A class action is a lawsuit in which one or more representative plaintiffs (in this case, Ohio Carpenters’ Pension Fund, Electrical Workers Pension Fund Local 103 I.B.E.W., and San Bernardino County Employees’ Retirement Association (collectively, “Plaintiffs”)) bring a lawsuit on behalf of themselves and other similarly situated persons (i.e., a class) who have similar claims against the defendants. The representative plaintiffs, the court, and counsel appointed to represent the class all have a responsibility to make sure that the interests of all class members are adequately represented.

Importantly, class members are NOT individually responsible for attorneys’ fees or litigation expenses. In a class action, attorneys’ fees and litigation expenses are paid from the settlement fund (or the court-awarded judgment amount) and must be approved by the court. If there is no recovery on behalf of the class, the attorneys do not get paid.

When a representative plaintiff enters a settlement with a defendant on behalf of a class, such as the Settlements with JPMorgan, State Street, UniCredit, and Natixis, the court will require that the members of the class be given notice of the settlement and an opportunity to be heard with respect to the settlement. The court then conducts a hearing (called a Settlement Hearing) to determine, among other things, if the settlement is fair, reasonable, and adequate.

You received the Notice because you requested it or records indicate that you may be a Settlement Class Member. As a potential Settlement Class Member, you have a right to know about the proposed Settlements with JPMorgan, State Street, UniCredit, and Natixis before the Court decides whether to approve the Settlements.

The Notice explains the Action, the Settlements, your legal rights, what benefits are available, who is eligible for them, and how you can seek to receive your portion of the benefits if you are eligible. The purpose of the Notice is also to inform you of the Settlement Hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlements and Distribution Plan and to consider requests for awards of attorneys’ fees, litigation expenses, and any service awards for Plaintiffs from the Settlement Fund.

Plaintiffs allege that Defendants conspired to fix the prices of European Government Bonds in both the primary and secondary markets. Plaintiffs allege that this conduct, designed to raise European Government Bond prices and to depress yields, was carried out through several interrelated means.

In the primary market, Plaintiffs allege that Defendants furthered this conspiracy by agreeing to artificially inflate European Government Bond prices at auction through a process known as “overbidding” and to otherwise coordinate their bidding strategies, thereby outbidding rivals and raising the benchmark for resale in the secondary market. In the secondary market, Plaintiffs allege that Defendants, in control of the supply of newly issued European Government Bonds, agreed to fix bid-ask spreads. This includes, Plaintiffs allege, agreeing on higher prices to charge investors for European Government Bonds. Defendants are alleged to have coordinated this scheme via online chatroom communications, where they explicitly fixed prices and bids and exchanged other sensitive, confidential information necessary to carry out the scheme.

Plaintiffs allege they were injured by these artificially inflated prices and fixed bid-ask spreads each time they transacted in European Government Bonds directly with a Defendant, or one of its affiliates, or an alleged co-conspirator and therefore pursue claims under the Sherman Act for themselves and on behalf of the class.

Plaintiffs filed the Third Amended Consolidated Class Action Complaint on December 3, 2019. ECF No. 87. On February 27, 2020, Defendants moved to dismiss the Third Amended Class Action Complaint for failure to state a claim and lack of personal jurisdiction. ECF No. 110. Following an exchange of letter briefs, on July 23, 2020, the Court issued a Decision and Order granting in part and denying in part the motion to dismiss. ECF No. 115. On August 6, 2020, certain Defendants filed a motion for reconsideration of the Court’s July 23, 2020 Decision and Order (ECF No. 119), which the Court denied on December 11, 2020. ECF No. 139.

On February 9, 2021, Plaintiffs filed the Fourth Amended Consolidated Class Action Complaint, naming additional Defendants. ECF No. 146. Defendants moved to dismiss the Fourth Amended Consolidated Class Action Complaint on April 16, 2021. See Appendices to ECF No. 206. On March 14, 2022, the Court issued a Decision and Order granting in part and denying in part the motion to dismiss. ECF No. 236. On March 28, 2022, certain Defendants filed motions for reconsideration of the Court’s March 14, 2022 Decision and Order (ECF No. 238), which the Court denied on June 16, 2022. ECF No. 270.

