Eugene Mannacio v. Sovereign Lending Group Incorporated - Frequently Asked Questions

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You received a notice because a Settlement has been reached in this Action and you may be a Class Member.  If you are a member of the Settlement Class, you may be eligible for the relief detailed below.

The notice explains the nature of the Action, the general terms of the proposed Settlement, and your legal rights and obligations.  To obtain more information about the Settlement, including information about how you can see a copy of the Settlement Agreement (which defines certain capitalized terms used in this notice), click here.

An individual (the “Plaintiff”) filed a lawsuit against Sovereign Lending on behalf of himself and all others similarly situated.  The lawsuit alleges and the Plaintiff claims that Sovereign Lending violated the Telephone Consumer Protection Act, 47 U.S.C. § 227 (the “TCPA”) by placing unsolicited calls to Plaintiff and members of the putative class on telephone numbers they had registered on the National Do Not Call Registry and after recipients asked not to be called.

Sovereign Lending denies each and every one of the allegations of unlawful conduct, any wrongdoing, and any liability whatsoever, and no court or other entity has made any judgment or other determination of any liability.  Sovereign Lending further denies that any Class Member is entitled to any relief and, other than for settlement purposes, that this Action is appropriate for certification as a class action.  The issuance of the notice is not an expression of the Court’s opinion on the merits or the lack of merits of the Plaintiff’s claims in the Action. For information about how to learn about what has happened in the Action to date, please see Section 20 below.

In a class action lawsuit, one or more people sue on behalf of other people who allegedly have similar claims.  For purposes of this proposed Settlement, one court will resolve the issues for all Settlement Class Members.  The company sued in this case, Sovereign Lending, is called the Defendant.

In a class action lawsuit, one or more people sue on behalf of other people who allegedly have similar claims. For purposes of this proposed Settlement, one court will resolve the issues for all Settlement Class Members. The company sued in this case, Sovereign Lending, is called the Defendant.

The Court has decided that everyone who fits this description is a Class Member for purposes of the proposed Settlement:  All persons or entities within the United States to whom Defendant or a third party acting on its behalf: (a) made one or more telephone calls, including while the call recipient’s number was on the National Do Not Call Registry; and/or (b) made one or more calls after asking Defendant or a third party acting on Defendant’s behalf to stop calling when that telephone number was obtained by the Defendant from The Money Source Inc.

If you are still not sure whether you are included in the Settlement Class, you can write or call the Settlement Administrator for free help.  The Settlement Administrator’s contact information is below:


Sovereign Lending TCPA Settlement

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324

1-833-383-7325

Email: [email protected]

Sovereign Lending has created a Settlement Fund of $500,000 which will be used to pay the Claims of Settlement Class Members, Settlement Class Counsel’s Fees, Costs, and Expenses Award (see Section 11 below), Plaintiff’s Service Payment (see Section 12 below), and compensation for the Settlement Administrator for providing notice to the Settlement Class and administering the Settlement.

If you are a Settlement Class Member, you are eligible to receive a pro rata share of the Settlement Fund by timely and validly submitting a Claim Form.

To qualify for a Settlement award, you must send in a Claim Form.  The Claim Form may be submitted electronically or by postal mail.  Read the instructions carefully, fill out the form, and postmark it by January 2, 2024 or submit it online on or before 11:59 p.m. (Pacific) on January 2, 2024.

As described in Sections 17 and 18, the Court will hold a hearing on February 27, 2024 at 1:30 pm to decide whether to approve the Settlement.  If the Court approves the Settlement, after that, there may be appeals.  It’s always uncertain whether these appeals can be resolved, and resolving them can take time, perhaps more than a year.  You can check on the progress of the case on this website.  Please be patient.

The Court has ordered that the law firms of Paronich Law, P.C. and Turke & Strauss LLP (“Settlement Class Counsel”) will represent the interests of all Settlement Class Members.  You will not be separately charged for these lawyers.  If you want to be represented by your own lawyer, you may hire one at your own expense.

Settlement Class Counsel will petition the Court to receive a Fees, Costs, and Expenses Award up to $166,666.66.  The Court will make the final decision as to the amount to be paid to the attorneys for their fees and costs.  You will not be required to separately pay any attorneys’ fees or costs to the Settlement Class Counsel.

