Honda Civic Tire Wear Settlement

A federal court authorized this notice. This is not a solicitation from a lawyer. The purpose of this notice is to tell you about a proposed settlement of a class action lawsuit. This notice describes the rights you may have in the settlement and what you need to do to claim those rights.

1. WHY DID I RECEIVE THIS NOTICE?
   You received this notice because you may have owned or leased: (1) a Honda Civic, model year 2006-2007; or (2) a Honda Civic Hybrid, model year 2006-2007, or a Honda Civic Hybrid, model year 2008 with a VIN that starts with JHMFA3 and ends with a number between 00001 and 10456.
   
   
2. WHY SHOULD I READ THIS NOTICE?
   You may be eligible to receive money and other benefits from the settlement of a lawsuit over uneven or rapid rear tire wear that your Civic may have experienced, and because the settlement, if approved, will release certain claims you might have.
   
   
3. WHAT IS THE LAWSUIT ABOUT?
   The lawsuit asserts that a part on your Civic was defectively designed, and that as a result the tires on some Civics wore out unevenly or prematurely. Honda denies that there was any defect on the Civics. There are no safety concerns for owners of these vehicles.
   
   
4. WHAT IS A CLASS ACTION?
   In a class action, one or more people called “class representatives” sue on behalf of people who may have similar claims. One court resolves the issues for all class members, except for class members who exclude themselves from the class.
   
   
5. HOW DO I KNOW IF I AM A CLASS MEMBER?
   You are a class member if you are a resident of the United States, Puerto Rico, the U.S. Virgin Islands, or Guam and you currently own or lease, or previously owned or leased, a Honda Civic, model years 2006-2007, a Honda Civic Hybrid, model years 2006-2007, or a Honda Civic Hybrid, model year 2008 with a VIN that starts with JHMFA3 and ends with a number between 00001 and 10456. You are not in the class if you work for Honda or one of its affiliated companies.
   
   
6. WHY IS THERE A SETTLEMENT?
   The parties on both sides, despite believing in their positions, decided that a settlement was better than the uncertainty and expense of litigation. The class representatives and their attorneys believe the settlement is best for all settlement class members.
   
   
7. WHAT CAN I GET UNDER THE SETTLEMENT?
   Under the proposed settlement, class members may receive two kinds of benefits.
   
   CURRENT OWNERS/LESSEES OF CLASS VEHICLES
   The first benefit is replacement of a “control arm” on your Civic, which you may be eligible to receive if you have experienced uneven or rapid tire wear on your Civic. To find out whether you are eligible for this benefit, you need to bring your Civic to an authorized Honda dealer for inspection or, alternatively, bring written proof that your Civic has experienced uneven or rapid tire wear to an authorized Honda dealer. The proof must be in the form of receipts or other documents from a tire shop, car dealership, or elsewhere that show that your Civic experienced the kind of uneven or rapid tire wear at issue in the lawsuit.
   
   CURRENT AND FORMER OWNERS/LESSEES OF CLASS VEHICLES
   To receive this benefit, you must bring your Civic to an authorized Honda dealer and provide the requisite information before January 16, 2014.
   1. Control Arm Replacement: If you have already paid to replace a control arm on your Civic as a result of premature or uneven tire wear (not because of an accident), you may submit a claim for reimbursement. Honda will reimburse you for parts and labor paid for the control arm replacement. To be eligible for reimbursement, you must provide proof of payment and submit a valid Claim Form before January 16, 2014.
      
      
   2. Reimbursement for Tire Wear: If you replaced your tires due to uneven or rapid tire wear, you may submit a claim for reimbursement. Honda will reimburse you on a pro rata basis in accordance with the following chart:
      

      Tire Reimbursement Schedule – Standard OEM Tires

      

      Tire Reimbursement Schedule – SI OEM Tires

      
      To be eligible for reimbursement, you must provide proof of payment, provide proof of uneven or premature tire wear and submit a valid Claim Form before January 16, 2014.
      
