YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

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1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION A federal court authorized this notice. This is not a solicitation from a lawyer. A Settlement will provide $19, in cash and $240, in debt relief to pay claims to persons that Portfolio Recovery Associates, LLC ( PRA ), served or caused to be served a Georgia Magistrate Court Statement of Claim in a civil action on or after July 1, 2013 which was identical to or substantially similar to Exhibits A and B to the Amended Complaint in an attempt to collect a debt incurred for personal, family, or household purposes. The Settlement resolves a lawsuit over whether such Statement of Claim violated the federal Fair Debt Collection Practices Act (FDCPA ), 15 U.S.C. 1692, et seq., which prohibits certain actions in the collection of consumer debt. The sides disagree over whether plaintiffs would have prevailed on their motion to certify the class and whether plaintiff and the class (if certified) could have prevailed at trial. Your legal rights are affected whether you act or don t act. Read this notice carefully. YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT SUBMIT A VALID CLAIM FORM Receive debt relief or, if you have paid your debt to PRA, a cash payment. EXCLUDE YOURSELF OBJECT GO TO A HEARING DO NOTHING If you ask to be excluded, you will get no payment. This allows you to pursue your own lawsuit at your expense against PRA about the legal claims in this case. Write to the Court about why you do not like the Settlement. Ask to speak in Court about the fairness of the Settlement. Have no opportunity for a payment. Give up rights. These rights and options and the deadlines to exercise them are explained in this notice. The Court in charge of this case still has to decide whether to approve the Settlement. Payments will be made if the Court approves the Settlement and after any appeals are resolved. Please be patient.

2 WHAT THIS NOTICE CONTAINS BASIC INFORMATION... Page 3 1. Why did I get this notice? 2. What is this lawsuit about? 3. Why is this a class action? 4. Why is there a Settlement? WHO IS IN THE SETTLEMENT... Page 3 5. How do I know if I am part of the Settlement? THE SETTLEMENT BENEFITS WHAT YOU GET... Page 4 6. What does the Settlement provide? 7. How much will my payment be? HOW YOU GET A PAYMENT... Page 4 8. How do I apply for a payment? 9. When would I receive my payment? 10. What am I giving up to receive a payment or stay in the Class? EXCLUDING YOURSELF FROM THE SETTLEMENT... Page How do I exclude myself from the Settlement? 12. If I don t exclude myself, can I sue Defendant for the same thing later? 13. If I exclude myself, can I get money from this Settlement? THE LAWYERS REPRESENTING YOU... Page Do I have a lawyer in this case? 15. How will the lawyers and class representative be paid? OBJECTING TO THE SETTLEMENT... Page How do I tell the Court that I do not like the Settlement? 17. What is the difference between objecting and excluding/opting-out? THE COURT S FAIRNESS HEARING... Page When and where will the Court decide whether to approve the Settlement? 19. May I speak at the hearing? IF YOU DO NOTHING... Page What happens if I do nothing at all? GETTING MORE INFORMATION... Page How do I get more information? 2

3 BASIC INFORMATION 1. Why did I get a notice? You received a notice because records indicate that, between and including July 1, 2013 and the present, PRA may have served you with a lawsuit using the Statement of Claim form at issue. 2. What is this lawsuit about? Plaintiffs, on behalf of themselves and a class of purportedly similarly situated people, allege that PRA violated the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692, by requiring mailed answers to be notarized and by omitting certain consumer rights included within the statutory form Statement of Claim. PRA expressly denies that it did anything wrong or that this case is appropriate for treatment as a class action. PRA also denies the allegations in the lawsuit. 3. Why is this a class action? In a class action, one or more people called Class Representative sue on behalf of people who have similar claims. All these people are a class or class members. One court resolves the issues for all class members, except for those who exclude themselves from the class. Judge Harold L. Murphy is in charge of this class action. 4. Why is there a Settlement? The Court did not decide in favor of the Plaintiff or Defendant. Both sides agreed to a settlement instead of going to trial. That way, they avoid the significant cost of a trial, and the people affected will get compensation. The Representative Plaintiff and the attorneys think the Settlement is best for all Settlement Class Members. WHO IS IN THE SETTLEMENT 5. How do I know if I am part of the Settlement? The Settlement provides certain relief for all actual Settlement Class Members, who are described as: (i) All persons to whom Defendant served or caused to be served a Georgia Magistrate Court Statement of Claim (ii) in a civil action on or after July 1, 2013 (iii) which was identical to or substantially similar to Exhibits A and B to the Amended Complaint (iv) in an attempt to collect a debt incurred for personal, family, or household purposes. There appear to be as many as 6,501 persons falling within this definition. 652 such persons no longer owe a debt to PRA and may make a claim for cash payment. The remaining class members may make a claim for debt relief. 3