The Plaintiff will request a Service Payment of up to $10,000 for his services as class representative and his efforts in bringing the Action.  The Court will make the final decision as to the amount to be paid to the Plaintiff.

If the Court approves the proposed Settlement, you will be releasing your claims against Sovereign Lending and the other entities allegedly involved in the calls at issue unless you have excluded yourself from the Settlement.  This generally means that you will not be able to file or pursue a lawsuit against Sovereign Lending or be part of any other lawsuit against Sovereign Lending asserting claims that were or could have been asserted in the Action. The Settlement Agreement contains the full terms of the release.

You may exclude yourself from the Class and the Settlement.  You can submit a request for exclusion to the Settlement Administrator electronically or by postal mail.  If you want to be excluded, you must either complete the Opt-Out Form, or write the Settlement Administrator stating: (a) the name and case number of the action – “Mannacio v. Sovereign Lending Group Inc. W.D. Wa. Case No. 3:22-cv-5498”; (b) the full name and the unique identification number for the Settlement Class Member assigned by the Settlement Administrator; (c) the address, telephone number, and email address (optional) of the Settlement Class Member seeking exclusion; (d) that the requestor does not wish to participate in the Settlement; and (e) be signed personally by you.  If you are not using the Opt-Out Form on this website, the request for exclusion must be sent to the Settlement Administrator at:

Sovereign Lending TCPA Settlement

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324


Your request for exclusion must be submitted electronically or be postmarked no later than January 2, 2024, at 11:59 pm (Pacific).  If you submit your request for exclusion by postal mail, you are responsible for your postage.


If you validly and timely request exclusion from the Settlement Class, you will be excluded from the Settlement Class, you will not be bound by the Settlement Agreement or the judgment entered in the Action, you will not be eligible to make a Claim for any benefit under the terms of the Settlement Agreement, you will not be entitled to submit an objection to the Settlement, and you will not be precluded from prosecuting any timely, individual claim against Sovereign Lending based on the conduct complained of in the Action.

At the date, time, and location stated in Section 18 below, the Court will hold a Fairness Hearing to determine if the Settlement is fair, reasonable, and adequate, and to also consider the attorneys who initiated the Action’s request for a Fees, Costs, and Expenses Award, and a Service Payment to the Plaintiff.

If you wish to object to the fairness, reasonableness, or adequacy of the Settlement Agreement or the proposed Settlement, you must write to the Court and must: (a) clearly identify the case name and number – “Mannacio v. Sovereign Lending Group Inc., W.D. Wa. Case No. 3:22-cv-5498”; (b) include the full name and the unique identification number for the Settlement Class Member assigned by the Settlement Administrator; (c) include the address, telephone number, and email address (optional) of the objecting Settlement Class Member; (d) include the full name, address, telephone number, and email address of the objector’s counsel, and the state bar(s) to which counsel is admitted (if the objector is represented by counsel); and (e) provide a detailed explanation stating the specific reasons for the objection, including any legal and factual support and any evidence in support of the objection.  The objection will not be valid if it only objects to the lawsuit’s appropriateness or merits.  Objections may be submitted to the Settlement Administrator electronically by email or by postal mail.  The Settlement Administrator will then have the objections submitted to the Court.  Or you may submit the objections directly to the Court.   If an objection is submitted by postal mail, the Settlement Class Member must pay for postage.  The Settlement Administrator’s contact information is below.

Sovereign Lending TCPA Settlement

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324


The mailing address to the Court is:

Clerk of the Court

United States District Court Western District of Washington (Tacoma)

1717 Pacific Avenue, Room 3100

Tacoma, WA 98402-3200


The objection must be submitted electronically or be postmarked no later than January 2, 2024 at 11:59 pm (Pacific). You may, but need not, submit your objection through counsel of your choice.  If you do make your objection through an attorney, you will be responsible for your personal attorney’s fees and costs.

IF YOU DO NOT TIMELY MAKE AN OBJECTION, YOU WILL BE DEEMED TO HAVE WAIVED ALL OBJECTIONS AND WILL NOT BE ENTITLED TO SPEAK AT THE FAIRNESS HEARING.

