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McCord v. PRG Real Estate Management Inc, et al.

United States District Court for the Middle District of North Carolina
Case No. 1:20-cv-854

Important Dates
Deadline to file a claim
Date of Preliminary Approval
Class Period
PAGA Period
Opt-Out Deadline
August 3, 2021
Objection Deadline
August 3, 2021
Dispute Deadline
August 3, 2021
Final Approval Hearing
September 7, 2021 3:30 PM
Disbursement Date
Expiration of Check Cashing Period
Important Documents & Info

THE DEADLINE TO SUBMIT A CLAIM FORM EXPIRED ON AUGUST 24, 2021.

IF YOU RESIDED IN ANY OF THE PROPERTIES IN NORTH CAROLINA OWNED AND/OR MANAGED BY PRG REAL ESTATE MANAGEMENT, INC. AND NEW PARK RIDGE ASSOCIATES, LLC (THE “DEFENDANTS”) OR THEIR AFFILIATES BETWEEN AUGUST 14, 2016 AND JUNE 25, 2018, YOU MAY BE ENTITLED TO BENEFITS FROM A CLASS ACTION SETTLEMENT.

WHAT IS THE LAWSUIT ABOUT?
The lawsuit alleges that the Defendants improperly charged court filing fees, sheriff service fees, and attorneys’ fees (“Eviction Fees”) when filing summary ejectment/eviction actions against their tenants. The lawsuit also alleged that Defendants threatened to charge allegedly improper Eviction Fees through written correspondence sent on or around the 6th of the month to all tenants who had not made a complete rental payment (the “Collection Letter”).

The lawsuit, as amended, brought four claims for relief: a violation of the North Carolina Residential Rental Agreements Act (N.C.G.S. § 42-46), a violation of the North Carolina Debt Collection Act (N.C.G.S. § 75-50 et seq.), a claim for negligence, and a claim for negligent misrepresentation, as well as seeking a declaratory judgment.

The Defendants deny these claims, contend that they have numerous defenses to the action, and deny that class certification is required or appropriate.

HOW DO I KNOW IF I AM IN THE SETTLEMENT?
There are two types of Class Members in this Action:

A. COLLECTION LETTER CLASS MEMBERS
You are a Collection Letter Class Member if you are a natural person who at any point between August 14, 2016 and June 25, 2018, resided in any of the properties in North Carolina owned and/or managed by any Defendants and received a letter that you would or may be charged Eviction Fees upon the filing of a summary ejectment action or that you owe Eviction Fees. A representative letter can be found here:

B. EVICTION FEE CLASS MEMBERS
You are an Eviction Fee Class Member if you are a natural person who at any point between August 14, 2016 and June 25, 2018, resided in any of the properties in North Carolina owned and/or managed by any Defendants and were charged and paid Eviction Fees.

Eviction Fee Class Members are also Collection Letter Class Members as they meet the requirements of both Classes.

Excluded from the Settlement Classes are (1) employees, directors, officers, and agents of Defendants; (2) persons who exclude themselves from the Settlement Classes as provided in this Notice; (3) anyone who has previously executed a written release that related to the collecting or threatening to collect Eviction Fees; and (4) the Court, the Court’s immediate family, and Court staff.

WHAT ARE MY OPTIONS?

COLLECTION LETTER CLASS

IF YOU DO NOTHING
You will remain a member of the Collection Letter Class and will automatically receive a Settlement Benefit. Members of this Class do not need to file a Claim. Members of this Class who are not also members of the Eviction Fee Class are not eligible for non-monetary relief.

IF YOU EXCLUDE YOURSELF BY AUGUST 3, 2021
You will receive no payment from the Settlement. This is the only option that allows you to ever be a part of any other lawsuit against the Defendants or their affiliates about the legal claims in this case.

OBJECT BY AUGUST 3, 2021
Write to the Court about why you think the Settlement is unfair, inadequate, or unreasonable.

GO TO A HEARING ON SEPTEMBER 7, 2021, AT 3:30 P.M
If you file an objection by August 3, 2021, and file a notice of intent to appear, you may ask to speak in Court about the fairness of the Settlement or hire counsel to speak on your behalf. To pursue this option, you must file and serve an objection and a notice of intent to appear by the deadlines for doing so.