On December 9, 2022, Plaintiffs filed a class action complaint in Ohio Carpenters’ Pension Fund, et al. v. Deutsche Bank AG, et al., No. 1:22-cv-10462-VM (S.D.N.Y.) against Deutsche Bank and Rabobank. Complaint, Ohio Carpenters’ Pension Fund v. Deutsche Bank AG, No. 1:22-cv-10462-VM (S.D.N.Y. Dec. 9, 2022) (“EGB II”), ECF No. 1.

The Court granted Plaintiffs’ motions for preliminary approval of the Settlements with State Street and JPMorgan on June 16, 2021 and May 2, 2022, respectively. ECF Nos. 212, 258. The Court granted Plaintiffs’ motion for preliminary of the Settlements with UniCredit and Natixis on May 16, 2023, and preliminarily approved amended settlements with UniCredit and Natixis on July 12, 2023.

The Action is proceeding against the non-settling Defendants.

Plaintiffs and Co-Lead Counsel believe that Settlement Class Members were damaged by Defendants’ conduct. JPMorgan, State Street, UniCredit, and Natixis do not agree with the allegations made by Plaintiffs, believe that they have meritorious defenses to Plaintiffs’ allegations, and believe that certain of Plaintiffs’ claims would have been rejected prior to trial, at trial, or on appeal. The Court has not decided in favor of either Plaintiffs, JPMorgan, State Street, UniCredit, or Natixis. Instead, Co-Lead Counsel engaged in separate settlement discussions with JPMorgan, State Street, UniCredit, and Natixis to reach negotiated resolutions of the Action. The Settlements allow both sides to avoid the risks and costs of lengthy litigation and the uncertainty of pre-trial proceedings, a trial, and appeals, and, if approved, they would permit eligible Settlement Class Members who or which submit valid claims to receive some compensation, rather than risk ultimately receiving nothing. Plaintiffs and Co-Lead Counsel believe the Settlements are in the best interest of all Settlement Class Members.

JPMorgan has agreed to pay a total of $13 million in cash for the benefit of the proposed JPMorgan and State Street Settlement Class (defined below) and to provide Cooperation Materials in connection with Plaintiffs’ continued prosecution of claims against the non-settling Defendants.

State Street has agreed to provide Cooperation Materials in connection with Plaintiffs’ continued prosecution of claims against the remaining Defendants.

State Street has agreed to provide Cooperation Materials in connection with Plaintiffs’ continued prosecution of claims against the remaining Defendants and their alleged co-conspirators.

UniCredit has agreed to pay a total of $13 million in cash for the benefit of the proposed UniCredit and Natixis Settlement Class (defined below) and to provide Cooperation Materials in connection with Plaintiffs’ continued prosecution of claims against the non-settling Defendants and against the defendants in EGB II.

Natixis has agreed to pay a total of $14 million in cash for the benefit of the proposed UniCredit and Natixis Settlement Class (defined below) and to provide Cooperation Materials in connection with Plaintiffs’ continued prosecution of claims against the non-settling Defendants and against the defendants in EGB II.

If the JPMorgan, UniCredit, and Natixis Settlements are approved, the Settlement Fund, plus interest earned from the date it was established, less any Taxes, any Notice and Administration Costs, any Court-awarded attorneys’ fees and litigation expenses, service awards for Plaintiffs, and any other costs or fees approved by the Court (the “Net Settlement Fund”) will be divided among all Settlement Class Members who submit valid Claim Forms.

The Stipulations preserve the Settlement Class’s right to recover the entire amount of damages against non-settling Defendants based on joint and several liability (after an offset post-trebling for the Settlement Amount). JPMorgan, State Street, UniCredit, and Natixis do not think that Plaintiffs would have prevailed at trial (had they successfully certified a class and survived summary judgment motions), and JPMorgan, State Street, UniCredit, and Natixis believe, as a result, Settlement Class Members would have received nothing.

If the Settlements are approved, JPMorgan, State Street, UniCredit, and Natixis will no longer be defendants in the Action, but the Action will continue against the non-settling Defendants and their co-conspirators. If the Settlements are not approved, JPMorgan, State Street, UniCredit, and Natixis will remain as defendants in the Action, and Plaintiffs will continue to pursue their claims against JPMorgan, State Street, UniCredit, Natixis, and non-settling Defendants.