4 Records indicate that you are likely a member of this Settlement Class. If you have questions about whether you are a Settlement Class Member, or are still not sure whether you are included, you can call or visit for more information. The Settlement Benefits What You Get 6. What does the Settlement provide? PRA has agreed to create a cash Settlement fund of $19, and a debt relief fund of $240, The cash fund will be divided among all Settlement Class Members who no longer owe a debt to PRA and send in a valid claim form, not to exceed $1, to any individual class member. The debt forgiveness fund will be divided among all remaining class members who send in a valid claim form, not to exceed such class member's indebtedness on the debt which gives rise to such class members claim. PRA has also ceased the practice of using the Statement of Claim at issue. 7. What much will my payment be? There are 6,501 known class member of which 652 of which are no longer indebted to PRA and will receive cash from this Settlement and there are 5,849 individuals who still owe PRA money and will receive debt relief from PRA. Given the likely number of valid claim forms (an estimated 10%), each class member who submits a valid claim form who does not owe PRA money would receive $ and each class member who does owe PRA money would receive debt relief of $ assuming all debts owed to PRA exceeded $ These are merely estimates and the actual payment or credit a class member ultimately receives could be substantially higher or lower based on the total number of valid claims received. If all class members submit a valid claim, then the cash payment would be no less than $30.48 and the debt relief would be no less than $ How You Get a Payment Submitting a Claim Form 8. How do I apply for a payment? To qualify for payment, you must send in a valid claim form to the Claims Administrator, who will verify your claim. You may have received a claim form as part of a mailing you received. You can also get a claim form on the internet at or by calling the Claims Administrator, Dahl Administration, at and requesting that a claim form be mailed to you. Read the instructions carefully, fill out the form, include all the information the form asks for, sign it, and mail it postmarked no later than September 21, When would I receive my payment? United States Magistrate Judge Walter E. Johnson will hold a hearing on October 22, 2015, to decide whether to approve the Settlement. Judge Johnson may approve the Settlement at the hearing or he may take some additional time to reach that decision, which may then be subject to an appeal to a higher court. It is always uncertain when such appeals can be resolved, and resolving them can take time, perhaps more than a year; hopefully much sooner. Please be patient. 4

5 10. What am I giving up to receive a payment or stay in the Class? Unless you exclude yourself, you are staying in the class, and that means that you cannot sue, continue to sue, or be part of any other lawsuit against PRA or related companies, for FDCPA or similar claims that happened in the past. It also means that all of the Court s orders will apply to you and legally bind you. This is true whether or not you submit a claim form. If you were to file your own lawsuit with regard to the claims at issue you could potentially recover up to $1, in statutory damages or set it off against what you owe PRA. However, in that case PRA would assert any and all defenses available to it in such a suit. The exact release is available in the Settlement Agreement, which is posted at Excluding Yourself From the Settlement If you don t want a payment from this Settlement, and you want to keep the right to sue or continue to sue PRA on your own about the legal issues in this case, then you must take steps to exclude yourself from the Settlement also referred to as opting out of the Settlement class. 11. How do I exclude myself from the Settlement? To exclude yourself from the Settlement, you must send a letter that states you want to be excluded from Woodward v. Portfolio Recovery Associates, LLC, Case No. 4:14-cv-0078-HLM (N.D.Ga). Be sure to include your full name, address, and telephone number. You must also include a statement that you wish to be excluded from the Settlement. You must mail your exclusion request postmarked no later than September 2, 2015 to: PRA FDCPA Statement of Claim Class c/o Dahl Administration PO Box 3614 Minneapolis MN If you ask to be excluded, you will not get any Settlement Award, and you cannot object to the Settlement. You will not be legally bound by anything that happens in this lawsuit. You may be able to sue (or continue to sue) PRA in the future. 12. If I don t exclude myself, can I sue Defendant for the same thing later? No. Unless you exclude yourself, you give up any right to sue PRA and related entities and companies for the claims that this Settlement resolves. If you have a pending lawsuit that may relate to the claims being released as part of this class Settlement, you should speak to your lawyer in that case immediately. You must exclude yourself from this Settlement Class to continue your own lawsuit. Remember, the exclusion deadline is September 2, If I exclude myself, can I get money from this Settlement? No. If you exclude yourself, you cannot receive money from this Settlement. But, if you exclude yourself from this Settlement you may sue, continue to sue, or be part of a different lawsuit against PRA based on the legal issues in this case. 5