FILE A NOTICE OF INTENT TO APPEAR BY AUGUST 3, 2021
Your Notice of Intent to Appear in Court at the Hearing must be filed with the Court and served on Class Counsel and Defendants’ Counsel no later than this date.

EVICTION FEE CLASS

IF YOU DO NOTHING
You will remain a member of the Eviction Fee Class and will automatically receive a Settlement Benefit. Members of this Class do not need to file a Claim, unless they wish to receive non-monetary relief.

SUBMIT A CLAIM FORM BY AUGUST 24, 2021
You must submit a valid and timely Claim Form if you are making a claim to Set Aside Judgment for Possession Pursuant to Rule 60(b)(5) of the Rules of Civil Procedure. If you submit the Claim Form, you will also receive the monetary Settlement Benefit.

IF YOU EXCLUDE YOURSELF BY AUGUST 3, 2021
You will receive no payment from the Settlement. This is the only option that allows you to ever be a part of any other lawsuit against the Defendants or their affiliates about the legal claims in this case.

OBJECT BY AUGUST 3, 2021
Write to the Court about why you think the Settlement is unfair, inadequate, or unreasonable.

GO TO A HEARING ON SEPTEMBER 7, 2021, AT 3:30 P.M
If you file an objection by August 3, 2021 and file a notice of intent to appear, you may ask to speak in Court about the fairness of the Settlement or hire counsel to speak on your behalf. To pursue this option, you must file and serve an objection and a notice of intent to appear by the deadlines for doing so.

FILE A NOTICE OF INTENT TO APPEAR BY AUGUST 3, 2021
Your Notice of Intent to Appear in Court at the Hearing must be filed with the Court and served on Class Counsel and Defendants’ Counsel no later than this date.

FREQUENTLY ASKED QUESTIONS


BASIC INFORMATION

+ 1.Why is there a notice?
You have a right to know about a proposed Settlement of a class action lawsuit, and about your options, before the Court decides whether to approve the Settlement.

The Court in charge of this case is the Honorable Catherine C. Eagles, a United States District Court Judge who was assigned this case, and the case is called Sharnice McCord v. PRG Real Estate Management, Inc. (“PRG”) and New Park Ridge Associates, LLC, Case No. 1:20-cv-854 (U.S.D.C. for the Middle District of NC). The individual who sued is called the Representative Plaintiff, and the companies being sued, are called the Defendants.


+ 2. What is this lawsuit about?
The lawsuit alleges that the Defendants improperly charged court filing fees, sheriff service fees, and attorneys’ fees (“Eviction Fees”) when filing summary ejectment/eviction actions against their tenants. The lawsuit also alleged that Defendants threatened to charge allegedly improper Eviction Fees through written correspondence sent on or around the 6th of the month to all tenants who had not made a complete rental payment (the “Collection Letter”).

The lawsuit, as amended, brought four claims for relief: a violation of the North Carolina Residential Rental Agreements Act (N.C.G.S. § 42-46), a violation of the North Carolina Debt Collection Act (N.C.G.S. § 75-50 et seq.), a claim for negligence, and a claim for negligent misrepresentation, as well as seeking a declaratory judgment.

The Defendants deny these claims, contend that they have numerous defenses to the action, and deny that class certification is required or appropriate.


+ 3. Why is this a class action?
In a class action, one or more people, called “Representative Plaintiff,” sue on behalf of people who have similar claims. All these people are in a “class” or “settlement class members,” except for those who exclude themselves from the Class. The Honorable Catherine C. Eagles in the U.S.D.C. for the Middle District of North Carolina, is in charge of this class action.


+ 4. Why is there a Settlement?
The Defendants deny that they did anything wrong. Both sides want to avoid the cost of further litigation. The Court has not decided in favor of the Representative Plaintiff or the Defendants. The Representative Plaintiff and their attorneys think the Settlement is best for everyone who is affected. The Settlement provides the opportunity for Settlement Class Members to receive Settlement benefits.

WHO IS IN THE SETTLEMENT?

