The information contained on this website is only a summary of the information presented in more detail in the Notice of Pendency and Proposed Settlement of Stockholder Class Action, Settlement Hearing, and Right to Appear (the “Notice”). All Record and beneficial holders of RAAC Class A Common Stock, Who Held Such Stock as of the Redemption Deadline of July 16, 2021, and who elected not to Redeem all or some of their stock, and their successors in interest who obtained shares by operation of law, excluding any excluded person (the “Class”).
Please also be advised that (i) Plaintiff Tomas Enrique Gomez (the “Plaintiff”), individually and on behalf of the Class (defined in Paragraph 26 below); and (ii) Defendants John J. Delaney, Stephen M. Case, Steven A. Museles, Phyllis R. Caldwell, Jason M. Fish, and Thomas Wagner (collectively, the “Defendants,” and together with Plaintiff, the “Parties,” and each a “Party”), have reached a proposed settlement for $7,500,000.00 in cash (the “Settlement Amount”) as set forth in the Stipulation (the “Settlement”). The Settlement, if approved, will resolve all claims in the Action.
All record and beneficial holders of RAAC Class A Common Stock who held such stock as of the Redemption Deadline of July 16, 2021, and who elected not to redeem all or some of their stock, and their successors in interest who obtained shares by operation of law, but excluding any Excluded Persons.Excluded Person means: (i) Defendants; (ii) members of the immediate family of any Individual Defendant; (iii) any stockholder that did not have redemption rights as of the Redemption Deadline; (iv) any parent, subsidiary, or affiliate of an Entity Defendant; (v) any entity in which any Defendant or any other Excluded Person, or group of Excluded Persons, has, or had as of the Redemption Deadline, a controlling interest; and (vi) the legal representatives, agents, affiliates, heirs, estates, successors, or assigns of any such Excluded Persons or of RAAC Management LLC.
PLEASE NOTE: The Class is a non-“opt-out” class settlement pursuant to Delaware Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2). Accordingly, Class Members do not have the right to exclude themselves from the Class.
Please Note: Receipt of the Notice does not mean that you are a Class Member or that you will be entitled to receive a payment from the Settlement.
Please be patient. If the Settlement is approved by the Court, it will take some time to conduct the Settlement distribution.
PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. This Notice explains how Class Members will be affected by the Settlement. The following table provides a brief summary of the rights you have as a Class Member and the relevant deadlines, which are described in more detail later in this Notice.
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TO MAXIMIZE YOUR RECOVERY POTENTIAL FROM THE SETTLEMENT, CLASS MEMBERS MUST SUBMIT A PROOF OF CLAIM AND RELEASE FORM NO LATER THAN FEBRUARY 21, 2026. |
If you are a member of the Class (defined in Paragraph 26 in the Notice), you may be eligible to receive a distribution from the Settlement proceeds. Class Members (defined in Paragraph 26 in the Notice) must submit a Proof of Claim and Release in order to maximize their recovery potential from the Settlement, if approved by the Court. See Paragraphs 36-42in the Notice for further discussion. |
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OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN NOVEMBER 26, 2025. |
If you are a member of the Class and would like to object to the proposed Settlement, the proposed Plan of Allocation, or Class Counsel’s request for a Fee and Expense Award or a representative party award, you may write to the Court by the deadline for submitting such objection and explain the reasons for your objection. |
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ATTEND A HEARING ON DECEMBER 11, 2025 AT 11:00 A.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN NOVEMBER 26, 2025. |
Filing a written objection and notice of intention to appear that is received by November 26, 2025, allows you to speak in Court, at the discretion of the Court, about your objection. In the Court’s discretion, the December 11, 2025 hearing may be conducted by telephone or videoconference (see Paragraphs 56-64 in the Notice.). If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection. |
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