COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA CIVIL ACTION

NOTICE OF CLASS ACTION SETTLEMENT AND FAIRNESS HEARING

A Pennsylvania Court has authorized this Notice. This is not a solicitation from a lawyer.
You are not being sued.

A settlement making $4.4 million available for payments to Class Members, for attorneys’ fees and for costs has been reached by parties to this lawsuit. This Court-approved notice explains the lawsuit, the proposed settlement, and your rights (including your right to object to this settlement) and your obligations if the Court grants final approval of the proposed settlement.

TO RECEIVE YOUR SETTLEMENT PAYMENT, YOU MUST RETURN YOUR CLAIM FORM BY MAIL OR EMAIL NO LATER THAN JUNE 2, 2026.

If you do not file a Claim Form and the settlement is finally approved, you will not receive any Settlement Payment. You will, however, release Defendants and Released Parties from the claims set forth in the Notice.

FOR MORE INFORMATION, READ THE NOTICE HERE.

Background:

This settlement resolves a lawsuit over whether Shannondell, Inc. (“Shannondell”) breached its Residence and Care Agreement with former residents by deducting certain costs for refurbishment and restoration of the former resident’s unit from that resident’s Entrance Fee Refund.

Shannondell denies the claims asserted in the Litigation. In addition, the parties disagree about how much money could have been awarded to you if the Plaintiffs were to prevail at trial. The settlement avoids the costs and risks to members of the Class like you from continuing with the lawsuit, and it provides relief to the Class.

If approved by the Court, this settlement will provide for $4.4 million in available settlement funds. The settlement monies will be distributed to Class Members who submit valid and timely claims, as well as payment of any Court-approved administrative costs, Class Counsel fees and expenses, and a Service Award to the Class Representative.

On February 3, 2026, the Court granted preliminary approval to the proposed settlement between Plaintiffs and Defendants and authorized issuing this notice to you. A hearing on the parties’ request for final approval of the settlement, as well as on Class Counsel’s motion for Plaintiffs’ Service Award, settlement administration costs, and Class Counsel attorneys’ fees, costs, and expenses will take place on September 23, 2026 at 10:00 a.m., before Judge Richard P. Haaz at the Court of Common Pleas for Montgomery County, Pennsylvania, 2 E. Airy St., Norristown, PA 19401. You may appear at the hearing, but you are not required to do so. If you object to the settlement, you must do so in writing no later than June 2, 2026. Instructions for making written objections are included in Item 10 in the Notice.