      
8. HOW DO I MAKE A CLAIM?
   Follow the instructions on the Claim Form that accompanies this notice. You must also include proof of repair and cost, and complete the certification as required by the Claim Form. Completed Claim Forms and supporting documentation must be submitted to the following address:
   
   Honda
   P.O. Box 2718
   Torrance, CA 90509
   
   All Claim Forms and supporting documents must postmarked by January 16, 2014. If you are a current Civic owner and want to find out whether you are eligible for a control arm replacement, you may bring your Civic to an authorized Honda dealer as soon as you receive this Notice.
   
   
9. WHAT DO I GIVE UP IF THE SETTLEMENT IS APPROVED?
   The settlement provides for a “release” of claims relating to uneven or premature rear tire wear on the Civics. This means you would not be able to sue over the cost of replacing tires, replacing a control arm, or any other monetary losses you might incur as a result of uneven or premature tire wear.
   
   
10. WHO WILL DETERMINE WHETHER THE SETTLEMENT IS FAIR?
    The judge will decide whether the settlement is fair to the class members. The judge will hold a hearing on October 28, 2013, at 10:00 a.m. in Courtroom 780 of the Edward R. Roybal Federal Building and U.S. Courthouse, 255 East Temple Street, Los Angeles, California 90012-3332. At that hearing, the Court will consider whether to approve the settlement. The Court will also determine the amount of any awards for the class representatives, and the amount of attorneys’ fees and costs to be awarded to the lawyers for the class.
    
    
11. CAN I OBJECT TO THE SETTLEMENT?
    Yes. If you are a settlement class member and do not opt out of the class, you have the right to object to the settlement. Any objection must be in writing and must be filed with the Court and sent to class counsel and Honda’s counsel at the addresses listed below. All objections must be filed electronically or postmarked on or before September 23, 2013.
    
    If you file an objection, it must include: (1) the title of the case, “Keegan v. American Honda Motor Co., Inc., No. 10-cv-09508”; (2) your name, address, and telephone number; (3) the approximate date when you bought or leased your Civic and the vehicle identification number (VIN) of your Civic; (4) a statement that you have reviewed the settlement class definition and that you are a settlement class member; (5) all legal and factual bases for any objection; and (6) copies of any documents that you wish to submit relating to your objection. In addition, if you object to the settlement, you must provide a list of all other objections submitted by you, or your counsel, to any class action settlements in any court in the United States in the previous five years. If you (or your counsel) have not objected to any other class action settlement in the United States in the previous five years, you must say so in the objection. You may also have to attend a deposition on the issues raised in the objection.
    
    If you intend to appear at the fairness hearing, you must file with the Court and send to all counsel listed below a notice of intention to appear at the hearing by the objection deadline. The notice must include copies of any papers, exhibits, or other evidence that you or your counsel will present to the Court. If you do not provide a timely notice of intention to appear, or if you do not file a timely objection, you may be deemed to have waived any objection to the settlement.
    
    

    Clerk of the Court	Class Counsel	Honda's Counsel
    Clerk of the Court Los Angeles Courthouse 312 North Spring Street Los Angeles, CA 90012	Michael A. Caddell Caddell & Chapman The Park in Houston Center 1331 Lamar, Suite 1070 Houston, TX 77010	Eric S. Mattson Michael C. Andolina Sidley Austin LLP One South Dearborn Chicago, IL 60603

    
    
12. WHAT SHOULD I DO IF I DO NOT WANT TO PARTICIPATE IN THE SETTLEMENT?
    To exclude yourself from the settlement, you must submit a written request for exclusion that includes: (a) your name, address, and telephone number; and (b) the approximate date of acquisition and vehicle identification number (VIN) of your Civic. All requests for exclusion must also contain a signed statement that: “I hereby request that I be excluded from the proposed settlement class in Keegan v. American Honda Motor Co., Inc., 10-cv-09508.” All requests for exclusion must be postmarked no later than September 23, 2013, and must be mailed to the Settlement Administrator:
    
    Honda
    P.O. Box 2722
    Torrance, CA 90509
    DO NOT REQUEST EXCLUSION IF YOU WISH TO PARTICIPATE IN THE SETTLEMENT.
    