Plaintiffs’ claims against non-settling Defendants will continue to be litigated and prepared for trial, whether or not the Settlements are approved. If damages are awarded against the non-settling Defendants, they may seek to reduce that damages award by the amount of the Settlements; any reduction would not affect Settlement Class Members’ recovery under the Settlements. The Court’s findings in any approval of the Settlements and certification of the Settlement Class will have no effect on the Court’s rulings on future motions involving the non-settling Defendants, including any motion to certify any other class in the Action.

In the Preliminary Approval Orders, the Court preliminarily approved the following Settlement Class for the JPMorgan and State Street Settlements:

Yes. You are not included in the Settlement Class if you are a Defendant, a direct or indirect parent, subsidiary, affiliate, or division of a Defendant, or Defendants’ alleged co-conspirators. In addition, all federal government entities and any judicial officer presiding over this Action and the members of his or her immediate family and judicial staff and any juror assigned to this Action are excluded from the Settlement Class.

If you are still not sure whether you are included, you can ask for free help. You can call toll-free 1-877-883-7336 (for callers outside the United States and Canada: 414-961-7813).

JPMorgan paid $13 million into a fund to be held for disbursement to the Settlement Class and to pay for Court- approved fees and expenses, if the JPMorgan Settlement is approved.

UniCredit paid $13 million into a fund to be held for disbursement to the Settlement Class and to pay for Court- approved fees and expenses, if the UniCredit Settlement is approved.

Natixis paid $14 million into a fund to be held for disbursement to the Settlement Class and to pay for Court- approved fees and expenses, if the Natixis Settlement is approved.

JPMorgan, State Street, UniCredit, and Natixis have also agreed to provide cooperation for the benefit of Plaintiffs and Settlement Class Members, including but not limited to the production of documents, transaction data, an attorney proffer, and/or witness interviews. Co-Lead Counsel believe the Cooperation Materials have and will continue to aid the continued prosecution of the Action against the non-settling Defendants as well as Deutsche Bank and Rabobank in the EGB II litigation.

If you are a Settlement Class Member and do not exclude yourself, you are eligible to submit a claim to receive your share of money from the Net Settlement Fund. A Claim Form is attached to the Notice. You may also obtain a Claim Form by this website or by contacting the Claims Administrator toll-free at 1-877-883-7336 (for callers outside the United States and Canada: 414-961-7813).

Claimants must electronically submit their Claim Forms online at www.EuropeanGovernmentBondsSettlement.com by 11:59 p.m. Eastern Time on January 29, 2024 OR mail the Claim Forms such that they are received no later than January 29, 2024 by the Claims Administrator at European Government Bonds Settlement, c/o A.B. Data, Ltd., P.O. Box 173119, Milwaukee, WI 53217.

Read the instructions carefully, fill out and sign the Claim Form, include all requested documents, and submit all materials on the Settlement Website at www.EuropeanGovernmentBondsSettlement.com.

Following receipt of your Claim Form, the Claims Administrator will send you a “Confirmation of Claim Receipt,” which will acknowledge receipt of your claim and will inform you of important next steps.

If you have already submitted a Claim Form after receiving the prior notice, you may want to submit another one. The UniCredit and Natixis Settlement Class includes European Government Bond transactions with Defendants, in addition to Deutsche Bank and Rabobank, from January 1, 2005 through December 31, 2016.

Please keep all data and documentation related to your eligible European Government Bond transactions. Having data and documentation may be important to substantiating your claim.

If you do not submit a Claim Form, you will not receive any payments under the Settlements.

At this time, it is not known precisely how much each Authorized Claimant will receive from the Net Settlement Fund or when payments will be made. The amount of your payment will be determined by the Distribution Plan, if it is approved, or by such other plan of distribution that is approved by the Court. For more information on the Distribution Plan, see question 13.

The Distribution Plan is available on this Settlement Website. The Multiplier Table referred to in the Distribution Plan is posted on this Settlement Website. Changes, if any, to the Multiplier Table based on newly available data or information will be promptly posted on this Settlement Website. Please check this Settlement Website for the most up-to-date information about the Distribution Plan.

