If you were a holder of Apollonia, LLC common units at the time of the April 16, 2019 acquisition of Apollonia, LLC by St. Renatus, LLC, a pending class action lawsuit may affect your rights.
The purpose of the Notice is to inform you of a class action lawsuit now pending in the United States District Court for the District of Minnesota (the “Court”) against Apollonia, LLC (“Apollonia” or the “Company”) Clifford M. Buchholz, Michael J. Herold, Ryan A. Martorano, and Mick A. Occhiato (collectively, the "Apollonia Defendants") and Frank R. Ramirez, Brent M. T. Keele, Stephen D. Tebo, Jerry Morgensen, James L. Parke, Joseph D. Schofield, III, St. Renatus, LLC, and SR Merger Sub, LLC, (collectively, the "St. Renatus Defendants" and together with the Apollonia Defendants, the "Defendants"). The Notice is intended only to advise you that the action has been certified by the Court to proceed as a class action on behalf of certain holders of common units of Apollonia, LLC and of your rights with respect to the lawsuit.
The Court has not decided whether Defendants did anything wrong. The Notice is not an admission by Defendants or an expression of any opinion of the Court concerning the merits of the lawsuit, and this is not a finding by the Court that the claims asserted by Tim Walsh, Julie Walsh, Gregory Ketchum, Patricia Ketchum, Peter Murphy, Sam Peterson, and Frank Baca (collectively, "Plaintiffs") in this case are valid. There is no settlement or monetary recovery at this time and there is no guarantee that there will be any recovery in the future. However, your legal rights are affected.
YOUR LEGAL RIGHTS ARE AFFECTED WHETHER OR NOT YOU ACT.
PLEASE READ THE COMPLETE NOTICE. CAREFULLY.
WHAT ARE MY OPTIONS?
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DO NOTHING
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By doing nothing, you are choosing to stay in the Class. If you stay in the Class and the Class obtains money or benefits, you will be notified about how to apply for a share. Regardless of whether the plaintiffs win or lose at trial or whether they settle, you will not be able to sue, or continue to sue the Defendants as part of any other lawsuit—for any claims based on the facts and conduct raised by this lawsuit. You will also be legally bound by all of the Orders the Court issues and Judgments the Court makes in this lawsuit.
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ASK TO BE EXCLUDED
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If you opt out of the Class (by stating in writing that you do not want to be in the Class in this lawsuit), you will give up the right to participate in any recovery that may occur. But you will keep any rights you may currently have to sue the Defendants regarding the legal claims at issue in this lawsuit. You also will not be bound by the Orders the Courts issues and Judgments the Court makes in this case. |
- These rights and options – and the deadlines to exercise them – are explained more fully in the Notice.