+ 5. How do I know if I am in the Settlement?
There are two types of Class Members in this Action:A. Collection Letter Class MembersYou are a Collection Letter Class Member if you are a natural person who at any point between August 14, 2016 and June 25, 2018, resided in any of the properties in North Carolina owned and/or managed by any Defendants and received a letter that you would or may be charged Eviction Fees upon the filing of a summary ejectment action or that you owe Eviction Fees. A representative letter can be found here:

B. Eviction Fee Class MembersYou are an Eviction Fee Class Member if you are a natural person who at any point between August 14, 2016 and June 25, 2018, resided in any of the properties in North Carolina owned and/or managed by any Defendants and were charged and paid Eviction Fees.

Eviction Fee Class Members are also Collection Letter Class Members as they meet the requirements of both Classes.

Excluded from the Settlement Classes are (1) employees, directors, officers, and agents of Defendants; (2) persons who exclude themselves from the Settlement Classes as provided in this Notice; (3) anyone who has previously executed a written release that related to the collecting or threatening to collect Eviction Fees; and (4) the Court, the Court’s immediate family, and Court staff.


+ 6. What if I am still not sure if I am included in the Settlement?
If you are not sure whether you are a Settlement Class Member, or have any other questions about the Settlement Agreement, click here, or call the toll-free number, 1 (888) 975-2352


SETTLEMENT BENEFITS

+ 7. What does the Settlement provide?
The Settlement provides two types of benefits: Monetary Relief and Non-Monetary Relief. Monetary Relief means $525,000.00 in cash, to be shared among members of both classes once attorneys’ fees and expenses, including but not limited to claims administration expenses, are deducted. Non-Monetary Relief means the availability of the Eviction Fee Class members to file a Consent Motion to Set Aside Judgment for Possession Pursuant to Rule 60(b)(6) and Stipulation of Dismissal. The Monetary Relief shall be used to pay all costs associated with the Settlement, including but not limited to (a) the costs of notice and administration of the Settlement, including for a Settlement Notice and Claims Administrator to process claims, objections, and opt-out requests; (b) the payment of valid approved claims; (c) attorneys’ fee awards (if any); (d) attorneys’ costs (actually incurred litigation expenses and other costs paid for the litigation apart from fees); (e) service award (if any) to the Representative Plaintiff; and (f) any other expenses.


+ 8. What can I get from the Settlement? A. Monetary Relief- Cash FundIf you are a member of the Collection Letter Class, you do NOT need to file a claim to obtain Collection Letter benefits. Defendants’ records demonstrate that you were sent at least one Collection Letter during the Relevant Time Period. Therefore, if the Settlement Agreement is approved in full, you will receive approximately $40.00 to $45.00 if you received a Collection Letter. The Collection Letter Class has been allotted $75,000.00 of the Settlement Fund, and there are 1,672 sets of unique Collection Letter Class units. The exact amount of compensation will be determined after administrative expenses, service award, and attorneys’ fees and costs are deducted.

You do NOT need to submit a valid Claim Form to obtain Collection Letter benefits.

If you are a member of the Eviction Fee Class, you do NOT need to file a claim to obtain Eviction Fee benefits. Defendants’ records demonstrate that members of the Eviction Fee Class were charged and paid Eviction Fees to Defendants during the Relevant Time Period. Accordingly, each Eviction Fee Class Member may receive compensation of approximately $700.00 for being charged and having paid Eviction Fees at least once. The exact amount of compensation will be determined after administrative expenses, service award, and attorneys’ fees and costs are deducted.

If you are a member of the Eviction Fee Class, you are also a member of the Collection Letter Class.

You do NOT need to submit a Claim Form to obtain Collection Letter Class benefits in addition to Eviction Fee Class benefits for which you are eligible automatically.

You do NOT need to submit a Claim Form to obtain Eviction Fee Class cash benefits.

B. Non-Monetary ReliefIn addition to the Monetary Relief described above, any member of the Eviction Fee Class is eligible to request a Consent Motion to Set Aside Judgment for Possession Pursuant to Rule 60(b)(5) and Stipulation of Dismissal. This document will allow all Eviction Fee Class members to file a consent motion to remove a judgment for possession obtained by Defendants. It is each class member’s obligation to then file the Consent Motion and Stipulation of Dismissal. Neither Defendants nor any of the properties managed by Defendants will be available to assist any class member with any aspect of this process.