The Court will hold the Settlement Hearing on January 5, 2024 at 10:00 a.m. to decide whether to approve the Settlements and Distribution Plan. If the Court approves the Settlements and Distribution Plan, there may be appeals after that. It can sometimes take a year or more for the appellate process to conclude. Please be patient; status updates will be posted at www.EuropeanGovernmentBondsSettlement.com.

After you submit a claim, the Claims Administrator will evaluate your Claim Form to determine if you have provided sufficient information to validate your membership in the Settlement Class and calculate your payment. If the Claims Administrator determines that your Claim is deficient or defective, it will contact you. If you subsequently provide information that satisfies the Claims Administrator concerning the validity of your claim, you will not have to do anything else. If any disputes cannot be resolved, Co-Lead Counsel will submit them to the Court, and the Court will make a final determination of the validity of your claim. The decision of the Court with respect to objections to the Claims Administrator’s claim determinations shall be final and binding, and there shall be no appeal to any court. Please keep all data and documentation related to your eligible European Government Bond transactions. Having data and documentation may be important to substantiating your claim.

Unless you exclude yourself, you remain a Settlement Class Member. That means you can’t sue, continue to sue, or be part of any other lawsuit about the Settled Claims against JPMorgan or State Street, UniCredit, or Natixis.

Upon the Effective Date of the Settlements, Plaintiffs and all Settlement Class Members shall be deemed to have, and by operation of the Judgments shall have, fully, finally, and forever waived, released, relinquished, and discharged all Settled Claims against the Settling Defendants, regardless of whether such Settlement Class Member executes and delivers a Claim Form. The capitalized terms used in this paragraph are defined in the Stipulations, Preliminary Approval Orders, or the Notice. For easy reference, certain of these terms are copied below:

• “Released Parties” in the JPMorgan Stipulation means JPMorgan, together with its respective past and present, direct and indirect corporate parents (including holding companies), subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past or present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns.

• “Released Parties” in the State Street Stipulation means State Street, together with its respective past and present, direct and indirect corporate parents (including holding companies), subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past or present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns.

• “Released Parties” in the UniCredit Stipulation means UniCredit, together with its respective past and present, direct and indirect corporate parents (including holding companies), subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past or present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns. For the avoidance of doubt, Released Parties include UniCredit Capital Markets LLC and UniCredit S.p.A., as well as their subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past or present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns.

• “Released Parties” in the Natixis Stipulation means Natixis, together with its respective past and present, direct and indirect corporate parents (including holding companies), subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past or present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns.

• “Settling Plaintiff Parties” in all Stipulations means individually and collectively each Plaintiff and Settlement Class Member, on behalf of himself, herself, or itself, and each of his, her, or its respective past and present, direct and indirect corporate parents (including holding companies), subsidiaries, related entities, affiliates, associates (all as defined in SEC Rule 12b-2 promulgated pursuant to the Securities Exchange Act of 1934), divisions, joint ventures, predecessors, successors, and each of their respective past and present officers, directors, partners, managing directors, employees, agents, contractors, attorneys, legal, or other representatives, trustees, trusts, heirs, beneficiaries, estates, executors, administrators, insurers, shareholders, advisors, and assigns, whether or not they object to the Settlement and whether or not they make a claim for payment from the Settlement Fund.

• “Settled Claims” in the State Street and JPMorgan Stipulations means any and all manner of claims, including Unknown Claims, causes of action, cross-claims, counter-claims, charges, liabilities, demands, judgments, suits, obligations, debts, setoffs, rights of recovery, or liabilities for any obligations of any kind whatsoever (however denominated), whether class or individual, in law or equity or arising under constitution, statute, regulation, ordinance, contract, or otherwise in nature, for fees, costs, penalties, fines, debts, expenses, attorneys’ fees, and damages, whenever incurred, and liabilities of any nature whatsoever (including joint and several, treble, or punitive damages), known or unknown, suspected or unsuspected, asserted or unasserted, choate or inchoate, which the Settling Plaintiff Parties ever had, now have, or hereafter can, shall, or may have, individually, representatively, derivatively, or in any capacity against JPMorgan or State Street that arise from or relate in any way to the conduct alleged in the Action, or conduct that could have been alleged in the Action based on the factual predicate of the Action, including any amended complaint or pleading therein. Settled Claims shall not include: (i) claims based on transactions that are outside the extraterritorial reach of the Sherman Act pursuant to Section 6a of the Sherman Act, 15 U.S.C. §6a; (ii) any claims relating to the enforcement of the Settlement; or (iii) any claims of any person or entity that submits a request for exclusion in connection with the Notice and whose request is accepted by the Court.