    If you validly request exclusion from the class, you will (a) not be entitled to any of the settlement benefits; (b) not be bound by any judgment entered in the lawsuit; (c) not be permitted to object to the settlement, and (d) be able to sue based on the issues raised in the lawsuit.
    
    If you do not request exclusion from the class, you will be bound by all judgments in the lawsuit in connection with the settlement.
    
    
13. WHAT IS THE DIFFERENCE BETWEEN OBJECTING TO THE SETTLEMENT AND EXCLUDING MYSELF FROM THE SETTLEMENT?
    Objecting simply tells the Court that you do not like something about the settlement. You can object and still file a claim for benefits. In contrast, excluding yourself is telling the Court that you do not want to be part of the settlement. If you exclude yourself, you have no basis to object because the lawsuit no longer affects you.
    
    
14. WHO REPRESENTS THE CLASS?
    The Court has appointed David J. Keegan, Luis Garcia, Eric Ellis, Charles Wright, Betty Kolstad, Carol Hinkle, Shawn Phillips, and Benittia Hall as class representatives. The class representatives in this action will ask the Court for awards of up to $35,000 total. Honda has agreed to pay up to this amount if approved by the Court, and your settlement benefits will not be reduced by the payment of this award.
    
    The Court has also appointed the following lawyers and their firms as class counsel:
    
    

    David A. Mazie Matthew R. Mendelsohn Mazie Slater Katz & Freeman, LLC 103 Eisenhower Parkway Roseland, New Jersey 07068	Michael A. Caddell Cynthia B. Chapman Cory S. Fein Caddell & Chapman The Park in Houston Center 1331 Lamar, Suite 1070 Houston, TX 77010
    Robert L. Starr The Law Offices of Robert L. Starr 23277 Ventura Boulevard Woodland Hills, California 91364	Payam Shahian Strategic Legal Practices, APC 1875 Century Park East, Suite 700 Los Angeles, California 90067

    These lawyers represent your interest in the lawsuit. You will not be charged for their services. You may, however, hire your own attorney at your own expense to advise you.
    
    

15. WHO IS RESPONSIBLE FOR CLASS COUNSEL’S FEES?
    Class counsel intends to ask the Court for an award of attorneys’ fees for their work on behalf of the settlement class, including their out-of-pocket expenses, in an amount not to exceed $3,165,000. Honda has agreed to pay up to this amount. You will not have to pay any of this amount.
    
    
16. WHEN WILL I RECEIVE MY SETTLEMENT BENEFITS?
    It cannot yet be predicted. The Court is scheduled to hold a final approval hearing on October 28, 2013 to decide whether to approve the settlement. If the Court approves the settlement, the payment of benefits to class members who submit valid claims will be made approximately 45 days from the deadline for filing claims. If appeals are filed, payment of claims will be delayed.
    
    If you are a current Civic owner and want to find out whether you are eligible for a control arm replacement, you may bring your Civic to an authorized Honda dealer as soon as you receive this Notice.
    
    
17. DO I HAVE TO ATTEND THE FINAL APPROVAL HEARING?
    No.
    
    
18. WHERE CAN I GET MORE INFORMATION?
    This Notice is only a summary of the lawsuit and proposed settlement. Pleadings and other information (including the Settlement Agreement) that have been filed in this lawsuit are available at www.ControlArmSettlement.com. If you have any questions about the settlement, check the website or contact the settlement administrator at 1-888-888-3082. DO NOT CONTACT THE COURT FOR INFORMATION.