In order to quality for this Non-Monetary Relief, all Eviction Fee Class members must file a valid and timely claim form.


+ 9. What am I giving up to stay in the Class?
Unless you exclude yourself from the Settlement, you cannot sue the Released Persons, continue to sue, or be part of any other lawsuit against the Released Persons about the claims released in this Settlement. It also means that all of the decisions by the Court will bind you. The Released Claims and Released Persons are defined in the Settlement Agreement and describe the legal claims that you give up if you stay in the Settlement Class. The Settlement Agreement is available here.

HOW TO GET A PAYMENT

+ 10. How can I get a payment?
A. Monetary Relief- Cash PaymentsEviction Fee Class Members do not need to submit a claim to obtain monetary Eviction Fee benefits. Defendant’s records will be used to determine your eligibility to participate in the Settlement. Eviction Fee Class Members are also members of the Collection Letter Class.

Collection Letter Class Members do not need to submit a claim to be eligible to receive a payment. Defendants’ records will be used to determine your eligibility to participate in the Settlement.

B. Non-Monetary ReliefEviction Fee Class members must submit a timely and valid claim to obtain the Consent Motion to Set Aside Judgment for Possession Pursuant to Rule 60(b)(5) and Stipulation of Dismissal.Mail:
McCord, et al. v. PRG Real Estate Management, Inc., et al.,
c/o CPT Group, Inc.
50 Corporate Park
Irvine, CA 92606
EMAIL: mccordapartmentncsettlement@cptgroup.comPlease read the instructions carefully, fill out the Claim Form, and mail it postmarked no later than August 24, 2021, or submit your Claim Form online at the Settlement Website,mccordapartmentncsettlement.com , by August 24, 2021.

If you do not submit a valid Claim Form by the deadline, you will not receive the Consent Motion to Set Aside.


+ 11. When will I get my benefits?
Benefits will be made after the Court grants “final approval” to the Settlement and after all appeals are resolved. If the Court approves the Settlement, there may be appeals. It’s always uncertain whether these appeals can be resolved and resolving them can take time.EXCLUDING YOURSELF FROM THE SETTLEMENTIf you do not want a payment from the Settlement, and you want to keep the right to sue or continue to sue the Released Persons on your own about the claims released in this Settlement, then you must take steps to get out. This is called excluding yourself—or it is sometimes referred to as “opting out” of the Settlement Class.

+ 12. How do I get out of the Settlement?
To exclude yourself, you must mail or email the Settlement Administrator, including the following:

  1. A caption or title that identifies it as “Request for Exclusion in McCord, et al. v. PRG Real Estate Management, Inc., et al., Case No. 1:20-cv-854”;
  2. Your full name and address; and telephone number.
  3. A statement that you wish to be excluded from the Settlement.

Your request for exclusion must be emailed or postmarked no later than August 3, 2021, to the Settlement Administrator at:SETTLEMENT ADMINISTRATOR:
Class Action Opt-Out
McCord, et al. v. PRG Real Estate Management, Inc., et al.,
c/o CPT Group, Inc.
50 Corporate Park
Irvine, CA 92606
EMAIL: mccordapartmentncsettlement@cptgroup.comNo person or entity may opt-out on behalf of another Class Member.If you do not include the required information or timely submit your request for exclusion, you will remain a Settlement Class Member and will not be able to sue the Released Persons about the claims in this lawsuit.


+ 13. If I don’t exclude myself, can I sue the Defendants for the same thing later?
No. Unless you exclude yourself, you give up any right to sue the Defendants and Released Persons for the claims that this Settlement resolves. If you have a pending lawsuit, speak to your lawyer in that lawsuit immediately. You must exclude yourself from this Settlement Class to continue your own lawsuit. If you properly exclude yourself from the Settlement Class, you shall not be bound by any orders or judgments entered in the Action relating to the Settlement Agreement.

+ 14. If I exclude myself, can I still get a payment?
No. You will not get any money from the Settlement if you exclude yourself. If you exclude yourself from the Settlement, do not send in a Claim Form.