• “Settled Claims” in the UniCredit and Natixis Stipulations means any and all manner of claims, including Unknown Claims, causes of action, cross-claims, counter-claims, charges, liabilities, demands, judgments, suits, obligations, debts, setoffs, rights of recovery, or liabilities for any obligations of any kind whatsoever (however denominated), whether class or individual, in law or equity or arising under constitution, statute, regulation, ordinance, contract, or otherwise in nature, for fees, costs, penalties, fines, debts, expenses, attorneys’ fees, and damages, whenever incurred, and liabilities of any nature whatsoever (including joint and several, treble, or punitive damages), known or unknown, suspected or unsuspected, asserted or unasserted, choate or inchoate, which the Settling Plaintiff Parties ever had, now have, or hereafter can, shall, or may have, individually, representatively, derivatively, or in any capacity against UniCredit or Natixis and any other Released Parties that arise from or relate in any way to the conduct alleged in the Action, or conduct that could have been alleged in the Action based on the factual predicate of the Action, including any amended complaint or pleading therein. Settled Claims include without limitation claims relating to the period January 1, 2005 through December 31, 2016 and any claims that could have been asserted against UniCredit or Natixis in EGB II. Settled Claims shall not include: (i) claims based on transactions that are outside the extraterritorial reach of the Sherman Act pursuant to Section 6a of the Sherman Act, 15 U.S.C. §6a; (ii) any claims relating to the enforcement of the Settlement; or (iii) any claims of any person or entity that submits a request for exclusion in connection with the Notice and whose request is accepted by the Court.

By remaining a Settlement Class Member, you do not give up any of your claims against the non-settling Defendants or in EGB II.

You are automatically a member of a Settlement Class if you fit the Settlement Class description. However, if you do not timely submit a Claim Form, you will not receive any payment from the Settlements. You will be bound by past and any future Court rulings, including rulings on the Settlements and Releases. Unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be a part of any other lawsuit against Settling Defendants or any of the other Released Parties based on the Settled Claims. Please see question 16 for a description of the Settled Claims.

If you are a Settlement Class Member and do not want to remain in the Settlement Class as to one or both Settlements, then you must take steps to exclude yourself from one or both Settlements. This is also sometimes referred to as “opting out” of a class.

Because there are four separate proposed Settlements (the JPMorgan Settlement, State Street Settlement, UniCredit Settlement, and Natixis Settlement), you will need to decide, for each of the proposed Settlements, whether to exclude yourself from a Settlement, or whether to remain in the Settlement Class for all Settlements.

If you exclude yourself from one or all of Settlements, you will be free to sue JPMorgan, State Street, UniCredit, and/or Natixis, depending on your opt-out selection, on your own for the claims being resolved by the Settlement(s). However, you will not receive any money from the JPMorgan Settlement, UniCredit Settlement, and/or Natixis Settlement, and Co-Lead Counsel will no longer represent you with respect to any claims against JPMorgan, State Street, UniCredit, and/or Natixis, depending on your opt-out selection. Co-Lead Counsel will, however, continue to represent you in the continuing litigation against non-settling Defendants.

You can exclude yourself by sending a written “Request for Exclusion.” You cannot exclude yourself by telephone or email. Your written Request for Exclusion must be mailed such that it is received by November 13, 2023, to European Government Bonds Settlement, ATTN: EXCLUSIONS, c/o A.B. Data, Ltd., P.O. Box 173001, Milwaukee, WI 53217, and must include: (a) the name, address, and telephone number of the member of the Settlement Class; (b) a list of all trade names or business names that the member of the Settlement Class requests to be excluded; (c) the name of this Action (“In re European Government Bonds Antitrust Litigation, No. 1:19-cv-02601 (S.D.N.Y.)”); (d) a statement certifying such person is a member of the Settlement Class; (e) documents sufficient to prove membership in the Settlement Class; (f) a statement that “I/we hereby request that I/we be excluded from the Settlement Class as it relates to the JPMorgan, State Street, UniCredit, [and/or] Natixis Settlements,” as applicable; and (g) the signature of the person or entity requesting the exclusion or an authorized representative, as well as proof of authorization to submit the request for exclusion if submitted by an authorized representative.

