-trial examination at the request of the Defendants. A Settlement Class member who does not intervene may not be subject to a pre-trial examination unless the Court considers that it would be useful for its determination of the issues of law or fact to be dealt with collectively. It is not necessary to intervene to object to the Settlement Agreement (see above) or to attend the Approval Hearings. Québec Settlement Class members who choose to intervene and who wish to be represented by a lawyer will have to hire their own lawyer. Québec Settlement Class members are Settlement Class Members whose Subject Vehicles are identified based on reasonably available information from GM as having been first retail sold in Québec.

The Ontario Superior Court of Justice held a Settlement Approval Hearing on July 30, 2024 at 10:00 a.m. and The Superior Court of Québec held a Settlement Approval hearing on July 31, 2024 at 9.30 a.m.

The purpose of the hearings was for the Court to determine whether to approve the Settlement as fair, reasonable, adequate, and in the best interests of the Settlement Class. At those hearings, the Court was available to hear any objections and arguments concerning the fairness of the Settlement. The Settlement has been approved, and the Effective Date is February 6, 2025.

You have the right to do nothing. If you do nothing, including not submitting a claim, you will not get any Settlement benefits. In addition, you can no longer be part of a class action or any other lawsuits against the Released Parties involving the Released Claims in this Settlement. Specifically, after approval by both Courts is Final, the Settlement will prohibit you from suing or being part of any other lawsuit or claim against the Released Parties that relate to the subject matter of the Actions, Related Actions and the Recalls, including, but not limited to, those relating to the design, manufacturing, advertising, testing, marketing, functionality, servicing, sale, lease or resale of the Subject Vehicles. However, Settlement Class Members will not waive or release any individual claims they may have against the Released Parties for personal injury, wrongful death or actual physical property damage arising from an accident involving a Subject Vehicle. Get advice from your own lawyer about legal deadlines for individual lawsuits.

Places to look for your VIN:

1. Driver’s side bottom corner of the windshield or dashboard in that area
2. On placards on the driver’s doorjamb
3. The bill of sale or lease
4. Recall notices
5. Vehicle registration
6. Correspondence from your financing or leasing company
7. Insurance policies or slips/cards

The Notices summarize the Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement, the Approval Orders, and any additional orders entered by the Courts pertaining to the Settlement, all of which are available (or will be available once entered by the Courts) under the Important Documents tab. If there is a conflict between the Notices and the Settlement Agreement, the Settlement Agreement applies.

You may obtain additional information by:

Calling the Settlement Phone Number: 1-888-995-0291

OR

Contacting Class Counsel:

Rochon Genova LLP
Attention: Jon Sloan
121 Richmond Street West
Suite #900
Toronto, ON M5H 2K1
jsloan@rochongenova.com
Tel: 1-800-462-3864 or local (416) 363-1867

Kim Spencer McPhee Barristers P.C.
Attention: Megan B. McPhee
1203-1200 Bay Street
Toronto, ON M5R 2A5
mbm@complexlaw.ca
Tel: (416) 596-1414