OBJECTING TO THE SETTLEMENT

+ 15. How can I tell the Court if I do not like the Settlement?
Any Class Member who does not timely and properly opt out of the Settlement may object to the fairness, reasonableness, or adequacy of the proposed Settlement under Federal Rule of Civil Procedure 23. Each Class Member who wishes to object to any term of this Agreement must do so, in writing, by filing a written objection with the Clerk of the Court and mailing it to Settlement Class Counsel, and counsel for Defendant.

The written objection must include: (i) the objector’s name, address, and telephone number; (ii) the name of this Action and the case number; (iii) a statement of each objection; (iv) proof of class membership, and (v) a written brief detailing the specific basis for each objection, including any legal and factual support the objector wishes to bring to the Court’s attention and any evidence the objector wishes to introduce in support of the objection.

If the objection is made through an attorney, the written objection must also include: (1) the identity and number of the Settlement Class members represented by objector’s counsel; (2) the number of such represented Settlement Class members who have opted out of the Settlement Class; and (3) the number of such represented Settlement Class members who have remained in the Settlement Class and have not objected. If the attorney intends to seek fees and expenses from anyone other than the objectors he or she represents, the attorney shall also file with the Court and serve upon Class Counsel and Defendants’ Counsel not later than fourteen days before the Final Fairness Hearing or as the Court may otherwise direct a document containing the following: (1) the amount of fees sought by the attorney for representing the objector and the factual and legal justification for the fees being sought; (2) a statement regarding whether the fees being sought were calculated on the basis of a lodestar, contingency, or other method; (3) the number of hours already spent by the attorney and an estimate of the hours to be spent in the future; and (4) the attorney’s hourly rate.

Objectors must also make themselves available for deposition by counsel for the Parties between the time the objection is filed and a date no later than five (5) days before the Final Fairness Hearing, and the objection must include the dates when the objector is available for deposition.

Any Settlement Class member who files and serves a written objection satisfying the requirements of this section, may appear at the Fairness Hearing, either in person or through personal counsel hired at the Settlement Class member’s expense, to object to any aspect of the fairness, reasonableness, or adequacy of the Settlement. Class members, or their attorneys, intending to make an appearance at the Final Fairness Hearing must deliver to Class Counsel and Defendants’ Counsel and have file-marked by the Court, no later than thirty days before the Final Fairness Hearing or as the Court otherwise may direct, a Notice of Intent to Appear. The Notice of Intent to Appear must: (1) state how much time the Settlement Class member anticipates needing to present the objection; (2) identify, by name, address, and telephone number all witnesses the Settlement Class member proposes to have testify; (3) summarize in detail the anticipated testimony of all such witnesses; (4) identify all exhibits the Settlement Class member intends to offer in support of the objection; and (5) attach complete copies of all such exhibits.

Your objection, along with any supporting material you wish to submit, must be filed with the Court, with a copy delivered to Class Counsel, Defendants’ Counsel and Settlement Administrator no later than, August 3, 2021, at the following addresses:

CLASS COUNSELDEFENDANTS’ COUNSELCOURTSETTLEMENT ADMINISTRATOR
Scott Harris
Patrick Wallace
Whitfield Bryson LLP
900 W. Morgan Street
Raleigh, North Carolina 27603

Edward H. Maginnis
Karl S. Gwaltney
Maginnis Law, PLLC
4801 Glenwood Avenue, Suite 310
Raleigh, North Carolina 27612

Jon Berkelhammer
Joseph Hammond
Ellis & Winters LLP
300 N. Greene Street, Suite 800
Greensboro, North Carolina 27401

Thomas H. Segars
Michelle A. Liguori
Ellis & Winters LLP
PO Box 33550
Raleigh, North Carolina, 27636

U.S.D.C. for the Middle District of North Carolina
323 E. Chapel Hill Street
Durham, NC 27702

Sharnice McCord v. PRG Real Estate Management, Inc. (“PRG”) and New Park Ridge Associates, LLC,
c/o CPT Group, Inc.
50 Corporate Park
Irvine, CA 92606

+ 16. What is the difference between objecting and excluding?
Objecting is simply telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement is telling the Court that you do not want to be part of the Settlement. If you exclude yourself from the Settlement, you have no basis to object to the Settlement because it no longer affects you.