A Request for Exclusion that does not include all the foregoing information, that does not contain the proper signature, that is sent to an address other than the one designated above, or that is not sent within the time specified shall be invalid and the person(s) filing such an invalid request shall be a Settlement Class Member and shall be bound by the Settlements, if approved.

All persons who submit valid and timely Requests for Exclusion in the manner set forth above shall have no rights under the Settlements, shall not share in the distribution of the Net Settlement Fund, and shall not be bound by the Settlements. Such persons will not be precluded from participating in future settlements, if any, or participating in any certified litigation classes in the Action in the future.

No. Unless you exclude yourself, you give up any right to sue JPMorgan, State Street, UniCredit, and/or Natixis for the Settled Claims. If you decide to exclude yourself, your decision will apply only to JPMorgan, State Street, UniCredit, and/or Natixis. It will not apply to any other class that might be certified by the Court with respect to the non-settling Defendants or their alleged co-conspirators, or any other class that may be approved by the Court.

You will not get any money from the JPMorgan Settlement, UniCredit Settlement, and/or Natixis Settlement if you exclude yourself.

No. If you exclude yourself, you are no longer a Settlement Class Member and may not object to any aspect of the Settlements.

If you are a Settlement Class Member and you do not exclude yourself, you can tell the Court what you think about the Settlements. You can object to all or any part of the Settlements, Distribution Plan, and/or application for attorneys’ fees and litigation expenses, and any service awards for Plaintiffs. You can give reasons why you think the Court should approve them or not. The Court will consider your views.

If you want to make an objection, you may enter an appearance in the Action, at your own expense, individually or through counsel of your own choice, by filing with the Clerk of Court a notice of appearance and your objection by November 13, 2023, and serving copies of your notice of appearance and objection on Co-Lead Counsel, JPMorgan’s Counsel, State Street’s Counsel, UniCredit’s Counsel, and Natixis’s Counsel at the following physical addresses:

Any Settlement Class Member who does not enter an appearance will be represented by Co-Lead Counsel.

If you choose to object, you must file a written objection. You cannot make an objection by telephone or email. Your written objection must include: (a) a heading that refers to this Action by case name and case number; (b) a statement of the specific legal and factual basis for each objection, including whether the objection applies only to the objecting person, a specific subset of the Settlement Class or the entire Settlement Class; (c) the identity, address, and telephone number of all counsel representing the objector (if any); (d) a statement of whether the objecting or intervening person or entity intends to appear at the Settlement Hearing, either in person or through counsel; (e) a statement clarifying which Settlement(s) the objection applies to (i.e., the JPMorgan Settlement, State Street Settlement, UniCredit Settlement, Natixis Settlement, or all Settlements); (f) a description of any and all evidence the objecting person or entity may offer at the Settlement Hearing, including but not limited to the names, addresses, and expected testimony of any witnesses and exhibits intended to be introduced at the Settlement Hearing; (g) documents sufficient to prove membership in the Settlement Class; and (h) a list of other cases in which the objector or intervenor or counsel for the objector or intervenor has appeared either as an objector or counsel for an objector in the last five years.

If you do not timely and validly submit your objection, your views may not be considered by the Court or any court on appeal.

Objecting is telling the Court that you do not like something about the Settlements. You can object to the Settlements only if you remain a Settlement Class Member and do not exclude yourself from the Settlements. Excluding yourself from the Settlements is telling the Court that you do not want to be a part of the Settlement Class. If you exclude yourself, you have no right to object to the Settlements because they no longer affect you.

The Court has appointed the lawyers listed below to represent you and the Settlement Class in this Action:

These lawyers are called Co-Lead Counsel. Co-Lead Counsel will apply to the Court for payment of attorneys’ fees and litigation expenses from the Settlement Fund. You will not otherwise be charged for Co-Lead Counsel’s services. If you want to be represented by your own lawyer, you may hire one at your own expense.