If you submit a written objection, you have the option to appear and request to be heard at the Fairness Hearing, either in person or through personal counsel.  You are not required, however, to appear.  However, if you, or your attorney, intend to make an appearance at the Fairness Hearing, you must include on your timely and valid objection a statement substantially similar to “Notice of Intention to Appear.”  Only those who submit timely objections including Notices of Intention to Appear may speak at the Fairness Hearing.  If you make an objection through an attorney, you will be responsible for your attorney’s fees and costs.


Objecting is simply telling the Court that you disagree with something about the Settlement.  You can object only if you stay in the Settlement Class.  Excluding yourself is telling the Court that you don’t want to be part of the Settlement Class.  If you exclude yourself, you have no basis to object because the Settlement no longer affects you.

The Court has preliminarily approved the Settlement and will hold a hearing to decide whether to give final approval to the Settlement.  The purpose of the Fairness Hearing will be for the Court to determine whether the Settlement should be approved as fair, reasonable, adequate, and in the best interests of the Settlement Class; to consider the Fees, Costs, and Expenses Award to the attorneys who initiated the Action; and to consider the request for a Service Payment to the Plaintiff.

On February 27, 2024 at 1:30 pm, a hearing will be held on the fairness of the proposed Settlement.  At the hearing, the Court will be available to hear any objections and arguments concerning the proposed Settlement’s fairness.  The hearing will take place before the Honorable Tiffany M. Cartwright, United States District Court Western District of Washington, 1717 Pacific Avenue, Suite 3124, Tacoma, WA 98402-3200 on February 27, 2024, at 1:30 pm.  The hearing may be postponed to a different date or time or location without notice.  Please check this website for any updates about the Settlement generally or the Fairness Hearing specifically.  If the date or time of the Fairness Hearing changes, an update to this website will be the only way you will be informed of the change. The login details are listed below:

Join ZoomGov Meeting 

https://wawd-uscourts.zoomgov.com/j/1619511852?pwd=bjJPVkFubUFZalV6V01GRktiTzdyUT09 

Meeting ID: 161 951 1852 

Passcode: 336734


At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement.  You may attend, but you do not have to.  As described above in Section 15, you may speak at the Fairness Hearing only if (a) you have timely submitted an objection, and (b) you have timely and validly provided a Notice of Intent to Appear.  If you have requested exclusion from the Settlement, however, you may not speak at the Fairness Hearing.

To see a copy of the Settlement Agreement, the Court’s Preliminary Approval Order, the application for a Fees, Costs, and Expenses Award, and the operative Complaint filed in the Action, please click here. Alternatively, you may contact the Settlement Administrator at the email address [email protected] or the U.S. postal (mailing) address: Sovereign Lending TCPA Settlement, c/o Kroll Settlement Administration LLC, PO Box 5324, New York, NY 10150-5324. You may also obtain information by calling 1-833-383-7325.

It is your responsibility to inform the Settlement Administrator of your updated information.  You may do so at the address below:

Sovereign Lending TCPA Settlement

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324

1-833-383-7325

Email: [email protected]


DO NOT ADDRESS ANY QUESTIONS ABOUT THE SETTLEMENT OR THE LITIGATION TO THE CLERK OF THE COURT OR THE JUDGE.

This website is authorized by the Court, supervised by counsel and controlled by Kroll Settlement Administration LLC, the Settlement Administrator approved by the Court. This is the only authorized website for this case.
Call
1-833-383-7325
Email
[email protected]
Mail
Sovereign Lending TCPA Settlement c/o Kroll Settlement Administration LLC
PO Box 5324
New York, NY 10150-5324

Important Dates

  • Exclusion Deadline.

    Tuesday, January 2, 2024 You must complete your Opt Out Form  online or mail your Opt Out Form so that it is postmarked no later than January 2, 2024 .

  • Objection Deadline.

    Tuesday, January 2, 2024 You must mail your objection(s) and/or notice of intent to appear at the Final Approval Hearing so that it/they are postmarked no later than January 2, 2024.

  • Claim Form Deadline.

    Tuesday, January 2, 2024 You must submit your Claim Form online no later than January 2, 2024, or mail your completed paper Claim Form so that it is postmarked no later than January 2, 2024.

  • Final Approval Hearing Date.

    Tuesday, February 27, 2024 The Final Approval Hearing is scheduled for February 27, 2024. Please check this website for updates.
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