THE LAWYERS REPRESENTING YOU

+ 17. Do I have a lawyer in this case?
Yes. The Court has appointed “Class Counsel” as designated in Question 15 of this Notice to represent the Settlement Classes.

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.

+ 18. How will the lawyers be paid?
Class Counsel intends to file a motion on or before August 23, 2021, seeking an award up to one-third (1/3) of the Monetary Relief in fees and approximately $3,500 in out of pocket expenses, as well as a service award in the amount of $2,500 for the Representative Plaintiff, to be drawn from the Settlement Fund. The Court will determine the amount of fees and expenses, and service award.

THE COURT’S FAIRNESS HEARING

+ 19. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Fairness Hearing on September 7, 2021, at 3:00 P.M. at the United States District Court for the Middle District of North Carolina before the Honorable Catherine C. Eagles, United States District Court Judge, in Courtroom No. 3, located at U.S.D.C. for the Middle District of North Carolina, John Hervey Wheeler U.S. Courthouse, 323 E. Chapel Hill Street, Durham, North Carolina. This may be changed to a virtual or telephonic hearing due to the pandemic, please check the settlement site regularly.

At the Fairness Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. The Court will also consider how much to pay Class Counsel and the Representative Plaintiff. If there are objections, the Court will consider them at this time. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take.

+ 20. Do I have to come to the hearing?
No. Class Counsel will answer any questions that the Court may have, but you may come at your own expense. If you submit an objection, you do not have to come to Court to talk about it. As long as you filed and mailed your written objection on time to the proper addresses, the Court will consider it. You may also pay your own lawyer to attend, but it’s not necessary.

+ 21. May I speak at the hearing?
Yes. You may ask the Court for permission to speak at the Fairness Hearing. To do so, you must send a letter saying that it is your “Notice of Intent to Appear.” Your request must be filed with the Clerk of the Court and served on Class Counsel and Defendants’ Counsel no later than August 3, 2021.

Any such request must state the name, address, and telephone number of the Class Member, as well as the name, address, and telephone number of the person that shall appear on his or her behalf. Any request for appearance that fails to satisfy these requirements, or that has otherwise not been properly or timely submitted, shall be deemed ineffective and a waiver of such Class Member’s rights to appear and to comment on the Settlement at the Fairness Hearing. Only the Parties, Settlement Class Members, or their counsel may request to appear and be heard at the Fairness Hearing. Persons or entities that opt out may not request to appear and be heard at the Fairness Hearing.

IF YOU DO NOTHING

+ 22. What happens if I do nothing at all?
If you are a Collection Letter Class Member or Eviction Fee Class Member and do nothing, you will receive a payment as described above. You will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the Released Persons about the legal issues in this case, ever again.GETTING MORE INFORMATION+ 23. How do I get more information?This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement, available at the Settlement Website,
mccordapartmentncsettlement.com. If you have additional questions or want to request a Claim Form, you can visit the Settlement Website or contact the Settlement Notice & Claims Administrator:Mail:
McCord, et al. v. PRG Real Estate Management, Inc., et al.,
c/o CPT Group, Inc.
50 Corporate Park
Irvine, CA 92606

EMAIL:
mccordapartmentncsettlement@cptgroup.com

TOLL-FREE: 1 (888) 975-2352
Updates will be posted at the Settlement Website, mccordapartmentncsettlement.com, as information about the Settlement process becomes available.

PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE CONCERNING THIS CASE.

COURT DOCUMENTS

The files below are PDF downloads that are relevant to this specific case. Please review them and if you have any questions, or would like additional information, please contact us Toll Free by calling 1 (888) 975-2352 or by sending an email to mccordapartmentncsettlement@cptgroup.com


OPERATIVE COMPLAINT

SETTLEMENT AGREEMENT

PRELIMINARY APPROVAL ORDER

LONG FORM NOTICE

CLAIM FORM

REPRESENTATIVE COLLECTION LETTER

Questions?

Please Call Toll Free
1(888)910-0257

Questions?

Please Call Toll-Free
1 (888) 975-2352mccordapartmentncsettlement@cptgroup.com

McCord v. PRG Real Estate Management Inc, et al.
Settlement Administrator
c/o CPT Group, Inc
50 Corporate Park
Irvine, CA 92606

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