To date, Co-Lead Counsel have not been paid any attorneys’ fees or reimbursed for any out-of-pocket litigation expenses. Any attorneys’ fees and litigation expenses will be awarded only as approved by the Court in amounts determined to be fair and reasonable. The Settlements provide that Co-Lead Counsel may apply to the Court for an award of attorneys’ fees and Litigation Expenses out of the Settlement Fund. Prior to the Settlement Hearing, Co-Lead Counsel will move for an award of up to 30% of the Settlement Fund (i.e., up to $12,000,000) in attorneys’ fees, plus payment of no more than $ 775,003.70 for Litigation Expenses, and for interest on such attorneys’ fees and Litigation Expenses at the same rate as the earnings in the Settlement Fund, accruing from the inception of the Settlement Fund until the attorneys’ fees and Litigation Expenses are paid.

The attorney fee application will be made collectively on behalf of Lowey Dannenberg, P.C., 44 S. Broadway, Ste. 1100, White Plains, NY 10601; Scott+Scott Attorneys at Law LLP, 230 Park Ave., 17th Fl., New York, NY 10169; DiCello Levitt LLC, 485 Lexington Ave., Ste. 1001, New York, NY 10017; and Berman Tabacco, 425 California St., Ste. 2300, San Francisco, CA 94101. In addition, DiCello Levitt has agreed to share its portion of the court-awarded attorneys’ fees with Labaton Sucharow LLP (former Co-Lead Counsel), 140 Broadway, New York, NY 10005, and Thornton Law Firm LLP, One Lincoln St., Boston, MA 02111, both of which assisted in the litigation of the case. Payment to them will in no way increase the fees that are deducted from the Settlement Fund.

This is only a summary of the request for attorneys’ fees and Litigation Expenses. Any motions in support of the requests will be available for viewing on the Settlement Website after they are filed no later than October 30, 2023. After that date, if you wish to review the motion papers, you may do so by viewing them at www.EuropeanGovernmentBondsSettlement.com.

The Court will consider the motion for attorneys’ fees and litigation expenses at or after the Settlement Hearing.

The Court will hold the Settlement Hearing on January 5, 2024 at 10:00 a.m. at the United States District Court for the Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl St., Courtroom 15B, New York, NY 10007. The Settlement Hearing may be moved to a different date or time without notice to you. Although you do not need to attend, if you plan to do so, you should check www.EuropeanGovernmentBondsSettlement.com before making travel plans.

At the Settlement Hearing, the Court will consider whether the Settlements are fair, reasonable, and adequate. The Court will also consider whether to approve the Distribution Plan and requests for attorneys’ fees and litigation expenses, and any service awards for Plaintiffs. If there are any objections, the Court will consider them at this time. We do not know how long the Settlement Hearing will take or when the Court will make its decision. The Court’s decision may be appealed.

No. Co-Lead Counsel will answer any questions the Court may have. You are, however, welcome to come at your own expense. If you send an objection, you do not have to come to Court to talk about it. As long as you file and serve your written objection on time, the Court will consider it. You may also hire your own lawyer to attend, but you are not required to do so.

You may ask the Court for permission to speak at the Settlement Hearing. If you want to appear at the Settlement Hearing, you may enter an appearance in the Action at your own expense, individually or through counsel of your own choice, by filing with the Clerk of Court a notice of appearance and your objection by November 13, 2023, and serving copies of your objection on Co-Lead Counsel, JPMorgan’s Counsel, State Street’s Counsel, UniCredit’s Counsel, and Natixis’s Counsel at the addresses set forth in Question 23. Any Settlement Class Member who does not enter an appearance will be represented by Co-Lead Counsel.

The Notice summarizes the Settlement Agreements and Distribution Plan. More details are in the Settlement Agreements and Distribution Plan, which are available for your review here. You may also call toll-free 1-877-883-7336 (for callers outside the United States and Canada: 414-961-7813) or write to the Claims Administrator at:

European Government Bonds Settlement
c/o A.B. Data, Ltd.
P.O. Box 173119
Milwaukee, WI 53217
info@EuropeanGovernmentBondsSettlement.com