6 14. Do I have a lawyer in this case? The Lawyers Representing You The Court appointed the law firm of Skaar & Feagle, LLP in Woodstock and Tucker, Georgia to represent you and other Settlement Class Members. These lawyers are called Class Counsel. You will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense. 15. How will the lawyers and class representative be paid? Class Counsel will ask the Court to approve payment of $35, to compensate them for attorneys fees, and to reimburse them for costs and expenses for investigating the facts, litigating the case, and negotiating the Settlement. Class Counsel will also seek an award of $2, for each named plaintiff, plus debt forgiveness for their services as Class Representatives. The Court may award less than these amounts. Defendant has agreed not to oppose these fees and expenses. These payments, along with the costs of administering the Settlement, are in addition to the Settlement Fund and will not be deducted from, reduce or affect the Settlement Fund. Objecting to the Settlement You can tell the Court that you do not agree with the Settlement or some part of it. 16. How do I tell the Court that I do not like the Settlement? If you are a Settlement Class Member, you can object to the Settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views. To object, you must send a letter saying that you object to the proposed Settlement in Woodward v. Portfolio Recovery Associates, LLC., Case No. 4:14-cv HLM (N.D.Ga). You must include each of the following: (a) your full name, address, telephone number(s); (b) whether you were served with the Statement of Claim at issue; (c) a statement of all grounds for objection; (d) all legal and evidentiary support for those grounds; (e) whether you were assisted or advised in the preparation of the objection by any attorney and, if so, the name and address of that attorney. Your objection to the Settlement must be postmarked no later than September 2, The objection must be mailed to the clerk with a copy to the attorneys of record at the addresses below: Clerk of the Court U.S. District Court for the Northern District of Georgia 600 East First Street Rome, GA Justin T. Holcombe Skaar & Feagle, LLP 133 Mirramont Lake Drive Woodstock, GA Robert E. Sickles Hinshaw & Culbertson, LLP 100 South Ashley Drive Suite 500 Tampa, FL What is the difference between objecting and excluding/opting-out? Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself or opting out is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself, you have no basis to object because the case no longer affects you. 6

7 The Fairness Hearing 18. When and where will the Court decide whether to approve the Settlement? The Court will hold a hearing to decide whether to approve the Settlement. This Fairness Hearing will be held at 10:00 a.m. on October 22, 2015 at the United States District Court for the Northern District of Georgia, Rome Division, 600 East First Street, Rome, Georgia in Courtroom 201. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, and whether to award attorneys fees, expenses, and service awards as described above, and in what amounts. If there are objections, the Court will consider them. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long it will take the Court to issue its decision. It is not necessary for you to appear at this hearing, but you may attend at your own expense. 19. May I speak at the hearing? You may ask the Court for permission to speak at the Fairness Hearing. To do so, you send a letter to the Clerk of Court at the address listed in Question 16 above saying that you object to the proposed Settlement and that you intend to appear (either on your own behalf or through counsel) at the Fairness Hearing in Woodward v. Portfolio Recovery Associates, LLC, Case No. 4:14-cv HLM (N.D.Ga). Be sure to include your full name, address, telephone number, the reasons you object to the Settlement and, if applicable, the full name, address and telephone number of your counsel. Your letter must be postmarked no later than September 2, You cannot speak at the hearing if you excluded yourself. 20. What happens if I do nothing at all? If You Do Nothing If you do nothing, you will not receive a payment or debt relief. To receive a payment or debt relief, you must submit a claim form. Unless you exclude yourself, you cannot start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against PRA about the legal issues in this case, ever again. 21. How do I get more information? Getting More Information This notice summarizes the proposed Settlement. More details are in a Settlement Agreement. You can get a copy of the Settlement Agreement by writing to Dahl Administration or by visiting You can call toll-free; write to the Claims Administrator at: PRA FDCPA Statement of Claim Class, c/o Dahl Administration, P.O. Box 3614, Minneapolis, MN ; or visit the website at www. PRAStatementofClaimSettlement.com where you will find answers to common questions about the Settlement, a claim form, plus other information to help you determine whether you are a Settlement Class Member and whether you are eligible for a payment or debt relief. 7

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